## Page 1 of 6 

# Memorandum

DATE : October 2, 2009

TO : RCRA Docket

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

SUBJECT : Subtitle C (Hazar dous Waste) Commerc ial Landfill Capacity

A. Available Commercial Landfill Capacity at the National Level

Available commercial landfill capacity is defined as the remaining capa city at a permitted facility that conducts commercial hazardous waste management us ing a landfill. In this context, a “commercial hazardous waste management facility” is a fa cility 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 Perfor med 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 fa cilities is estimated to be between 21.7 and 25.4

million tons. These available ca pacity estimates are based on: actual capacity estimates provided by facilities in Apr il-September 2009, information prov ided by EPA Regions and States in April/May 2009, and capacity estimates dev eloped 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 landf ills 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 fac ilities was estimated to be between 22.6 and 37.2

million tons. These available ca pacity 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 Dispos al 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 commercia l landfill capacity at each of the existing 19 facilities. These available capaci ty estimates are based on: actual capacity es timates 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 La ndfill 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 C lean Harbors Westmoreland (EPA ID CAD000633164). These fac ilities are no longer accepting waste for disposal.

b EPA was not able to obtain updated information on available co mmercial landfill capacity at this facility. Thus, EPA derived low and high available commercial landfill capacity estimates fo r this facility using 1995-2007 Biennial Report data.

Sources: Consultations with commercial landfill facilities, collaboration with EPA Regions and States, and RCRAInfo/Biennial R eport. Data as of April – September 2009.

## Page 3 of 6 C. Permits Issued for Existing Commerc ial Landfill Facilities in Past Years

The section discusses already appr oved and permitted landfill capacity (i.e., historic data) for which existing facilities applied for duri ng 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 capaci ty 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 th is 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 la ndfill 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 perm itted 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 c onvert this capacity estimate into tons.

## Page 4 of 6 Exhibit 2. Facilities with Landfill Un its 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 t he date specifying when the other information in the process deta il data record (i.e., process, capacity, and operat ing 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 c onvert this capacity estimate into tons. Note, however, that EPA obtained the facility’s currently availabl e capacity by contacting the fa cility.

NA Not Available

Source: RCRAInfo/Permit Module. Data as of April – September 2009.

## Page 5 of 6 D. Landfill Capacity Expansions at Existing Commercial Landfill Facilities

This section discusses the potential expansion of landfill ce ll capacity in the ex isting facilities with approved permits for landfill units. Again, based on our data sources 4 

## , at this time, no new facilities plan to apply for a Subtitle C commercial landfill permit.

Based on conversation with a limited number of repr esentatives 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 availabl e 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 capa city 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, collaborat ion with EPA Regions and States, and RCRAInfo/Permit Module. Da ta as of April – September 2009.Page 6 of 6Exhibit 3. Near- and Long-TermLandfill Capacity ExpansionsNear-Term Additional Capacity(2009 and 2010)Long-Term Additional Capacity(After 2010)EPA IDSite NameCapacityAvailabilityCubicYardsTonsaEstimatedLife ofCapacity(years)CapacityAvailabilityCubicYardsTonsaEstimatedLife ofCapacity(years)NYD049836679 CWM CHEMICAL SERVICES, LLC----- ----- ----- -----Permit under Review NA 2,900,000 NAALD000622464 CHEMICAL WASTE MANAGEMENT 2010 NA 550,000 1Plans to Expand LandfillCapacity within 5 YearsNA NA NAIND980503890HERITAGE ENVIRONMENTALSERVICES LLC----- ----- ----- -----Plans to Re-PermitSubtitle C and D Landfills2,000,000 1,654,975 NALAD000777201CHEMICAL WASTE MANAGEMENTLAKE CHARLES2010 NA NA NAPlans to Construct anAdditional Cell AnnuallyNA NA NAOKD065438376CLEAN HARBORSENVIRONMENTAL SERVICESLONE MOUNTAIN FACILITYWithin theNext 3 Years668,500 553,175 7Plans to Expand Capacityas Part of PermitRenewal Process3,500,000 2,896,207 24TXD069452340 US ECOLOGY TEXAS INCFirst Quarter20102,400,000 1,985,970 NA ----- ----- ----- -----TXD988088464WASTE CONTROL SPECIALISTSLLCMid 2010 710,000 587,516 NA ----- ----- ----- -----UTD991301748CLEAN HARBORS GRASSYMOUNTAIN, LLC.----- ----- ----- -----Initial Stages of Permitting 284,000 235,006 3CAD980675276CLEAN HARBORSBUTTONWILLOW, INCJuly 1, 2009 1,058,000 875,482 4Plans to Expand Capacityin 3 to 4 YearsNA NA NACAT000646117CHEMICAL WASTEMANAGEMENT, INC.Summer 2010 5,000,000 4,137,438 8 NA NA NA NANVT330010000 US ECOLOGY NEVADA----- ----- ----- -----Plans to Expand Capacityin 10 YearsNA NA NAIDD073114654 US ECOLOGY IDAHO INC SITE B Spring 2009 750,000 620,616 1 Landfill Design Stages NA NA NAORD089452353CHEMICAL WASTE MANAGEMENTOF THE NORTHWEST----- ----- ----- -----Plans to Expand Capacityin 3 YearsNA NA NAaCapacity in tons was estimated using a waste density of 8.194 pounds/gallon. This waste density is based on wastes reportedto in Generation and Management (GM) Forms (Section 2)and Waste Received from Offsite (WR) Forms of the 1999-2007 BR.NA Not AvailableSource: Consultations with commercial landfillfacilities. Data as of April – September 2009.