EPA-230/2-86-005
          United States        Office of Policy,       March 1985
          Environmental Protection    Planning and Evaluation
          Agency          Washington, DC 20460
          Policy Planning and Evaluation
          Assessment of Incineration
          As A  Treatment Method for
          Liquid  Organic Hazardous
          Wastes
          Background Report
          Assessment of the Commercial
          Hazardous Waste Incineration
          Market

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ASSESSMENT OF  THE  COMMERCIAL
HAZARDOUS WASTE  INCINERATION MARKET
March 1985
A background  report  for the study by
EPA's Office  of  Policy, Planning and
Evaluation:   "Assessment of Incineration
As A Treatment Method For Liquid Organic
Hazardous Waste."
Prepared by:

Booze, Allen  and  Hamilton Inc.
7315 Wisconsin Avenue
Suite 1100W
Bethesda, Maryland    20914
Prepared for:

Office of Policy Analysis
U.S. Environmental  Protection Agency
Washington, DC   20460

EPA Project Officer:  John Chamberlin

         U.S. Environmental Protection Agency
         Region  V, Library
         230 South Dearborn Street
         Chicago, Illinois  60604

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                         ACKNOWLEDGMENTS
     This report was prepared by Booz, Allen & Hamilton Inc.
under subcontract to Putnam, Hayes & Bartlett, Inc.  The Booz,
Allen effort was managed by Lawrence Cahill.  Geoffrey Back
served as lead analyst with editorial assistance from Ran Farmer.

     The EPA Project Officer, from the Office of Policy Analysis,
was John Chamberlin.  Review assistance was provided by Sam
Napolitano, and members of the Incineration Study Steering Group.

     We would like to acknowledge the cooperation of several other
EPA offices, staff, and contractors:
Office of Solid Waste

Barry Stoll
Marlene Suit
Mike Burns
Dan Tuttle (Westat, Inc.)
Greg Faber (DPRA)
Larry Rosengrant
Susan Bromm
Eric Males
Frank Smith
David Sussman
Francine Jacoff
Bob Scarberry (JRB Assoc.)

Office of Pesticides and
Toxic Substances

Glen Kuntz
Office of Management Systems and
Evaluation

Joe Retzer
Jean Caufield

Office of Research and Development

Glen Shira
Jim Basilico

Office of Water Regulations and
Standards

Alan Rubin
Mark Kohorst

Office of Policy Analysis

Phil Paparotis
Jeff Kolb
     Additionally, many hazardous waste firms provided invaluable
insights into the market, but each firm's involvement was solicited
on a confidential, non-attributable basis due to the sensitive
nature of market information.

     Finally, the basic data used in this report have been reviewed
for accuracy and completeness by the waste management industry,
appropriate trade associations, and environmental groups.  Their
comments and suggestions were recedved in a one-day workshop
held on November 8, 1984.

     Identification of specific firms or technologies in this report
does not constitute endorsement or approval by the U.S.  Environmental
Protection Agency.  Questions concerning this report should be
addressed to:  John Chamberlin, Office of Policy Analysis (PM-220),
U.S. EPA, 401 M Street, S.W., Washington, D.C.  20460.

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              TABLE   OF   CONTENTS
                                                        Page
                                                       Number
      ACKNOWLEDGMENTS

      EXECUTIVE SUMMARY                                   1

  I.  INTRODUCTION                                      1-1

      1.    Background And Objectives                     1-1
      2.    Methodology                                  1-2
      3.    Limitations                                  1-4
      4.    Organization Of The Report                   1-6

 II.  INCINERATION MARKET PROFILE                      II-l

      1.    Market  Size And Regional Distribution       II-l
      2.    Incineration Technology And Capacity        II-2
      3.    Waste Volumes And Types Handled             II-5
      4.    Regulatory Approach For Incineration        II-9
      5.    Market  Shares And Competition               II-9
      6.    Prices                                       11-12
      7.    Barriers To Market Entry                    11-14
      8.    Financial Position And Market Strategies    11-14

III.  BASELINE INCINERATION SUPPLY AND DEMAND         III-l

      1.    Incineration Of LOHWs:                     III-2
           Current On-Site And Commercial
           Capacity Utilization

      2.    Incineration Of PCBs:                       III-7
           Quantities Incinerated And
           Available Capacity

      3.    Incineration Demand:  Influence            III-ll
           Of  Superfund Cleanup Activities

      4.    Incineration Demand:  Baseline             111-12
           Waste Quantities Managed In
           Landfills,  Injection Wells,
           And Disposal Impoundments

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                                                        Page
                                                       Number
IV.    PROJECTED CHANGES  IN  INCINERATION  DEMAND           IV-1
      AND CAPACITY UTILIZATION

      1.    Projected  Incineration  Demand                IV-1
           Without Regulatory Change

           (1)   Demand For  PCB  Incineration              IV-2
                Capacity

           (2)   Availability Of On-Site  Capacity        IV-3

           (3)   Commercialization  Of Alternative        IV-4
                Technologies

           (4)   Declining Landfill Capacity              IV-6

           (5)   Superfund's Influence                   IV-6

      2.    Projected  Incineration  Demand And            IV-7
           Capacity Utilization With Regulatory
           Change

           (1)   Land  Disposal Restrictions               IV-8

           (2)   Waste-In-Boilers Restrictions            IV-15

           (3)   Additional  Waste Listings               IV-18

           (4)   Lowering The Small Quantity              IV-20
                Generator Exemption

  V.   PROJECTED CHANGES  IN  LOHW INCINERATION             V-l
      CAPACITY

      1.    Increased  Capacity Utilization And             V-l
           New  Land-Based Capacity

      2.    Development Of Commercial Incineration-       V-2
           At-Sea

 VI.   IMPLICATIONS OF THE MARKET ANALYSIS               VI-1

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                                                       Page
                                                      Number
APPENDIX A - Definition Of Liquid Organic
             Hazardous Wastes

APPENDIX B - Estimation Of The Total Quantity
             Of LOHWs Incinerated On-Site And
             Off-Site

APPENDIX C - Market Analysis Modules:  Logic
             Diagrams For Baseline Market
             Conditions And Regulatory Scenario
             Analyses - Mid-Range Estimates Case

APPENDIX D - Low-Range And High-Range Estimates
             Case Summaries

APPENDIX E - Definitions Of Terms Used In The
             Market Analysis

APPENDIX F - References

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                LIST   OF   EXHIBITS
                                                         Page
                                                        Number
S-l    Incinerator Equivalents  Estimated To Be             3
       Necessary To Handle The  Excess  Demand For
       Commercial Incineration  Capacity For LOHWs

  1.    Commercial And Non-Commercial Incineration        II-3
       Facilities By Region

  2.    Distribution Of Operational Hazardous            II-4
       Waste Incinerators  By Type

  3.    Capacity Of Operational  Liquid  Hazardous         II-6
       Waste Incinerators

  4.    Liquid Wastes Incinerated In 1981 By EPA         II-7
       Waste Code

  5.    Similarities/Differences In Technical            11-10
       Requirements For Incineration Among
       Regulatory Programs

  6.    Comparison Of Quoted Prices For Nine             11-13
       Major Hazardous Waste Firms In  1981

  7.    Estimated Baseline  LOHW  Incineration             III-3
       Capacity Utilization--Mid-Range Case

  8.    Commercial Incineration  Capacity For LOHWs        III-6

  9.    Estimated Incineration Capacity Utilization      111-10
       For PCBs

 10.    Baseline Mid-Range  Estimates Of Hazardous        111-14
       Wastes Landfilled, Injected Into Wells, Or
       Disposed In Surface Impoundments

 11.    Alternative Thermal Technologies Judged          IV-5
       Suited To Destroy Liquid Organic
       Wastestreams

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                                                        Page
                                                       Number
12.   Effects Of Landfill Restrictions On                IV-11
      Incineration Of Liquid Organic
      Hazardous Wastes --Mid-Range Case

13.   Effects Of Restrictions On Deep Well               IV-13
      Injection:  Major Analytical Assumptions
      For The Mid-Range Case

14.   Quantities Of Waste-Derived Fuel                   IV-17
      Materials Burned By Type

15.   Effects Of Restrictions On Burning Hazardous       IV-19
      Wastes In Boilers On Incineration Of Liquid
      Organic Hazardous Wastes--Mid-Range Case

16.   Incineration-At-Sea Capacity                        V-3

17.   Incinerator Equivalents Estimated To Be            VI-3
      Necessary To Handle The Excess Demand For
      Commercial Incineration Capacity For LOHWs
      Under Four Regulatory Scenarios

18.   Incinerator Equivalents Estimated To Be            VI-5
      Necessary To Handle The Excess Demand
      For Commercial Incineration Capacity For
      LOHWs Under Combinations Of Four
      Regulatory Scenarios

A-l   Lists of Liquid Organic Hazardous Wastes            A-2
      Developed By The Office Of Solid Waste
      For The Incineration Market Study

A-2   LOHW Waste Code Categorization Scheme               A-4
      Developed For The Incineration Market
      Study

B-l   Quantities Of LOHWs Incinerated In 1981             B-2

B-2   Variations In Estimated Quantities Of               B-4
      LOHWs Incinerated In 1981

B-3   Total Wastes And LOHWs  Managed By                   B-7
      Management Technology

B-4   Definition Of Commercial Activity:                  B-10
      Percent Of All Wastes Received By TSDs From
      Off-Site Either Same-Firm Or Other-Firm
      Origin - 1981 RIA National Survey

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                                                        Page
                                                       Number
B-5   Defining A "Commercial"  Threshold:                 B-ll
      On-Site And Off-Site Splits Of  Wastes
      Managed By Technology

B-6   On-Site V. Off-Site National Splits  By            B-12
      Technology For All Wastes - 1981 National
      Survey Data

B-7   On-Site V. Off-Site National Splits   By           B-15
      Technology For All Wastes - 1981 National
      Survey Data

B-8   On-Site V. Off-Site National Splits  By            B-16
      Technology And LOHW Category - 1981
      National Survey Data

D-l   Variations In Key Assumptions/Data                 D-2
      Across Sensitivity Analysis Cases For
      Each Market Analysis Module

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                    EXECUTIVE SUMMARY
    The U.S.  EPA intends to  develop an overall  policy  on
the proper  management of  liquid  organic hazardous  wastes
(LOHWs) .  The need  for such  a  policy  is driven,  in  part,
by  the reauthorization  of  the  Resource Conservation  and
Recovery  Act  (RCRA)  that calls  for  prohibitions  or  re-
strictions  on  certain   management  practices   for   these
wastes.   These  regulatory  changes  would  likely  increase
the demand  for  incineration  capacity  and other  treatment
capacity for these wastes.

    The purpose of  this  study is  to  focus on  current  base-
line supply and demand in the commercial incineration mar-
ket, and  to  estimate how demand  and supply may  change  in
response  to  the  proposed RCRA  regulatory  changes.   This
report  presents  the  results  of  that   incineration  market
assessment.

    Baseline  incineration capacity  utilization  estimates
suggest that available on-site  (i.e.,  captive)  and commer-
cial  incineration  capacity for  LOHWs   is  not  fully  util-
ized.    Both  on-site  and commercial capacity  utilization
may range anywhere  from  around  37 to about 74  percent  for
commercial capacity  depending upon  the  estimated quantity
of LOHWs  currently  incinerated.   The lower estimate  of  37
percent is based upon  the EPA's analysis of  waste-handling
data from the  1981  National  Survey  applied  to  independent
estimates of  on-site  and commercial   incineration  capac-
ity.   The higher  estimate of  74  percent reflects industry
suggestions  that more  LOHWs are currently  incinerated than
the EPA estimate.   As  a  portion of  the  larger  market,  in-
dustry  sources  also  report  that commercial  incineration
capacity  utilization  for liquid  PCBs   is  at or near  100
percent.

    Both  on-site   and   commercial   incineration  capacity
utilization  are  expected to  increase  as a  result of  in-
creased  demand,   even  in  the  absence  of  the  regulatory
changes the EPA  may implement.   Over  the short-term,  the
key factors behind  an increase  in  the  demand  for  commer-
cial incineration are seen to  include:

         An  increased demand for PCB incineration capacity

         Generators' concerns over   the  long-term liabili-
         ties of impermanent waste disposal

         Increased Superfund clean-up activities

         Declining landfill capacity
                           -I-

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         Slowed  commercialization of  alternative  innova-
         tive technologies

         An absence of quickly  available  on-site incinera-
         tion capacity.

Commercial  incineration  capacity  is  seen  to grow  little
over the  short-term  as  regulatory constraints  (i.e.,  com-
plexity  of regulations,  permit  delays,  siting  difficul-
ties) are  perceived  to  result  in  a  3  to 5  year  lag-time.
Longer-term market  forecasts for  incineration demand  and
supply are less definitive.

    With  the  regulations  called for  in the  RCRA reauthor-
ization legislation, the  predictions are  unanimous:   with-
out  large  increases  in  capacity,  the demand for  incinera-
tion  will exceed  supply.   Commercial  incineration  firms
characterize  these  changes as  a  "boon"  to  their  markets.
They claim that effects are  already being felt as  the mar-
ket anticipates implementation of the expected RCRA rules.

    The perceptions  of  industry are confirmed  by the  re-
sults of  the  scenario  analyses  as  summarized  in  Exhibit
S-l.  Each of the  land disposal  restriction scenarios  ex-
amined are projected to  result  in an excess  of  demand  for
incineration  over  existing commercial incineration  capac-
ity  (fully utilized) by  some 215  to  306 percent  based  on
the average or mid-range  sensitivity analysis.*   The anal-
ysis  of  the  waste-in-boilers  restrictions  indicated  less
of an excess  in  demand—only 106  percent of existing com-
mercial incineration capacity (fully  utilized).

    Exhibit S-l goes a step  further to translate  the esti-
mated  excess  demand into  incinerator  equivalents.   Two
incinerator equivalent measures are shown -- the  number  of
land-based facilities of  probable future  "average"  capac-
ity needed to accomodate  the added demand,  and  the  number
of  probable   future  "average"  capacity  incinerator  ships
that  would accomodate  the  added demand.    This  approach
translates the  incremental change in demand for  incinera-
tion into the most tangible  form  of a market response,  the
building  of facilities and ships.  As shown in  the  exhib-
it,  as  many  as   26   land-based  incinerator   facilities
(20,000 metric tons each)  or 10 incinerator  ships (50,000
    Each  scenario  had  at  least  one  key  assumption  for
    which  a  range  of possible values  was  offered  by  the
    sources consulted for the  study.  All  the lower values
    of these  ranges were used  to construct  a "low-range"
    case, and all the higher values  were  used to construct
    a "high-range"  case.  The mid-range case  was the aver-
    age of the lower and higher values.
                            -2-

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                                                  -£-
                                    MILLIONS OF METRIC TONS/YEAR OF LOHW

                                                 S                               S
I i
                                   NUMBER OF LAND-BASED INCINERATORS
                                    NEEDED TO HANDLE EXCESS DEMAND*
                                       NUMBER OF INCINERATOR SHIPS
                                    NEEDED TO HANDLE EXCESS DEMAND**

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metric  tons  each)  would  provide  liquids  incineration  ca-
pacity equivalent to the  excess of  demand  for incineration
over existing commercial  capacity predicted  for  the injec-
tion  well  restrictions   scenario.   Slightly  fewer  land-
based facilities  (24) or  ships (9)  would  be  equivalent to
the  excess  demand  estimated under  the disposal  impound-
ments  prohibition  scenario.  The  excess  demand  brought
about by  landfill  restrictions is  shown as  equivalent to
14  land-based  facilities  or 6 ships.   Not  shown  in  the
exhibit are  future additions  to  existing capacity  (land-
based or  at-sea)  as no  planned  capacity data were  avail-
able, or options such as  combinations of land-based facil-
ities and ships as a way  to  handle  any  estimated excess of
demand under each of the regulatory scenarios.
                            -4-

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                     I.  INTRODUCTION
1.  BACKGROUND AND OBJECTIVES

    As part  of an overall  policy on managing  liquid haz-
ardous wastes,  the  U.S.  EPA is  conducting  a comprehensive
assessment of  the benefits  and risks of  incineration as a
means to  treat/dispose  of liquid organic  hazardous  wastes
(LOHWs).   Several  interrelated  areas  of possible  regula-
tory/policy change are focal points for this assessment:

         Amendments to prohibit  or  otherwise restrict land
         disposal of liquid hazardous wastes.

         Tighter  controls over  the burning of  hazardous
         wastes in industrial boilers and furnaces

         The Agency's ongoing  review of  the need for  and
         advisability of  permitting  incineration-at-sea of
         hazardous  wastes  (including  development  of  the
         applicable  regulations)  as  an   alternative   to
         land-based incineration

         Additions to the list of hazardous  wastes  and/or
         the lowering of  the small quantity  generator  ex-
         emption under RCRA

These changes are likely  to  alter the  economic  forces that
shape the current  commercial,  LOHW  incineration  market.
Incineration-at-sea,  if   permitted  by  the  EPA*  and  the
states,  would  expand  available capacity.   Current  commer-
cial  (and captive)  LOHW  incineration capacity  could  be
taxed or  exceeded over  the  short-term as  large quantities
of LOHWs  move  into  the  market  in response  to  controls on
burning  hazardous  wastes in boilers  or  from restrictions
on  land  disposal.  New   waste  listings  and lowering  the
Federal  small  quantity generator exemption could also  in-
crease LOHW volumes  available to be incinerated.
    In May  1984,  the EPA  did  not approve  pending  operat-
    ing,  research,  and  test burn  permit applications  for
    incineration-at-sea   until  completion  of  its  overall
    LOHW  incineration  study  and  development  of  Federal
    regulations governing this  practice.
                           1-1

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    The objective of this study  is  to  provide  the  EPA with
information on  the  current  and probable  future  conditions
of  the  commercial   industry  for  incineration  of  LOHWs,
including  PCBs.   Starting  from  a  profile  of the  current
market  for  commercial  incineration  of LOHWs, an  economic
analysis of commercial LOHW incineration  capacity  utiliza-
tion  is presented.   This  analysis  serves  two  functions:
to analyze market changes and project  industry  supply  and
demand  in response to possible changes  in the  RCRA regula-
tions,  and to provide the EPA with an  analytical  tool  for
future  evaluations  of  alternative  scenarios  as more  and
better data become available.

