Cr

cDATE STAMP

MEMO

WHITMOYER LABORATORIES, INC.MYERSTOWN. PENNA., U. S. A.

Dole July 21, 1980

To R. L. Widerkehr - Bristol (2)

From H. M, Huffman

CC:

D. J. KingR. D. Frawley-Cliftifn-&.- Croesus

Subject: ARSENICAL WASTE DISPOSAL

As per your request, I submit the attached report by

Mr. Rich Rosera describing some past history / our present

situation/ and future possibilities for more economical

handling methods. Also Attached is our latest information

regarding impending federal and state regulations on

generation} treatment; transportation; and disposal of

hazardous wastes under the Resource Conservation and Recovery

Act of 1976.

If there is more information on this subject you

reguire, please let me know.

Harold K. Huffman

HMH :lcb

300006

•»

DATE STAMP

MEMO

WHITMOYER LABORATORIES, INC.MYERSTOWN. PENNA., U. S. A.

Dale July 14, 1980

To H. M. Huffman V'

From R. S. Rosera

CC:

»

Subject: ARSENICAL WASTE DISPOSAL

Awareness of the Importance of waste disposal practices in the manufactureof arsenical products came relatively early to Whitmoyer. As a result ofineffective treatment and disposal from 1957 to 1964, an estimated fourmillion pounds of total arsenic in vater was put into lagoons or piles atthe My erst own plant and at a nearby dump. After Rohm and Haas acquiredWhitmoyer in 196A, contamination of the groundwater and the TulpehockenCreek in the Myerstovn area was discovered and a remedial program begunimmediately. An 83' x 123* x 12* waterproofed reinforced concrete vaultwas constructed at the plant, and into this was placed contaminated soiland relatively insoluble waste materials containing an estimated three mil-lion pounds of total arsenic. Wells were drilled in the contaminated ground-water area and treatment of water pumped from them with ferric sulfate pre-cipitated the arsenic and reduced the soluble arsenic to about 1 ppm. Thisoperation continued for &t years and resulted in recovery of 425,000 Ib. ofarsenic from groundwater; it vas stopped after reaching a removal rate ofonly 40-60 Ib./week and the remaining level of arsenic in the groundwaterhas not markedly changed since that time. The capital cost for this remed-ial action was $380,000. The Pennsylvania Department of Health, and laterthe Department of Environmental Resources (DER) were aware of and in agree-ment with the remedial program throughout its course. The program has re-cently been selected by the.EPA as one of ten throughout the country to besummarized and presented as an example of what can be done to correct environ-mental contamination.

Concurrent *i' h the remedial program was one to upgrade the arsenical pro-duction f< xT ies and maintain production of arsanilic acid and carbarsone.The ca t; st for this from 1964 to 1968 was $840,000. Included in thiswas tb c< t fa chemical sewer system and tankage. A permit was obtainedfor oc j ng of arsenical wastes; the largest volumes by far were ar-senic : z quors and arsenical waste salt solution, which were hauledout vi. t ik .ruck. See Table I for a summary. This system operated untilthe be; n: ng of 1971, when arsenical production was voluntarily shut downby Rohm ana Haas and ocean dumping halted in response to adverse publicityin the Philadelphia Inquirer and political pressure from RepresentativeSandman of New Jersey. Production resumed in 1972 following development ofa process by Rohm and Haas for recycling arsenic acid mother liquors;only 30-35% of the arsenic charged reacts to form crude arsanilic acid, andrecycle made 80-90% yields on arsenic for AA-Crude production possible.

An alternative to ocean dumping for' disposal of waste was still needed. Thetype of waste generated was reduced to solid drums of waste salt, (obtainedthrough evaporation), carbon, still tars, and occasional batches of concen-trated recycle arsenic acid. These were accumulated and stored while a

300007

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ARSENICAL WASTE DISPOSAL July 14, 1980

search for a land-based disposal method was sought. One proposed disposalmethod, by a company named Chem-Fix, called for chemical fixation of thearsenic waste; eventually it floundered because the DER would not approveuse of the proposed disposal site. Finally in 1974 approval vas obtainedto send vaste to Chem-Trol, a secure chemical landfill in Model City, N.Y.(north of Niagara Falls). In 1977 use of a similar disposal method inKiagaraFalls began',-.and in 1980 a site in Pennsylvania vas located. SeeTable II for details. In each case the companies and sites used for dis-posal vent through a careful evaluation process. The two Kev York sitesvere inspected by the .Rohm and Haas corporate environmental group and hadtheir financial backing investigated as veil. Periodic inspections of allthe sites continues. As an example of their credentials, CECOS vas theprime contractor for "phase 1" of the Love Canal clean-up.

