Taking Stock Volume 16

2 Feature Analysis: Off-site Transfers to Disposal in North America, 2014–2018

2.4 Analysis of Off-site Transfers to Disposal, 2014–2018

2.4.6 Cross-border transfers for disposal in North America, 2014–2018

As mentioned in chapter 1, a portion of the industrial waste produced by North American facilities each year is sent to other countries of the region. During the 2014-2018 period, annual cross-border transfers for disposal (shown by category in Figure 22) totaled between 3.4 million and 5.6 million kg, representing approximately 2% of total cross-border transfers (see Figure 9).^[68]

There are four cross-border transfer patterns, or flows, represented in the North American PRTR data: Canada to the United States; Mexico to the United States; the United States to Canada; and the United States to Mexico. Table 38 shows that transfers from Canadian facilities to the United States for disposal accounted for the largest proportions of all such transfers in the region, reflecting Canada’s prominence among the three countries for total cross-border transfers during this period (chapter 1).

Transfers from Canada to the United States for disposal

Canadian transfers to the United States for disposal (mainly to landfills or surface impoundments) ranged between 2.4 and 2.8 million kg annually—except in 2015 and 2016, where they increased to almost 5 million kg. Of approximately 25 reporting sectors, the five in Table 39 accounted for at least 83% of the annual totals.

The increases for 2015 and 2016 were driven by large transfers of sodium fluoride from Rio Tinto Alcan in Jonquière (Québec), a pot line processing facility in the all other nonmetallic mineral product manufacturing sector (NAICS 32799). These transfers were to EQ Detroit, Inc., a hazardous waste storage, treatment and disposal site in Detroit, Michigan. Previously, the facility transferred similar quantities of sodium fluoride to a Canadian facility, Newalta Corporation in Chateauguay, Québec.

Facilities in the waste management sector (NAICS 562), such as Revolution Environmental Solutions, Clean Harbors Canada, Toxco Waste Management, and the Greater Vancouver Sewerage Waste-to-Energy facility, transferred a wide range of metal compounds such as zinc, cadmium, lead, and nickel, along with total phosphorous, toluene, xylenes, and others, to landfills or surface impoundments located in Michigan, Oregon, Washington, and other states.

Several Safety-Kleen and Clean Harbors facilities in Canada also transferred between 200,000 and 500,000 kg each year (mainly of chromium, lead, and other metal compounds) to Clean Harbors and EQ Detroit facilities located in Arkansas, Texas, and Nebraska for stabilization or treatment prior to disposal. Two Revolution Environmental Solutions facilities located in Ontario also transferred approximately 175,000 kg each year (consisting mainly of sulfuric acid, hydrochloric acid, and nitric acid/nitrate compounds) to facilities such as Environmental Geo Technologies (Michigan) and Vickery Environmental (Ohio) for underground injection.

Cross-border transfers to disposal by the non-ferrous metal (except copper and aluminum) processing sector (NAICS 33149) were driven by Tonolli Canada, a battery recycling facility in Ontario. It transferred pollutants such as arsenic, antimony, lead, zinc, and vanadium compounds to landfills or surface impoundments in several states including Michigan, Pennsylvania, New York, and Ohio.

Facilities in the alumina and aluminum production and processing sector (NAICS 33131), such as Aluminerie de Bécancour and Scepter–Baie Comeau (Québec), Kaiser Aluminum (Ontario), and Rio Tinto Alcan–Kitimat (British Columbia), transferred pollutants such as calcium fluoride, zinc compounds, benzo(b) fluoranthene, chrysene, and others, to US landfills or surface impoundments during this period. However, as of 2016 most transfers by this sector (consisting mainly of aluminum fume (or dust), manganese, zinc, vanadium, and other metal compounds) were driven by the Scepter Aluminum plant in Saguenay, Québec.

Finally, one facility in the pulp manufacturing sector (NAICS 32211), the Twin Rivers pulp mill in Edmunston, New Brunswick, reported transfers to the United States for land application. This facility transferred from about 40,000 kg to over 200,000 kg each year of total phosphorous, chlorine, manganese and other metal compounds to a location identified as “Maine farmland” in Madawaska, Maine (which is just across the border from Edmunston).

Transfers from Mexico to the United States for disposal

Mexican transfers to the United States for disposal (almost all to storage prior to disposal) were of less than 65,000 kg each year except for 2018, where they increased to almost 1.6 million kg. A total of 14 sectors reported during this period, but those reporting the largest proportions in 2014 were not the same as in 2018. Therefore, Table 40 presents the six industry sectors that, together, accounted for at least 50% of the total each year.