2.  METHODOLOGY

    This  incineration  market assessment  is one  component
of a  larger  study being  conducted  by  several EPA offices
and contractors centered on a comparative risk analysis of
land-based and  incineration-at-sea  of  LOHWs.   Several  of
these  other  studies are  direct  inputs to  the  market  as-
sessment.  The  market  assessment   itself consists of  two
parts—a  profile  of the  current LOHW  incineration  market
and an economic analysis of  the  industry  to project  the
demand  for  and  supply  of  incineration capacity under  al-
ternative regulatory scenarios provided by the Agency.

    The  market  profile  was developed  from  past  EPA  re-
ports,  extensive discussions  with  EPA  staff,  and  contacts
with  leading  firms  in  the  hazardous waste management  in-
dustry.   The  profile focuses on  market size  and  partici-
pants'  market  share, LOHW  volumes  incinerated,  available
technologies, and  the  EPA's current* regulatory  program
for incineration.  A particularly  intensive area of inves-
tigation, led by the Office of Solid  Waste,  concerned  es-
timating  quantities  of LOHWs  managed by  type  and  technol-
ogy  (see Appendices A  and B) .   The  principal source  of
these  data  was the  National  Survey  of  Hazardous  Waste
Generators and  Treatment, Storage,  and Disposal Facilities
Regulated  Under  RCRA in   1981  (the  1981 RIA  National Sur-
vey) (1,2).

    The  economic analysis portion of  the market asessment
is an  evaluation of  LOHW incineration capacity utilization
comparing  estimated  on-site and commercial LOHW incinera-
tion  capacity  (i.e.,  supply)  with  estimated volumes  of
LOHWs  to be  incinerated  (i.e.,  demand).  This  comparison
is done for baseline market conditions, and a series of
*Through September, 1984.
                            1-2

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cases projecting  demand  and supply in  response  to several
RCRA  regulatory  amendment scenarios  (developed  in consul-
tation with the EPA).  Projected  trends  in  demand  and sup-
ply  are  also examined  in the  absence  of  any  significant
regulatory changes.

    Baseline  market  conditions  are  established  on  the
basis of  three  different estimates of  commercial  LOHW in-
cineration capacity  utilization.   These  varying  estimates
of baseline capacity  utilization,  reflect uncertainty over
the  present  relationship of the demand  for LOHW incinera-
tion  and  the  supply of  LOHW  incineration capacity.   Chap-
ter  III  discusses  these baseline  estimates.   In  Chapter
IV,  the  projected  impacts  of each  regulatory  amendment
scenario  are  expressed  as  incremental  increases  above
these baseline estimates.

    Individual  components or  modules  in  the  overall  as-
sessment were analyzed  separately.   For  example,  a  module
was devoted solely to estimating  incineration  capacity for
PCBs.  Modules  were  also  developed  for   each  regulatory
amendment scenario.  Each module  was  developed  through the
use of a  logic  diagram  through which key data  and assump-
tions  could  be  displayed  and tracked.   Each  analytical
"template" visually  traces  the flow of  logic behind  the
analysis  leading  to  a  final  capacity  utilization  esti-
mate.  Its design allows for  individual  estimates  and as-
sumptions to  be modified easily  to generate new  results.
With  these  modules  then, the  EPA can  perform  iterative
assessments as  new  data become  available  or  as  policies
are modified.

    The logic diagrams  presented in  Appendix  C trace  the
calculations  for  the most  likely  estimates  for  the  data
and assumptions in each  module, drawn from  the  best avail-
able sources consulted during  the study.  In some  of these
cases, the  most  likely  estimate  is  the approximate  mid-
point between  a  high and low  bound  for individual  data/
assumptions as  suggested  by  these  sources.   These  high-
range and low-range  estimates within each  module  are sum-
marized in  Appendix  D.   Given that  there  is  a  range  of
possible estimates  for   some  of the  key  data  and  assump-
tions, a  sensitivity analysis  has  been  incorporated  into
the  economic  analysis  to capture  the  range  of  possible
outcomes to each module calculation.

    The sensitivity  analysis  has  been built from  the com-
bination of  lower and upper  bounds for  selected  key data
and  assumptions  across  all  the  modules.   For example,  a
"low-range estimates case" was  developed  out of  the combi-
nation of the lowest estimates  provided  for these  selected
                           1-3

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data and  assumptions  within each and every  module.   Simi-
larly, a  "high-range  estimates case" was built  from indi-
vidual high-range  modules  that use  the higher  estimates
suggested  for   these   same  key  data   and  assumptions.
Selecting  an  average   between these  two  bounds  is  the
"mid-range  estimates  case",  presented  here as  the  most
likely case,  if, for  any one  assumption, either  the lower
or higher  bound may be  correct.   However,   results  of  the
low-range  and high-range  cases are  presented  along  with
the mid-range case  analysis throughout the report.

3.  LIMITATIONS

    Use of  a sensitivity analysis  in this  market  assess-
ment emphasizes that certain key limitations of  this anal-
ysis should  be kept in  mind  when evaluating its results.
These  limitations  fall  into  two,  non-exclusive  classes,
and each  can be corrected  for in the  future  as more  and
better data become  available to the Agency.

    (1)  Limitations of a National-Level Analysis

         The  market  assessment  presented in  this  report
    has been  conducted at  the national  level.   Conceptu-
    ally,  one can conceive  of  a regional analysis  and,  in
    fact,  such an analysis  was  contemplated  originally.   A
    regional  analysis  has  several  benefits,   principal
    among  these  is the  ability to  assess   regional  costs
    and  capacity  shortfalls   that  might  otherwise  "wash
    out"   at  the national  level.   These regional  impacts
    may be  quite varied in  response  to  the land disposal
    restrictions and other  RCRA regulatory amendments.

         The  1981  RIA  National Survey  data   available  on
    regional waste  management  capacities  and quantities  of
    LOHWs  generated  and managed  by  region, however,   do
    not allow a regional  focus for  the market  analysis.
    The absence  of  reliable LOHW quantity data  for a  re-
    gional analysis reflects  the considerable  statistical
    uncertainty  in  extrapolating  to  national  level  waste
    quantity data (acknowledged in the RIA National  Survey
    report)  from  limited sample  sizes  when  the data  are
    cut by EPA  region  or by some  form  of service  region.
    In its  place,  however,  there  has been  an  attempt  to
    present some limited regional-based  information.   Com-
    mercial  incineration  facilities  have been  character-
    ized   as  to  their  location  in  four  service  regions.
    Selected  firms  within  these service  regions  have  been
    contacted and  asked for their  general   assessement  of
                           1-4

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                                                                    r
    market  activity,  trends,  and  problems  over the  next
    five  to ten years.   These assessments  are  summarized
    in Chapter IV.*

    (2)  Data Inconsistencies and Unavailability

         As noted earlier, data  quality/uncertainty  issues
    arise in  several  areas  of the market  assessment.   Nu-
    merous  sources of  data  were utilized  in the analysis,
    and  these sources often  present inconsistencies  that
    cannot be reconciled easily or at all.   In  some  cases,
    estimates of the same parameter  are conflicting  or  the
    relationships set  by "good" estimates of two  parame-
    ters run  contrary  to  a  third.   Limitations  in the  RIA
    National  Survey  data are  treated  exhaustively  in  the
    Survey  report.   These range  from  limitations   in  the
    survey  design  to  significant sampling  and  nonsampling
    errors.    In  addition, there  are definitional  differ-
    ences between  these  sources  and  the  use  of  similar
    terms in  this  report.  Appendix E  covers the  defini-
    tions of key terms in this report.

         Some of the necessary data  also  are not available
    in  any   easily  accessible  form.   Several  regulatory
    scenarios, for example,  have yet to be developed fully
    pending  further Agency study.  In other  cases, such as
    the  demands  Superfund clean-up  activity may have  on
    available  RCRA  capacity,  sufficiently  detailed  data
    simply  do  not  yet exist  for  conducting  anything  more
    than  a  very  rough,   preliminary analysis.   In  cases
    such  as  these,  engineering judgment was  applied  to
    develop  a  range  of possible estimates.   This range of
    estimates was then used in the sensitivity  analysis to
    calculate a range of  capacity utilization consequences.

         Whenever possible,  attempts were  made  to  recon-
    cile and corroborate estimates and  assumptions used in
    the analysis.  This was not always  possible.  The  pri-
    mary  concern,  however,   was to  reach   some  consensus
    that these  estimates/assumptions are  at  least  reason-
    able or  "in  the ballpark", and  to  measure  the  sensi-
    tivity of  the  results to  variations  in  these  assump-
    tions.  All  estimates and  assumptions  are  documented
    as to their  specific  or  general  source  given the  con-
    fidentiality of  some  information collected  during  the
    study.
*   All industry respondents requested  that  their  specific
    comments  were  to  be  considered   confidential   and,
    therefore, non-attributable.
                           1-5

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4.  ORGANIZATION OF THE REPORT

    The  remaining  five chapters of  the report  follow the
analytical progression  from baseline market  conditions  to
projected, regulatory-induced  changes  in  incineration de-
mand  and supply.  Chapter  II  presents a  profile of  the
current  incineration  market.   This  profile  includes  an
overview  of  the market's  size and regional  distribution,
waste volumes  and  types handled,  and the  applicable  regu-
lations, and a discussion of market  shares,  prices,  compe-
tition, and barriers to market entry.

    This  information is  used   in  Chapter  III  to  develop
estimates of  baseline  LOHW incineration  demand and  sup-
ply.  Both on-site  and commercial baseline  LOHW  incinera-
tion capacity utilization is estimated.   Also developed  in
this  chapter  are  estimates of  the  volumes  of  hazardous
wastes managed, on-site and off-site,  in  landfills,  injec-
tion   wells,    disposal   impoundments,   and   industrial
boilers.  These  volumes  represent  those wastes  that  would
be affected by the RCRA regulatory  amendments discussed  in
Chapter IV.

    Chapter  IV  looks at probable  future  demands  on  incin-
eration capacity.  Two  forms  of this projected  demand are
examined.  In  the  first section,  increases in demand are
estimated  in   the  absence  of  major  regulatory  changes.
Conversations   with  industry   sources   indicate  that  this
nonregulatory-induced  increase in  demand  is likely,  but
difficult to quantify.  Factors and influences behind  this
increase  are  identified.   In  the  second  section,  several
regulatory-induced changes  in  demand  are  analyzed.   Each
of  the   regulatory   scenarios  are   analyzed  separately.
Their  effect  on  demand is  assumed  to be  instantaneous,
that is,  the analysis  avoids  speculating on  a schedule  of
implementation for these  regulations,  and no  additions  to
present  capacity  are  assumed.   Mid-range, low-range,  and
high-range demand  estimates are  presented.   Included  are
scenarios on land disposal  restrictions (landfills,  injec-
tion  wells,  and  disposal  impoundments)   and  controls  on
burning hazardous wastes in boilers.

    In  Chapter  V,   probable   increases   in  incineration
capacity  are  estimated.   This  includes   a  discussion  of
industry's views  of  their ability  to make  additional ca-
pacity  available  over the  next three  to  five years.   In
addition, data  are  presented  on the development  of  incin-
eration-at-sea capacity.   It   is expected that nearly  all
of  this  added capacity will  be for  thermal  treatment  of
liquid wastes.
                           1-6

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    The analyses of projected  increases  in  demand and sup-
ply come together  in  Chapter VI.   The key  feature  of this
comparison  is  the  projected,  regulatory-induced  excess of
demand over  full-capacity  supply  as translated  into land-
based and  incineration-at-sea equivalents.   Any  excess of
the  demand  for  incineration  over  full-capacity  levels
(mid-range estimates  of demand only)  is equated  to  an es-
timated  number  of land-based incinerators  of  "average"
capacity  and  an  estimated  number  of  "average"  capacity
incinerator  ships.   This  provides  a  consistent  basis  for
measuring and  comparing  the  supply and  demand  impacts of
the various  regulatory  amendments to RCRA  on the  commer-
cial incineration market.   Though not equated  to incinera-
tor equivalents,  results  of  the  lowand high-range  demand
analyses are presented.
                           1-7

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             II.  INCINERATION MARKET PROFILE
    Understanding the  potential  impact  of anticipated reg-
ulatory amendments requires definition  of a starting point
or  baseline to  which  comparisons  can  be  made.   In  this
section,  a  profile  of  the current  commercial incineration
market  is presented as  background for baseline estimates
of  incineration  capacity  utilization.   General  information
is  presented  on market size  and participants,  waste  vol-
umes handled,  available  technologies and capacity,  and  on
the  existing   regulatory  approach  for  incineration.   The
economic  structure  of  the market  is  described including
estimates of market shares and prices.  Also discussed are
competitive  pressures,   barriers   to   entry,  and  growth
strategies.   Some information  is  also  developed  on  the
regional character of the commercial incineration industry.

1.  MARKET SIZE AND REGIONAL DISTRIBUTION

    Estimates  of  the  number  of  commercial  incineration
facilities  range from  25 to  40  (3,4,5,6,7).   These  are
privately  owned/operated  facilities that have  (or  intend
to have)  incineration  capacity  devoted  mostly  to  handling
wastes, for a  fee,  from  other  firms.*  Far  more firms can
provide access  to  incineration  capacity,  but  only  through
other firms that they do  not own.   Estimates of  on-site  or
captive  incineration  facilities   range  from  200  to  210
firms (3).

    The range  in the estimated number of  commercial facil-
ities reflects  growth  in the market  over time, errors  in
the available data, and differences  in  defining commercial
activity.   For example, sources of  these  estimates  cover  a
period from December  1980 to July 1984,  during which in-
cinerator  units  have come on-line or gone  out-of-service.
Permit status  also changes with time.  Commercial  facili-
ties, whose Part A permit data  indicates incineration
    This  is  the preferred  definition  of  "commercial"  for
    the market  study.   This  definition  focuses on  wastes
    origin-  ating   from  off-site  and  from  other  firms.
    This  defini-  tion  is   intended  to  include  intrafirm
    shipments between  off-site  commercial  facilities,  but
    exclude intrafirm  shipments  between  a generator  and  a
    captive TSD  owned by  the generator  (see also  Appen-
    dix E) .
                           II-l

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activity, may later be denied a permit  to  operate,  or they
may discontinue plans  to operate a hazardous  waste incin-
erator.

    The  estimated  total  number  of  operating  hazardous
waste  incinerators  ranges  from  270 to  340  units  depending
upon  completion  of planned  construction  (3) .   Commercial
facilities may account  for 30 to  50  of these  units,  that
is, some  80  percent of hazardous waste  incinerators  oper-
ate at  the  generator's  site or as  part of a  captive  haz-
ardous waste management facility (3).

    Many of  the  incineration facilities, both  on-site  and
commercial,  and most of the  incinerator  units,  are  located
in  the Southeast  and  Southwest  as  shown  in Exhibit  1.
Fewer  firms  are  located in  the  Middle Atlantic  and  North
Central regions of  the U.S., but commercial  firms in  these
areas  have   significant  capacity.    Even  fewer   firms  are
located in the Western U.S.

2.  INCINERATION TECHNOLOGY AND CAPACITY

    For  handling  LOHWs,  liquid  injection  is  the  primary
incineration  technology.   Other  technologies,  such as  ro-
tary  and cement kilns,  can also handle liquids as  well as
solids.  The  Mitre  Telephone Survey  (3) indicated  that 52
percent of all reporting hazardous  waste incinerators were
liquid injection units.*   In total, some 77  percent of  all
the incinerators reporting  could handle liquids,  including
liquids-capable  multiple   hearth/chamber    units,   rotary
kilns, and fume incinerators.  Exhibit  2 shows the  distri-
bution  of  operational  hazardous   waste  incinerators  by
technology  as estimated  by  Mitre  (3) .   Additional  data
obtained  by  Mitre  indicate  that   while  liquid  injection
units  dominate,  newer  units tend  to be  rotary kilns  or
fume  incinerators.   This  general   trend  is  confirmed  by
industry sources.

    Total incineration  capacity for  all  hazardous wastes
(or just  LOHWs)  is difficult to estimate.   Exact capacity
of  individual units is generally  not known  or  the avail-
able  data reflect  respondents'  different  interpretations
of capacity  (e.g.,  hourly  throughput  capacity, heat capac-
ity, annual total capacity) .  Operational parameters—hours
    Data  on  incinerator units  by  type are  also available
    from  the RIA  National Survey.   However,  as  of  this
    writing, efforts are still  underway  to verify and cor-
    rect these data.
                           II-2

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                             EXHIBIT 1
 Commercial and Non-Commercial Incineration Facilities By  Region
EPA
REGION
I
II
III
IV
V
VI
VII
VIII
IX
X
NON- COMMERCIAL
INCINERATION
FACILITIES
(SOURCE: (3))
7
26
26
38
28
57

• 22


COMMERCIAL
INCINERATION
FACILITIES
(SOURCE: (3))
1
2
3
9
4
6
1
0
2
0
COMMERCIAL
INCINERATION
FACILITIES
(SOURCE: (4))
5
6
4
11
6
6
1
0
1
0
COMMERCIAL
INCINERATION
FACILITIES
(SOURCE: ( 7 ))
3
1
1
7
6
6
0
0
1
0
COMMERCIAL
INCINERATION
FACILITIES
(SOURCE: (6))
3
2
4
13
7
3
2
0
1
0
204
28
41
25
                                                                        38

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                              EXHIBIT 2
              Distribution of  Operational Hazardous
                    Waste  Incinerators by Type
INCINERATOR TECHNOLOGY
Liquid Injection
Hearth/Chamber
Liquids
Solids
Rotary Kiln
Liquids
Solids
Fume (Liquids)
Controlled Air
Combination
Miscellaneous (Solids) a

NUMBER
REPORTED
BY MITRE
137
56
33
23
11
10
1
24
-
5
31
264
PERCENT
0F
TOTAL
51.9
21.2


4.2


9.1

1.9
11.7
100
a)  Includes ammunition/explosives units, drum burners, and other solid units.