A comparison of the approximately 7,000,000 Ib. of arsenical vaste generatedbetween 1972 and 1980 vith the 251,500,000 Ib. of vastes generated from 1965to 1971 is very revealing. Although the production volume between 1965 and1971 vas higher than between 1972 and 1980, the difference that the recycleprocess has made, is dramatically illustrated by this drastic vaste volumereduction.

Current Processing and Disposal Methods

The chemistry of the arsanilic acid process is rather simple and straight-forward:

OH' & V

+ HO - As - OH —————>// 120°C'0

Aniline Arsenic Acid Aniline ArsenateM.W. 93 142 - 235

+ H20

HO - As - OHo 300008

Aniline Arsenate Arsanilic Acid Water235 217 18

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ARSENICAL WASTE DISPOSAL July 14, 1980

Current Processing and Disposal Methods

Perchlorethylene (PCE) helps reduce the excess of aniline needed to maintainfluidity in the reaction , and also allows the vater of reaction to be readilyremoved at a relatively low temperature. The old non-recycle process, with-out PCE, required a larger excess of aniline and had a shorter reaction holdtime at 170°C; at this temperature, aniline would vaporize and aid in strip-ping off the vater. ';

Even under ideal conditions, the recoverable yield of arsanilic acid fromthe above reaction is only 35-40%, based on the arsenic acid charged. Thebasic problem is formation of byproducts and further reaction products, suchas the following:

HO - As - (. >-NH2

Diaminodiphenyl Arsonic Acid Triaminotriphenyl Arsonic Acid(DDAA) (TTAA)

Any DDAA formed can be hydrolyzed easily back to arsanilic acid duringfurther processing, but the reaction to the quite insoluble TTAA is ratherirreversible. In addition to this, high molecular weight aniline-based tarscan form.

Once the reaction is completed, the rest of the processing (see the Arseni-cal Process Flow Sheet) has the following aims:

1. Removal of excess aniline by:a) Extraction of arsenical reaction products with water and removal of

AC (aniline crude) containing aniline and most of the aniline tars.b) Extraction of more aniline with PCE.c) Stripping of most of the remaining aniline, with hydrolysis of DDAA

to arsanilic acid taking place as well.2. Recovery of as much crude arsanilic acid (TA) as possible by crystal-

lization, centrifuging, and washing, while not crystallizing the anilinearsenate that is also present.

3. Purification and decolorization of TA by dissolving in caustic and car-bon treatment, followed by re-acidification, filtration, washing anddrying; reaction with sodium cyanate (NaCNO) to form Carbarsone can alsotake place.

4. Recovery and/or recycling of:i a) Recycle arsenic (aniline arsenate) by evaporation of excess water,

carbon treatment to remove impurities, and filtration.

300009

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;, ARSENICAL.WASTE DISPOSAL July 14, 1980»

Current Processing and Disposal Methods

b) Crude PCE, through distillation to get purified FCE and separate itfrom crude aniline.

c) Crude aniline (AC), through vacuum stripping to obtain an aniline-perchlorethylene (AN/PCE) mixture and residual still bottoms (tars).

d) Aniline-water solution (AW) obtained from stripping in tank D-240(A% aniline in water distilled) and in tank D-200 (4 1% aniline invater distilled), through recycling to reactor drop tanks and re-cycling of AW from D-200 stripping as make-up vater for D-2AOstripping.

e) Arsanilic acid mother liquors (Recycle M.L.) obtained from washing. of recrystallized arsanilic acid, through use in slurrying TA intank D-100 before purification.

5. Minimization of the three types of vaste generated:a) Carbon from purification of recyie arsenic and decolorization of TA

during processing to Arsanilic Acid and Carbarsone.b) Tars from AC distillation still bottomsc) Aqueous vaste from:

i) Carbarsone mother liquors (M.L.), which are too high in salt con-tent to recycle.

ii) Excess arsanilic acid mother liquors (this occurs, for instance,if no Carbarsone production is taking place).

iii) Excess AW.6. Treatment of the aqueous waste by evaporation of water and centrifuging

to remove resulting salt. . •

Potentially a fourth type of waste is recycle arsenic. However, sincestart-up of the current process in 1977, purification of this material forrecycle has been sufficient to obviate any need for discard. Table IIIsummarizes characteristics of the current arsenical wastes. Some additionalcomments about each type are made below..

