AN ANALYSIS OF THE OFF-SITE TREATMENT OF HAZARDOUS WASTE GENERATED IN NORTH CAROLINA

IN 1990

by the

North Carolina

Hazardous Waste Management Commission

February 7, 1992

S U M M A R Y

The Hazardous Waste Management Commission has performed an analysis of the large quantity hazardous waste generated and shipped off-site during 1990. The Commission has evaluated how wastes which were reported as "in storage" and "in containers" might have been treated according to the proportions of treatment used for each of 189 waste types generated and shipped off-site by the state's large quantity generators. The Commission analyzed North Carolina's waste by waste type to clarify the varying effects of regulation changes and to determine more accurately the treatments in use by the state's large and small quantity generators.

The EPA has mandated that some large quantity wastes no longer be placed in landfills without prior treatment. To assist generators in finding proper treatment technologies for these wastes, the EPA issued rules outlining the "Best Demonstrated Available Technologies (BDAT)" for treating these landbanned wastes. Since these landbans are now in effect, the Commission made a comparison of how large quantity wastes were treated off-site in North Carolina in 1990 and BDAT treatments recommended by the EPA. According to the application of BDAT, 4,560,401 pounds of these wastes generated during 1990 would have to be re-routed from landfills to other treatment methods. The EPA's recommended BDAT for these wastes would send them to treatment by energy recovery, incineration and physical treatment methods.

The Commission has also analyzed reports on waste generated during 1990 from approximately half (1,330) of the state's 2,691 small quantity generators. Most small quantity wastes are shipped off-site for treatment. These reports, required by North Carolina law in 1989 as reports on the efforts of small quantity generators to reduce their wastes, previously have not been analyzed. Reports from the other half of the small quantity generators were either incomplete or contained information insufficient for analysis. Small quantity generators added another 24 waste types to the total types of wastes generated and shipped off-site in North Carolina, bringing to 213 the number of waste types evaluated in the Commission's analysis. The Commission added the waste generated by half of the small quantity generators, proportionally according to the off- site treatments used by the large quantity generators, to the waste being treated and disposed of during 1990. The Commission found that waste from only half of the state's small quantity generators accounts for 17,442,481 pounds of waste generated in 1990. An unknown portion of this waste may have been reported as treated during 1990 in TSD facilities.

The Commission received reports from the Hazardous Waste Section on the number of facilities which intend to stop burning hazardous waste as a fuel because of the requirements of the federal Boiler and Industrial Furnace Regulations. These regulations require industrial boilers and furnaces to meet the same requirements for facility standards as those required by the Resource Conservation and Recovery Act for hazardous waste treatment facilities. A total of 28 facilities have notified the Hazardous Waste Section that they intend to stop burning their hazardous waste on-site. These facilities must now send their waste off-site for treatment. The Commission found that these facilities will be adding 6,254,698 pounds of waste to the total waste generated in North Carolina. The Commission found that 4,468,589 pounds of this waste is likely to be sent to energy recovery processes and 1,786,109 pounds to incineration.

These evaluations have identified 17.4 million pounds of waste from small quantity generators in 1990 and 6.2 million pounds of waste resulting from the subsequent enactment of the Boiler and Industrial Furnace regulations. They have also shown additional amounts of waste going to specific categories of treatment as a result of changing regulations. The following categories of treatment have experienced the largest increases over totals previously reported for 1990:

Energy Recovery 23% Solvent Recovery 20% Chemical Treatment 14% Physical Treatment 12% Incineration 11% Biological Treatment 11%

Because of the effects of EPA's landban regulations, waste being sent to landfills should show a decrease of 7 percent.

This analysis indicates that less hazardous waste should be going to landfills in the future, and that more waste will be sent to the treatment methods indicated above.