SOURCE:  (3).
                                II-4

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per day, days  per  year,  and so forth—are also so variable
as to be difficult to  characterize  as "typical".   The data
that are available on  liquids incinerator unit capacities,
however,  are  shown in  Exhibit  3(3).*   A  wide   range  of
throughput capacity is indicated, but  the  distribution is
skewed  towards generally smaller  (less  than  200  gallons/
hour)  units.   Using  these  data,  an  estimate  of  total
available baseline LOHW capacity, on-site  and commercial,
is developed in Chapter III.

3.  WASTE VOLUMES AND TYPES HANDLED

    Those waste  types  that are liquids and  incinerated or
potentially  incinerable are  the  target  wastes  for  this
market  analysis.    Information  on   the   types  of  waste
streams incinerated comes  from the 1981  RIA National Sur-
vey  (2).  The  Office of Solid Waste  (OSTT)  has coordinated
the development of  this information.

    Exhibit  4  summarizes  the waste  type and  volume  data
obtained from  RIA  National Survey.   Estimates  of  the vol-
ume of  LOHWs  incinerated  in 1981 range arou .d 0.9 million
metric tons  (MMT).**  Most  of  this amount is accounted for
by three  waste code categories:  miscellaneous commercial
chemical product  wastes,  ignitable  wastes,  and  solvents.
According to survey data,  98 percent of  these wastes were
incinerated on-site.
 *  Data in the RIA National Survey can  be  used to develop
    capacity estimates by technology.  As of  this writing,
    however, OSW's efforts to develop  such  an estimate for
    commercial  incineration  capacity  had  not  been  com-
    pleted.  The main difficulties were  proper interpreta-
    tion of  design hour '.y  feed  rates  (expressed  in  mass
    units)   provided  by   respondents  to  the  survey,   and
    scaling up  from a limited  survey  sample  of commercial
    facilities  to  national  totals.   These  problems forced
    the use of  independent  estimates  of total  and commer-
    cial incineration  capacity.

**  The RIA  National  Survey  itself consisted of  several
    general   and    technology-specific    questionnaires.
    Sources for LOHW  quantity  data  are  adjusted  responses
    to  the  TSD General  Questionnaire  and  data  from  the
    Incinerator  Questionnaire.    OSW  prefers  to  use  re-
    sponses from the Incinerator Questionnaire (1).
                           II-5

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                                    EXHIBIT  3
      Capacity of Operational Liquid Hazardous Waste Incinerators
CAPACITY
RANGE
(gal/hr)
0-50
51 - 100
101 - 200
201 - 300
301 - 500
501 - 1,000
1,001 - 2,000
2,001 - 5,000
5,001 - 10,000
Total Reporting
Unknown Capacity^
Total
Number of
Units
49
29
24
23
11
22
17
6
4
185
24
209
Percent of
Total
26.5
15.7
13.0
12.4
5.9
11.9
9.2
3.2
2.2
100.0

SOURCE:  (3)
aThese non-reporting units were operated by commercial incineration firms.
                                         II-6

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                     EXHIBIT 4
Liquid Organic Hazardous Wastes Incinerated In 1981
  By  EPA Waste Code or  RIA  National Survey Waste
                 Combination  Code3
EPA Waste Code or RIA National
Survey Combination Code
DOOO
D001
D002
D003
F001
F002
F003
F005
K001
K015
K016
K018
K036
K083
K085
K093
P063
P068
PO74
P106
U002
U003
U023
U031
U043
U044
U053
U056
U074
U080
U098
U117
U122
U123
U133
U154
U188
U196
U220
U223
Amount Incinerated As Liquid
(Metric Tons/Yr)b
19,159.2
227,463.5
10,637.8
12,973.7
33.5
6,003.3
90,112.8
65,705.3
66.9
569.1
3,656.3
5,735.5
301.3
1,963.9
1,472.9
662.1
230.6
148.8
874.1
3.7
1,926.7
9,068.2
941.0
357.1
2,440.0
3.7
93.0
401.7
2,745.0
7.4
7.4
7.4
915.0
3.7
89.3
297.6
4,307.2
3.7
3.7
178.5
                          II-7

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                   EXHIBIT 4 (Continued)
  Liquid Organic Hazardous Wastes Incinerated In  1981
    By  EPA Waste  Code or  RIA National Survey  Waste
                     Combination Code3
EPA Waste Code or  RIA National
    Survey Combination Code
Amount  Incinerated As Liquid
      (Metric Tons/Yr)b
X001
X002
X013
X015
X028
X042
X072
X110
X124
X175
X179
X182
No Code
22.3
535.6
2.436.3
5.545.8
1.335.3
23,232.1
2,640.9
2,387.9
3.7
1,606.8
11.2
300,775.3
46,326.6
                                              858,431.7

                                         (0.86 million metric tons/year)
 a)  See also Appendices A and B.
 b)  Assumes 268.8519 gallons per metric ton.
 SOURCE:  (1).
                                II-8

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    Appendix A lists those EPA  waste  codes  or RIA National
Survey waste combination codes   OSW defines as potentially
incinerable LOHWs  (1) .   This list  was developed  from re-
sponses  to the  RIA  National  Survey  that  indicated  the
physical  form  and  volumes  of incinerated  wastes,  combined
with  incinerability rankings  drawn  from  the  Engineering
Handbook  for Hazardous Waste  Incineration  (8) .   Appendix B
describes the series of analyses  behind the estimated vol-
umes of LOHWs  incinerated, and  the  on-site  versus off-site
splits of these totals.

    Efforts continue  at  the  EPA  to  refine  incineration-
related   information  from  the  survey.   These  additonal
studies will attempt to more  carefully characterize incin-
erated  waste  streams   (particularly  the   characteristic
wastes)  by waste   code  and  physical  form  to  eliminate
double counting of certain waste streams.*

4.  REGULATORY APPROACH FOR INCINERATION

    The regulatory  programs  governing  land-based  and sea-
based incineration are derived  from three  statutes.  Land-
based  incineration of  all  non-PCB  hazardous  wastes  is
covered under  the  RCRA  regulations.   The  incineration  of
PCBs is  a special  regulatory area  under the  authority  of
the  Toxic Substaces  Control Act  (TSCA).   Regulation  of
incineration-at-sea is,  as  yet, not  fully  developed  as  a
regulatory program.  Statutory  authority  for  these regula-
tions  is  derived  from  the  amended  Marine  Protection,
Research,  and  Sanctuaries Act.

    A review  of  these statutes  and programs has  been de-
veloped by  the  EPA as  part  of the  larger  incineration
study  (9).  Exhibit  5  highlights their analysis.   In sum-
mary, these programs  share several similarities  in  their
approach,   but  differences  do  exist  in  at  least  four
areas:     technical  requirements,   permitting  procedures,
issues of potential liability,  and  in a "needs"  determina-
tion process required for permitting incineration-at-sea.

5.  MARKET SHARES AND COMPETITION

    While there are anywhere  from 25 to 40  commercial in-
cineration facilities,  only  5  to  10 of these  facilities
are generally  viewed as  "majors", especially on a national
    For example, a  respondent might report  an  incinerated
    F003  wastestream  twice   as  a  D001  and  F003  waste-
    stream.   The  EPA's  reclassification might  list  this
    wastestream as  a F003 waste only.
                           II-9

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                                                       EXHIBIT 5
                             Similarities/Differences  in Technical Requirements  For
                                      Incineration Among Regulatory Programs
     Technical
     Requirement
Incineration-At-Sea  (MPRSA)
 (As Proposed  Regulations)
 Land-Based Incineration
         (RCRA)
        PCBs
       (TSCA)
   Hydrogen chloride
Total acid forming emissions
after dispersal and initial
mixing shall lead to less  than
a 10 percent change in
alkalinity
99.9% removal or no more
than 4 Ibs. an hour
Limited as specified by
Regional Administrator
   Particulates
M  Destruction efficiency
I   (DE) or destruction
o  removal efficiency (ORE)

   Residence time;
   temperature

   Environmental
   monitoring
No limit
                                                              Less than 0.08  grains/dscf
                                                              corrected for amount of
                                                              oxygen in stack gas
DE:  99.99% (99.9999%  for PCBs)   ORE:   99.99%
1 second or longer ;1100°C
Extensive
Determined by trial burn
Not required
Liquids:  99.9% combustion
efficiency
Solids:  99.9999% ORE

2 seconds at 1200°C
1.5 seconds at 1600°C

Not required
   Stack monitoring
Proposed for 10  parameters
including potential products
of incomplete combustion
Required for 5 parameters
Required for 6 parameters
   Waste analysis
Required before  each burn -
extensive
Specific plan developed  for
permit - must be followed
PCB content limited per
trial burn
   SOURCE:   (9)  with additional  changes derived from conversations  with  EPA staff.

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level.   These facilities  (and  a few others)  also control
significant regional market shares.

    Definitions of  a  market share in this  market do vary.
The major  facilities  can be  chosen  on  the  basis of esti-
mated  total  existing  capacity to  incinerate all hazardous
wastes  and  estimated  revenues.   How much  of this existing
capacity  is  being  utilized,  however,  may  not  be  known.
Some of these facilities may be operating  at  or near ca-
pacity.   Percent  capacity  utilization,  therefore,  may be
an important market-share estimate criterion.

    Capacity  and  capacity  utilization  also vary  by waste
type.   For  example,  industry  sources indicate  that  exist-
ing  incineration  capacity  for  PCBs  is   fully  utilized
(10).   This  reflects  both  the mandatory  and  voluntary
phaseout of  electrical  equipment containing PCBs,  and op-
erating problems  experienced  by  the  permitted  incineration
facilities  that  limit  their   total  available  capacity.
Market  shares,  therefore,  can also be  ranked  by available
capacity  for  individual  waste   types.  Facilityand  waste-
specific capacity utilization data,  however, are generally
not available.

    The commercial  incineration  market  is  being  viewed as
increasingly  competitive by  industry  sources.  This  in-
creased competitiveness  is  seen  as taking  two  forms:  cost
competitiveness of  thermal treatment  with  land  disposal,
and competition  among commercial  firms to  capture  larger
market shares.

    Thermal  treatment  of  liquid wastes  is becoming  more
cost competitive  with waste management technologies,  such
as landfills,  which have historically  enjoyed a  cost ad-
vantage.  Changes to the RCRA program in  recent years, and
those  expected  to  be  promulgated, are  seen  as  important
influences to  the narrowing  of  this historical,  up-front
cost differential.  The  Superfund  program  has  also brought
about  a narrowing  of  the  full  cost differential  between
landfills and  incineration, that is,  costs  including  con-
sideration of  potential long-term liabilities.  Incinera-
tion industry sources characterize the  Superfund program's
influence as leading their  customers  to "prefer"  incinera-
tion of their wastes  (liquid, solid, and  sludge)  as  a  less
risky alternative in terms  of potential long-term liabili-
ties.   This expected  preference  translates  into industry's
projections of a  broadened and   bullish market  for  commer-
cial incineration services, especially  in  light of assump-
tions that, on  the  margin, many generators  will  presently
choose  not  to expend  the  resources  necessary  to  have  a
fully  permitted  treatment/disposal  facility.   Industry
                          11-11

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sources do acknowledge, however, that  the  "lessons"  of the
Superfund program may induce some of  the  larger generators
to expend these the resources  in the  interest  of maintain-
ing full control over the disposition  of  their  wastes, and
may result in the additon or expansion of  on-site inciner-
ation capabilities.

    Expectations  for  a  growing  commercial  incineration
market also  present  the prospect of  increased  competition
among  existing  facilities.   Contacts  with  commercial in-
cineration firms  indicate  that  a  lead time  of three  to
five years must be  anticipated when seeking to  add  or ex-
pand  permitted  incineration  capacity  (11).    Such  lead
times, in fact, are  being  built into  their  plans  to bring
new  facilities  or  units  on-line.   Over   the  short  term,
this  leaves  existing  firms larger  and medium  sized firms
in  particular  with  finite  capacity  competing  with  each
other to capture their share of a growing  market.

6.  PRICES

    Many  of   the  competitive  influences  discussed  above
would tend to dictate high  per unit  prices for  incinerated
hazardous wastes.   Some waste  types do, in fact,  command a
premium.   Exhibit 6 shows,  however,  that per unit inciner-
ation prices actually vary  over a wide range.   Engineering
difficulties  in handling  the  waste  and its  emission prod-
ucts  once   burned,   and   the   degree-of-hazard  involved,
largely determine the  extent  of this  price  range (exclud-
ing transportation costs).  Other major price  determinants
include  the  revenues  received  from  energy recovery  (if
practiced) and the cost to  obtain higher  Btu-valued wastes
to burn  with lower  Btu-valued wastes.  This latter  "cost"
has become a more  significant factor  as  generators  retain
high Btu-valued wastes  to  reuse or  to  incinerate  (and re-
cover energy from)  on-site.

    In  the   LOHW  incineration  market, available  capacity
for  a particular waste type  can  influence prices.   For
example,   given  the  high demand  for  and limited  supply  of
PCB  incineration  capacity,  facilities permitted and not
permitted  to burn  the  higher  priced PCBs are  able  to
charge near  PCB prices  for  all other incinerable hazardous
wastes.   Generators  must  pay  this  higher  price  either  to
induce an incineration  firm to handle  a non-PCB waste in-
stead of PCBs, or because a non-PCB  permitted  facility can
command a higher  price in  the  face  of an increase  in the
demand for their  services.   Some of  the  major  facilities
with  the  greatest available capacity are almost  entirely
dedicated to handling  PCBs, leaving generators  of  non-PCB
wastes  to seek  out  medium-sized  and smaller  facilities
with less capacity.   Industry  sources  also report that the
                          11-12

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H
M
I
!-•
CO
                                               EXHIBIT 6
                              Comparison of Quoted  Prices for Nine Major
                                    Hazardous Waste Firms  in  1981
                                          By Waste Technology
                    WASTE
                 MANAGEMENT
                     TYPE
LANDFILL


LAND TREATMENT

INCINERATION
                CHEMICAL
                TREATMENT

                RESOURCE
                RECOVERY

                DEEP WELL
                INJECTION
                     WASTE
                   DESCRIPTION
DRUM
BULK

ALL

HI-BTU VALUE LIQUIDS :
LIQUIDS
SOLIDS, TOXIC LIQUIDS

ACIDS/ALKALINES
TOXICS/HEAVY METALS

ALL
               OILY WASTEWATER
               TOXIC RINSEWATER
                               PRICE IN DOLLARS PER GALLON
                                    1
                   TRANSPORTATION-$O.15/TON-MILE
                 Source:   (12)

-------
PCB market activity  is  so brisk as to create  two  to three
month-long backlogs  of  both PCBs and  non-PCB  wastes wait-
ing to be incinerated at  several  facilities (given current
practical operational maximums)(11) .

7.  BARRIERS TO MARKET ENTRY

    The ability  of incinerator firms  to enter  the  market
or  to  add/expand  available capacity  is a critical  issue
for  the  market   analysis.   Incineration  firms  contacted
indicated  that public  opposition  to and  regulatory  re-
quirements for permitting  hazardous  waste  incinerators may
mean a  three  to  five year  delay  before  a new  unit  is on-
line and  operational.   These  problems are  cited  as  major
impediments to market entry or expansion.

    Incineration  technology and  services  also require  a
substantial capital  investment.   Locations must be  chosen
and markets selected that  afford  a  reasonably  certain sup-
ply of  incinerable  wastes sufficient to  offset  that in-
vestment.  This creates a  business  risk  that  is considered
carefully by companies  planning  to  enter the  market  or  to
expand  their  market  posi-tion.  Large business risks  may
also figure in any delay  in market response  to a "ghost"
regulatory market until  these  regulatory  changes  become
more defined.

8.  FINANCIAL POSITION AND MARKET STRATEGIES

    Financial  data  are only  available   for   some of  the
larger,   multi-service,   waste  management  companies,  and
these data frequently fail  to  separate out  their  incinera-
tion operations.   Industry  sources  indicate that  incinera-
tion services  may  account  for  15-25 percent of total off-
site waste management revenues  (11).   This  share is  likely
to increase.

    A major market strategy of  the  last  three  years  in the
commercial waste  management industry  has  been  the  expan-
sion  of  capabilities  and/or  capacity   by  acquisitions.
While this  has been  an industry-wide trend,   it  has been
less visible in the  commercial incineration market.   There
have been some notable  exceptions,  among them  SCA  Chemical
Services'  acquisition   of  an   incinerator   in  Chicago,
Illinois,  and,  now, Waste Management  Inc.'s  successful
acquisition of  SCA.   These acquisitions do not result  in
any net change  in  industry-wide  capacity, but  they  can
introduce  new participants to  the  market,   and  lead  to
higher market prices.
                          11-14

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       III.   BASELINE  INCINERATION  SUPPLY AND DEMAND
    Baseline  capacity  utilization  estimates suggest  that
available on-site and commercial  incineration capacity for
LOHWs  is  not  fully  utilized.  Both on-site  and commercial
LOHW  incineration capacity  utilization may  range  anywhere
from  40 to 80 percent depending upon  the  quantity  of LOHWs
presently incinerated.   The lower  estimate  is based  upon
the  EPA's  analysis  of  waste handling data  from  the  1981
RIA  National  Survey applied to  independent estimates  of
on-site and  commercial  LOHW incineration capacity.*   The
higher  estimate  reflects   industry  suggestions  that  the
quantity of LOHWs incinerated is  higher  than  EPA's  esti-
mate,  and  that  commercial  capacity  utilization is  around
80 percent.   As a portion  of  the larger market,  industry
sources also  report  that  currently  permitted  commercial
incineration capacity for liquid PCBs  is fully utilized.