Arsenic Salt; Although Arsanilic Acid is produced in the largest quantity,it results in only about 0.64 Ib. of salt per pound of ArsanilicAcid, whereas .Carbarsone production generates about 2.15 Ib. ofsalt per pound of Carbarsone. In addition, the volume of arsanilicacid mother liquors generated is less because they can be recycledwhile Carbarsone mother liquors cannot. Abbott Laboratories useda process for purifying their TA which did not result in saltgeneration: dissolving TA in a large amount of hot water, carbontreatment, cooling and filtration. However, they ended up witha large volume of arsanilic acid mother liquors to recycle, and webelieve that our system minimizes the volume of waste we generate.It should be kept in mind that Abbott produced only ArsanilicAcid; if they had produced Carbarsone, they would have ended upwith the same kind of waste salt solution that we do. As Table •III indicates, this salt represents 60-70% of the waste drums that

< we generate, given the current product mix.

300011

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ARSENICAL. WASTE DISPOSAL July 14, 1980

Current Processing end Disposal Methods ' .

In addition to the direct costs for disposal shown in Table II,treatment of salt solution to evaporate vater and centrifuge saltrepresents a major investment in labor, steam,equipment, mainten-ance and pollution monitoring:

Labor:':With our current set up, the services of two men pershift for vaste equipment operation are required vhenoperating at capacity; it might be possible to eliminateone man per shift by spending around $50,000 -or so forautomatic control equipment.

Steam: For operation at capacity, an estimated 83,000-105,000gallons of <?6 fuel oil is used annually to generate steamfor evaporation; for the current #6 fuel oil cost of52.5c/gal., this represents $44,000-$55,000/year.

Equipment and Maintenance: The aqueous vaste system has tvoiron tanks for storage; an evaporator-reboiler system oftwo glass-lined vessels and a titanium pump and reboiler;and a salt removal system of two stainless steel tanks anda rubber-lined centrifuge. All of these have requiredrepairs, and some of them may have to be replaced entirelyin the future, because, the low pH salt solution is verycorrosive.

Pollution monitoring: The Pennsylvania Department of Environ-mental Resources (DER) air discharge permit for the wasteevaporator requires collection and analysis of 2-3 samplesweekly. Ve have had problems in the past with emissionsof aniline and with pH control. We aim to keep anilineout of the waste system as much as possible. Future reg-ulations on emissions of aniline and arsenic because ofcarcinogenicity are of concern here.

Carbon; Table III shows that the two types of waste carbon generated areconsiderably different in character, although they have alwaysbeen lumped together for disposal purposes. The primary differenceis the percent of arsenic in the two types. No attempt has everbeen made to regenerate this carbon, since it is unlikely thatarsenic and/or aniline removed from it could be reused anyway.Currently we are evaluating a different brand of carbon to determineif it would work better end thus allow us to use less of it. Car-bon usage '•".suits in about one-third of our annual waste generation.The two filter presses used for filtering the carbon currently re-quire upgrading to improve filter cake collection.

Tars; Although the volume of tars generated annually is small, they mustbe handled with care to avoid problems. They are drummed while hot,and then harden upon cooling; an unlined, closed-head drum is used,es opposed to open-head drums for other wastes. If not enoughaniline has been evaporated, the tars will not harden completely.Judgement concerning when to drum the still bottoms is called for,

300012

ARSENICAL WASTE DISPOSAL July 14, 1980

Tars; (cent*d)

as veil as checking of each drum after cooling. If the drumcontents.are not solid after cooling, they are recharged forfurther distillation. Repairs to the AC still, vhich generatesthese tars, have been few when compared to those needed for themore complex crude PCE still.

Disposal Sites

A. SCA Services

In April 1969, Chetn-Trol rullution Services vas founded by Louis E. Wagnerand Theodore J. Reese, both of whom had backgrounds in the chemicalindustry. In February 1972, Chem-Trol began operating at its current240 acre site in Model City, N.Y., north of Niagara Falls; the site vaspreviously used for rocket fuel manufacturing by Olin Kathieson ChemicalCo. Chem-Trol's aim from the start vas scientific,integrated treatmentand disposal of hazardous industrial vastes; they filled a distinctvoid in doing this, Wcause they quickly attracted business from allover the northerst region of the country.

