Texas Hazardous Waste Volume Decreases Lead US

texas hazardous waste volume leads US

While reviewing e-Manifest data, we found a surprising fact. Texas leads the United States in year-over-year (YOY) decrease of hazardous waste. Through the beginning of August 2020, Texas hazardous waste tonnage is down approximately 75,000 tons compared to the same time period in 2019. This is based on tons shipped in using EPA’s e-Manifest data.

What factors are causing the decrease in Texas hazardous waste volumes? Texas hazardous waste volumes in 2020 have been dramatically impacted by lack of event business in the refinery sector, economic impact from Coronavirus and a sharp decline in volumes related to the 2019 Intercontinental Terminals (ITC) fire.

Texas, even though having a large decrease in volumes shipped in 2020, still leads the US in hazardous waste volume. Below we will look at the industries, shippers and critical factors impacting present volumes in comparison to prior years.

(Note: Many of the charts in this article are interactive, hover your mouse over the chart to see additional data. Also, due to these charts being interactive and not an image, they take a little longer to load.)

Monthly Hazardous Waste Volumes Are Down Every Month In 2020

Monthly hazardous waste tonnage shipped compared to prior year are down every month through July. In particular, July volumes are down nearly 22% YOY. The spike in 2019 July volumes are predominantly from disposal related to ITC.

Texas Hazardous Waste Volumes Are Down 18%

Texas is 16th in the United States in percentage decrease from prior year hazardous waste volumes.

Compared to 2019, Texas hazardous waste volumes are down approximately 18%. Texas is 16th in the United States in percentage decrease from prior year hazardous waste volumes. Hawaii leads the US currently with an 84% decrease from 2019.

Non-Hazardous Waste Volumes in Texas Are Down 11%

If we only factor waste that is not EPA hazardous, Texas volumes are down around 11% with 2020 tonnage behind 2019 by approximately 92,000 tons. Texas is a state where non-hazardous Class 1 wastes must be recorded on a hazardous waste manifest and submitted into e-Manifest. We have filtered out non-hazardous waste for the charts in this article.


Check out our page here where you can view our most current state volumes from e-Manifest. For an overview of what’s happening with waste volumes for all states, you can view our article “State Analysis – Year Over Year Trends.”

Coronavirus and Decreases In Monthly Waste Shipments

Every month in 2020 saw fewer manifests shipped in Texas than the year before. For the first quarter of 2020 manifest volumes shipped were in sync with the previous year at about a 6% decrease. Then we see a substantial break from that trend in April 2020, coinciding with Covid lockdowns.

Hazardous Waste Shipments Decrease Over 12% After Coronavirus Lockdowns Begin

Texas lockdowns related to coronavirus began in mid to late March 2020. We then see second quarter shipments of hazardous waste decrease over 12% from first quarter.

Changes In Shipping Methods and Container Types

Large Decrease in Bulk Shipments

Tanker (TT) and Roll-off (CM) shipments drastically decreased in 2020. Tankers with a decrease of over 47% and roll-offs decreasing over 33%. Decreases in these types of containers lead to a substantial decrease in overall tons compared to non-bulk containers like drums. Surprisingly, tank cars saw a large percentage increase in 2020.

The following chart shows container types used in 2019 and 2020 by Texas hazardous waste shippers. For this analysis we use data through the beginning of August 2020.

Reduced Volumes For 9 of the 10 Largest Hazardous Waste Shippers

Using year-over-year data comparing 2019 volumes to 2020, we see that 9 out of 10 of the largest hazardous waste shippers had volumes decreases. These are the top 10 shippers with the most volume through August 2019 and 2020.

The chart below shows 2019 volumes as a blue line compared with 2020 volumes.


If we chart just the change of YOY tons for these shippers, and total these these volumes, we see a decrease of over 47,000 tons (nearly 63% of the YOY volume reduction for 2020!) Intercontinental Terminals Deer Park and ExxonMobil Baytown Refinery alone account for approximately one-third of the YOY decrease.

The Top 5% of Texas Shippers Make Up 90% of YOY Volume Decrease

40% of shippers showed YOY tonnage growth

Let’s look at the top 5% (around 300 generators) of hazardous waste shippers by tonnage. If we sum their year-over-year change in tons, we find they constitute over 90% of the YOY decrease in volume we are trying to identify.

If we analyze the table below and count how many shippers have shipped more in 2020, we see that around 40% of shippers showed YOY tonnage growth. However, the decreases in volumes from the approximately remaining 60% of hazardous waste shippers were too much to overcome.


Exempt Generators In The Top 5% List

A note about shippers in the above list: One of the challenges in analyzing e-Manifest data is dealing with shippers that are not registered in e-Manifest (VSQGs/CESQGs.) According to EPA, these shippers do not have to register because they generate less than 100kg of hazardous waste per month. These shippers are very small shippers but can add up to a significant volume in total, especially in major cities.

We need to look at these percentages for shippers as broader indicators. A few (less than 10) of the generators in the top 5% list are groupings of exempt generators by zip code.

Texas Hazardous Waste Volumes By Industry

We are seeing most industries down across the board when analyzing volumes by a facility’s NAICS code. NAICS (North American Industry Classification System) is a classification system that groups like businesses together from very specific niches (6 digit NAICS code) to very broad categories (2 digit sector code.) For more information about NAICS, you can read here.

A note about the NAICS data presented: We only have NAICS codes for shippers that have registered with EPA. So, exempt very small volume shippers (VSQGs/CESQGs) unfortunately are not able to be included in these charts.

Texas Hazardous Waste Volumes by NAICS Sub-Sector


NAICS Sub-Sectors are the first 3 digits of an organization’s NAICS code. In the below chart, we show 2019 and 2020 tonnage data for Texas shippers by their NAICS Sub-Sector.