    In this section, market  profile information in Chapter
II is  used  to  develop  baselines  for  the regulatory  scen-
ario analyses.  Baseline estimates are developed for:

         Incineration of  LOHWs:  Current  On-Site  and  Com-
         mercial Capacity Utilization

         Incineration of  PCBs:  Quantities Incinerated  and
         Available Capacity

         Incineration   Demand:   Influence   of   Superfund
         Clean-Up Activities

         Incineration Demand: Quantities of  Wastes Managed
         in Landfills,  Injection  Wells,  Boilers  and  Dis-
         posal Impoundments.
    As of  this  writing,  EPA  staff  were still  involved  in
    an effort to use  the  RIA National Survey data  base  to
    develop estimates of commercial and  noncommercial  LOHW
    incineration  capacity.    Difficulties   encountered  in
    this effort have  included:  determination of  practical
    maximum  operating  hours  per  year;  interpretation  of
    design  feed  rate  capacities  as  expressed   in  mass
    units;   and  attempting  to  scale  up  a  small  survey
    sample of commercial  firms  to national  totals.  Given
    that this  analysis  is   incomplete,  the  market study
    relies on industry's  estimates  of commercial LOHW in-
    cineration  capacity as determined  through a series  of
    phone interviews with commercial  industry respresenta-
    tives.
                          III-l

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Detailed descriptions  of the  data  and assumptions  behind
these baseline  estimates are covered  in  Appendices A  and
B.  Highlighted  in  the following sections are  the results
of these baseline analyses,  and a description  of  a  sensi-
tivity analysis based on variations in the key assumptions.

    The range  of  possible outcomes in this  baseline anal-
ysis and the  scenarios  analysis in Chapter IV  must  be  em-
phasized.    Some  data   for  the  analyses  are  either  not
available and must be estimated, or different sources  lead
to estimates  that  differ and  cannot be  resolved.   Where
the data  have had to  be estimated,  the  reasonableness  of
these assumptions  has  been  confirmed, whenever  possible,
in discussions with EPA  staff  and  industry sources.   Where
sources differ in  their estimates,  a range  of  possible
estimates have  been  incorporated into a  sensitivity anal-
ysis.   In Appendix  C,  portions  of  the analysis  where  key
assumptions have been modified  in  the sensitivity analysis
are  indicated in the  logic diagrams (within  the dotted-
line boxes).   Appendix D presents  additional  data  on  the
sensitivity analysis itself.

1.  INCINERATION OF LOHWs;  CURRENT ON-SITE  AND COMMERCIAL
    CAPACITY UTILIZATION

    Baseline  commercial  LOHW  incineration capacity  utili-
zation, based upon RIA National  Survey  estimates  of  the
quantity of LOHWs incinerated,  is estimated  to be 37  per-
cent.  Discussions with  commercial  incineration firms  sug-
gest that  LOHW incineration capacity  utilization (includ-
ing  for PCBs)  is closer  to  80 percent  with  liquid  PCB
incineration  capacity   utilization  (as  a portion  of  the
total LOHW  market)  at  near 100 percent.   Impressions  of
noncommercial  LOHW  incineration  capacity utilization  are
not as firm, but generally range from 20 to 60  percent.

    As  shown  in Exhibit 7, estimates  of  commercial incin-
eration capacity utilization for LOHWs range  from 37 to 74
percent.  Noncommercial or  on-site LOHW  incineration  ca-
pacity  utilization  is  shown to range from  27  to 54  per-
cent.  The  estimates  of the lower end of  these ranges  are
based upon:

         An estimated 0.8 MMT  of LOHWs incinerated  on-site
         against  3.1 MMT of available on-site  LOHW incin-
         erator capacity
                           III-2

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                                                     EXHIBIT  7
                               Estimated Baseline LOHW Incineration  Capacity
                                           Utilization—Mid-Range  Casea
                                                  ESTIMATED DEMAND
       TOTAL QUANTITY OF
       LOHWs INCINCERATED
ONSITE/OFFSITE
  SPLITS
 TOTAL QUANTITY
 INCINERATED ONSITE
TOTAL QUANTITY
INCINERATED OFFSITE
             1.392
       million metric tons/yr
   90% onsite
   10% offsite
      1.253
million metric tons/yr
      0.139
million metric tons/yr
                                                 ESTIMATED CAPACITY
M
M
I
       TOTAL  LOHW
       INCINERATION CAPACITY
ONSITE/OFFSITE
   SPLITS
 TOTAL ONSITE LOHW
 INCINERATION CAPACITY
NET TOTAL OFFSITE LOWH
INCINERATION CAPACITY
              3.4
        million metric tons/yr
 91.2%  onsite
  8.8%  offsite
      3.1
million metric tons/yr
0.30 - 0.048b = 0.252
million metric tons/yr
                                                                                CAPACITY UTILIZATION
      a)  See  also Appendix c

      b)  Amount of capacity estimated to  be devoted
         solely to incineration of liquid PCBs
                                                                      Onsite
                                                                        40%
                                                             Offsite
                                                               55%

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         An  estimated  0.09  MMT  of  LOHWs   incinerated  at
         commercial facilities  against  0.252 MMT of avail-
         able  "net"  commercial LOHW  incineration capacity
         (where  net  capacity equals  total  commercial LOHW
         capacity  (0.3  MMT)  minus  PCB  incineration capac-
         ity  (0.048 MMT)).

These estimates  of the  quantity of  LOHWs incinerated pres-
ently on-site and off-site  are derived  from the  RIA  Na-
tional Survey  estimate  of  0.9 MMT  of LOHWs incinerated in
1981 and the  assumption that  90  percent of  LOHWs  are  in-
cinerated on-site.   Alternatively,  industry  source's sug-
gestion that  commercial LOHW  incineration  capacity utili-
zation  is  closer  to  80  percent  would  indicate that  the
quantity of LOHWs  incinerated may  be as high as 1.86  MMT
against a "net"  available  capacity  of 0.252  MMT.   This is
shown in Exhibit 7 as  the high range estimate of  74 per-
cent commercial  capacity  utilization.   Given these  bounds,
therefore,  a  most likely  estimate  of commercial  capacity
utilization for  LOHWs may be  about  55 percent (i.e., quan-
tity of LOHWs incinerated = 1.4 MMT).

    There are varying degrees  of  confidence in the  reason-
ableness of these  estimates.   On  the demand  side,  the  RIA
National Survey  estimate  of  0.9 MMT  of  LOHW's incinerated
is subject to two  sources of  uncertainty.   First,  there is
some question as to whether  the list  of  LOHWs developed by
the EPA  (see  Appendix  A) may lead  to  overestimating  or
underestimating  the  total quantity of   LOHWs incinerated.
Second,   there are  numerous  uncertainties   in the  survey
data itself,   that  is, the confidence  bands  associated with
the waste  quantity  data  are  quite  large.   Finally,  the
base year  for the Survey is  1981;  current  quantities  of
LOHWs incinerated  are  likely  to be  higher.   Discussions
with industry sources indicate  that their estimate  of near
80  percent  capacity  utilization reflects   such  a  higher
estimate of demand.

    There seems  to be,  however, some reasonable  agreement
between industry sources  and the RIA National Survey data
as to the 90  percent on-site  and  10 percent off-site split
of the  total  LOHWs incinerated.  Analyses  of the  data  on
total LOHW quantities  provided by  OSW  indicate a  93 per-
cent on-site  versus 7 percent  off-site  split (see Appendix
B).  Industry  sources  confirmed a  90 percent on-site  and
10 percent  off-site distribution as  reasonable.*
*   It  should  be  pointed out  that  current  knowledge  of
    on-site  or  noncommercial   incineration   activity  is
    based more on  speculation or extrapolation  of  limited
    data rather than on extensive quantitative information.
                           III-4

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    The  reasonableness  of  total existing on-site  and com-
mercial  LOHW incineration  capacity estimates  is hard  to
judge.   The  3.4  MMT  of total  LOHW  incineration  capacity
represents  a modified  estimate  from Mitre's  study  (3) ,
drawing  upon practical  maximum  operational  characteristics
for commercial  incinerators.   Mitre's data  on  incinerator
hourly throughput  indicated a median value  of  595 gallons
per hour  from  a census/survey of  209  incineration facili-
ties.  Conversations with  commercial  incinerator  operators
indicated that  as  a practical maximum, their units  run  24
hours per day  for  300  days per year  (i.e.,  7200  hours per
year or 82 percent of  all the hours in one year).*

    The  91 percent on-site and 9  percent off-site distri-
bution of this  total  3.4 MMT of  incineration capacity for
LOHWs is an  assumption  derived  from fixing  current commer-
cial incineration capacity  for  LOHWs  (including  for  liquid
PCBs)  at 0.3 MMT.  This commercial  incineration  capacity
figure is a  rounded estimate of  capacity totals  suggested
by  some  industry  sources  following their  three-tier  view
of  capacity  as  shown   in  Exhibit  8.   In  total,  industry
sources  place   available commercial incineration  capacity
for LOHWs between 0.250 and 0.285 MMT.

    It should be noted,  however,  that  given the preference
of  expressing  incineration capacity as a heat  release ca-
pacity,   these  capacity  estimates  expressed in mass  units
should be interpreted  cautiously.  Industry sources  asked
to estimate commercial  incineration capacity for  LOHWs had
to  make  a variety of  judgments based on their  individual
experience and  expertise.   For  example,  conversion  of  an
incinerator's  heat release  capacity  rating into  a  mass
throughput  requires  knowing  the   heating  values  of  the
waste streams burned (and other characteristics  that affect
    Industry sources  report  that 80  to  85 percent  of  the
    hours in a year can be considered as  a practical maxi-
    mum under conditions of  sufficient demand  and assuming
    otherwise   maximum  operational   performance.    This
    translates  into  an estimated downtime period for  re-
    pairs  and   replacement  of  30  days   per  year  plus  a
    buffer  of  at  least  3  days  per month to account  for
    electrical  outages,  re-start  time,  sub-optimal  per-
    formance conditions, bad weather, and the  like.   Prac-
    tical maximums of 90 to  95 percent of the  hours  in  any
    one to  two  month period may be possible  when  burning
    easily handled, "clean"  liquids.
                           III-5

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                               EXHIBIT 8
           Commercial Incineration Capacity  For Liquid
                      Organic Hazardous Wastes
Commercial Incineration
Firms By Size Class
 Average Annual
 Capacity For
Hazardous Wastes
(Metric Tons/Yr)
Average Annual Capacity
   For Liquid Organic
   Hazardous  Wastes
    (Metric Tons/Yr)
First Tier Firms

  Largest 3 Firms
  (5 Incinerator Units)

Second Tier Firms

  2 Mid-Size Firms
  (2 Incinerator Units)

Third Tier Firms

  About 25 Smaller Firms
  (25 Incinerator Units)
       Total All Firms
      0.159a
    0.032-0.036C
      0.113e
    0.304-0.308
       0.032-0.036d
           0.113d
       0.256-0.260
a)  Assumes  a capacity of 70 million Ibs. per year per  unit.
b)  Assumes  30 percent of total capacity for solids,  70 percent for
    liquids  per unit.
c)  Assumes  a capacity of 35-40 million Ibs. per year per unit.
d)  Assumes  all of  total capacity is for liquids.
e)  Assumes  an average capacity of 10 million Ibs. per  year per unit.
                                III-6

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the  combustibility  of  the  waste   or   handling  of  the
combusion  products).   A rotary  kiln  rated at  120  million
Btu  per  hour can  burn  15,000 Ibs per  hour of  a 8000 Btu
per  pound  waste opposed to only  10,000  Ibs per  hour  of a
12,000 Btu per pound waste.   If supplemental  fuel  is re-
quired  to support  combustion of  a  low  Btu-value  waste,
however,  less  throughput of  the waste  (in mass terms) can
be achieved.   When asked to  estimate  commercial incinera-
tion capacity  in metric  tons  per  year,  therefore, industry
sources  were told  to  assume  an average  waste  given the
types of wastes they handle.

    Industry  sources  questioned also  had to consider the
physical  form  (i.e.,  liquid,  solid,  or  sludge)  of  the
waste streams burned at  their facilities, especially those
facilities with  rotary  kiln units.   Rotary kilns can burn
a  combination  of  liquid,   solid,  or  sludge-type  wastes.
This means that their capacity  for  liquids is  not  exclu-
sive of  their  capacity  for  other waste  types,  that  is,  if
fewer solids  are  burned,  there is more  capacity available
to burn  liquids.  Industry  sources  were  told,  therefore,
to  assume their  current  waste  feed mix in  calculating
their current  capacity  to  burn LOHWs.   Chapter  V examines
how  changes  in the waste feed  mix (reflecting  changes  in
demand)  could change the estimate of  availabale commercial
incineration capacity for LOHWs.

2.  INCINERATION  OF  PCBS;   QUANTITIES  INCINERATED  AND
    AVAILABLE CAPACITY

    As a  special regulatory  topic and  area of commercial
incineration  industry  activity,  the  incineration of  PCBs
was  examined  as  a  separate  market analysis module.   Esti-
mates of  liquid PCB quantities  incinerated and available
capacity were  developed.  Data  sources  included the  July,
1982, PCB  Use Rule RIA  (13), permit  information supplied
by the EPA,  the February,  1982,  EEI/USWAG report on PCBs
(14), and discussions with  industry contacts (11).

    Permit information  provided by  the  Office  of  Pesti-
cides and  Toxic Substances  in May,  1984, indicated  that
the  four  commercial incinerators permitted to  burn  PCBs*
have  a  combined  annual capacity of 57,415  metric  tons
(0.057 MMT) of PCBs.  This  was confirmed by industry
 *  These incinerators are  owned and operated by  ENSCO in
    Arkansas, Rollins Environmental  Services  in  Texas,  SCA
    Chemical Services in Illinois  (now owned  by  Waste Man-
    agement, Inc.), and General Electric in Massachusetts.
                          III-7

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sources  (11).*   For  this  market analysis,  3,673  metric
tons  of  likely captive  capacity  (the  General  Electric
facility) was not  counted  leaving a  net  available  annual
capacity  of  53,742 metric  tons.  Ninety  percent of  this
figure,  or  48,368  metric  tons,  was  assumed  to  be  liquid
PCB incineration capacity.

    Industry sources indicate that commercial  PCB inciner-
ators are operating currently at  or near full  capacity for
PCBs.**   This  assumption  of  100  percent  capacity  utili-
zation  was  incorporated  into  the PCB incineration  anal-
ysis,  that  is,  the baseline  total volume  of   liquid  PCBs
incinerated was set at  a  figure equal  to  the  estimated
liquid PCBs capacity,  or 48,368  metric  tons.

    At an assumed 184 gallons/metric ton,  this  48 thousand
metric tons of  capacity  equates  to a total of  8.9 million
gallons  of  liquid PCBs.   It is  assumed,  therefore,  that
the volumes of  liquid PCBs  originating from  the phaseout
of PCB capacitors and askarel transformers, the failure of
PCB-contaminated mineral  oil  transformers, and  past  stor-
age  (so-called  carryover  volumes)  of  liquid   PCBs  should
equal  a  total  of  8.9 million  gallons.   Discussions  with
PCB incineration firms  indicate,  however,  that  demand for
liquid  PCB incineration capacity  actually  exceeds  cur-
rent capacity  for PCBs as reflected in  two to  three month
 *  Questions of  how to  define  incineration capacity  for
    PCBs were raised  by industry sources  contacted.   Some
    felt that the capacity estimates  expressed as a  mass
    throughput should  include  not only  the PCBs,  but  the
    PCB-contaminated  fluids  or  products  as  well.   Given
    their   estimate  that   for   every    pound  of   PCB-
    contaminated  fluid  burned that  15  to 20  percent  are
    PCBs, the capacity estimates shown in  Appendix  C  would
    be  five  to  six  times greater than  shown.    The  esti-
    mates used, however,  reflect only the PCBs  and  these
    estimates appear reasonable given the  15  to 20  percent
    rule-of-thumb.  Wastes  burned with  the PCBs are  con-
    sidered not part of the capacity for  PCBs.

**  As used here,  full capacity  refers to  a maximum capac-
    ity  industry  defines  on  the basis  of current opera-
    tional performance  that,  in some  cases,  is  not  opti-
    mal,  and on  the   basis  of  permit   limits  that  are
    subject  to  change.   This  does  not  mean  that  these
    incinerators  are operating  at  100  percent  of  their
    rated capacity for all wastes.
                           III-8

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backlogs  for  handling  these  wastes.   No  data could  be
assembled,  however  to  quantify  this  reported  excess  of
demand.

    The  complete  PCB module  is  presented in Appendix  C.
The module  estimates both the quantities  of  -PCBs  inciner-
ated  (i.e.,  demand)  and  available  commercial incineration
capacity  for  PCBs (i.e.,  supply).  The  demand  analysis  is
presented  in keeping with  the  demand  versus supply  sym-
metry of  the  other  modules,  however,  it is  not  a  critical
analysis  for  the  remainder of  the market  assessment.   In
fact, as  noted  below and  in Appendix C, there  are  consid-
erable uncertainties to the demand analysis.