The Hazardous Waste Management Commission recommends

Those plans continuing efforts to make long-term plans for North Carolina's hazardous waste management needs. should not be based on the amounts of waste generated during any one year. A s this analysis has shown, variables resulting from effective regulations and from waste generated by unreported sources have a substantial effect on the total waste for which management must be planned. Facilities which will answer the needs of the generators in this state are still needed in North Carolina.

HWMC: 2/92

AN ANALYSIS OF THE OFF-SITE TREATMENT OF HAZARDOUS WASTE GENERATED IN NORTH CAROLINA

IN 1990 by the

Hazardous Waste Management Commission February 1992

Introduction

The Hazardous Waste Management Commission is directed by the North Carolina General Assembly to make a periodic review of current and projected hazardous waste generation from all sources within the State to determine whether additional facilities for the management of hazardous waste may be needed [N.C.G.S. Chapter 130B-7(a)(l)]. The following report provides an analysis of the waste generated during 1990, utilizing information from the North Carolina Hazardous Waste 1990 Annual Report and other records of the Hazardous Waste Section of the Solid Waste Management Division, Department of Environment, Health and Natural Resources.

The question of what kinds of hazardous waste management facilities are needed in the State of North Carolina has been debated intensively since the institution of the Resource Conservation and Recovery Act in 1976. This analysis is intended to assist government leaders in answering the question of need based on the types and amounts of waste generated in North Carolina and how that waste is treated. It should be noted that hazardous waste generation and management in the State and the nation are constantly changing, and subject to variables in reporting, governmental regulations and policies. The Hazardous Waste Management Commission has completed this analysis to help determine what facilities are needed over the next 20 years. Additional considerations, including cleanup wastes, waste reduction efforts, economic growth and production, interstate commerce and other regulatory changes are of great importance in evaluating future facility needs. A discussion of some of these variables is made at the end of this report.

The Commission has based its analysis solely on the division of off-site treatments used by generators according to the 1990 Annual Report information. Its assumptions have been based on discussions with the Hazardous Waste Section and with hazardous waste treaters. incomplete data may account for some inconsistencies. Therefore, the Commission presents this analysis as a general reflection of off-site treatment methods currently in use by North Carolina's generators of hazardous waste.

Percentage rounding and

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ANALYSIS OF WASTE TREATMENT METHODS

The following analysis consists of an evaluation of the methods of treatment used by generators in 1990 and the treatments expected to be used by the generators of stored, containerized and small quantity wastes. Assumptions used are based on a study of the customary treatments used for certain waste types and on EPA's "Best Demonstrated Available Technology" (BDAT) for landbanned wastes. (Landbanned wastes are those which previously were allowed to be sent directly to landfills and now must undergo treatment prior to landfilling.)

The Commission has evaluated two classes of generators. These include the state's large quantity generators (those who generate 2,200 pounds of waste per month or more) and small quantity generators (those generating less than 2,200, but more than 220 pounds of waste per month). This report analyzes how large quantity wastes were treated in 1990, and the effect of adding waste generated by small quantity generators. The report also evaluates changes in treatment methods necessitated by the landban regulations, substituting those treatment methods recommended by the EPA (BDAT) for wastes which have been banned from landfills. Finally, the report adds waste being shipped off-site as a result of new Boiler and Industrial Furnace Regulations. The Boiler and Industrial Furnace Regulations subject industrial boilers and furnaces to the general facility standards applicable to hazardous waste treatment, storage, and disposal facilities.

Rather than evaluate overall generation and treatment figures, the Commission has studied individual waste types to determine what percentage of waste generated in each type has gone to specific treatments. Identical analyses were carried out on each waste type generated by North Carolina's large quantity generators. There are 189 "types" of waste generated in large quantities in North Carolina. Small quantity generators contribute an additional 24 waste types. Therefore, this analysis looks at 213 different waste types.