In 1973, Chem-Trol became a subsidiary of SCA Services, a veil-knownBoston-based company specializing in trash collection and disposal;they are listed on the New York Stock Exchange.- About that time, SCAalso acquired Earthline Co., whose services ve have since used fortank cleaning (but not for disposal). Recently SCA decided to integrateits subsidiaries into the main company, eliminating the use of thename Chem-Trol zr.z servicing us out of the Newark, N.J. office, vherethe former Earthline subsidiary operates a liquid vaste treatment plant.

Dr. Clarke of the Rohm and Haas environmental group inspected the sitein late 1973 and approved it before disposal of arsenical vaste beganthere; he also visited it at least one other time, in 1976. To date,they have received operating permits from the New York State Departmentof Environmental Conservation (DEC) for seven secure landfill sites ontheir property and they are in the process of applying for their eighth.Their landfills nave an underlying barrier of clay about 50 ft. thick.Earth is partially excavated over a several acre site, and sections ofa chlorinated polyethylene (Hypalon) liner or liners with a combinedthickness of up to 100 mils are velded together as a further barrier.The landfill ie segmented according to the type of vaste to be disposed:heavy metals, "pseudo metals" (including arsenic), halogenated organics,flammable vaste and general vastes. After filling, each landfill is 'capped vith clay 'end landscaped. Originally, the leachate from landfillsvas put through a thermal oxidation (incineration) unit, but I believe thatnow thay have approval for vater treatment and discharge to the-Upcfr QNiagara River. O 01) U1 0

The main problems that Chem-Trol and SCA have had have been ones associatedvith their rapid growth and related to specific personnel. In 1979, SCA'sformer president and chairman vere convicted of fraud in a conflict-of-

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ARSENICAL WASTE DISPOSAL July 14, I960

Disposal Sites

A. SCA Services (cont'd)

interest scheme. Their personnel turnover has been rather large. In1976, SCA fired the president and founder of Chem-Trol, Louis Wagner.He immediately founded Hewco Chemical Waste Systems, the other majordisposal site ve have dealt vith, on the same principles as Chem-Trol;he took many employees vith him. SCA has had few problems, however,vith satisfying Ptate an* federal regulatory requirements. Localopposition has been a nuisance, but thus far has not endangeredcontinuing operations. At present ve cannot ship arsenical vaste tothem because their last landfill has been filled before the permitfor their next one is approved. Further comments on the statepermitting process are made below.

SCA or its subsidiaries also operate other hazardous vaste disposalsites. In addition to liquid treatment in Newark, K.J. and securelandfill in Model City, there is also secure landfills inPinewood, South Carolina, and in Kawkawlin, Michigan. Their one majorsetback vas a secure landfill in Wilsonville, 111., where the operationwas shutdown in 1977 as the result of a local residents' suit, whichwas supported by the state attorney general. This vas done,in spite ofapproval by the state and federal EPA of disposal at the site, be ausethere had been no public hearings about it.

B. CECOS International

CECOS stands for "Chemical and Environmental Conservation Systems,11 andis the new name for Kewco Chemical Waste Systems, Inc. As explainedabove, Kewco was started by Louis Wagner in 1976 after his dismissalby SCA from Chem-Trol. He vas able to obtain financial backing fromELF Holding, Inc., a holding company representing (reportedly) theinterests of five individuals in Kewco and a number of other companies:Gibralter Steel, Seneca Steel, Kiagara Sand, and several real estatecompanies. Kewco began an operation similar to that of Chem-Trol inAugust 1976 on a greater than 400 acre site just outside the Kiagara Fallscity limits. The site had previously been used by Union Carbide fordisposal of lime in connection vith acetylene production, and vas stillbeing used for disposal of calcium fluoride from Cooker Chemical andmercury sludges from Olin. The underlying stratum vas dolomite limestonecovered by several feet of clay.

