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Vertac Dioxin Waste Disposal Options

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Vertac Dioxin Waste Disposal Options VERTAC DIOXIN WASTE DISPOSAL OPTIONS Site History The Vertac Chemical Corporation, Jacksonville, Arkansas, plant has been the continuing object of EPA scrutiny since dioxin-contaminated wastes were found there in 1979. Because of the extremely toxic nature of these wastes, a suit was filed by the United States and the Arkansas Department of Pollution Control and Ecology against Vertac and its predecessor. Hercules, Incorporated, for injunctive relief to clean up the facility. One of the problems at the facility involved the disposal of approximately 4,000 drums containing 2,4,5-T wastes. These wastes were highly contaminated with tetrachlorodibenzo-p-dioxin (TCDD), one of the most toxic man-made substances known. In 1982 a Consent Decree was entered in the Vertac case. Part of this Consent Decree required Vertac to submit and implement a waste management C\J plan to dispose of the containerized waste on site. r<^ 0 Prior to entry of the Consent Decree, EPA was concerned that these wastes^ might be disposed of in an unregulated land disposal facility. As a result, a^ rule was promulgated under Section 6(a) of the Toxic Substances Control Act. This so called "Vertac Rule" prohibited off-site disposal of the 2,4,5-T waste or other dioxin contaminated waste. Vertac was required to store the waste until an acceptable disposal method could be found. The acceptable method for dioxin disposal was promulgated on January 14, 1985, as part of the new Dioxin Listing Rule, a regulation under the Resource Conservation and Recovery Act (RCRA). This rule allows disposal of some dioxin only at facilities with a RCRA permit, or by incineration or thermal treatment at facilities which have interim status under RCRA and have received, a special certification to dispose of dioxin waste from EPA. As yet, no commercial facility has received certification or a permit to dispose of dioxin. As a result of the history of the Vertac case, Vertac is now storing approximately 16,000 drums of 2,4-D waste, as well as the original 2,4,5-T waste. As mentioned above, they have submitted to EPA a waste management plan for the disposal of all the containerized waste by incineration onsite in ENSCO's mobile incinerator. Vertac has also entered into a contract with ENSCO to dispose of the waste. This plan has been incorporated into a proposed Order to be entered by the Court. So far, the Arkansas Department of Pollution Control and Ecology (ADPC&E) and EPA Region 6 have agreed to Vertac's proposal. Concurrence from EPA Headquarters and the Department of Justice is awaited. Thereafter, a public comment period will take place. Disposal Options There has been some opposition to the onsite incineration of the Vertac waste and more can be anticipated in the future. However, there are two major factors to consider regarding opposition to the Vertac proposal. First, Vertac was required by the Consent Decree to submit a plan to dispose VT9.13 4- 09130480 of the wastes. As soon as a disposal option was available, Vertac did propose a plan which not only complies with the Consent Decree but also complies with the Dioxin Listing Rule. Second, in the short term (one to two years), the only possible disposal option is incineration in a certified Incinerator or thermal treatment unit. In examining this second factor, other disposal possibilities can be considered but all appear to be unlikely or long term. The most common method of disposal in the past has been land disposal or "landfill ing." However, many substances, including dioxin waste, have been identified as candidates for being banned from land disposal facilities by November 1986. Additionally, land disposal in facilities which are not fully permitted for dioxin waste is prohibited by the Listing Rule. Thus, based on current agency views and policy, it is unlikely that any land disposal facility in would be permitted for dioxin wastes and very likely that these wastes will (^J be banned from land disposal entirely. ^ Deep well injection is a disposal method used to place liquid hazardous ° wastes in geological formations which contain them underground. This 0 practice also constitutes land disposal and may be prohibited. Additionally, o this method can only be used for liquids, and the Vertac wastes consist of a large amount of solids. This leaves incineration and thermal treatment as disposal options. Such facilities must either have interim status to operate and be certified ^ES^ or be fully permitted under RCRA. At this time, there are no facilities with the required approvals. However, there are a number of incineration facilities with interim status to burn hazardous waste and which may be able to meet the requirements to be certified. Although some of the requirements for certification are somewhat less than a full permit, the operating requirements are even more stringent than for a RCRA hazardous waste (non dioxin) incinerator, the main difference being that a unit used to