An environmental specialist with one of the U.S.'s largest waste treating companies warns that waste generators, including the massive Gulf Coast refining and petrochemical complex, are approaching their most serious, significant deadline since passage of the Resource Conservation and Recovery Act (RCRA) of 1976.
The deadline is a result of land ban disposal regulations that represent, says John T. Biedry, program manager for Chemical Waste Management Inc. (CWM), "the U.S. Environmental Protection Agency's most ambitious, confusing regulatory effort to date."
The regulations do not ban hazardous wastes from disposal in landfills but require treatment before disposal. This contrasts with the early years of RCRA when little or no treatment was required and a "cradle to grave" manifest system was the major regulatory control.
A process that has been inching forward since 1984 will climax May 8 with inclusion of mandatory treatment standards, without extensions, for more than 415 hazardous wastes. By comparison, only 121 wastes have been covered by land ban treatment standards issued since 1986.
In addition, variances refiners have had for disposing of solids and sludges will end Aug. 8.
Congress left the Environmental Protection Agency no leeway in the timing of enforcement of the new regulations.
Biedry says the mass of new standards favors incineration for disposal of hazardous wastes. That's because most of the wastes are organic.
A study of treatment standards for all the waste codes shows, he says, that out of 500 treatment technologies 380 involve incineration.
But incineration is not the final solution. Ash and scrubber water from the burning demand further treatment or specific disposal techniques.
DISPOSAL REGULATIONS
The land ban disposal regulations, Biedry says, are a direct result of the Hazardous and Solids Waste Amendments passed by Congress in 1984 during the Reagan administration.
Those amendments forced EPA to divide a list of more than 500 waste codes into thirds and imposed three "hammer dates," when EPA was to issue treatment standards for each third. "Hammer" means a prescribed treatment by an irrevocable deadline.
EPA missed the first two deadlines of Aug. 8, 1988, and June 9, 1989, for the first and second thirds. The wastes in these thirds were to be automatically banned from landfill.
But the amendments said if EPA did not make its statutory deadline the scheduled wastes would be pushed off to the last third, and in the interim the wastes would be subject to "soft hammer" provisions. That meant the waste generator had some leeway in determining the treatment method, if any, before disposal in an authorized landfill.
Biedry says those missed deadlines and soft hammer solutions made the regulations appear less severe than expected.
Any leeway will end with the May 8 final deadline for the last third. There will be only hard hammer treatments after that. The question that will be answered then will be whether waste generators and outside firms have developed the capacity to treat the wastes as prescribed.
However, refiners will have a few more months of respite from the hard hammer for a certain body of wastes. They have a national capacity variance that expires Aug. 8 for dissolved air flotation float, slop oil emulsions, heat exchanger sludge, API separator sludge, and tank bottoms (leaded).
PORT ARTHUR INCINERATOR
CWM owns and operates a rotary kiln incinerator at Port Arthur, Tex., which is going through trial burns. It is rated at 150 MMBTU.
Solids, sludge, energetic liquids (liquids with fuel value), lean water, and wastes in containers feed into the ceramic lined, rotating kiln that measures 14 by 80 ft.
The unit can shred steel drums containing wastes, reducing the metal to slag in the kiln. The kiln is maintained at a temperature of 1,500-1,900 F.
As the waste is heated, organics are destroyed in place or volatilized and later destroyed in the gas phase in the kiln or afterburner. The afterburner is maintained at a temperature of 2,200-2,500 F.
Gases are then quenched down to 185 F., scrubbed for acid gases and larger particulates, then scrubbed for fine particulates.
Scrubber water goes into a deep well at the Port Arthur site. Ash goes to CWM's Lake Charles, La., plant for immobilization and disposal.
CWM expects industry-wide demand for incineration will grow by about 1 million tons by 1993, while incineration capacity will double during that period.
An unknown factor is the role of product kilns-those making a specific product like cement. They now burn fuel wastes, but industry observers believe they will stay away from solids and sludges, CWM says.
Temporary capacity shortages could crop up, but most industry observers do not believe a long term capacity shortage will develop.
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