CECOS has received operating permits for three secure landfills, eachlarger than the previous one, since beginning operations. An aerialphotograph of their latest "secure chemical management facility" isattached. The photograph shows the secure landfill 03 and its varioussegments, along vith their tertiary waste water treatment plant at the

i, top of the picture. This tertiary treatment consists of sand filtration,carbon adsorption, and aeration/biological oxidation. Effluent is thendischarged to the Kiagara Falls Municipal Treatment Plant, which is alsoa tertiary treatment plant. Qnftftf A

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ARSENICAL WASTE DISPOSAL July 14, I960

B. CECOS International tcont'd)

Like SCA, CECOS features integrated, "closed loop" processing anddisposal of hazardous wastes. For each landfill there is a threedimensional map of the location of each drum and the reported contentsthereof. Apprqval for disposal of each type of vaste must be obtainedahead of time, but problems with waste shipments (e.g., leaking drums)can be dealt with at the site. If, according to independent groundwatermonitoring, an increase in the level of a hazardous compound occurs, theexact location of a break in the landfill lining can be pinpointed andexcavated. As with SCA, CECOS also does outside remedial work at suchplaces as the Love Canal and the Silresim site in Massachusetts.

There are some differences between SCA and CECOS operations, the greatestbeing a current disposal cost of $21/drum for SCA versus $35/drum forCECOS. I believe that the main reason for this difference is the extraexpense that CECOS incurred last year in obtaining the permit for theirsecure landfill #3: basically, they were required to meet the then proposedResource Conservation and Recovery Act (RCRA) regulations, including thesubstantial financial requirements. Some of these costs are summarizedor implied in the attached page entitled, "Your Liability Protection." Thedisposal cost of $2I/drum at SCA is really academic at present, since theyare currently undergoing the same permitting process that CECOS did andhave run out of space at their Model City landfill for the time being; whenSCA does open up a new landfill, their disposal costs are likely to have aquantum increase for the same reason as those for CECOS did. Anotherdifference that CECOS claims is a commitment to no "storage" beforedisposal takes place. It is worth a premium to some waste generators toknow that their wastes will always be promptly buried in an approvedsite and won't be "stored11. The danger with storage is that the materialmay never actually be disposed of as was the case with Chemical Controlin Elisabeth, N.J. or Chem-Dyne is Hamilton, Ohio. It is a definiteselling point nowadays. CECOS is one of the few approved disposal sitesfor PCS's (polychlorinated biphenyIs).

CECOS also has a facility at Williamsburg, Ohio, east of Cincinnati.We have approval to use this facility for our wastes, but we have neverhad to. CECOS representatives have talked for years of opening a hazardouswaste disposal landfill near Hazel'-en, PA, and now are discussing theopening of a facility for liquid waste treatment in Chester, PA. Neitherfacility will be operating in time to register before the RCRA August 18"hazardous waste activity" notification deadline, so a lengthy approvalprocess is likely. In Niagara Falls they have plans for a high tempera-ture incinerator, but this should not affect us.

Because of its rapid growth, CECOS has had some of the same organizationalproblems that SCA has had: high turnover of personnel and questionable'organizational efficiency. However, their top management team is stillintact, and their degree of organization seems to be improving.

300015

4626 Royal" AvenuoNiagara Falls. N.Y. 14303

CHEMICAL AND ENVIRONMENTAL CONSERVATION SYSTEMS (716) 278*1811

Y NtVVCO CHEMICAL WASTE SVSTEMSVOUR LIABILITY PROTECTION

We have 'told you about our new approved SecureChemical Landfill which we will refer to in the future as theSecure Chemical Management Facility (SCMF).

This facility provides for the safe and effectivedisposal of your chemical waste products, and thereforeminimizes your immediate liability as a waste generator. Nowwe would like to g-tue you. 4ome o ($ the. 4peC't4<tc4 .o£ how you.pAOtected ^Aom long £eAm tiabJitJity by working with CECOS.

1) A 20 yza.fi Mon<t£oA<Lng, Maintenance and ContingencyPlan (MMCP) has been approved by the New York State DEC. Thisprogram includes CECOS1 monitoring, maintenance and contingencyplans covering surface water quality, groundwater quality andhydrology, control of SCMF internal leachate, lagoon and tanklevels, and air quality, for a 20 year period after facilityclosure. Th<i& MMCP dtmonAtfiatu OUA opeAatlonal compliancewith all wateA and alA quality itandaAd.6.

2} Vziy Aub&tantiat peA^oAmance bond* and tAu.4thave been provided to insure the completion of these long termclosure, monitoring and maintenance activities.