Large Quantity Generators of Hazardous Waste

Because hazardous waste is generated in many forms and contains differing chemical constituents, it must be treated by differing methods. Treatment methods used by North Carolina generators include a variety of physical, chemical and biological treatments, as well as solvent recovery, energy recovery (Sometimes referred to as "fuel substitution," energy recovery is the process of burning hazardous waste as a fuel.), metals recovery, landfilling and incineration. Except for the treatment of hazardous

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wastewaters which is primarily performed on-site, most North Carolina large generators do not have their own treatment technologies on-site and must send their hazardous waste off-site for treatment. An analysis of the types and amounts of waste sent off-site for treatment is essential in determining the State's needs for treatment facilities. Therefore, this report looks only at the waste sent off-site for treatment in 1990.

Large quantity generators are required to file annual reports with the Hazardous Waste Section listing the types and amounts of waste they generate, as well as the type of treatment or disposal designated for that waste. The 1990 Annual Report states that 204,413,198 pounds of large quantity waste was shipped off-site for treatment. Of that amount, the report shows that 81,414,127 pounds were sent to incineration; 44,718,455 pounds to landfills: 24,957,309 to energy recovery; 14,731,710 pounds to solvent recovery; 7,815,044 to metals recovery; 14,510,607 pounds to storage; and, 16,265,946 pounds to other treatment and disposal facilities. For this analysis, the types of treatment methods used by large quantity generators have been evaluated, with particular emphasis on the types of treatment expected to be used for waste reported as "in storage" or "in containers. "

Stored Waste

An analysis of wastes listed in the storage category of the Annual Report was necessary because "storage" does not designate the final disposition of the wastes. Wastes shipped to storage facilities are later re-shipped to final disposal. To determine what types of treatment and disposal methods are expected for the stored waste, we have assumed that each type of stored waste would be treated in the same manner as identical waste which initially went on to treatment methods.

For example, there were 14,229,104 pounds of DO01 waste shipped off-site for treatment by large generators in 1990. Of that amount, 2,183,822 pounds were listed as going into storage. To determine what types of treatment would eventually be used to treat the stored waste, we have assumed that it would be sent to the same treatment categories according to the same proportions as all DO01 waste generated by the majority of North Carolina generators.

Containerized Waste

A similar szsumption was made in analyzing waste reported as "trea-cment in a tank" or "treatment in surface

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impoundments." This assumption was employed to more accurately define the method of treatment, rather that the container in which treatment took place. Generally, three categories of treatment are used for containerized wastes. These include chemical treatment, physical treatment and biological treatment. For this analysis, containerized wastes have been divided and placed into the actual treatment categories being used in each waste type. This analysis enabled the Commission to look solely at the treatment methods used to treat large quantity waste.

Note: Small amounts of waste reported in the 1990 Annual Report were placed in the categories "Other Treatment" and "Other Disposal. It The Commission could not make assumptions designating exact treatment or disposal methods for these wastes. Therefore, these categories have not been changed in the analysis.

The following table shows the amounts of waste treated or disposed of by the treatment methods used and expected to be used by the state's large generators of hazardous waste:

TABLE 1: Large Quantity Waste Treatment Methods Used-1990 (Includes Distribution of Stored and Containerized Waste)

(in pounds)

Landfill Other Disposal Solvent Recovery Energy Recovery Metals Recovery Incineration Chemical Treatment Physical Treatment Biological Treatment Other Treatment

46 , 736,890 40,679

18,090,845 29,053,940 8,018,057 83,466,598 6,772 , 865 9,346,041 2,593,532 289 , 709

A study of the above treatment methods reveals, in greater detail, much the same hierarchy of treatments used as reported in the 1990 Annual Report. The treatments, from most used to least used, are: Incineration, landfill, energy recovery, solvent recovery, physical treatment, metals recovery, chemical treatment, biological treatment, other treatments, and other disposal methods.

