Page 1 of 6 

Memorandum

DATE: October 2, 2009 

TO: RCRA Docket 

FROM: C. Pan Lee, Environmental Scientist, U.S. EPA/OSWER/ORCR/PIID 

SUBJECT: Subtitle C (Hazardous Waste) Commercial Landfill Capacity 

A. Available Commercial Landfill Capacity at the National Level 

Available commercial landfill capacity is defined as the remaining capacity at a permitted facility that 

conducts commercial hazardous waste management using a landfill. In this context, a “commercial 

hazardous waste management facility” is a facility that conducts commercial hazardous waste 

management: (1) for any generator or facility, or (2) for a limited group of generators or facilities. 

• Commercial Landfill Capacity Analysis Performed in 2009. Estimated 21.7 – 25.4 million 

tons of available capacity from 19 commercial facilities with Subtitle C landfill capacity. 

As of September 2009, there were 19 commercial hazardous waste landfills in 15 States (AL, CA, 

CO, ID, IL, IN, LA, MI, NV, NY, OH, OK, OR, TX, and UT).1

 The total available commercial 

landfill capacity for hazardous wastes at these facilities is estimated to be between 21.7 and 25.4 

million tons. These available capacity estimates are based on: actual capacity estimates 

provided by facilities in April-September 2009, information provided by EPA Regions and States 

in April/May 2009, and capacity estimates developed using 1995-2007 Biennial Report data. 

• Commercial Landfill Capacity Analysis Performed in 2000.2

 Estimated 22.6 – 37.2 million 

tons of available capacity from 21 commercial facilities with Subtitle C landfill capacity. 

As of July 2000, there were 21 commercial hazardous waste landfills in 16 States (AL, CA, CO, 

ID, IL, IN, LA, MI, NV, NY, OH, OK, OR, SC, TX, and UT). The total available commercial landfill 

capacity for hazardous wastes at these facilities was estimated to be between 22.6 and 37.2 

million tons. These available capacity estimates are based on: actual capacity estimates 

provided by facilities in May/July 2000 and capacity estimates developed using 1995-1999 

Biennial Report data. 

 

1

 Note that there are two additional permitted commercial landfill facilities: Clean Harbors Baton Rouge, LLC (EPA ID 

LAD010395127) and Clean Harbors Westmoreland (EPA ID CAD000633164). However, these facilities are no longer accepting 

waste for disposal. 

2

 U.S. EPA, Background Document for Capacity Analysis for Land Disposal Restrictions: Newly Identified Dye and Pigment 

Manufacturing Wastes (Final Rule), Appendix B, February 2005. 
 Page 2 of 6 

B. Available Commercial Landfill Capacity at Existing Facilities 

Exhibit 1 provides information on the available commercial landfill capacity at each of the existing 19 

facilities. These available capacity estimates are based on: actual capacity estimates provided by 

facilities in April-September 2009, information provided by EPA Regions and States in April/May 2009, 

and capacity estimates developed using 1995 - 2007 Biennial Report data. 

Exhibit 1. Available Commercial Landfill Capacity for Hazardous Wastes a 

(Sorted in ascending order by EPA Region and EPA ID Number) 

Available Commercial 

Landfill Capacity, 2009 EPA 

Region State EPA ID Site Name 

Low High 

2 NY NYD049836679 CWM CHEMICAL SERVICES, LLC 384,437 384,437 

4 AL ALD000622464 CHEMICAL WASTE MANAGEMENT 550,000 550,000 

5 IL ILD000805812 PEORIA DISPOSAL CO INC 8,275 8,275 

5 IL ILD010284248 CID RECYCLING & DISPOSAL FAC 6,620 6,620 

5 IN IND980503890 HERITAGE ENVIRONMENTAL SERVICES LLC 8,124,876 8,124,876 

5 MI MID048090633 WAYNE DISPOSAL INC b 4,611,655 8,310,324 

5 OH OHD045243706 ENVIROSAFE SERVICES OF OHIO INC 719,426 719,426 

6 LA LAD000777201 CHEMICAL WASTE MANAGEMENT LAKE CHARLES 330,995 330,995 

6 OK OKD065438376 CLEAN HARBORS ENVIRONMENTAL SERVICES 

LONE MOUNTAIN FACILITY 222,444 222,444 

6 TX TXD069452340 US ECOLOGY TEXAS INC 136,730 136,730 

6 TX TXD988088464 WASTE CONTROL SPECIALISTS LLC 253,211 253,211 

8 CO COD991300484 CLEAN HARBORS DEER TRAIL LLC 330,995 330,995 

8 UT UTD982598898 ENERGYSOLUTIONS, LLC (PREV. ENVIROCARE) 192,027 192,027 

8 UT UTD991301748 CLEAN HARBORS GRASSY MOUNTAIN, LLC. 283,001 283,001 

9 CA CAD980675276 CLEAN HARBORS BUTTONWILLOW, INC 12,412 12,412 

9 CA CAT000646117 CHEMICAL WASTE MANAGEMENT, INC. 661,990 661,990 

9 NV NVT330010000 US ECOLOGY NEVADA 306,170 306,170 

10 ID IDD073114654 US ECOLOGY IDAHO INC SITE B 1,572,226 1,572,226 

10 OR ORD089452353 CHEMICAL WASTE MANAGEMENT OF THE 

NORTHWEST 2,981,188 2,981,188 

Total 21,688,678 25,387,347 

a

 Excludes two additional permitted commercial landfill facilities: Clean Harbors Baton Rouge, LLC (EPA ID LAD010395127) and Clean 