3) Special tJidbJitJitg -cnAa^ance has been secured inthe amounts of $5 million per occurrence, and $10 million.aggregate for claims arising from the gradual A.elea4e OH escapeo£ hazaidoiu wai-te. Also, we have general HabJitJity ^cn^uAancewith combined single limits of $11 million jJOA. Sudden OHacc-cden-tal occurrence.s involving escape or release of hazardouswaste.

4) Annually, CECOS is providing not less than $&0,000and on site working space, £o* the. 4CA.V4.ce4 o£ peA£Onncl to besecured and 4upeAvu.4ed by the. MS-DEC to en^uAe £ull-^mej.n&pe.ct'ion and implementation of all monitoring, maintenance,and closure progra'ms together with the fulfillment of all otherPermit conditions.

Ntw Votik. State.'* Enu-cAonmental Con4eAva£<con Law4iij &tfu.c.t and are patterned after, and administered with the

Federal RCRA provisions in mind. In being the first to securethese NYS-DEC "Permits To Operate", CECOS *.& the. tf-c.A-6* <tn the.Un-cted State.* to comply with the. pAopo^ed (but ye.t to be.implemented) ^/cnanc-cal Aeiponi-tb-cl^tt/ Aequ^AementA oi the.FcdeAal RCRA law. OUA obje.ct4.ve. /* to pAoulde you with max-cmum

({Aom tiabmty . 300016

l

- 9 -»

^ ARSENICAL WASTE DISPOSAL July 14, 1980 -

C. Stabatrol

Stabatrol is a email, younger (circa 1976), privately-held hazardousvaste disposal company whose operations are currently limited toPennsylvania. Stabatrol1s president is Richard Valiga, and theemployees ve have dealt vith mostly have backgrounds in Pennsylvania;one has previously worked for the state DER in a position dealing vithhazardous vaste. Perhaps as a result of this, they seem to have a goodrapport vith the DER. Stabatrol has taken a completely differentapproach to disposal of hazardous vastes than SCA and CECOS. They have anumber of small sites scattered throughout Pennsylvania and obtain approvalfor vaste disposal from the DER on a case-by-case basis according to thetype of vaste; according to them, they have never had an approval denied.The site ve are currently approved to use is near New Kilford, PA,north of Scranton.

Stabatrol has two types of operations that they conduct at their sites.One is chemical fixation or stabilization of .bulk vastes via their"Terra-Tite" process; application of this to our vastesseems doubtfulat present. The other operation of "vaulting" is really just a somewhatdifferent method of landfilling bulk or drummed vastes. It isdesigned in such a vay (see sketch of Stabatrol Vault Construction) that

x an impervious "Terra-Tite" barrier is both . above and below thevaste. A sump is provided for leachate collection, but leachateshould be minimal as long as the protective barrier is intact. Thevault is considerably smaller in length and width than the landfillsof SCA and CECOS, and drums would be stacked only about four high.

Because of the case-by-case nature of getting approval for vaste disposal,it takes much more time to get approval for disposal of specificvastes than it does vith SCA and CECOS. Recently the DER added a leachingtest requirement which ve are currently doing for our salt and carbonvaste. This vill cost an estimated $2500 to complete and will becredited against future disposal costs. The analyses required vill takea month to do because some testing is being done at an outside laboratory.Another difference in dealing vith Stabatrol is that every problem vithvaste drums is promptly-reported because they cannot handle drums vithleaks, excessive liquid, etc. like SCA or CECOS can. But they have givenus excellent service and feedback. Another significant difference betveenStabatrol and the New York sites is that Stabatrol required a specificvolume commitment, which ve negotiated at 1000 drums minimum for the firstyear; however, ve do get a price break of $0.75/drum for volume in excessof this. Stabatrol must also provide for drum storage at their sitesuntil they accumulate enough vastes to build a vault; this can be adisadvantage for storage times of several months.

In the near future, Stabatrol plans to open a large disposal site nearYork, PA specifically for hazardous wastes. If they succeed, they vill notonly be very close to us, but might have the only such approved site inPennsylvania before the RCRA filing deadline of August 18th.