    The supply or capacity  analysis,  however, is important
to the overall market assessment.   The  estimate  of  commer-
cial  incineration capacity  for   liquid  PCBs derived  from
this module  is subtracted from the  total commercial incin-
eration capacity  figure  to  generate a  net capacity figure
for all  other LOHWs.  This  net  capacity  figure includes,
therefore,  capacity  used to  burn everything else,  except
the PCBs  themselves, including  the fluids  contaminated  by
the PCBs.

    The key data  and assumptions  from the  PCB module anal-
ysis  are  summarized  in  Exhibit  9.   Data  in the  PCB  Use
Rule RIA and the EEI/USWAG reports provided:

         Estimates  of  the  total  amount of  PCB-containing
         fluids  (plus  solvent  rinse)   from  the mandatory
         phaseout  of PCB capacitors   and  askarel  trans-
         formers  (3.2 million gallons)

         The  total  volume of  PCB-contaminated  fluids  re-
         moved  from failed mineral oil transformer  units
          (34.7 million gallons).

All of the PCB-containing fluids  were assumed to have PCBs
in excess of  500  ppm, while only 1.1  percent of the  PCB-
contaminated  fluids  contained PCBs above  that  concentra-
tion.  All  this  volume must  be   incinerated  under  current
regulations.   An  additional  11.8  percent  of  the  PCB-
contaminated fluids  were  assumed  to contain  50  to  500  ppm
PCBs.  Of this volume, 90 percent was assumed to be incin-
erated with  the  remainder sent to  landfills  and/or treat-
ment facilities.

    From  PCB  capacitors,  askarel transformers,  and failed
mineral oil  transformers,  therefore,  a  total of 7.3  mil-
lion gallons  of  PCB fluids  is estimated  to be available
annually for incineration.  This  left a difference of 1.6
                          III-9

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                                                      EXHIBIT 9
                             Estimated  Incineration  Capacity Utilization  For PCBsa
                                                   ESTIMATED DEMAND
        TOTAL QUANTITY
        OF PCB FLUIDS
PERCENT CONTAINING
<500 ppm, PCBs
PERCENT CONTAINING
>500 ppm PCBs
  PERCENT
INCINERATED
TOTAL QUANTITY
 INCINERATED
I
(-•
o
        use phaseout  of
      PCB cagacitors/askarel  trans-
       formers
3,196.118 gallons 100% 100% 3, 196,118
replacement/failure of
contaminated mineral oil
transformers
34,726,852 gallons 1.1% 100% 381,995
11.8% 90% 3,687,992
carryover volumes from
storage
1,633,607 gallonsb 100% 100% 1,C33,607


48.368
metric
tons/yr
@ 184
gal/MT
                                                  ESTIMATED CAPACITY
        TOTAL PCB  INCINERATION
            CAPACITY
  TOTAL COMMERCIAL PCB
  INCINERATION CAPACITY
        PERCENT OF
        CAPACITY FOR LIQUIDS
             TOTAL CAPACITY
             FOR LIQUIDS PCBs
            57,415
       metric  tons  PCB  fluid/yr
        53,742
metric tons  PCB  fluid/year
                                                                       90%
                                       48,368
                                  metric tons PCB fluid/yr
                                                                                     CAPACITY UTILIZATION
                                                                                                  100%*-
     a)  See also Appendix C.
     b)  With industry sources indicating  at or near 100 percent capacity utilization for PCBs,  carryover volume  determined
         determined from difference of  estimated capacity minus estimated demand from use phaseout  of  PCB capacitors/
         transformers and replacement/failure of mineral oil transformers.
     c)  Determined from conversations  with industry sources.  Used to establish total estimated demand.

-------
million gallons  from the 100 percent  capacity utilization
estimate of 8.9 million  gallons.   Lacking another suitable
estimate,  this  additional  1.6 million gallons  was assumed
to come out of the volume of liquid PCBs in storage.

    Perhaps the  most uncertain  assumptions in  this  anal-
ysis are those on  the rate  of use  phaseout for PCB capaci-
tors and  askarel transformers  (and  the PCB  fluid volumes
that result).   Phaseout  rates used  in EPA's  reports (and
used here) have been criticized  as not taking  into account
the  accelerated  voluntary   phaseout   of   these  equipment.
Industry sources consulted  indicate that  the phaseout rate
ij» higher  than has  been predicted due to these voluntary
programs.  These  sources argue  that the  PCB fluids volume
may  be two to three times greater than the  3.2 million
gallons  estimated  from  the  1982  PCB Use  Rule  RIA data
(13).  If  so,  and assuming  near full  use  of available PCB
incineration  capacity,   this  would   indicate  that  large
quantities of PCB  fluids are  in  storage awaiting handling,
and that PCB  incineration demand greatly  exceeds available
incineration capacity at least  for the next three to four
years.*

    Commercial  incineration firms  stress  the  major  influ-
ence  of  PCB   incineration  demand  towards  higher  market
prices and less capacity available  for non-PCB incinerable
liquid wastes.  Over the short-term, this  large demand may
dictate  the  ability of  the  incineration industry to re-
spond  (as  well as  the  cost to  generators)  to  added LOHW
volumes brought  about  by regulatory change.   Better  esti-
mates of this  demand are needed.

3.  INCINERATION DEMAND;   INFLUENCE  OF SUPERFUND CLEAN-UP
    ACTIVITIES

    In recent months, there has  been  considerable interest
in looking at  how Superfund activities,  both  removals and
remedial cleanups, may affect RCRA waste  management capac-
ity.   How  large on influence these activities  may have  on
commercial incineration  capacity is  the subject  of  a mod-
ule for this market analysis.

    No estimate of  total quantities  of waste  sent to RCRA
facilities from  Superfund  removal and  remedial  sites  is
directly available.  The data exists,  but  the  data base  is
fragmented, distributed  across   several  sources,  and fre-
quently lacks  the detail needed  for a market analysis.
    Chapter IV also discusses  projections  of PCB incinera-
    tion demand, and examines  possible  increases in incin-
    eration capacity for liquid PCBs.
                          III-ll

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Quantities of  wastes  sent  off-site may  be  recorded,  for
example,  but  little  information is  available  as  to  the
specific composition of these wastes.   In  other  cases,  the
quantity information may be very sketchy.

    Currently,   there  are  efforts to  compile  and  evaluate
the available data.   Some preliminary  estimates do  exist.
Data compiled  by Booz, Allen  for  30  remedial  sites,  for
example,  indicate that 178,000  metric  tons  of wastes  were
excavated and sent off-site for  disposal  in landfills.   If
as  much as 15  percent of  these wastes   were incinerable
liquids,  these  volumes,  if  incinerated,  would  utilize  11
percent of commercial incineration  capacity  available  na-
tionwide, perhaps more on a regional  basis.  How much  of
these  wastes  were  liquids  and  incinerable  or  how  much
waste  from  these  sites  was  sent  off-site  for  treatment
(including incineration)  is  not known.   Even less is  di-
rectly  known  about  quantities  of  incinerable wastes  sent
off-site for  handling from removal sites.

    What  may  happen from  future Superfund  activities  is,
of course, difficult to estimate, but  given current  trends
the  waste quantities  may be  quite  large.   Few  remedial
sites have been  completed,  for  example, and  the number  of
National  Priorities  List  sites  is  growing.   Estimates  of
the  potential  number  of  hazardous  waste  sites range  as
high as 20,000.  As yet,  commercial  incineration firms and
waste  management firms as  a whole  report  little  overall
impact  on capacity  from receipt of Superfund wastes  (10) .
On  a  seasonal  basis,  management  of Superfund wastes  does
occasionally   lead  to  delays   in  handling  non-Superfund
wastes, as Superfund  responses  tend to be concentrated  in
the months of  May through  October.   These  firms  comment,
however,  that  if Superfund  responses  are  accelerated  and
spread  out throughout the year,  and  if land disposal  re-
strictions and  regulations for  the management  of  dioxin-
contaminated  wastes  are enacted, then  available incinera-
tion capacity  for Superfund  wastes may  be  a significant
concern.

4.  INCINERATION  DEMAND;   BASELINE  WASTE  QUANTITIES  MAN-
    AGED  IN  LANDFILLS, INJECTION WELLS,  BOILERS AND  DIS-
    POSAL IMPOUNDMENTS

    Each  of the regulatory amendments  analyzed  in  Chapter
IV  is  built  upon baseline  estimates   of  the quantity  of
hazardous wastes managed, on-site  and off-site, in  land-
fills,  boilers,  injection wells,  and disposal  impound-
ments.  It is  these baseline conditions  that are  expected
to  shift  as  regulatory changes  move   LOHWs  out of  these
technologies  to incineration.    Both  on-site  and  off-site
baseline  conditions  must  be  estimated as  generators  may
elect  to  increase or  reduce  their on-site waste  management
activities in response to these regulatory changes.

                          111-12

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    Exhibit  10 shows  the baseline  mid-,  low-,  and high-
range  estimates  calculated for wastes managed  on-site and
off-site  by  technology.   The  starting  points  for  these
estimates are  the  RIA National Survey estimate of 264 MMT
of  wastes generated  in  1981  (2)  and  preliminary results
from the EPA's Boiler Survey (15).  RIA National Survey
 data  were also used to calculate  what percentage of  all was
tes generated  were managed in  landfills  (1.2%),  injection
wells  (12.1%), and disposal impoundments (7.2%).

    The  key  assumption in  these  baseline calculations is
the on-site  and off-site  distribution  of the  wastes man-
aged by  technology.   For  the baseline  estimates of  wastes
injected  in  wells  or  disposed  in  impoundments, the  on-
site/off-site  split is derived from  an  analysis of data
drawn  from  the RIA  National  Survey  (see  Appendix  B) .
These  splits  do   not  vary  across  the  three  sensitivity
analysis  cases  as  no other sources  offered  an  alternative
distribution  (i.e.,  the   sensitivity analysis cases  for
these  two scenarios  reflect  variations  in  other assump-
tions)  .   The  on-site/off-site  split  does  vary  across  the
low-,   mid-,  and  high-range estimate  cases for  wastes man-
aged in  landfills.   The  low-range case distribution of 43
percent  on-site  and  57  percent  off-site  is derived from
the analysis  of the RIA  National Survey data.   The high-
range  case  of 16  percent on-site and 84  percent off-site
reflects a comparison  of  the  3.2  MMT of wastes managed in
landfills in 1981  according to  the  Survey  with  independent
estimates that  2.7 MMT of  wastes were managed in commer-
cial landfills  in  1980  (7,  12,  16).   The mid-range case
represents  an  average case  relative  to  these  possible
upper   and lower bounds.   All  three  sensitivity  analysis
cases   become  baselines,  therefore,  against  which the  in-
cremental change  in demand due to RCRA  regulatory  change
can be measured.   These  possible  incremental   changes  in
the demand  for incineration capacity  are  examined  in  the
next chapter.
                          111-13

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                                                      EXHIBIT 10
                    Baseline Mid-Range  Estimates Of  Hazardous Wastes  Landfilled,  Injected
                                  Into  Wells,  Disposed In  Surface  Impoundments3
    TOTAL QUANTITY
    OF WASTES
    GENERATED
                    PERCENT OF WASTES
                    GENERATED GOING TO:
                      TOTAL QUANTITY
                      OF WASTES:
                 ONSITE/OFFSITE
                    SPLITS
                TOTAL QUANTITY
                OF ONSITE WASTES:
                      TOTAL QUANTITY
                      OF OFFSITE
                      WASTES:
                                                      LANDFILLS
       264
    million metric
    tons/yr
                        1.2%
                        3.2
                      million metric
                      tons/yr
                     30% onsite
                     70% offsite
                   0.95
                million metric
                tons/yr
                         2.22
                     million metric
                     tons/yr
i
i-1
*>•
   264
million metric
tons/yr
12.1%
                                                   INJECTION WELLS
  31.9
million metric
tons/yr
97.5% onsite
 2.5% offsite
  31.1
million metric
tons/yr
   0.8
million metric
tons/yr
                                                DISPOSAL IMPOUNDMENTS
       264
     million metric
     tons/yr
                        7.2%
                        19
                      million metric
                      tons/yr
                     95% onsite
                      5% offsite
                  18.06
                million metric
                tons/yr
                        0.95
                     million metric
                     tons/yr
   a)  See also Appendix C

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    IV.  PROJECTED CHANGES IN INCINERATION DEMAND AND
          CAPACITY UTILIZATION
    On-site  and  off-site  incineration  demand  is  expected
to increase  even  in  the absence of  the  regulatory changes
to RCRA  the EPA  expects  to  implement.   If the land  dis-
posal  restrictions,  and  other  regulatory amendments  are
implemented, however,  the shift  of  LOHWs  to  incineration
is projected to  be even  greater.   How much  greater  these
shifts could be,  over  the very short-term, with and  with-
out  anticipated  changes  to  the  RCRA  regulations is  the
subject of this chapter.

1.  PROJECTED INCINERATION DEMAND WITHOUT REGULATORY CHANGE

    Commercial incineration  firms  forecast a  growing  mar-
ket for their  services  over  the next three to five years,
even if the  current RCRA  regulations  are  not  modified  sub-
stantially.  Their  reasoning  is  fairly  consistent across
larger and  smaller  firms  and  whether or  not  incineration
is their  sole  service  or  one of several  waste treatment/
disposal  services.   These firms  cite several  factors  be-
hind their short-term projections:

         Increasing demand for PCB incineration capacity

         Slowed commercialization of  alternative  technolo-
         gies

         Questionable  responsiveness  of  "available"   on-
         site incineration capacity

         Declining landfill capacity

         Increased   Superfund  clean-up   activities   and
         Superfund policies that encourage incineration

         Generators'  increasing liability concerns.

Generally,  these  factors  are  seen  to increase the short-
term demand  for  incineration  services  by anywhere from  5
to 20 percent.  All things being  equal,  incineration  firms
seem  to   feel  that  present   unused   incineration  capacity
nationwide  and the  expected  growth  in  capacity   will  be
able to  handle this demand.   Several firms hint  that  re-
gional capacity,  particularly  in the  West and  Midwest,  may
be a problem* but they  provide few  specifics  (i.e., little
quantification) behind their hy- pothesis.
                           IV-1

-------
    Longer-term market forecasts in the  absence  of regula-
tory changes are less definitive.   PCB  incineration demand
(for fluids containing more  than  500  ppm PCBs)  is  seen to
decline as  the  mandatory  phase-out deadlines  are  reached.
Competition from alternative  innovative  technologies (both
thermal and non-thermal)  is  considered hard to  judge  five
to ten years out.  Similarly, there are  significant uncer-
tainties to how successful  generators will be  in  reducing
waste generation, or  to  how big a  move  there  might be to
increased on-site incineration of  liquid wastes.

    Each of these  factors are  discussed generally  in  the
following sections.

    (1)   Demand for  PCB Incineration Capacity

         Commercial   firms permitted  to  burn  PCBs  see  a
    large,   but  short-term  growth  potential  for  inciner-
    ating PCB -  contaminated products with PCBs in excess
    of 500  ppm.   These products would  be fluids  from  PCB
    capacitors  (as  well  as  the  capacitors  themselves  in
    some cases) and  askarel  transformers that must  be  in-
    cinerated   under  the  current  regulatory  framework.
    Most believe that EPA's estimates of  the PCB phase-out
    volumes to  be handled  as  too  low.   these  firms  see
    users of PCB-containing  equipment  greatly  accelerating
    their  phase-out   of   equipment  voluntarily  above  the
    minimum rate necessary   to  meet  the  mandated  dead-
    lines.   This  accelerated  phase-out  rate  means,  how-
    ever,  that  this  market  is expected  to remain  strong
    for  only  another  three  to  four   years.   Whether  the
    market  continues  to  be  strong beyond  that point  is
    seen to depend  on how owners of  PCB-containing equip-
    ment with   PCBs  in the  50  to 500  ppm  concentration
    range  choose  to  handle  these  PCB  fluids,  and  which
    treatment/disposal options  remain  open to  them.   If
    restrictions  on   burning  hazardous  wastes  in  boilers
    act to  limit  the practice  of  burning these fluids in
    industrial/utility boilers,  and/or  if  PCBs are  pro-
    hibited from  landfills,   then  the incineration  market
    for  PCBs  may  remain fairly  strong  for  the  next  25
    years according  to some  industry projections.
    The reasons  behind  possible shortfalls in  capacity  in
    these two  regions  differ.  In  the  West,  the  issue  is
    apparently few  commercial facilities.  In  the Midwest
    the demand for PCB  incineration  is  seen to  be  so great
    as to limit  the availability of capacity  for  non-PCB,
    liquid wastes.
                           IV-2

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 (2)   Availability  of On-site Capacity

      Whether  the  demand  for   commercial   incineration
 services  grows  may  depend  upon the  availability and
 expandability  of  on-site  incineration  capacity.   Few
 sources  reviewed  for  this study,  however,  could pro-
 vide  a definite fix on  available on-site  incineration
 capacity  for LOHWs.   Based upon  the  data available,
 current on-site  capacity utilization may range from 27
 to  54 percent.   While  there  may be capacity available,
 how the  remaining capacity is  distributed regionally
 and whether the operating economics  and size  of  these
 on-site   incinerators  preclude  increased  use  is un-
 known.   There are simply not  enough data  on on-site
 capacity  to resolve these  unknowns.

      Whatever  the current utilization  of  on-site in-
 cineration  capacity,  however,   many  commercial   firms
 believe  that few  generators can  and/or desire  to  go
 through  the regulatory  process to  permit  greater use
 of  their  existing capacity or  to  expand  that capac-
 ity.   Many  of   the  commercial  firms  cite regulatory
 complexity,  costs, and  delays  as a  critical  limit  on
 their ability  to  expand  services.  They  stress that
 these problems  may be  more  limiting  for  a generator,
 particularly  the smaller to mid-size generators.  This
 hesitancy,   however,   could  be   countered  over  the
 longer-term by  a  generator's  increasing concerns over
 the  potential   liabilities  associated  with   off-site
 treatment/disposal.