Harbors Westmoreland (EPA ID CAD000633164). These facilities are no longer accepting waste for disposal. 

b

 EPA was not able to obtain updated information on available commercial landfill capacity at this facility. Thus, EPA derived low and 

high available commercial landfill capacity estimates for this facility using 1995-2007 Biennial Report data. 

Sources: Consultations with commercial landfill facilities, collaboration with EPA Regions and States, and RCRAInfo/Biennial Report. 

Data as of April – September 2009. 
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C. Permits Issued for Existing Commercial Landfill Facilities in Past Years 

The section discusses already approved and permitted landfill capacity (i.e., historic data) for which 

existing facilities applied for during the past several years. 

Based on RCRAInfo data (as of September 2009), the three most recent permits issued to commercial 

hazardous waste landfill facilities include: 

• Heritage Environmental Services, LLC (EPA ID Number IND980503890). On July 14, 2009, 

approximately 0.99 acres of landfill capacity were permitted for this facility.3

 The currently 

available commercial landfill capacity of this facility is estimated to be 8.1 million tons. 

• U.S. Ecology Nevada (EPA ID Number NVT330010000). On September 1, 2008, 

approximately 1.4 million tons of landfill capacity were permitted for this facility. The currently 

available commercial landfill capacity of this facility is estimated to be 306,170 tons. 

• Cid Recycling and Disposal (EPA ID Number ILD010284248). On July 16, 2008, 

approximately 1.28 million tons of landfill capacity were permitted for this facility. The currently 

available commercial landfill capacity of this facility is estimated to be 6,620 tons. 

Exhibit 2 provides information on facilities with landfill units permitted between 2000 and 2009. The 

exhibit also provides information on the permitted capacity. 

A facility may apply for a permit to build Subtitle C landfill cells. It is important to note, however, that 

permitted capacity does not mean that the capacity is readily available. Based on consultations 

conducted in April-September 2009, some of the facilities with permitted landfill capacity have not 

constructed all landfill cells to meet their maximum permitted capacity. That is, facilities build the landfill 

cells gradually, as long as the permit is still valid and there is demand to dispose of hazardous wastes in 

a landfill cell. A RCRA Permit usually lasts for 10 years and can be renewed before it expires. 

 

3

 In RCRAInfo, the unit of measure for this facility’s permitted capacity is “acres.” There is not sufficient information to convert this 

capacity estimate into tons. 
 Page 4 of 6 

Exhibit 2. Facilities with Landfill Units Permitted between 2000 and 2009 

(Sorted in descending order by process status effective date) 

EPA ID Number Facility Name Process Status 

Effective Date a

Permitted 

Capacity (tons) 

IND980503890 HERITAGE ENVIRONMENTAL SERVICES LLC 7/14/2009 NA b

NVT330010000 US ECOLOGY NEVADA 09/01/2008 1,365,355 

ILD010284248 CID RECYCLING & DISPOSAL FAC 7/16/2008 1,281,778 

TXD069452340 US ECOLOGY TEXAS INC 5/19/2008 472,909 

COD991300484 CLEAN HARBORS DEER TRAIL LLC 11/01/2006 342,580 

COD991300484 CLEAN HARBORS DEER TRAIL LLC 1/20/2006 2,275,591 

OHD045243706 ENVIROSAFE SERVICES OF OHIO INC 12/29/2005 2,625,039 

UTD991301748 CLEAN HARBORS GRASSY MOUNTAIN, LLC. 08/31/2005 408,514 

NYD049836679 CWM CHEMICAL SERVICES, LLC 08/05/2005 2,891,639 

NVT330010000 US ECOLOGY NEVADA 04/29/2005 1,952,871 

UTD982598898 ENERGYSOLUTIONS, LLC (PREV. ENVIROCARE) 03/24/2004 796,871 

IDD073114654 US ECOLOGY IDAHO INC SITE B 10/02/2003 3,125,007 

CAT000646117 CHEMICAL WASTE MANAGEMENT, INC. 06/16/2003 8,854,117 

ILD000805812 PEORIA DISPOSAL CO INC 12/18/2002 2,183,391 

ORD089452353 CHEMICAL WASTE MANAGEMENT OF THE NORTHWEST 09/19/2002 2,033,225 

TXD988088464 WASTE CONTROL SPECIALISTS LLC 04/24/2002 1,302,465 

UTD991301748 CLEAN HARBORS GRASSY MOUNTAIN, LLC. 09/05/2000 865,089 

IDD073114654 US ECOLOGY IDAHO INC SITE B 06/10/2000 1,937,761 

TXD069452340 US ECOLOGY TEXAS INC 02/08/2000 NA b

a

 In RCRAInfo, “process status effective date” is defined as the date specifying when the other information in the process detail data 

record (i.e., process, capacity, and operating and legal status) became effective. 