Recommended Treatments (BDAT) for Landbanned Waste

The next step of the analysis was to apply EPA's recommended treatment methods to waste which now comes under restrictions known as "landbans." These regulations require

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that waste which previously was sent directly to landfills now must be treated first according to EPA recommendations, called "Best Demonstrated Available Technology" (BDAT). The following is an evaluation of specific types of large quantity waste which was sent to landfills in 1990, which is now required to be treated first by other methods. The waste type, amount of waste shipped to landfills, and amount which must now go to other treatment is detailed below:

TABLE 2: EPA Recommended Treatment for Landbanned Waste

WASTE TYPE AMOUNT BDAT TREATMENT DISTRIBUTION (in pounds)

DO01 Landfill 203,178 FS;

PT; I

F005 Landfill 4,356,777 I

u201 Landfill 446 FS;

I

67,726 67,726 67,726

4,356,777

223 223

FS=Fuel Substitution; PT=Physical Treatment; I=Incineration N O T E : EPA Recommendations are not listed in a specific order of preference, but as a selection of treatments from which generators may choose the one most appropriate for the specific waste.

In 1990, approximately 4.5 million pounds of waste were sent to landfills which must now be sent to a combination of other treatments, primarily energy recovery (identical to EPA's designation of fuel substitution), incineration and physical treatment. From this analysis, we can expect this waste to be added to the following treatment categories:

Energy Recovery: 67,949 pounds Incineration: 4,424,726 pounds Physical Treatment: 67,726 pounds

Small Quantity Generators of Hazardous Waste

The Commission also analyzed generation figures obtained from small quantity generators (generators of between 2,200 and 220 pounds of hazardous waste per month). Beginning in 1990, small quantity generators were required to report to the State their waste minimization programs. Included in these reports are the types and amounts of waste

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they generate. These reports, which previously have not been analyzed, provide the first direct account of the hazardous waste generated by North Carolina's small businesses.

Yet another category of small quantity generators is that of the "conditionally exempt small generator." This group of generators, like small quantity generators, is not required to report its waste generation to governmental agencies. Conditionally exempt small generators generate less than 220 pounds of hazardous waste per month. Most conditionally exempt generators collect quantities of waste on-site (usually in drums or other containers) before contracting with a hazardous waste management company to transport the waste off-site for treatment. The Hazardous Waste Section has information only on 425 of these generators, and does not know the total amounts of waste they add to the state's treatment and disposal needs.

Of North Carolina's 2,691 small quantity generators on record with the Hazardous Waste Section in March 1991, approximately half (1,330) provided reports sufficiently accurate for analysis. Since 1990 records represented only the second year such reports have been collected, the Commission is hopeful that more accurate reporting will occur in the future. Even though these records do not offer a complete account of all waste generated by small quantity generators, the Commission has analyzed the information available to better gauge the impact of small quantity waste on the state's overall treatment needs.

The Commission has assumed that small quantity waste was sent proportionately to the same treatment methods as large quantity waste. This assumption is based on the fact that each waste type, whether it is generated by a large generator or a small generator, contains the same characteristics and must be treated by the same methods. In an analysis of these small quantity generators contributing to North Carolina's total waste generation, the following additional wastes are added to each treatment method by small quantity generators:

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TABLE 3: Small Quantity Waste Treatment Methods* (Based on Treatment Methods Used by Large Generators-1990)

(in pounds)

Landfill Other Disposal Solvent Recovery Energy Recovery Metals Recovery Incineration Chemical Treatment Physical Treatment Biological Treatment Other Treatment

1,249,162 765

4 , 524,471 4,440,796

37,980 4,402,189 1,087,788 1,249,829 328,244 10,036

* This waste was not counted in the 1990 Annual Report. Small Quantity Generators are not required to report to the State the amounts and types of waste they generate. These figures were obtained from the Waste Minimization Plans submitted by Small Quantity Generators for waste generated during 1990.