dispose of dioxin wastes must demonstrate an ability to destroy 99.9999% of the dioxin, while other hazardous wastes must only achieve a 99.99% destruction efficiency. Based on the foregoing, it is clear that incineration (including other thermal treatment) is the only truly viable alternative. Proceeding from this conclusion, types and locations of incinerators can be examined and compared. Incinerators consist of basically two types - stationary and mobile. Only one stationary incinerator applied to burn dioxin waste in this Region. However, additional information was needed and has not been received by EPA. ENSCO, through Vertac, has applied for certification for its mobile incinerator to be used at the Vertac Jacksonville plant site. All certifications are site specific and thus, the application only applies to the Vertac site. No other applications have been received to certify any mobile incinerators in this Region. The only other major issue concerning incineration is whether to do it onsite at the Vertac plant or elsewhere. Time, safety, and economics all dictate that the incineration take place onsite. As stated above, the only 09130481 complete certification application received has been for the Vertac plant site. At a minimum, if another site were chosen, another application would have to be prepared and filed. The person making such an application would have to be the site owner. Therefore, Vertac would have to acquire the property, or the property owner would have to be willing to apply for certification, which seems unlikely. If the proposed incineration were to tane place ai. d location tnat does not currently have interim status to operate under RCRA, a full permit would be required, which would take the better part of two years, in comparison, the certification process should take considerably less than one year. Assuming that the incinerator would operate efficiently no matter where it was placed, the problem of transporting and handling 20,000 drums poses risks of its own. Disposal onsite allows much less handling of the drums, thus minimizing the risk of spills and releases. Plus, if spills do occur, they are isolated to the Vertac site. Hundreds of truck loads ^o of wastes wuuia nave 10 oe transported on mghways and through towns on their way to a disposal site, posing a risk of spills and traffic accidents, potentially causing widespread contamination. l\p^ 0 Finally, onsite incineration makes the most sense economically. The o factors described above: time delays, the cost of preparing applications, Q transportation costs, and potential liability for spills, make offsite disposal mucn more cosny ana less attractive from an economic viewpoint. Conclusion The current Vertac proposal for onsite incineration is fully in. compliance with all environmental requirements, meets the Consent Decree requirements, and is the safest, most timely, and cost effective way of dealing with their wastes. 03130462 VERTAC CHEMICAL CORPORATION JACKSONVILLE/ ARKANSAS DIOXIN CERTIFICATION 0 THE DIOXIN CERTIFICATION PROCESS FOR THE ENSCO MOBILE INCINERATOR IS EXPECTED TO PROCEED AS SCHEDULED. 0 PUBLIC OPPOSITION TO ON-SITE DIOXIN INCINERATION IS EXPECTED TO BE WELL-ORGANIZED AND VOCAL. r- 0 ADVERSE HEALTH EFFECTS HAVE BEEN WIDELY REPORTED IN THE LOCAL PRESS CM DESPITE REPORTS FROM CDC THAT DATA INDICATE NO CURRENT HEALTH HAZARD, m 0 0 MANY JACKSONVILLE CITIZENS FAVOR OFF-SITE INCINERATION. HOWEVER/ ° THERE ARE SEVERAL DISADVANTAGES: o - PRESENTLY NO OFF-SITE FACILITIES PERMITTED TO COMMERICIALLY TREAT OR DISPOSE OF DIOXIN WASTE. - PRESENTLY NO CERTIFICATIONS THAT ALLOW INTERIM STATUS FACILITIES TO COMMERCIALLY INCINERATE OR THERMALLY TREAT DIOXIN WASTE. - ADDITIONAL HANDLING AND TRANSPORTATION OF DRUMS PRESENTS A POTENTIALLY GREATER RISK OF EXPOSURE TO THE PUBLIC. HUNDREDS OF TRUCKLOADS OF WASTES WOULD HAVE TO BE TRANSPORTED ON HIGHWAYS AND THROUGH TOWNS EN ROUTE TO A DISPOSAL SITE. - PUBLIC OPPOSITION JUST AS LIKELY AT ANY ALTERNATE SITE. 0 ADVANTAGES OF ON-SITE DIOXIN INCINERATION; - THE ENSCO INCINERATOR WILL BE ON-LINE AND AVAILABLE FOR INCINERATTION BEFORE ANY OTHER TREATMENT OR DISPOSAL ALTERNATIVE. - ON-SITE MANAGEMENT OF THE DRUMMED WASTE REQUIRES MUCH LESS HANDLING THAN OFF-SITE TRANSPORTATION AND TREATMENT. - RELATIVE COSTS OF ON-SITE INCINERATION ARE MUCH LESS THAN FOR OFF-SITE BECAUSE OF VERY HIGH TRANSPORTATION COSTS. Vertac Chemical Corporation Jacksonville, Arkansas DIOXIN CERTIFICATION 0 The Dioxin Certification process for the ENSCO mobile incinerator is expected to proceed as schediuled. 0 However, public opposition to on-site dioxin incineration in Jacksonville is expected to be well-organized and vocal. 0 Adverse health effects have been widely reported in the local press despite reports from CDC that their evaluations of enviornmental Q-, data indicate no current health hazard. 0 Although many Jacksonville citizens apparently favor off-site incineration^ there are several disadvantages: 0 0 - There are presently no off-site facilities with a permit to Q commericially treat or dispose of dioxin waste.
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