b

 In RCRAInfo, the unit of measure for this facility’s permitted capacity is “acres.” There is not sufficient information to convert this 

capacity estimate into tons. Note, however, that EPA obtained the facility’s currently available capacity by contacting the facility. 

NA Not Available 

Source: RCRAInfo/Permit Module. Data as of April – September 2009. 
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D. Landfill Capacity Expansions at Existing Commercial Landfill Facilities 

This section discusses the potential expansion of landfill cell capacity in the existing facilities with 

approved permits for landfill units. Again, based on our data sources4

, at this time, no new facilities plan 

to apply for a Subtitle C commercial landfill permit. 

Based on conversation with a limited number of representatives from commercial landfill facilities, the 

following two facilities expanded their landfill capacity recently: 

• Clean Harbors Buttonwillow, Inc. (EPA ID CAD980675276). Approximately 0.88 million tons of 

commercial landfill capacity would become available on July 1, 2009. This capacity is expected 

to last about 4 years. 

• US Ecology Idaho Inc. Site B (EPA ID IDD073114654). The last cell of the existing landfill was 

under construction under a temporary authorization. This new cell would increase the capacity of 

the landfill by 0.62 million tons. The facility expected to receive approval for the permit 

modification associated with the increase in capacity in the next few days after the call (i.e., a few 

days after April 29, 2009). 

Exhibit 3 provides information on near- and long-term landfill capacity expansions. 

 

4

 Consultations with commercial landfill facilities, collaboration with EPA Regions and States, and RCRAInfo/Permit Module. Data 

as of April – September 2009. 
 Page 6 of 6 

Exhibit 3. Near- and Long-Term Landfill Capacity Expansions 

Near-Term Additional Capacity 

(2009 and 2010) 

Long-Term Ad

(Afte

EPA ID Site Name 

Capacity 

Availability 

Cubic Yards Tons a

Estimated 

Life of 

Capacity 

(years) 

Capacity 

Availability 

Cu

Ya

NYD049836679 CWM CHEMICAL SERVICES, LLC ----- ----- ----- ----- Permit under Review N

ALD000622464 CHEMICAL WASTE MANAGEMENT 2010 NA 550,000 1 Plans to Expand Landfill Capacity within 5 Years N

IND980503890 HERITAGE ENVIRONMENTAL SERVICES LLC ----- ----- ----- ----- Plans to Re-Permit Subtitle C and D Landfills 2,00

LAD000777201 CHEMICAL WASTE MANAGEMENT LAKE CHARLES 2010 NA NA NA Plans to Construct an Additional Cell Annually N

OKD065438376 

CLEAN HARBORS ENVIRONMENTAL SERVICES LONE MOUNTAIN FACILITY 

Within the 

Next 3 Years 668,500 553,175 7 

Plans to Expand Capacity 

as Part of Permit 

Renewal Process 

3,50

TXD069452340 US ECOLOGY TEXAS INC First Quarter 2010 2,400,000 1,985,970 NA ----- -TXD988088464 WASTE CONTROL SPECIALISTS LLC Mid 2010 710,000 587,516 NA ----- -

UTD991301748 CLEAN HARBORS GRASSY MOUNTAIN, LLC. ----- ----- ----- ----- Initial Stages of Permitting 284

CAD980675276 CLEAN HARBORS BUTTONWILLOW, INC July 1, 2009 1,058,000 875,482 4 Plans to Expand Capacity in 3 to 4 Years N

CAT000646117 CHEMICAL WASTE MANAGEMENT, INC. Summer 2010 5,000,000 4,137,438 8 NA NNVT330010000 US ECOLOGY NEVADA ----- ----- ----- ----- Plans to Expand Capacity in 10 Years N

IDD073114654 US ECOLOGY IDAHO INC SITE B Spring 2009 750,000 620,616 1 Landfill Design Stages N

ORD089452353 CHEMICAL WASTE MANAGEMENT OF THE NORTHWEST ----- ----- ----- ----- Plans to Expand Capacity in 3 Years N

a Capacity in tons was estimated using a waste density of 8.194 pounds/gallon. This waste density is based on wastes reported to in Generation and Manageme

and Waste Received from Offsite (WR) Forms of the 1999-2007 BR. NA Not Available Source: Consultations with commercial landfill facilities. Data as of April – September 2009.