In this analysis of half of the state's small quantity generators, a total of approximately 17.4 million pounds may be added to the waste reported in 1990. Portions of this waste may have been reported as treated during 1990 in TSD facilities. From the reports submitted, the Commission could not determine the remaining amounts of waste generated by small quantity generators. If we assume that this waste underwent the same treatment as the waste generated by large quantity generators in 1990, the following hierarchy of treatment methods is observed: Solvent recovery, energy recovery, incineration, physical treatment, landfill, chemical treatment, biological treatment, metals recovery, other treatments, and other disposal methods.

Effects of Boiler and Industrial Furnace Regulations(B1F)

In August 1991, new federal regulations went into effect requiring companies which burn hazardous waste as a fuel in their boilers and industrial furnaces to meet the same requirements as hazardous waste facilities. North Carolina companies which will not retrofit on-site boilers and furnaces to meet the new standards must now send waste, previously burned on-site, off-site f o r treatment and disposal.

The Hazardous Waste Section required these companies to notify the state of their intent either to meet the new

Page 8 standards for their boilers and furnaces, or to stop burning hazardous waste as a fuel. The results of these notifications provide an account of how much and what types of waste are expected to be shipped off-site for treatment and disposal. Each generator supplied information about the waste type and form affected by the BIF regulations. Wastes with high Btu capacities are most often in liquid form. Therefore, the Commission has assumed that if the waste being shipped is reported to be in liquid form, it will be shipped to energy recovery. If the waste was listed in solid form, the Commission has assumed it will be incinerated.

A total of 28 North Carolina industries which previously burned their own hazardous waste on-site have notified the Hazardous Waste Section that they intend to stop burning hazardous waste as a fuel. These facilities will be adding 6,254,698 pounds of waste to that being shipped off-site for treatment by North Carolina generators. A breakdown of the amounts of new "BIF wastes" added to the energy recovery and incineration categories of treatment is as follows:

Energy Recovery 4,468,589 pounds Incineration 1,786,109 pounds

The following table presents a review of actual treatments employed by generators, expected treatments for stored and containerized waste, the effect of landban restrictions (BDAT), the additional waste from small quantity generators, and increases due to the enactment of the BIF regulations:

TABLE 4: Waste from All Categories by Treatment Method

SQG BIF LQG BDAT (in pounds)

LF 46,736,890 (4,560,401) OD 40,679 SR 18,090,845 ER 29,053,940 67,949 MR 8,018,057 I 83,466,598 4,424,726 CT 6,772,865 PT 9,346,041 67,726 BT 2,593,532 OT 289,709

1,249,162 765

4,524,471 4,440,796 4,468,589

37,980 4,402,189 1,786,109 1,087,788 1,249,829 328,244 10,036

LQG=Large Quantity Generators; BDAT=EPA's Best Demonstrated Available Technology; SQG=Small Quantity Generators; BIF=Boiler and Industrial Furnace Regulations

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The following table provides a comparison showing the total waste from large quantity generators in 1990 and the total waste going to each treatment method after making the regulatory and small generator changes outlined above:

TABLE 5: Comparison of Wastes Studied By Treatment Method (Based on 1990 Generation Reports)

(in pounds)

TREATMENT LARGE QUANTITY WASTES CHANGED BY METHOD WASTE ONLY REGULATION/SQG's*

Landfill 46,736,890 Other Disposal 40,679 Solvent Recovery 18,090,845 Energy Recovery 29,053,940 Metals Recovery 8,018,057 Incineration 83,466,598** Chemical Treatment 6,772,865 Physical Treatment 9,346,041 Biological Treatment 2,593,532 Other Treatment 289,709

43,425,651 41,444

22,615,316 38,031,274 8,056,037 94,079,622** 7,860,653

10,663,596 2,921,776

299,745

* This model of the treatment of 1990 wastes is based on changes in regulations since 1990 and on additional waste supplied by reports from small quantity generators.

** These figures include one large cleanup of 73 million pounds of contaminated soils during 1990. Therefore, it is apparent that 20 million pounds of other incinerable waste is accounted for here.