It is interesting to note that for each of these industry sectors, the total was driven by just one facility:

• Hardware manufacturing sector (NAICS 33251): Schlage de México, located in Tecate, Baja California, transferred nickel and chromium compounds (each in the amount of 26,085 kg) in 2014 to the World Resources facility in Arizona, which produces metal concentrates from manufacturing residues.
• Coating, engraving, and heat-treating sector (NAICS 33281): Intermetro de México, located in Chihuahua, reported transfers of a total of 9,732 kg of chromium and nickel compounds in 2014 to Heritage Environmental Services, a hazardous waste management facility in Arizona. However, online information for the Intermetro facility indicates that it is a furniture manufacturer; therefore, it should have reported under NAICS code 33721.^[69]
• Motor vehicle steering/suspension components manufacturing sector (NAICS 33633): Key Automotive Accessories de México, located in the state of Tamaulipas, transferred a total of more than 6,000 kg of xylenes and toluene to the Clean Harbors facility in La Porte, Texas in 2014 and 2015.
• Unknown sector (NAICS 99999): Grupo Schumex, located in the state of Tamaulipas, reported 22,013 kg in lead compounds transferred in 2016 to All Star Metals, a ship recycling and metals processing facility in Brownsville, Texas. While the sector is not indicated in Grupo Schumex’s PRTR report, online information indicates it is a maquiladora in the electrical equipment manufacturing sector (NAICS 33531).^[70]
• Battery manufacturing sector (NAICS 33591): C&D Technologies Reynosa, a located in Tamaulipas, transferred almost 1.5 million kg of lead compounds to the Buick Resource Recycling facility in Missouri, which recycles spend lead-acid batteries and other lead-bearing waste.
• All other electrical equipment/component manufacturing sector (NAICS 33599): In 2017 and 2018, the Grupo Schumex facility mentioned above reported transfers of about 80,000 kg of lead compounds to the All Star Metals facility in Texas.

Transfers from the United States to Canada for Disposal

Transfers from the United States to Canada for disposal ranged between 615,000 kg and just over 1 million kg each year. These amounts were divided fairly evenly among transfers to landfills or surface impoundments, stabilization/treatment prior to disposal, and “other disposal (unknown).” Small proportions were also transferred to underground injection. Of 46 industry sectors reporting during this period, the five shown in Table 41 accounted for at least 50% of the total each year.

A few facilities in the waste management sector (NAICS 562), such as Heritage Environmental Services of Indiana, Clean Earth of New Jersey, and Clean Harbors facilities in Massachusetts and Texas, dominated the transfers to Canada for disposal in landfills or surface impoundments. These facilities transferred nickel, copper, chromium, lead, zinc, and arsenic compounds to Stablex, a hazardous waste treatment and secure disposal facility located in Blainville, Québec. Clean Earth of New Jersey also transferred trichloroethylene to the Englobe facility in Montréal, which specializes in soil remediation.

Facilities such as Retriev Technologies in Ohio and Cycle Chem Inc. and Veolia Technical Solutions (New Jersey) also transferred cadmium, arsenic, zinc, lead and chromium compounds to stabilization or treatment prior to disposal to facilities such as Stablex and Revolution Environmental Solutions (Midhurst, Ontario). Several facilities such as US Ecology (Texas) and Vickery Environmental (Ohio) also transferred pollutants such as ethylene glycol, sodium nitrate, mercury, zinc, and other metal compounds to “other disposal (unknown),” primarily to Stablex and the Clean Harbors (Corunna, Ontario) facility.

The transfers in 2014 by the non-ferrous metals (except copper, aluminum) sector (NAICS 33149) were reported by one facility, Revere Smelting and Refining (New York), which transferred lead, chromium, antimony, and arsenic compounds to Stablex (Québec) for disposal. The 2018 transfers to landfills or surface impoundments were driven by the American Zinc and Recycling facility in Pennsylvania, which transferred zinc, manganese, lead, nickel, and cadmium compounds to the Stablex facility and the Clean Harbors (Corunna) facility.

In 2017 and 2018, Supercon Inc., a manufacturer of superconducting wire, transferred nitric acid and nitrate compounds, as well as copper compounds, to Stablex for underground injection. The transfers by this sector to “other disposal (unknown)” in 2018 were driven by the BASF facility in South Carolina, which transferred almost 7,000 kg of barium compounds to the Vale Canada nickel smelting complex in Copper Cliff, Ontario.

A few facilities in the coating, engraving, heat treating/allied activities sector (NAICS 33281) drove the transfers reported by this sector between 2014 and 2018. They are Unimetal Surface Finishing, Pape Electroplating, and Waterbury Plating (all located in Connecticut), which transferred zinc, copper, nickel, and lead compounds to the Stablex facility for stabilization or treatment prior to disposal.

