Annual Legislative Report on the Hazardous Waste Regulatory Program for Report Year 2015

1 Division of Solid Waste Management Hazardous Waste Program Annual Report 2015 Tennessee Department of Environment and Conservation September 2017 FD010318 2 Table of Contents Preface 3 About the Solid Waste Program 3 How the Data is Collected 4 Understanding Reporting Cycles 4 Quantity of Data Managed 4, 5 Description of Regulated Entities 6-10 Waste Generation 11-14 Waste Reduction 15-17 Enforcement and Compliance 18, 19 Permitting 20,2 1 Fees 22, 23 Program Contacts 24, 25 List of Active Hazardous Waste Generators Appendix A List of Active Hazardous Waste Treatment, Storage, and Disposal Facilities Appendix B List of Active Hazardous Waste Transporters Appendix C 3 PREFACE The Commissioner of the Department of Environment and Conservation and the Underground Storage Tanks and Solid Waste Disposal Control Board hereby submit this report on behalf of the State of Tennessee’s Hazardous Waste Regulatory Program. About the Solid Waste Management’s Hazardous Waste Program The Hazardous Waste Management Program regulates hazardous waste generation, transportation, storage, treatment, and disposal. It has authority over facilities subject to EPA RCRA Subtitle C. Such activities are overseen by EPA Region 4. The Hazardous Waste Management Program operates under the authority of the Hazardous Waste Management Act of 1977 (T.C.A. §68-212-101 et seq.) and various Hazardous Waste Management rules. Implementation of Tennessee's hazardous waste program began in October 1980. Regulation of hazardous waste is also a federal responsibility under the Resource Conservation and Recovery Act (RCRA). Tennessee has been authorized by EPA to administer the majority of the federal program and receives a grant in support of this effort. Other funding for this program is obtained through a fee collection system as well as State appropriations. The coordinated state and federal program regulates activities such as: the permitting and inspection of hazardous waste storage, recycling, treatment, and disposal facilities; the management of hazardous waste from generators (primarily manufacturing industry) through the required Waste Stream Notifications, Annual Reports, and Waste Reduction Reports; the annual registration of hazardous waste transporters and the regulation of used oil. Hazardous waste management facilities receive hazardous wastes for treatment, storage, or disposal. These facilities are often referred to as treatment, storage, and disposal facilities, or TSDFs. Treatment facilities use various processes (such as incineration or oxidation) to alter the character or composition of hazardous wastes. Some treatment processes enable waste to be recovered and reused in manufacturing settings, while other treatment processes dramatical- ly reduce the amount of hazardous waste. Storage facilities temporarily hold hazardous wastes until they are treated or disposed of. Disposal facilities permanently contain hazardous wastes. The most common type of disposal facility is a landfill, where hazardous wastes are disposed of in carefully constructed units designed to protect groundwater and surface-water resources. Detailed regulations to ensure that TSDFs operate safely and protect human health and the environment are found in Tennessee Rule 0400- 12-01-.06 and .07. Facilities that currently or plan to treat, store, or dispose of hazardous wastes must obtain a RCRA permit. A RCRA permit is a legally binding document that establishes operating require- ments and various provisions specific to the needs of the permit appli- cant depending on the treatment, storage, or disposal activities conducted at the facility. Permits are written to address the specific geog- raphy of the facility, the types of hazardous waste management units, and the specific waste streams that will be managed at the facility. The permit also outlines facility design and operation, lays out safety stand- ards, and describes activities that the facility must perform, such as monitoring and reporting. Permits typically require facilities to devel- op emergency plans, obtain insurance and financial backing, and train employees to handle hazards and can include facility-specific require- ments such as groundwater monitoring. 