Cleanup Wastes

The Commission has made every attempt to study the effect of cleanup wastes. Because information is not available on the exact types and amounts of wastes which are listed on the State's "Inactive Hazardous Waste Sites Priority List," the annual effect of cleanup wastes on the state's overall generation cannot be calculated. However, the Commission does recognize that cleanups are and should - be ongoing, whether from one-time efforts and Superfund sources, or from cleanups instituted by large quantity generators.

In 1990, there was a large cleanup of 72,963,379 pounds of creosote-contaminated soils at the Southern Wood Piedmont

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site in Chatham County. This waste was shipped to Marine Shale Processors in Louisiana for treatment by incineration.

TABLE 6: A Study of Cleanup Waste, 1987-1990 (in pounds)

1987

1988

28,851,646

34,513,809

1989 9,459,569

1990 96,003,368

The Commission believes that cleanups of North Carolina's inactive and illegal dump sites will continue annually. While it is not possible to gauge the amounts or types of waste generated in cleanups, it is also impossible to determine the types of treatment facilities needed for these wastes. In the past, however, most cleanup waste has been disposed of either in landfills or in incinerators. Because of annual fluctuations, which are primarily a result of business revenues and funding availabilities (such as those received from the federal Superfund), the Commission assumes that more cleanups will take place during economically stable, healthy years.

The Commission also acknowledges that it is the State of North Carolina's policy to treat and manage cleanup waste on-site whenever possible. Yet, on-site cleanup has been the exception rather than the rule. A Superfund site in Beaufort County is a prime example. After the EPA excavated the pesticide waste and prepared for on-site incineration, local residents objected to locating an incinerator there, so off-site disposal had to initiated. The waste then met several roadblocks after its scheduled disposal out-of- state, and further shipments were halted because of North Carolina's failure to meet the requirements of its Capacity Assurance Plan to the federal government. The EPA estimates that an additional 800 tons of waste remain at the site.

North Carolina,.with approximately 750 known cleanup sites located in almost every county, continues to face the problem of what to do with these wastes. Inactive waste disposal sites are constantly being added to the State's inventory as they are discovered and reported. While some may encourage fencing off such sites and leaving them undisturbed, others recognize the potential danger of groundwater contamination from improgerly buried wastes.

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The Commission believes that the problem of cleaning up our past mistakes will continue to be a problem we must solve. The treatment capabilities needed to handle these wastes, whether on-site or off-site, must be considered in any long- term hazardous waste management plans for the State.

Waste Reduction and Economic Growth Projections

North Carolina has been a national pioneer in instituting statewide waste reduction efforts. Over the past several years, industry has continued to participate in reducing the generation of waste, either by changing the raw materials it uses or by recycling the wastes remaining following production. Technologies for reusing or recycling hazardous waste, as well as substitutions of less hazardous materials will no doubt continue to be important to every industry in North Carolina. When an industry does not have to pay to dispose of a waste, it is increasing its profits. The incentive to reduce and reuse makes good business sense.

The reduction of hazardous waste is limited by public demand for products whose manufacture necessarily involves hazardous wastes. The N.C. Office of Waste Reduction estimates that economic growth will keep waste production high despite process improvements and additional recycling efforts.

The Commission agrees that annual "recurring" generation of hazardous waste will remain stable, showing incremental growth over the next 20 years. Recurring waste is that which is generated by industry annually. This is waste which is generated by the state's large generators and which, as we have seen in this report, is well-documented annually by the Hazardous Waste Section. As we have also observed in this analysis, there are other categories of waste which are unknown, not reported fully, not now regulated, or which are just coming under new regulations. North Carolina must be prepared to manage all of these categories of waste during the next 20 years.