      How  a  particular  generator  will balance   these
 issues  either in  favor  of or  against on-site manage-
 ment  of  its wastes is not easy to predict.   Available
 resources (includes  having an  existing site), corpor-
 ate philosophy  and image,  and  the type of operation or
 business  will  all influence  that  choice.   For  some
 generators,  like  some  major  chemical  companies, on-
 site  waste  management  will be  seen as a natural exten-
 sion  of  their  capabilities  and  experience,  and  these
 will  be the resources  available to  construct the ne-
 cessary  program and  facilities.   Other  chemical com-
panies  may  share  the  same corporate  philosophies and
 basic expertise,  but  the  variety  of  their production
 lines and,  therefore,  their  wastes may preclude build-
 ing sufficient  capacity.  In  these cases, their option
 would be  to  scrutinize  commercial  waste  management
 facilities  carefully  against  specified acceptance cri-
 teria.  This  practice  can be seen  at  work  in  the com-
 mercial waste management  industry.   Still  other  major
 waste  generating   industries   (e.g.,  the  automobile
 industry)  may  not have  the  requisite  experience  or
                       IV-3

-------
interest in  developing  on-site waste  management  capa-
bilities, and  will also  elect to  care- fully  select
commercial waste management services.

     Such  considerations   are  also  important  in  the
analyses to  follow in  the next  section on  projected
demand for incineration capacity  under each regulatory
scenario.  In  each scenario,  there  is an  assumption
that  the  incinerable  fraction of the  wastes  affected
by  the  restrictions may  move on-site or   off-site  in
order to be  incinerated.   Most of the  wastes  (95  per-
cent) originally  being managed  at commercial  facili-
ties are assumed to remain at  commercial facilities  to
be  incinerated,  while  the majority of the wastes  (60
percent) originally  managed on-site  move   off-site  to
be  incinerated  at  commercial  facilities.   This  latter
assumption reflects the judgment  that/ on  the  margin,
most generators will elect to have commercial  facili-
ties incinerate their  wastes.

(3)  Commercialization  of  Alternative  Technologies

     There are  several alternative* thermal waste man-
agement  technologies  that  are options  to  both  land-
based   incineration  and   at-sea   incineration.    How
quickly  these  technologies break into  the  commercial
waste management market,  become  permitted,  and  estab-
lish  sufficient capacity  are the  principal  determi-
nants of their competitive threat.

     The "commercialization  rate" for  emerging  alter-
native  thermal  technologies  was  the subject of  a sep-
arate study by  the EPA's Office of  Research and  Devel-
opment  (ORD)  (17).  Over 50 processes  were  reviewed  by
ORD; of these,  20 were reviewed in  detail.   Only  11  of
the 20 were  rated usable to treat or  destroy  the LOHWs
of  concern  in  the  market  study  (see  Exhibit  11) .
These  11  processes  were  considered  to   offer  the
"greatest  relative  potential  to  affect waste  manage-
ment practices over the next five years."
As differentiated  from conventional  incineration pro-
cesses.
                       IV-4

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                                                      EXHIBIT 11
                              Alternative  Thermal  Technologies  Judged Suited
                                  To  "Destroy" Liquid Organic Wastestreams
     THERMAL/PYROLYTIC TECHNOLOGY
                                                                       LIQUID ORGANIC WASTESTREAMS8
                                             D001
D002
D003
F001
                                                                         F003
F005
K049
                                         K051
                                          U122
                                                                                                            PCB
                                                ASKARELS
  HIGH TEMPERATURE FLUID WALL

  MOLTEN SALT

  WET AIR OXIDATION

  PLASMA ARC

  ROTARY PYROLYZER

  LOW TEMPERATURE FLUID WALL

  ADVANCED ELECTRIC REACTORS

  CATALYTIC DEHALOGENATION

  HIGH TEMPERATURE PYROLYSIS

  THERMAL PLASMA PROCESS

  CORONA GLOW  PROCESS

  FLUID PHASE  OXIDATION

  CIRCULATING  BED INCINERATION

  AQUEOUS PHASE ALKALINE

  MOLTEN GLASS INCINERATION

  FLUID BED (POWER RECOVERY)

  SUPERCRITICAL WATER

  CATALYZED WET OXIDATION

  MICROWAVE PLASMA
  Waste types selected as "representative" by ORD.
SOURCE:  (20)
                                               "Destroys"  waste

                                               "Destroys"  waste in
                                               aqueous solutions

-------
      While the draft ORD  report did not  forecast  com-
 mercialization rates per  se, some  statements on  com-
 mercial availability were made.   Many of  the  processes
 discussed  "are  or   will   soon   be   available  commer-
 cially."   None of them,  however,  were considered  able
 to significantly  "affect the overall adoption of  ther-
 mal treatment  technology  over  the  next  five years."
 Any changes would likely  be "accumulated  gradually."
 As to  the scale  of these  changes,  that  is,  to  what
 degree will  on-site or commercial  thermal  treatment
 capacity  change,   no estimate is  provided  in the  ORD
 report.

      Some  benefits   from   commercialization  of  these
 alternative technologies are  noted  by ORD.  Many  are
 designed   to  offer  more effective  and  efficient  de-
 struction  of   LOHWs  over  conventional  processes,  or
 operate  at  such  high  temperatures  that   the   more
 difficult-to-destroy wastes can  be handled.   The  scale
 of some  designs  also  make them  more  mobile allowing
 transportation to the site.

      Industry  sources asked to  comment  on  the  commer-
 cialization rate  of  alternative technologies cited  no
 specifics,  but indicated generally that  they  perceived
 the rate  as "slow."  Many  firms feel that  established
 incineration   processes  enjoy  a  regulatory  advantage
 over  emerging  technologies.   They perceive  permitting
 complexities  and  costs  as  limiting,  at least, the  mar-
 ketability of  innovative  processes,  if  not limiting
 innovation itself.

 (4)   Declining Landfill  Capacity

      While there  are several large landfills  with  sig-
 nificant  remaining life-time capacity,  there  have  been
 several  site  closures.  In these  cases,  sites   have
 reached   capacity,  or  active  sites  have  been  closed
 voluntarily or through  regulatory action.  The  rate  of
 future site closures is difficult to  predict,  but  it
 is clear  that  the  addition of  landfill  capacity  will
 be,  at best,   slow  (due  to  regulatory disfavor, public
^opposition to  siting,   and  so  forth) .   This  has  led
 commercial incineration  firms  to  speculate  that  net
 landfill  capacity will  decline, and that the  commer-
 cial  incineration market should  grow  as a  result.

 (5)   Superfund's  Influence

      Two  significant influences  on incineration market
 growth are linked,  by  both generators and waste  man-
 agement firms, to  the   Superfund  program.   The first,
                        IV-6

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    covered in Chapter  II,  is the potential  for  Superfund
    clean-up  activities  to  present   added   volumes  for
    incineration.   The  second,  and  perhaps  most  influ-
    ential  over  the  longer  term,  is  the  interaction  of
    RCRA and Superfund  to  increase  generators'  perceptions
    of and  concerns  over the liabilities of  off-site dis-
    posal of  their  wastes (18) .  Even  if it  is  permitted
    legally, the  impermanancy  of land disposing  wastes  is
    being  perceived   increasingly  as open  to  potentially
    costly  liabilities  either  in terms  of dollars,  image,
    or both.   These   negatives are  viewed as  considerably
    less likely  when  the wastes  are  incinerated  properly.
    Commercial firms  feel  strongly that  it  is this  "risk
    equation"  that  drives  more  generators  to   pay  the
    higher  up-front costs to  incinerate  their  highly  toxic
    wastes.

    In the  absence  of  regulatory  change,  therefore,  the
strong perception is  that  the demand for on-site  and com-
mercial  incineration  capacity will increase.   Exactly  how
much  this  increase  might be  cannot  be  estimated  from  the
data  available.   Some guesses place  the increase as con-
siderable,  that  is,   as much  as 20  percent over  current
demand levels.  Others  figure the balance of  market  influ-
ences  as  too close  to call, and  see  a  much  more  modest
increase  (5 percent).   There  are  signs of  at least some
market growth, however,  growth  that can only  benefit from
some of the regulatory changes being considered by the EPA.

2.  PROJECTED INCINERATION DEMAND AND CAPACITY UTILIZATION
    WITH REGULATORY CHANGE

    The  projections  of  market  growth  if RCRA regulatory
changes are implemented immediately are  nearly unanimous:
increased demand over  the  shortto  mid-term with  on-site
and commercial  incineration  capacity  unable  to  meet  the
demand.  All industry  sources contacted  see  the RCRA  regu-
latory changes as  a  "boon" to the  commercial incineration
market.  In fact, the  anticipation that  these  changes will
occur  is  already sparking  a "marked  increase"  in  wastes
available for  incineration.   The LOHW  incineration  market
is  seen  as  becoming   increasingly  competitive with  those
waste  management technologies that  have historically  en-
joyed a competitive edge in costs.

    How  successfully  the  commercial  incineration  firms
will  be  able to meet  the  added demand  is more  specula-
tive.   If   existing  capacity  is  available  and regulatory
changes are phased in  gradually, the consensus  is that  the
market could be able  to  meet  the demand.  Commercial  waste
management  firms  are  planning  now to  add  capacity,  par-
ticularly   rotary  kilns,  but  the  three  to  five  year,
                           IV-7

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regulatory-induced,  lag  time  for  bringing  new  capacity
on-line means that there must be sufficient  lead  time.   If
capacity utilization is underestimated, and  if  the regula-
tory changes are  strict and enacted too  rapidly,  however,
capacity shortfalls  are projected  as  likely.  The  influ-
ence of these factors are examined  specifically  in Chapter
VI.

    Each of  the  following   analyses  attempt  to  estimate
possible outcomes  of   several  RCRA  regulatory  amendment
scenarios as measured by  incineration  capacity  utilization
(on-site and  commercial)  assuming  no  increase  in  capac-
ity.  Each "futures" analysis  is based on  one  or more  of
the  baseline  market estimates  developed  in Chapter  III.
Each scenario has also  been  evaluated by  means of  a  sensi-
tivity analysis with development of low-range,  mid-range,
and  high-range estimate  cases.   The  logic  diagrams  in
Appendix C trace  the analysis  for  the mid-range case  des-
ignated here as the  most  likely outcome.  Appendix  D  sum-
marizes those  key data and  assumptions  varied  as part  of
the lowand  highrange cases.

    The RCRA  regulatory  amendment  scenarios analyzed  in-
clude:

         Restrictions on the land disposal of LOHWs  (land-
         fills, deep well injection, and  disposal  impound-
         ments)

         Restrictions on  burning and  hazardous wastes  in
         boilers/furnaces

         Additional listings of  organic  liquids  as hazard-
         ous wastes.

The regulatory amendment scenarios were developed  by or  in
consultation with EPA  staff.  While  these  scenarios  rea-
sonably  reflect  Agency  thinking,   they  are  not  formal
Agency positions  nor necessarily how the  draft  regulations
might  appear.   They are  intended  solely to speculate  on
possible outcomes covering  a range  of options  built  into
the sensitivity analysis.

     (1)  Land Disposal Restrictions

         Three different forms of restrictions  on  the land
    disposal of LOHWs are examined:

              Restrictions on landfilling LOHWs  whose con-
              stituents exceed specified concentrations
                           IV-8

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          Restrictions on deep well injection of LOHWs

          A ban on disposing  LOHWs  in  surface impound-
          ments.

Each land disposal restriction  is  evaluated separately
for its  impact  on on-site and  commercial  incineration
capacity utilization.

     1.   Landfill Restrictions

          The reauthorization  of  RCRA, passed  by  Con-
     gress  and   recently  signed   by   the   President,
     direct  the  EPA  to  prohibit  the  landfilling  (or
     other  land  disposal)  of  hazardous  wastes  when
     this practice  does  not  protect  human health  and
     the environment.  Potential  waste candidates  for
     the ban are  specified as well  as  the  schedule for
     evaluating  all  wastes   against   the   prohibition
     decision  rule.   Other   restrictions   apply   to
     liquids in  landfills.   Variances  to the prohibi-
     tions are allowed for limited  periods  if alterna-
     tive  waste  management  capacity  is  unavailable.
     Otherwise, the prohibitions are effective  immedi-
     ately.

          Estimates of how  much waste currently  land-
     filled would ultimately be affected by these  pro-
     hibitions range  from 25  to 75 percent of  current
     totals.   The  range  reflects  uncertainty   over
     which wastes  would  eventually be prohibited,  and
     whether pretreatment  to make  the waste  substan-
     tially less  toxic or  less mobile could  be accom-
     plished to  allow these  wastes to still be  land-
     filled.  The EPA, in some  preliminary  analyses of
     the restrictions, assumes  that 50 percent of  the
     wastes now landfilled might be affected.

          The landfilled  restrictions  scenario  devel-
     oped for  the market  analysis examines  how  much
     waste,   now  landfilled,   might  move out  of  land-
     fills  to   be incinerated  at  commercial  facili-
     ties.   The scenario  is built upon the  three  base-
     line  estimate  cases  for  wastes  now  landfilled
     (see Chapter  III)  that  reflect  variation in  the
     estimated percentage of wastes landfilled  on-site
     and at  commercial  facilities.   In estimating  the
     possible  impact  of  the  landfill   restrictions,
     variations  in the  percent of landfilled  wastes
     affected are built into the low-, mid-,  and  high-
     range estimate cases, as  25  percent,  50 percent,
     and   75  percent   of    all   wastes   landfilled,
     respectively.
                       IV-9

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              Landfill  restrictions  affecting 50%  of  all
         hazardous  wastes landfilled  (the mid-range  case)
         might increase net commercial  incineration  capac-
         ity utilization  to  215% of present capacity.   The
         influence  on on-site  capacity  utilization  is  es-
         timated to be far less,  that  is an  increase  from
         40  to  43  percent  of  present  capacity.    These
         effects are  based  upon  several  additional  key
         assumptions:

                   Only thirty  percent  of  the  wastes  af-
                   fected  by  the restrictions are  inciner-
                   ated*

                   On  the  margin, most  (60 percent)  of  the
                   incinerable,        restriction-affected
                   wastes   once  landfilled   on-site  move
                   off-site  to  be  incinerated (40  percent
                   remain  on-site to  be  incinerated)

                   Nearly  all (95 percent) of the  inciner-
                   able,  restriction-affected wastes land-
                   filled  off-site  remain off-site  to  be
                   incinerated  (5 percent  of these  wastes
                   are  no longer  sent  off-site but  return
                   on-site to be incinerated).

         Similar assumptions   are  applied in  the  low-range
         and high-range estimate cases.

              The  results of all  three sensitivity  anal-
         ysis cases are shown in Exhibit 12.  With  only 25
         percent of the wastes  landfilled affected  by  the
         restrictions  and an  on-site/off-site distribution
         of wastes  now landfilled  of   43  and 57  percent,
         respectively,   commercial   incineration   capacity
         utilization  is   estimated  at   112%  of   capacity
         after  the  restrictions are  implemented.    If  the
         percentage of wastes  affected  is as  high as  75
         percent with  84  percent of the wastes now land-
         filled off-site,  commercial incineration  capacity
         utilization is calculated to be 327% of
*   This  assumes  that  the  remaining  70  percent  of  the
    wastes are  handled  in  other  ways  including  resource
    recovery,  waste  reduction,   pretreatment   for   land-
    filling,   chemical   treatment,   and  any  other   non-
    incineration method.   This assumption  was  not  varied
    in the sensitivity analysis  as  alternatives were  not
    offered.
                          IV-10

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                                    EXHIBIT  12
      Effects  Of  Landfill  Restrictions  On  Incineration
    Of  Liquid  Organic  Hazardous Wastes--Mid-Range  Casea
Total Quantity Landfilled
  (Million Metric Tons/Yr)

Percent Of Wastes Affected By Landfill
Restrictions

Percent Of Affected Wastes That Are
Incinerated

Total Quantity To Be Incinerated
  (Million Metric Tons/Yr)

Quantity Incinerated After Estimated
Onsite/Offsite Shifts
  (Million Metric Tons/Yr)

Baseline Demand For Incineration
  (Million Metric Tons/Yr)

Total Demand For Incineration
  (Million MEtric Tons/Yr)

Incineration Capacity For LOHWs
  (Million Metric Tons/Yr)

Percent Capacity Utilization
                                                         Onsite
                                                          0.95°
50%c
30*°
0.143
0.074s
1.253
1.327
3.1
                                                         42.6%
Offsite

2.22b


50»c


30%d


0.333


0.4028



0.139
                           0.541
                           0.252
                                                                                   214.7%
a)  See also Appendix C.
b)  See Exhibit  10.
c)  Estimates supplied by EPA staff ranged from 25% to  75%.  Twenty-five percent and  75% taken  as low-range
    and high-range cases, respectively, in sensitivity analysis  (see Appendix D).  Mid-range case - 50%.
d)  Assumes that other waste management methods (e.g.. pretreatment. source reduction) will be used in
    handling of  remaining 70% of  the waste.
e)  Assumes that 40% of the on-site origin wastes stay on-site to be incinerated while 60,% goes off-site,
    and that 95% of the off-site  waste stayd off-site  to be incinerated while 5% moves back on-site to
    be incinerated.
f)  Is commercial incineration  capacity net that estimated for liquid PCBs.  See Appendix  C.

-------
capacity.   Whatever   the  assumptions,  therefore,
one outcome of  this  scenario analysis  appears  to
hold true.  Landfilled  restrictions  are likely  to
make available for incineration  a  sufficient vol-
ume of wastes to consume  remaining  unused commer-
cial capacity and leave the  demand  for  commercial
incineration  capacity  for  LOHWs  above  current
supply.