4 How the data is collected: Handlers of hazardous waste are required to notify the state of their activity pursuant to the HAZARDOUS WASTE MANAGEMENT REGULATIONS CHAPTER 0400-12-01. Forms are sent to these entities annually requiring each handler to report on their hazardous waste activity. Completed forms are required to be submitted by March 1st of each year detailing their hazardous waste activity for the previous calendar year, frequently referred to as the “Report Year”. Forms received on March 1st contain information from the previous year. For example, data for calendar year 2015 is received by March 1, 2016 (Fig. 1). Corrections and resubmission may be required by the reporting entity. Reporting of data to EPA is also required. Handler information (site location, name, etc) is entered into EPA’s data system (RCRAInfo) by the Waste Activity Audit staff. Certain waste handling data is extracted from these annual reports and uploaded to EPA as part of the Biennial Reporting System (BRS). Figure 1 - REPORT YEAR 2015 (based on calendar year 2015) START OF DATA PERIOD END OF DATA PERIOD MUST BE POSTMARKED BY AUDIT AND DATA ENTRY January 1, 2015 December 31, 2015 March 1, 2016 Summer or Fall of 2016 Understanding Reporting Cycles: Figure 2 indicates the overlapping nature of reporting cycles. Data in this report is based on the “Report Year” scenario outlined in Figure 1. Figure 2 - REPORT YEAR 2015 - Overlapping Cycles CALENDAR CYCLE TN FISCAL YEAR FEDERAL FISCAL YEAR BEGINS ENDS BEGINS ENDS BEGINS ENDS January 1, 2015 December 31, July 1, 2014 June 30, 2015 October 1, 2014 September 30, 2015 2015 BIENNIAL DATA is reported to EPA every two years based on odd-ending years. Data is for one year only and based on the REPORT YEAR. Data for the BIENNIAL report is usually due to EPA in late June or early July following the REPORTING YEAR. FEDERAL FISCAL YEAR reporting generally involves Compliance Monitoring and Enforcement (CME) data. EPA de- termines Tennessee’s adherence to the RCRA Program based on how many inspections are conducted and the numbers of enforcement actions in any FEDERAL FISCAL YEAR. Quantity of Data Managed: Hazardous waste must be managed from generation to disposal or “cradle-to-grave”. Once a hazardous waste is generated, the generator must be able to identify the points of generation, the amount of time the waste was accumulated and to whom the waste was given to be transported to a treatment or disposal facility. These data are reported annually on forms to the Department. Submitted forms are required to be permanently retained. Figure 3 details this tracking of waste in general terms. Figure 4 identifies required forms to be submitted to the Department and the number of records (potentially) that may be submitted. 5 Quantity of Data Managed (continued): Figure 3 - Data Management / Tracking from Generation to Treatment / Disposal Waste Stream 1 Amt Generated 1 Amt Shipped 1 Amt Treated / Disposed 1 Facility Waste Stream 2 Amt Generated 2 Amt Shipped 2 Transporter Amt Treated / Disposed 2 Waste Stream 3 Amt Generated 3 Amt Shipped 3 Amt Treated / Disposed 3 Several pages of forms are returned from the regulated sites. Figure 4 indicates the estimated total of pages returned. Note that in some cases, several records can be placed on one form as in Form TWR(CN-0905). At one point in the past, there were over 32,000 records submitted by Treatment, Storage, Disposal(TSD) sites. Figure 4 - Report Year Estimated Number of Forms Returned Information Pertains To Form ID Records per Estimated Total Estimated Total Facility Sites Records Facility Core Data Location, Contact Form HN-H 1 3000 3000 Persons Waste Stream Description and Form WSR 1 to 1,200 3000 10,000 + Amounts Offsite Shipping Shipments and Form OSR 1 to 50 3000 2500 Amounts Total Waste Re- Shipments and Form TWR 1 to 30,000 25 30,000 + ceived Amounts Rec’d 6 REGULATED ENTITIES 7 Descriptions of Regulated Entities: The Tennessee Hazardous Waste Management Act of 1977, TCA Section 68-212-101, requires the Division of Solid Waste Management to identify and regulate Hazardous Waste Generators, Hazardous Waste Treatment Storage and Disposal Facilities (TSDF), and Hazardous Waste Transporters. Hazardous Waste Generators are categorized into three groups: Large Quantity Generators (LQG); Small Quantity Generators (SQG); and Conditionally Exempt Small Quantity Generators (CESQG). Conditions for determination of these generator statuses are listed in Figure 7. Figure 5 - 2015 Hazardous Waste Handlers, Waste Streams and Tons of Hazardous Waste Generated 1717 Conditionally Exempt Small Quantity Generators (CESQG) 638 Small Quantity Generators (SQG) 614 Large Quantity Generators (LQG) 23 TSDF Active Generators 50 Active TSD Facilities 284 Hazardous Waste Transporters 44 Hazardous Waste Transfer Facilities 69 Used Oil Transporters 35 Used Oil Transfer Stations 11,956 Number of Hazardous Waste Streams 42,563,923 Tons of Hazardous Waste Generated Note: Some data values may change slightly as adjustments and audits are completed. This can occur over a period of years. Every attempt is made to obtain the most current data. Figure 6 - Graph of Hazardous Waste Generator Universe by Year 8 Descriptions of Regulated Entities (continued): Figure 7 - Hazardous Waste Generator Categories

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