Observations

This analysis shows that when only a few recent regulation changes are considered, and only a part of the small generation waste is added, North Carolina's overall hazardous waste generation increases in every category except landfilling. The decrease in landfilling is a result

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I

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of the application of the landban restrictions, which remove 7 percent of waste landfilled in 1990 to other treatment categories. Increases and decreases in each treatment category are:

Landfill Other Disposal Solvent Recovery Energy Recovery Metals Recovery Incineration Chemical Treatment Physical Treatment Biological Treatment Other Treatment

7 % 2 %

20 % 23 %

.5 % 11 % 14 % 12 % 11 % 3 %

decrease increase increase increase increase increase increase increase increase increase

It is instructive to also look at what has not been included in this analysis. Information sufficient for analysis is lacking on cleanup wastes, on the effect of the new Toxicity Characteristic Leaching Procedure, which may take more wastes out of landfills and into other primary treatment methods, and on the contributions of conditionally exempt small generators. As regulatory timetables take effect and more detailed information is produced on inactive waste disposal sites, some of this information may emerge. Other regulation changes by the EPA may bring additional wastes under the hazardous waste realm, or limit the types of treatment recommended for them. A s an example, the recently required Toxicity Characteristic Leaching Procedure imposes more stringent standards on wastes going into the nation's landfills. If these wastes, primarily petroleum- based wastes, do not meet the new standards, they must be treated to meet the standards prior to landfilling. The result could well mean an increase in the use of other treatment methods.

As stated previously, hazardous waste management operates in a fluid environment of continually changing regulations and policies. Information will continue to be added on subjects such as inactive waste disposal sites. Under present regulations, we do not know precisely what amounts of waste are generated by the smallest generators in our state, who are presently exempt from reporting requirements.

In addition to the fluctuations in hazardous waste regulations and hazardous waste reporting, federal efforts to reauthorize the nation's major hazardous waste law (the Resource Conservation and Recovery Act) are now underway. Complicating already complex management problems, this

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reauthorization will focus on issues such as the interstate commerce of hazardous waste and questions about whether states should be able to enforce bans and capacity limits, or charge higher fees for waste imported from states without their own adequate treatment and disposal capacities.

North Carolina is more than familiar with these problems, as it has suffered its own share of regional ostracism in the past. Currently, the only thing certain is that the RCRA reauthorization debate will be a long one. Whether it will eventually solve these problems or further exacerbate them is an answer for which all the states must wait.

CONCLUSIONS

This analysis is supplemental to the information provided in the 1990 Annual Report on North Carolina Hazardous Waste by the Hazardous Waste Section of the Division of Solid Waste Management, Department of Environment, Health, and Natural Resources. It shows the effects on the totals of half of the small quantity generators registered in North Carolina (those for which information was available), and the effects that present landban regulations and Boiler and Industrial Furnace Regulations would have had on the 1990 totals. The following conclusions were reached:

1) Of the wastes which EPA has now banned from landfills, approximately 4 . 5 million pounds of waste generated in North Carolina during 1990 by large quantity generators would have gone primarily to incinerators under present regulations.

2) The known small quantity generation is calculated to have added the following quantities to the figures previously reported for 1990 (in millions of pounds): 1.2 to landfill, 4 . 5 to solvent recovery, 4 . 4 to energy recovery, 4 . 4 to incineration, 1.1 to chemical treatment, and 1.2 to biological treatment.

3 ) The current air emission standards now in effect for boilers and furnaces would have added 4 . 5 million pounds to the 1990 energy recovery total, and 1.8 million pounds to incineration.

,

It is clear to the Commission that North Carolina needs safe and properly operated hazardous waste facilities. A s shown in this analysis, those facilities should reflect the regulatory reality that no longer allows us to bury our wastes in the land. It is also clear that, with such

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requirements as those imposed by the Boiler and Industrial Furnace Regulations, limits on air emissions are more stringent than ever.

The Hazardous Waste Management Commission recommends continuing efforts to make long-term plans for North Carolina's hazardous waste management needs. These plans cannot and should not be based on the amounts of waste generated during any one year. They must be designed to consider what we know about hazardous waste generation and what we expect to be regulated and generated in the years to come.

HWMC: 2/92

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