300018

oU-

<O

J< isZl•

aoooin

- 10 -

ARSENICAL WASTE DISPOSAL July 14, I960

RCRA Regulations and Pennsylvania's Law

RCRA regulations have now largely been finalized by the EPA, through rulesissued in February and May. The Department of Transportation (DOT) alsoissued shipping regulations covering hazardous vaste in May. I have summarizedthe impact of the proposed RCRA regulations on us in previous reports, but Ihave not yet been able to plow through the final rules issued in May to assesstheir changes. I will be doing this shortly, however, because notificationof any hazardous vaste activity before August 18th is vital. Mr. Croesushas obtained the notification form and is vorking on completing it. Hazardousvaste activity includes generation, treatment, storage for more than 90 days,disposal or transportation. There is little doubt that our arsenic vastesare hazardous and other vastes could be hazardous as veil (e.g., empty drumsof DOT hazardous materials).

As of the beginning of July, Pennsylvania has a. law governing hazardous vasteson the state level. When regulations based on it are issued, the DER villprobably be granted "primacy" in administering RCRA provisions in Pennsylvaniaby the EPA. Although the law in some cases is more stringent than RCRA(e.g., specifying minimum fines for criminal violations and higher maximumfines), it is probable that its "financial responsibility" provisions vill bemore flexible than those of RCRA. It makes a distinction between generators vhodo treatment (like us) and commercial treatment plants. At a recent seminar onthe subject, Mr. Galida of the DER stated that it vas intended to tailorfinancial responsibility requirements to the individual plant on a "slidingscale."

The one thing that seems assured at present is that individual states andlocalities vill not be allowed to exclude hazardous vaste generated in anotherstate. There are several bases for this:

(A) A U.S. Supreme Court decision several years ago that one state couldnot exclude transport of another state's vaste for disposal. In thisinstance, New Jersey vas trying to exclude dumping of vaste from the cityof Philadelphia.

(B) RCRA provisions which give the U.S. EPA sole authority to administerRCRA or determine vho does. If a state attempted to bar hazardous vastedisposal from another state, the EPA vould not certify it to administerRCRA. An early version of the Pennsylvania law could have stoppedhazardous vaste disposal entirely by granting elected county officialsveto power over hazardous vaste disposal siting; fortunately, this vasdropped in the final version.

(C) Local ordinances banning transport of hazardous materials or vastes areillegal and are pre-empted by U.S. DOT authority. The DOT is currentlyconsidering regulations vhich vould restrict routes for transport ofradioactive materials, and this may be a prelude to something similar'for hazardous materials in general. However, this is different thana total ban and could have the benefit of bringing order to the situation.

300020

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ARSENICAL WASTE DISPOSAL July 14, 1980 .

Future Directions

The need to dispose of arsenical vastes is one which will never completely goaway as long as we continue to manufacture arsenical products. The natureof the reaction is such that unusuable by-products are formed no mattervhat the reaction conditions. However, much progress has been made throughthe years on optimizing reaction conditions, improving reactor productivity,and improving yields; this is the focus of continuing efforts as well. Effortshave also been made through equipment design and operator training to minimizephysical losses through purges, poor filtration and the like. Optimizingcrystallization conditions for arsanilic acid and Carbarsone is currently receivinattention because of recent problems which may have been caused by excessiveby-products.of reaction. Production of arsanilic acid is a relatively complexprocess, but using good quality materials and getting an optimum reaction isthe most important factor both in getting good yields and in minimizing waste.Once the arsenic is in the waste, however, it is neither practical nor .economical to attempt recovery of it, because it is in such a form (as tars,TTAA, arsenites, etc.) as to render it useless to us..

At present, we are also looking at waste handling to economize on costs.Particularly if we stay with our current method of waste salt solutiontreatment by evaporation and isolation of the salt, we might be able toeconomize by some method of bulk handling of the salt and/or carbon insteadof drumming. For example, both wastes would be put into 35,000 Ib. capacity"roll-oij;" containers for transport. Howe/er, this might mean eliminating oneor more of the disposal companies we now deal with. Transportation cost wouldalso be more expensive and thus offset at least some of the savings. •

Disposal of the waste salt solution as a liquid is an option where threefactors are essential: cost, closeness of the treatment plant(s), andreliability of operation of the tit-Lment plant(s). If all of these itemsare satisfactory, it could save us expenses for labor, maintenance, equipmentreplacement, pollution monitoring, and the future financial responsibilityrequirements of being a waste treatment plant. Ve are currently pursuing fourpossibilities for outside treatment of arsenical wastewater in southeasternPennsylvania. Presumably, we could haul waste using our own trucks, which wouldalso be an advantage costwise...

Richard S. Rosera

RSR:lcb

300021