2.   Injection Well Restrictions

     Restrictions on  deep well  injection  of haz-
ardous wastes  are also called  for  in the  RCRA
reauthorization.  Analysis  of this  scenario pro-
jects a  similar, if  not a greater,  impact  as the
landfill restrictions.  As  much as  74  percent  of
available  on-site  incineration  capacity and  450
percent  of  available commercial  incineration ca-
pacity  could be utilized   under  the  high-range
case.  The  effect  on both on-site  and  commercial
incineration capacity utilization  is considerable
as the quantity  of  wastes injected  into wells  is
estimated  to  be quite  large  (32  MMT).  Even  a
small  percentage  of this   volume   (6.5  percent)
translates into a large quantity of waste.

     Exhibit  13  details  the  major  sensitivity
analysis  assumptions of  the deep  well injection
scenario.   As   with  the   landfill  restrictions
scenario,  the  low-range,  mid-range,  and  high-
range estimate  cases for  the deep  well injection
scenario  reflect a  range of 25 to  75  percent  in
the percentage of wastes  affected  by the restric-
tions.   As the  most likely case,   the mid-range
case estimates  that  50  percent  of  the  wastes are
affected.  This would result in  a  demand for com-
mercial  incineration  capacity of 306%  of present
capacity,  and  a demand for  on-site incineration
capacity of  54%  of  present  capacity.   Results  of
the low-range case are  162%  and  34% of  commercial
and  on-site capacity,  respectively.    As  noted,
assuming  that  75 percent  of  the  wastes  are af-
fected   (the  high-range  case)  is  projected  to
result  in  a  demand  for  commercial incineration
capacity of 450% of current  capacity.

     Each  sensitivity  analysis  case  assumes that
not  all  of the  restriction-affected wastes would
be  incinerable, in  fact,  each analysis  assumes
that  65  percent  of   the  restricted  wastes  would
not  be  incinerable.   Thirty percent  of  the re-
stricted wastes would have to be pretreated  to be
                  IV-12

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                                                     EXHIBIT  13
                                Effects  Of Restrictions  On  Deep  Well  Injection:
                               Major Analytical Assumptions For  Mid-Range Case3
PERCENT OF PERCENT OF
INJECTED WASTES AFFECTED WASTES
AFFECTED THAT ARE NOT
INCINERABLE
PERCENT OF
AFFECTED WASTES
THAT ARE DIRECTLY
INCINERABLE
AND ARE INCINERATED
PERCENT OF
AFFECTED WASTES
THAT ARE
INDIRECTLY
INCINERABLE
INDIRECTLY INCINERABLE WASTES AFTER
PRETREATMENT
PERCENT INCINERABLE
AND INCINERATED
PERCENT NOT
INCINERABLE
         50%
65% b
5%'
30%
5%'
                                                                                                          95%
t-t
<
I
H«
to
                            TOTAL INCINERABLE AND INCINERATED = 6.5%  OF  ORIGINAL VOLUME AFFECTED
        a)  See also Appendix C
        b)  Assumes that majority of wastes injected are either not  incinerable or cannot be made (i.e.,  treated to be)
            incinerable, and will be managed by other means.
        c)  Assumes that only 5%  of affected wastes are directly incinerable  (i.e., no treatment needed)  and are
            incinerated.
        d)  Assumes that a fraction of the affected wastes can be made  incinerable with pretreatment.
        e)  After pretreatment, most of wastes are not incinerable (i.e., water or dilute streams)  and only a small
            percentage is incinerable and incinerated.  Non-incinerable fraction is managed by other means.

-------
     made  incinerable,  leaving only  5  percent of  the
     original  volume  of  these indirectly  incinerable
     wastes  as actually  incinerated  (assumes that  95
     percent  of  the   initial  volume  is  water).   An
     additional 5  percent of  the  restricted waste  is
     assumed  to  be  directly  incinerable.*   Of  the
     original  total  volume of  restricted wastes  pre-
     viously  injected,  therefore/  only  6.5  percent
     actually   becomes   available  for   incineration.
     This reasoning is applied to  wastes  injected into
     on-site  and   commercial   wells   (most  wastes/  98
     percent/  are  assumed  to  be  injected  into  on-site
     wells.  Most of this  incinerable volume is  incin-
     erated  at commercial  facilities  (95  percent  of
     the affected  wastes  originally  injected  off-site
     and 60  percent of the affected  wastes  originally
     injected on-site) .

          In  sum,  possible restrictions  on deep  well
     injection of  hazardous wastes are  hard  to  evalu-
     ate.  Exactly how such restrictions  would  operate
     is not  certain as the capacity  to  pretreat  thes«
     frequently very dilute, very  large  volume  aqueous
     wastes  is  not known.   These wastes may  be  incin-
     erable, but the EPA does  not  know of  any technol-
     ogy  capable   of   handling  the  large  volumes  of
     wastes   economically.    The   scenario   analyzed
     shows,  however,  that commercial incineration  ca-
     pacity could be exceeded  easily  if  only 1  percent
     of the  32 MMT of  wastes  injected were incinerable
     and incinerated at commercial facilities.

     3.   Disposal Impoundment Ban

          Amendments  to  RCRA  would  extend  land  dis-
     posal  prohibitions  to the  disposal  of  hazardous
     wastes  in surface   impoundments.   Assuming  that
     facilities that treat and/or  store  wastes  in sur-
     face  impoundments would  operate to  preclude dis-
     posal   of  wastes  in these   impoundments,   this
     amendment  would  preclude  the practice  of  dispos-
     ing  wastes  in  surface   impoundments,  so-called
     disposal  impoundments.
While some fraction of  injected wastes  may be directly
or  indirectly  incinerable,  this  fraction  may be  far
less  than  the  assumed  5  percent,   respectively.   The
EPA indicated in their  Task  1  report that  they "do not
have  adequate  information  on  commercially  feasible
pretreatment and volume reduction of these  wastes"  to
believe that  this  could occur on a  sufficiently  large
scale (1).

                      IV-14

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          The  impact  of  a ban on  the  disposal of haz-
     ardous  wastes  in surface  impoundments  on commer-
     cial  incineration  capacity   is  hard to  predict.
     There  are many  uncertainties  and  weaknesses  in
     the  available  data.  Primary among these  is  the
     estimate  that  10 percent of  the  wastes placed in
     disposal  impoundments are  incinerable.*  Of these
     incinerable  wastes,  the  scenario  assumes  that
     either  25 percent/  50 percent, or  75  percent  are
     actually  incinerated.   These options  constitute
     the  range  jf values suggested for this assumption
     as  incorporated  into  the  low-,  mid-,  and  high-
     range cases of the  sensitivity analysis.

          With   50   percent   of   the   incinerable,
     restriction-affected  wastes  actually incinerated,
     commercial capacity utilization  is estimated  to
     be  288%  of  current capacity.   This compares  to
     153% of  capacity for the  low-range  estimate case
     and  423%  of  capacity for  the high-range  estimate
     case.  Similar calculations  for  on-site incinera-
     tion  capacity  utilization  range  from 33   to  7-2
     percent  of capacity with  52 percent of  capacity
     as the  mid-range result.   These estimated impacts
     are  comparable  to  those calculated for  the deep
     well injection restrictions scenario.

(2)  Waste-in-Boilers Restrictions

     According  to EPA estimates,  some  924 million gal-
lons of  waste-derived  fuel  materials  were burned  in
about  2,800  industrial  boilers  and furnaces*  in 1983
(15, 19) .

     These data also  show that,  by type, most  waste-
derived  fuel  materials  were non-solvent,  non-aqueous
organic wastes and  solid  residues.   Exhibit  14  shows
the  percentages  of   waste-derived fuel  materials  by
type taken from preliminary Boiler Survey results.
It should be noted that  the  scenario analyzed concerns
a ban  on  future waste disposal  in  impoundments rather
than cleaning up old  disposal  impoundments.   The esti-
mate that  10 percent  of the  wastes sent to  disposal
impoundments are incinerable is based upon  a  compari-
son of 1981 RIA National Survey  data on  the  volumes of
LOHWs  in  disposal  impoundments  (456.5  MMT) with  the
volume of  all wastes  in disposal  impoundments (4,012
MMT)  (see Appendix B, Exhibits B-7 and B-8).
                      IV-15

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     As a subset of  waste-derived  fuel materials, haz-
ardous wastes were burned  in  about  1160 devices.   Pre-
liminary  data  from  the EPA's  Boiler  Survey  indicate
that, in 1983, at a minimum;

          Some 30 utility  boilers  burned 7,000 gallons
          of hazardous wastes

          About  188   non-industrial   devices   (mostly
          space heaters) burned  19,000  gallons of haz-
          ardous wastes

          About   945    industrial    devices    burned
          153,000,000 gallons of hazardous wastes.

     Concerns over the  health  risks  of burning hazard-
ous  wastes  in boilers has prompted  Congress  and  the
EPA to consider controls on this practice.   When  these
practices are brought  further under  the  RCRA  Subtitle
C  regulatory  umbrella, this may lead to a  decline  in
waste-in-boilers activity  and  an   increase  in  wastes
available  for commercial   incineration.   As  such,  a
scenario analysis module was  developed  to estimate  the
magnitude and  impact of this  possible shift  (see  Ap-
pendix C) .

     The  key  questions  appear to  be  how  strict  the
waste-in-boilers  regulations   might   be   and  how  many
boilers will  be unable to comply  (at  a "reasonable"
cost) with  the  standards imposed.   The  scenario  anal-
ysis  summarized  in  Exhibit  15  reflects  the  EPA's
assumption that 35 percent of  the  boiler/furnace  popu-
lation  burning  hazardous  wastes  would  be  unable  to
comply  based  on  their capabilities  and  the  type  of
waste burned, and would choose to  shut  down.   If only
75 percent  of  the  wastes these devices  burned becomes
available for  incineration and  most  (70 percent)  of
this volume moves  to  commercial units to be  inciner-
ated,  commercial   incineration  capacity  utilization
might increase to 106 percent of existing capacity.
There  are  actually  a  variety  of devices  that  burn
waste-derived  fuel materials.   These  include  indus-
trial  and  non-industrial  boilers,  kilns,  industrial
furnaces,  process  heaters,   space  heaters,  non-RCRA
incinerators,  and other  combustion  devices.   Indus-
trial boilers and  furnaces are the focus  here  as  they
are estimated to  burn  nearly 75 percent of  all waste-
derived fuel materials (19).
                      IV-16

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                                 EXHIBIT 14

                 Quantities of Waste-Derived Fuel Materials
                               Burned By Type
MATERIAL TYPE
Aqueous inorganics
Aqueous organics
Organic solvents
Other organic wastes
Reactives
Corrosives
Other solid residues
Other wastes
QUANTITY BURNED
(10a gallons)
14
65
67
321

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With only 30  percent  of this volume moving  to on-site
incinerators,  on-site capacity  utilization  would  in-
crease marginally to 42 percent of existing capacity.

     The EPA's  estimate of 35  percent reflects  a  be-
lief  that  most  boilers   and   furnaces   already  can
achieve the destruction efficiencies and  emission con-
trols likely  to be mandated  or will  do  so at  little
cost.   Some  incineration   industry  sources  contacted
tend to  agree,  and some  estimate  that far  fewer will
be impacted (perhaps  only  10  percent).  However,  there
are those who disagree  and  place this  estimate as high
as 50 percent.   These sources believe  that  few owner/
operators of  these  devices  will  choose  to  bear  the
regulatory  "costs"  of  continuing  to  operate  even  if
they comply technically  with regulations.  This will
be particularly true,  they  predict,  if extensive  waste
testing  and  performance  monitoring   requirements  are
imposed.  In  the  long run, it  may be  cheaper  to send
their wastes  to commercial  facilities than to  estab-
lish  the mandated  programs  and  procedures  that  the
commercial  incinerator firms already have in place.

     The sensitivity  analysis  for  the  waste-in-boilers
module  varies  the  percentage  of  wastes burned that
becomes  available   for  incineration  from the devices
that shut  down.  If  only 50  percent  of  these  wastes
are   incinerated,   commercial   incineration  capacity
utilization might only  be  71  percent  of capacity.  The
remainder of  these  wastes,  it  is  assumed,  would  be
handled  by  other  means  including,  for  example,  re-
source  recovery and  waste reduction.   Conversely,  if
all  the wastes  are  incinerated,  commercial  incinera-
tion capacity  utilization is estimated to be  142 per-
cent of capacity.

(3)  Additional Waste Listings

     Another  regulatory-induced  influence on  incinera-
tion demand would  be  additions to the list  of hazard-
ous  wastes.  This  would  bring  more  wastes  into  the
RCRA  scheme  adding  to  volumes   of   hazardous   wastes
already  handled at  RCRA-permitted  facilities.   Depend-
ing  upon how  large  a  quantity of  incinerable  wastes
this  involved,  commercial  incineration capacity  might
not be sufficient.

     OSW has  estimated that a total of 1.2  MMT of or-
ganic  liquids would  be added from new waste  listings
as  a  result  of  the Industry  Studies  Program   (20).
Presently,  90  percent of these  wastes are managed on-
site.  These on-site  management practices consist of
                       IV-18

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                                                               EXHIBIT  15
                           Effects  Of  Restrictions On  Burning  Hazardous  Wastes  In  Boilers
                     On The  Incineration  Of Liquid Organic Hazardous Wastes--Mid-Range  Case3
 i
i-1
VO
Total Quantity of Hazardous Wastes Burned
In Boilers
  (Million Metric Tons/Yr)

Percent Of Boiler Population Affected By
Restrictions

Percent of Wastes From Affected Boilers
That Is Incinerated

Total Quantity Now Incinerated
  (Million Metric Tons/Yr)

Quantity Incinerated
  .  Onsite  (Million Metric Tons/Yr)
  .  Offsite (Million Metric Tons/Yr)

Baseline Quantity Incinerated
  .  Onsite (Million Metric Tons/Yr)
  .  Offsite (Million Metric Tons/Yr)

Total Quantity Incinerated
     Onsite (Million Metric Tons/Yr)
  .  Offsite (Million Metric Tons/Yr)

Incineration Capacity
  .  Onsite (Million Metric Tons/Yr)
  .  OFfsite (Million Metric Tons/Yr)

Percent Capacity Utilization
  .  Onsite (Million Metric Tons/Yr)
  .  Offsite (Million Metric Tons/Yr)
                                                                                 0.7°



                                                                                35%c


                                                                                75%d


                                                                                 0.184
                                                                                 0.055  (30% Of Total Now Incinerated)
                                                                                 0.129  (70% Of Total Now Incinerated)
                                                                                 1.253
                                                                                 0.139
1.308
0.268
                                                                                 3.1
                                                                                 0.252e
                                                                                42.2%
                                                                               106.3%
                              a)  See also Appendix C.
                              b)  Is subset of  3.5 million metric tons/yr  of waste-derived fuel materials burned
                                 in boilers according to the EPA's 1983 Boiler Survey.
                              c)  As suggested  by EPA staff from preliminary results of  the Boiler Survey.
                              d)  EPA staff suggested range of 50% to 100%.  Seventy-five percent is mid-range.
                              e)  Is commercial capacity net that estimated for liquid PCBs.  See also  Appendix C.

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burning  these  wastes  in  boilers   (39%),  incinerating
these   wastes   (25%),    or   recovering   these   wastes
(17%).*  Of the wastes managed off-site,  most  are sold
to other  firms  (46%) ,  recovered (39%) ,  or  incinerated
(t>%)  .*  The  data  EPA supplied,  however,  does  not  in-
dicate  what  fraction   of  these  wastes  are  already
handled at RCRA facilities.

     Though these  wastes are  not  presently listed  as
hazardous,  it  is  assumed  that most are  handled  at
RCRA-permitted facilities.   If so,  the  net effect  on
incineration  demand  after   they  are  formally  listed
should  be  small.   This presumes  that  most  of  the
wastes  would  still  be  managed  on-site.   Any  wastes
sent  off-site  and  incinerated  probably  would  affect
demand  only by  5 percent.   Even  at the  80  percent
baseline  utilization  figure,  this  would still  leave
excess  off-site  incineration  capacity.   Lacking  more
specific  data,  however,  it  is  difficult  to  predict
these effects.

     One  new  waste  listing  contemplated may  have  a
significant  effect—the   proposed   listing  of  certain
wastes containing chlorinated  dioxins (CDDs),  dibenzo-
furans  (CDFs), and phenols,  and their phenoxy  deriva-
tives.  In  particular,  there is reason  to  believe  the
quantities  of  CDD- and  CDF-containing wastes  "gener-
ated"  from  CERCLA waste  site clean  ups  may be  quite
large.   These  wastes  are  likely   to be  contaminated
soils  that  will  either  have to be stored or  treated
on-site,  or sent  off-site  to  be  incinerated,  land-
filled, or stored.

(4)  Lowering the Small Quantity Generator Exemption

     Little  data  is  available   for  predicting  the
effect of this regulatory change on  commercial incin-
eration  demand.   Opinions  vary  as  to  how much  more
wastes  would  have to  be managed.   Some believe  that
the  concern over  potential  liabilities  already  has
prompted  small  quantity  generators to  send  their
wastes  to  RCRA  facilities.    Lowering the  exemption,
therefore,  would  have   little  net  effect.    Others
believe that this  is not the case   and that  waste vol-
umes would increase considerably.
OSW  has  attempted  to  eliminate  double-counting  of
wastes in these estimates.
                       IV-20

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         In  developing  this analysis,  EPA staff  were  not
    in  the  position to even  predict the  possible effects
    of  a  lowering of the  small quantity  generator  exemp-
    tion.   Studies  aimed  at gathering  data on  this  ques-
    tion  are underway;  some  preliminary  results  indicate
    that the  total  quantity may be no more than 1 million
    tons.   EPA staff  and  industry  sources  contacted  do
    agree that  any possible impact  will be more  signifi-
    cant on a regional basis,  and that  regional  capacity
    shortfalls could occur.
    Even given  a  series of generally  conservative  assump-
tions,  four  possible RCRA  regulatory  scenarios  are  esti-
mated to have a major impact  on  off-site commercial incin-
eration  capacity  utilization  if  implemented  immediately.
Lacking  increases  in available capacity, each of the four
could result  in increasing demand far beyond  existing ca-
pacity.  These amendments include:

         A ban on landfilling LOHWs

         Restrictions on deep well injection of LOHWs

         Restrictions on disposing  LOHWs  in  surface  im-
         poundments

         Controls on burning hazardous wastes in boilers.