Chemical Manufacturing is by far the leading Sub-Sector resulting in hazardous waste volumes in Texas. Overall tonnage for this Sub-Sector is down around 10% YOY. We see most Sub-Sectors showing YOY decreases. In the chart above, we are only showing Sub-Sectors with greater than 1,000 tons shipped.

Texas Hazardous Waste YOY Volume By NAICS Sub-Sector Complete Table

Below we show 2019 and 2020 hazardous waste volumes by NAICS Sub-Sector. We show the difference in tons and the percent difference from the previous year. The data is sorted by increasing value from the largest YOY decrease.

Petroleum and Coal Products Manufacturing (code 324) sector account for one-third of YOY volume decreases. We have a few of our previous top 10 shippers part of this sector (ExxonMobil Baytown Refinery, Blanchard Refining)

Texas Hazardous Waste Volumes by Six Digit NAICS Code

We took a look at the broader Sub-Sector, now let us review the volumes using the more specific six digit NAICS code. The chart below shows 2019 and 2020 hazardous waste tons for NAICS codes shipping more than 1000 tons.

Petroleum Refineries are clearly down YOY. We see from drilling down further into the specific industry that refineries are causing more than 86% of the decrease in the Petroleum and Coal Products Manufacturing Sub-Sector. We see a few industries with growth including Natural Gas Extraction (211130) and Plastics Material and Resin Manufacturing (325211).

The below table shows YOY volumes by six digit NAICS Sub-Sector. The difference in tons and the percent difference from the previous year is shown. Data is sorted by increasing value from the largest YOY decrease.

Refineries Lead As Industry With Largest Decrease In Hazardous Waste Volumes

In Texas, petroleum refineries account for the largest YOY decrease in hazardous waste volumes for any sector. Economic factors have been known to have influence on large maintenance projects at refineries. These projects generate large volumes of K and F code hazardous waste.

Below we see monthly volumes shipped from petroleum refineries with the individual refiners color coded (you can hover your mouse over the chart for more information.) Premcor (in purple) jumps out from this chart in 2019. For 2020, we also see that Valero Corpus Christi possibly had some event or maintenance project in April 2020.

Refinery-specific Hazardous Wastes

We are going to look at tonnage volumes of specific EPA hazardous waste codes. The EPA waste codes we will delve more into are:

  • F037
  • K169
  • K170
  • K171

F037 Hazardous Waste from Texas Refineries

The short description of how F037 is defined is, “Petroleum refinery primary oil/water/solids separation sludge—Any sludge generated from the gravitational separation of oil/water/solids during the storage or treatment of process wastewaters and oily cooling wastewaters from petroleum refineries.” The below chart shows volumes of the refinery-specific EPA hazardous waste code “F037.”

The refineries shipping are in various colors showing the event nature of these hazardous waste volumes. We will also show charts for a few additional refinery-specific hazardous waste codes below.

K169 Hazardous Waste from Texas Refineries

Hazardous wastes carrying the K169 EPA waste code are solids from the bottoms of crude oil storage tanks. Over time the bottoms of these tanks accumulate very thick material that does not flow into the refining process. Eventually due to the decreased storage capacity or maintenance requirements, the solids in these tanks will have to be removed. These solids are classified as K169. EPA specifically defines this waste as “Crude oil storage tank sediment from petroleum refining operations.”

K170 Hazardous Waste from Texas Refineries

K170 is defined as “Clarified slurry oil tank sediment and/or in-line filter/separation solids from petroleum refining operations”….are you getting hungry yet?

This waste does not historically appear to be shipped by many refineries in Texas. We can see that 2020 is far behind 2019 tons shipped. On a positive note (if you are in the hazardous waste industry), we also see that ExxonMobil Baytown has started shipping again in August 2020.

K171 Hazardous Waste from Texas Refineries

K171 relates to disposal of specific catalyst from refineries. K171 volumes are more consistent across the board compared to the previous refinery wastes. EPA defines K171 as “Spent Hydrotreating catalyst from petroleum refining operations, including guard beds used to desulfurize feeds to other catalytic reactors (this listing does not include inert support media)”

This NAICS code had us really curious about what was causing the sharp change in volumes from this particular industry. We created the chart below which shows monthly volumes for this NAICS code as far back as we have e-Manifest. Each shipper is a unique color so you can see the volume of each shipper for the month.

This industry is down not because of Covid or market conditions but because 2019 had vastly more volume from May 2019 through November 2019. This NAICS code had a major spike in volume from one shipper, Intercontinental Terminals Deer Park.

On March 1, 2019 a leak from a tank storing ignitable hydrocarbons caused a huge chemical fire at Intercontinental Terminals (ITC) in Deer Park, TX. The fire would burn for days and create millions of gallons of wastewater requiring disposal. This event is one of the primary reasons Texas hazardous waste volumes increased significantly in 2019. ITC is the sole reason “Other Warehousing and Storage” appears as a major Sub-Sector for Texas hazardous waste volumes.

We wanted to see if volumes were still continuing from ITC, what their previous waste history was and where their hazardous waste went for ultimate disposal. The below chart shows just that. The destination facilities are color coded and if you hover your mouse on the chart you can see additional information.

We can clearly see that ITC generated tens of thousands of tons of hazardous waste in 2019 compared to other years. The hazardous waste volume decline in Texas related to ITC does not show economic slowdown but volumes for this shipper returning to normal.

How We Get Our Data

All data and analytics comes from our Knowsys application which brings together numerous environmental, compliance and industry datasets for the most comprehensive, current and connected business intelligence application for solid and hazardous waste.

If you would like more information about Knowsys or other ways we can help your company, please contact us.

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