Off-site facilities

For those waste streams that can impact public health or the environment (if mismanaged), provide a summary of the treatment and disposal methods (for example, solvents are incinerated or recycled, lab wastes are incinerated) used to manage them and identify the on-site or off-site facilities used. Is the disposal of the waste adequately documented (for example, retention of manifests, bills of lading or transfer notes) ... 

M - Estimate is based on monitoring data or measurements for the toxic chemical as released to the environment and/or off-site facility. 

U.S. EPA has shown that 90% of process water can be recycled to the front end of the system for slurry preparation, and the rest must be treated on site or transported to an off-site facility.80 During the aerobic process, some contaminated air may be formed and emitted from the reactor. Depending on the air characteristics, a compatible air pollution control device may be used, such as activated carbon. Slurry biodegradation has been shown to be successful in treating soils contaminated with soluble organics, PAHs, and petroleum waste. The process has been most effective with contaminant concentrations ranging from 2500 mg/kg to 250,000 mg/kg. 

Catalytic processes (finid catalytic cracking, catalytic hydrocracking, hydro-treating, isomerization, ether manufacture) also create some residuals in the form of spent catalysts and catalyst fines or particulates. The latter are sometimes separated from exiting gases by electrostatic precipitators or filters. These are collected and disposed of in landfills or may be recovered by off-site facilities. The potential for waste generation and hence leakage of emissions is discussed below for individual processes. 

The level of control and validation documentation required (i.e., through increased testing and tighter specifications) increases as one moves closer, in a multistep, in-plant process, to the outcomes [i.e., final intermediate(s) and the API itself]. Naturally, when key and final intermediates are sourced from outside the company, they must enter with appropriate certificates of analysis (CofA), plus thorough inspections of off-site facilities by quality assurance personnel. 

RCRA-regulated facilities operated by the Dow Chemical Company characterize all hazardous and nonhazardous wastes generated on-site or received from off-site locations according to a waste analysis plan as required by RCRA and prepared in accordance with federal and state regulations.28 The waste analysis plan is a part of the RCRA permit for the facility and describes the procedures used to collect information needed for the storage, treatment, and disposal of waste either on-site or at an off-site facility. Specified in the waste analysis plan are the following elements ... 

The above procedures are specified in the site s waste analysis plan and RCRA permit and thus are required by law. For Dow Chemical Company sites that use off-site facilities for treatment and disposal, these same protocols are generally used because of the requirements established by the off-site facilities permits or regulatory requirements for receipt of hazardous wastes. 

The total direct cost (TDC) includes both the direct installation costs and the costs of site preparation and buildings. Further, the sum of the total direct cost and total indirect cost (or direct installation costs) is termed the battery limits cost. Finally, the battery limits cost plus the cost of off-site facilities (e.g., a railroad spur) comprise the total depreciable investment. Put simply, this is the portion of the TCI for which the firm is permitted to take a depreciation deduction on its corporate income tax return. The other portion of the TCI, namely, land and working capital, may not be depreciated. Hence, this portion is called the total nondepreciable investment. 

Since several wastes are received at the off-site facility, this will improve the economics for processing. 

Estimated investment costs for Cases A and B are shown in Table III. Investment costs are based upon erection of the plant on the U.S. Gulf Coast. Erected costs include the first catalyst charge but exclude associated off-site facilities, crystallizer, and royalty charges. Estimated operating costs are shown in Table IV. Utility costs in dollars per calendar day are based upon use of electric drivers for pumps and compressors, maximum use of air coolers, and fired furnaces for reboiling the light ends... 

Several mobile treatment systems discussed earlier in this chapter can be dispatched to the site of an NSCWM discovery to perform on-site treatment of the item. An alternative to the use of mobile systems is to overpack the chemical waste to be treated in a multiple-round container (MRC) and transport it to an off-site facility for treatment or storage. 

The second stage involves the subsequent treatment and disposal of the RRS or EDS secondary waste streams, whether at the site where they are generated or at an off-site facility. Although the RAP mechanism applied for operation of the RRS or EDS device itself will affect the choice of RAP mechanism for treatment of the RRS or EDS secondary waste streams, the two are nevertheless distinct. 

Finding 4-8. Certain state regulators have been considering reqniring that secondary wastes be agent-free before they are released to off-site facilities. This wonld pose a serious problem for the non-stockpile program, becanse NSCWM can be recovered anywhere and the off-site transport of secondary wastes may be a viable management option. 

On-site or off-site facilities should include at least ... 

The second stage involves the subsequent treatment and disposal of the EDS waste streams, whether at the site where they are generated or at an off-site facility. 

If the EDS waste is to be treated in an off-site facility and is determined to be a hazardons waste, the Army must either find a permitted hazardous waste TSDF to accept the waste, or a new facihty mnst be permitted. Considering the RRS and MMD experience, and the low volume of the EDS wastes that would be genaated in most cases, the Army is likely to seek an existing TSDE that is willing to accept the waste." The TSDE wonld need to determine whether it can treat the EDS nentralent pnrsnant to its existing permit or... 

---