Phelps Dodge Copper Products of El Paso, Texas, a facility in the copper rolling, drawing, extruding, and alloying sector (NAICS 33142), accounted for all of the transfers to “other disposal (unknown)” reported by this sector between 2014 and 2016. It sent selenium, antimony, nickel and arsenic compounds to the Glencore Canada copper and precious metals refinery located in Montréal, Québec. Prior to 2016, three IWG Nest Inc. facilities located in New York transferred a few thousand kilograms of copper compounds to Stablex for stabilization or treatment prior to disposal.

In 2016 and 2018, Dow Chemical of Midland, Michigan, a facility in the pesticide and other agricultural chemical manufacturing sector (NAICS 32532), reported transfers of a total of almost 280,000 kg of manganese compounds to the Clean Harbors facility in Corunna, Ontario, for “other disposal (unknown).” 

Transfers from the United States to Mexico for disposal

Transfers from the United States to Mexico during this period were reported by 14 facilities in 11 industry sectors and ranged from 1,315 kg to just under 3,500 each year. Table 42 shows the three sectors that, together, accounted for most of these transfers, which were primarily to “other disposal (unknown).”

These data were driven by one facility in each of the three industry sectors:

• Iron and steel mills/ferroalloy manufacturing sector (NAICS 33111): From 2014 through 2016, the Gerdau-Fort Smith mill in Arkansas transferred a total of almost 3,000 kg of barium compounds to Zinc Nacional, a facility located in the state of Nuevo León that produces zinc oxide and recycles electric arc furnace dust.
• Fabric Coating Mills (NAICS 31332): Flexfirm Products Inc., a facility located in South El Monte, California, transferred between 100 and 150 kg each year of antimony compounds to Recicladora Temarry de México, a waste management facility located in Baja California.
• Iron and steel pipes/tubes manufacturing sector (NAICS 33121): From 2016 through 2018, the Western Tube and Conduit facility in Long Beach, California, transferred a total of more than 4,000 kg of zinc compounds to the Recicladora Temarry de México facility in Baja California.

These cross-border transfers data provide certain insights relative to the sources and types of transfers reported. For many facilities a key consideration in the choice of a recipient installation is the recipient’s ability to adequately treat and dispose of the waste, which is most likely the reason that certain US facilities opt to send their waste to a specialized Canadian facility such as Stablex or Clean Harbors. These recipients might be selected because, although located across the border, they are the closest available options offering the specialized services required; or the decision might rest on other factors (e.g., established relationships, economies of scale, lack of local processing capacity). Nevertheless, transferring waste across national borders for disposal can be costly, depending on the nature of the waste, handling requirements, fuel costs, and disposal fees.^[71] As mentioned in section 2.3, facilities, as well countries, must also contend with the social cost of transporting hazardous waste across borders.

For some wastes, options are very limited. Such is the case of spent pot lining (SPL) waste, considered to be a significant waste management challenge for the aluminum industry because of its highly toxic cyanide and fluoride content. Primary aluminum is produced by electrolytic reduction of alumina in cells, or pots, which must be disposed of once they are no longer usable. Since 2008, the Rio Tinto Alcan pot line processing facility in Jonquière, Quebec has treated and recycled spent SPL waste. However, such technologies are emerging and expensive, as are the liabilities associated with inadequate landfilling. As a result, many aluminum smelters have simply stored their SPL waste for decades, waiting for a recycling technology that can add value to it, or for a more economical and secure disposal option.^[72] In the case of Rio Tinto Alcan’s recycling process, the residual ash, considered to be inert and non-hazardous, is typically sent to cement kilns to be used in the production of concrete.

In some cases, the data for cross-border transfers raise questions about the nature and management of the disposed waste. One example is that of the transfers to land application of between 100,000 kg and 200,000 kg of pollutants each year by the Twin Rivers pulp mill in New Brunswick to a location identified only as “Maine farmland.” No other information is provided about this site, including the entity responsible for ensuring that the waste is managed in an environmentally sound way.

These data also bring up the broader issue of reported waste disposal practices and whether the data reflect errors in reporting, or the inadequacy of the available disposal categories to reflect facilities’ actual practices. For example, certain reported transfers of metals to either storage prior to disposal or to “other disposal (unknown)” seem to be intended for recycling or reuse (e.g., the C&D Technologies Reynosa facility’s transfers of lead compounds to the Buick Resource Recycling facility; the Western Tube and Conduit facility’s transfers of zinc compounds to the Recicladora Temarry de México facility). However, a likely part of the issue is the fact that, as mentioned earlier, PRTR data often do not allow for the tracking of pollutants beyond the first recipient indicated by the source facility.