    Each of  the regulatory changes  is viewed by  the com-
mercial  incineration  industry as a likely  "boon"  to  their
market.  They feel strongly that liquids incineration will
become  increasingly  competitive  with  alternative  waste
management technologies.  Not all of  the impetus for mar-
ket  growth  will   come   from  regulatory  change,  however.
Industry  sources  see  generators'  increased awareness  of
the potential liabilities  of  improper waste disposal as a
major  market  growth  factor.   Generators,  conscious  of
experiences  with  the  Superfund  program,   are  turning  to
methods, such as  incineration,  that they perceive  as less
risky and less costly options  over  the long-term.  Commer-
cial  incineration  firms already report  an  increase  in
business motivated by this factor alone.

    This market analysis demonstrates  the  possibility that
existing commercial  incineration capacity may be insuffi-
cient to  accommodate increased  demand.   The next  chapter
examines specifically how  much  LOHW  incineration capacity
may increase over the short- to long-term.
                          IV-21

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    V.   PROJECTED  CHANGES  IN LOHW INCINERATION  CAPACITY

    The  regulatory  scenarios  examined  in  the  previous
chapters are founded on two broad assumptions:  each regu-
latory change is  implemented  immediately and LOHW inciner-
ation capacity  does  not increase.  There  are  indications,
however, that LOHW incineration capacity  is  increasing or
could be increased given some pending developments.

    This market analysis assumes  there  are  four  sources of
additional  available  incineration  capacity for  LOHWs  to
meet any increase in demand.  These are:

         Use of remaining  commercial  incineration capacity
         for liquids

         Shifts in the  waste  feed mix  to  burn less  solids
         and sludges and more liquids

         Construction  and  improved operation  of  new land-
         based,  liquids incineration facilities

         Development   of    commercial   incineration-at-sea
         capacity.

1.  INCREASED  CAPACITY  UTILIZATION  AND   NEW  LAND-BASED
    CAPACITY

    Over the short-term, usage  of any remaining commercial
LOHW incineration capacity  would  be  the most likely  market
response.  As noted  in Chapter  III,  however,  exactly  how
much commercial LOHW incineration capacity  remains  is  un-
clear.   The baseline  market  analysis' low-and  mid-range
calculations place existing commercial  incineration  capac-
ity  utilization  anywhere  from  37  to  55  percent, respec-
tively.  Industry  sources  suggest  commercial  incineration
capacity utilization may be closer  to 80  percent, and they
indicate that commercial  incineration capacity utilization
for PCBs is  at  or near  100 percent  (PCS  incineration  de-
mand probably exceeds  supply).   Remaining  commercial LOHW
incineration capacity,  therefore, may  range anywhere from
20  to  60 percent of  total net commercial  capacity   (0.252
MMT) .

    Alternatively,  commercial  incineration  firms,   faced
with an  increase  in  LOHWs  available  for  incineration,  may
alter their current  waste  feed mix by  burning less  solids
and sludges  and more  liquids.   Solids  and  liquids  capac-
ity,  particularly for  a   rotary  kiln,   is  not  exclusive.
Capacity  now  devoted  to  solids  can   be  switched   to
liquids.  This  would  represent another  short-term  option
that would make additional  capacity available  to handle an
excess of demand  over  capacity.   It  would have  to  be  as-
sumed,  however,   that  prices  for  burning   the  additional

                            V-l

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liquids would  be sufficient  to displace  the solids  mar-
ket.  A reference  to Exhibit  6 in  Chapter  II shows  that
prices to  incinerate non-highly toxic  liquids would  have
to  rise  anywhere  from  $1.00  to  $2.00  per  gallon  to
displace solids and highly toxic liquids.

    In  Chapter  IV,  incineration   industry  sources  were
quoted  as  considering   regulatory  complexity   and  con-
straints as major  impediments  to  market  entry and/or  the
addition of new capacity.  These  sources estimate  that  a
lag time of at  least 3 years  must  be figured  into any  pro-
jection of added incineration  capacity, longer if signifi-
cant public opposition  is encountered.   They  have  figured
this  lag  time,  for  example,  into plans  for several  (as
many  as  10)  new land-based  facilities  and/or units  over
the next 5 to  7 years.   If true,  this would  indicate  that
new  land-based  incineration  capacity  would  be  only  a
mid- to long-term  possibility.  Unfortunately, no  commer-
cial  firm  contacted  that  indicated  an  intention   to  add
units over the next few  years  was willing to provide  ca-
pacity data.

2.  DEVELOPMENT OF INCINERATIQN-AT-SEA CAPACITY

    Development  of  incineration-at-sea  capacity  would  in-
crease total  LOHW  incineration capacity.  Accordingly,  a
module was  developed to  estimate  the currently  available
incineration-at-sea capacity.

    Based upon information supplied by EPA staff  and  in-
dustry sources,  some 247,000  metric tons per year  of  ca-
pacity is available  with the  three  incineration  ships  now
built(21).   Most,  if not  all, of  this  capacity would  be
for liquid wastes.   This compares to an  estimated  300,000
metric tons per year of land-based incineration capacity
for LOHWs (including PCBs).   As shown in  Exhibit 16,  less
than  half of   this  capacity would be  supplied by  the  two
operating Vulcanus  ships  owned by  Ocean Combustion  Ser-
vices, and  the  remainder by  the  Apollo  I  ship owned  by
At-Sea Incineration.  Not  included in Exhibit 16, however,
are planned incinerator  ships.   These would include At-Sea
Incineration's  second Apollo vessel and  an  unknown number
of  ships/barges  planned  by  Seaburn   and  Environmental
Oceanic Services.   While there was  some  data available to
estimate  the  capacity   represented  by  these  additional
ships, they were not included given that  there  is  no  com-
parable data for planned  land-based incinerators.

    The operational  assumptions detailed  in  Appendix C and
summarized in Exhibit 16 were developed in consultation
                           V-2

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                                                     EXHIBIT  16
                                           Incineration-At-Sea Capacity9
i
00
Incineration Vessel
Vulcanus I
Vulcanus II
Apollo I

Burn Capacity
Per Voyage
(Metric Tons)
3,600b
3,600b
6,000d

Estimated Number
of Voyages
Per Year
16C
16C
22e

Estimated
Annual Capacity
(Metric Tons/Yr)
57,600
57,600
132,000
247,200f
(0.247 million metric tons/y
          a)  See also Appendix  C.  Source:  (21).
          b)  Estimated per unit throughput capacity of 1,650 gal/hr at 240 hours  of  burning  and  10  Ibs/gal;
              2  units  of  Vulcanus I, 3 units on Vulcanus II with 2  operating per voyage.
          c)  Estimated turnaround  time of 3 weeks (5 days intransit, 10 days to burn,  and  5  days to reload)
              less  one voyage per year.
          d)  Estimated per unit throughput capacity of 2,750 gal/hr at 240 hours  of  burning  and  10  Ibs/gal;
              2  units  on  ship.
          e)  Estimated turnaround  time of 2 weeks (2 days intransit, 10 days to burn,  and  2  days to reload
              less  4 voyages per year.
          f)  Represents  capacity for incinerator ships presently constructed.  Are at  least  3  additional
              planned  vessels not included.

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with staff from the Office of Water  Regulations  and Stand-
ards  (OWRS)  with  some  confirmation  by industry  sources.
There  are  several  uncertainties  to  these data,  however,
that could  reduce the  estimate  of  existing  incineration-
at-sea capacity.   For  example,  the  Vulcanus  I, now  oper-
ating in European waters, may not be  moved to  serve a U.S.
market.     This   would    reduce    available    existing
incineration-at-sea capacity  by nearly  25 percent.   Sec-
ondly, the  per  voyage capacities  estimated for each ship
assume that each incinerator will operate  at  full  through-
put  capacity without   significant  operating  problems  or
downtime.

    Another  issue  is just  how many voyages  to the  burn
site(s)  each  ship will  be able  to  make, per year.   Each
firm has estimated a  theoretical per  year maximum  based
upon their  expected turnaround times.   The figures  shown
in  Exhibit  16  are  downgrades of  these maximums  allowing
for  some operational and  logistics  problems.   Even  some-
what fewer trips may be made per year,  OWRS estimates, due
to  these problems  as well as  possible seasonal limits  on
operations.  How many ships  will  be  allowed to  operate  at
the  burn site(s)   at  one ,tirae  is  also still  unresolved.
These questions are likely to  be  resolved  when  the incin-
eration-at-sea regulations are issued in 1985.
    The addition  of existing  incineration-at-sea  capacity
would  nearly double  the  current commercial  incineration
capacity for  LOHWs.   This would  reduce  commercial  capac-
ity  utilization  after  landfill  restrictions  (mid-range
case)  from  over 215  percent of  capacity  to  108  percent.
The  estimated effect  of restrictions on burning  wastes in
boilers  (mid-range  case)  would  drop from  106 percent of
capacity to 54 percent.

    The   availability    of    additional   land-based   or
incineration-at-sea capacity,  therefore, is seen  to offer
some  moderation of  the  capacity shortfalls  anticipated.
The  key  issue then becomes  how  rapidly this capacity is
added  to  the off-site  market.   These types of  issues are
the subject of Chapter VI.
                           V-4

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         VI.  IMPLICATIONS OF THE MARKET ANALYSIS


    The regulatory  scenario  analyses  in Chapters IV  and V
have "assumed  that any  regulatory-induced  changes  in  LOHW
incineration demand occur quickly, perhaps within a 1  to 3
year  period.   Over   that   same  1  to   3   year   period,
regulatory-induced and market-induced changes  in incinera-
tion capacity*  are likely  to  be slower.   As such,  these
instantaneous demand-supply  comparisons project a  demand
on incineration exceeding present incineration capacity.

    In this chapter, the  increase  in  incineration  capacity
required to  meet  this full  demand  is translated into two
measures of  incinerator  capacity equivalents.   This  anal-
ysis translates  the  projected   impact  of  each  regulatory
scenario into the  building  of incineration  facilities and
ships.   The building of a land-based  incinerator or incin-
erator ship  is, of  course,  the most  tangible  impact  these
regulatory changes may have, and the  key process that will
shape  the  market's  response.   Therefore,  this  approach
provides a  consistent  basis for  measuring  the potential
impacts of the regulatory amendments to RCRA.

    In addition,  this  approach  provides an  alternative to
an  analysis  that  attempts  to estimate  the  impacts   of  a
phased regulatory  implementation schedule.   No clear  guid-
ance on  a  possible phased  implementation  and  compliance
schedule was available at  the  time of this  analysis.   The
RCRA reauthorization  legislation  does  allow  for   a  delay
before the prohibitions or restrictions would  have  to take
effect, if  the  EPA Administrator determines  that  adequate
capacity  will not be  available  to  handle an  immediate
promulgation of the regulations.**

    It  bears repeating  that  the   reasonableness  of  this
market  analysis  rests  entirely  on  the reasonableness of
the assumpitons and data used in the regulatory scenario
*   Capacity changes also  have  a regulation-dependent com-
    ponent.  Development  of  incineration-at-sea  capacity,
    for  example,  must  await  development of  regulations,
    and  increases  in land-based  incineration  capacity are
    tied to a separate permitting process.

**  Implementation of the  regulation  is distinguished here
    from development of the  regulation itself.  The RCRA
    reauthorization  legislation  does  indicate  how  rapidly
    the EPA must act to develop the applicable regulations.
                           VI-1

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analyses  (Chapter  IV).   Every  effort has been  made,  given
the available data, to ground these  analyses  in realistic,
supported assessments  of the market and possible  regula-
tory change.   Yet, as discussed  in Chapters  III and  IV,
some of the data and assumptions cannot be confirmed
as reasonable  as  there are significant  unknowns  or  incon-
sistencies   to  resolve.    Variations   in   these   data/
assumptions have, therefore, been incorporated  into  a sen-
sitivity analysis.

    Exhibit  17 summarizes  the  results  of  estimated  in-
creases  in  the demand on  incineration relative  to  avail-
able existing LOHW capacity under the  four RCRA regulatory
scenarios:

         Restrictions on landfilling LOHWs
         A prohibition on underground injection of LOHWs
         A  prohibition  on disposing LOHWs  in  surface  im-
         poundments.
         Restrictions  on the burning  of hazardous  wastes
         in industrial boilers

The exhibit  shows that,  given  the  mid-range case  assump-
tions,  all  four  scenarios  are estimated to increase  the
demand  for  incineration  above  existing commercial inciner-
ation  capacity for  LOHWs  (fully utilized),  significantly
so for  each  of the three land  disposal restrictions scen-
arios.  All three  land disposal restrictions  scenarios are
also projected to create an excess  of  demand  over existing
capacity  given the  low-range   case  assumptons.  Only  the
low-range case for  the  wastes-in-boilers restrictions is
estimated to  leave the  demand  for   incineration  below ex-
isting  available capacity.

    If  each scenario may lead to  increasing  the demand for
incineration to levels exceeding  available  existing capac-
ity for  LOHWs,  a  logical question to ask is  how  much will
commercial  LOHW  incineration capacity  have to  increase to
match  this  demand.   Exhibit 17  attempts  to  answer  this
question.  On  the  one  hand,  the exhibit shows that  some of
the increase  in  demand will be accomodated by  an increase
in the  utilization of existing commercial capacity  to 100
percent.  How  much of an  increase   in  commercial capacity
utilization would depend on  the baseline estimate capacity
utilization.   If  present  commercial  capacity  utilization
is closer  to the 80 or  90  percent  level as  some industry
sources  suggest,  then  the residual  capacity  available may
not absorb much of the projected increase in demand.
                           VI-2

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                                                                      EXHIBIT  17
                                               INCINERATOR EQUIVALENTS ESTIMATED TO BE NECESSARY TO
                                                    HANDLE THE EXCESS DEMAND FOR COMMERCIAL
                                          INCINERATION  CAPACITY FOR LOHWs UNDER 4 REGULATORY SCENARIOS
             1.0
H
 I
00
        I
        1
o
             0.5
          RANGE OF
           EXCESS
           DEMAND
          OVER FULL
         ' CAPACITY
         UTILIZATION
                                    UPPER
                                           )    FULL
                                           >  CAPACITY
                                             UTILIZATION
              100% EXISTING
            CAPACITY UTILIZATION
                  (0.252)
                                                                                                                             10
                                                                                                                                         COi
                                                                                                                  14
                                                                                                                                     0.3
                                                                                                                                     0
                                        LANDFILL
                                      RESTRICTIONS
                                                DEEP WELL
                                                INJECTION
                                              RES I MCI IONS
   DISPOSAL
IMPOUNDMENTS
 PROHIBITION
  WASTES-IN-
   BOILERS
RESTRICTIONS
           •PROBABLE FUTURE AVERAGE ANNUAL CAPACITY FOR NEW FACILITIES = 20,000 METRIC TONS
          "PROBABLE FUTURE AVERAGE ANNUAL CAPACITY FOR SHIPS = 50.000 METRIC TONS.

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    The  key  feature of  the  exhibit,  however,  is  how  any
remaining excess demand over supply  is translated into  the
two measures of  incinerator  equivalents—equivalent "aver-
age"  capacity   land-based  incinerators   and   equivalent
"average"  capacity  incinerator   ships.   For  example,   at
full  capacity  utilization,   landfill  restrictions  (mid-
range estimates) are estimated  to result in an  excess  de-
mand of  0.289  MT  (0.541  MT  - 0.252  MT) .  In Exhibit  17,
this difference  is shown  to  be equaled by bringing on-line
14  additional  land-based  incinerator  facilities  (at  a
probable future  average capacity  of  20,000  metric tons  per
year per new facility)  or 6  incinerator  ships  (at a prob-
able  future  average capacity of  50,000 metric   tons  per
year per ship).  The largest  impact  a scenario may have in
terms of incinerator  equivalents is  estimated  to be  26
land-based facilities  and 10 ships.    This  would  be needed
if all disposal  of LOHWs  in  injection wells was  prohibited
(with only 6.5 percent  of the affected wastes incinerated).

    Given  that   several  of  these regulatory  restrictions
may  be   implemented  concurrently by  the EPA,  Exhibit  18
examines the impact of combinations  of the  four  regulatory
scenarios.  Again, any excess in the  demand  for  incinera-
tion over  existing  available  commercial incineration  ca-
pacity for LOHWs (fully  utilized)  is translated  into  in-
cinerator equivalents.   The  landfill and wastes-in-boilers
restrictions  (mid-range  cases)   considered  together  are
projected  to  result in  an  excess  of  demand  (0.669 MT  -
0.252 MT = 0.417 MT)  equivalent  to  21 land-based inciner-
ator facilities  or  8  incinerator ships.   All three  land
disposal  restrictions  (mid-range cases)  are estimated  to
require  75 land-based  incinerator facilities or  30 incin-
erator ships to handle the  estimated excess demand.   The
addition  of  wastes-in-boilers  restrictions  to   the  three
land disposal restrictions results  in only  a  marginal  in-
crease to 82 land-based facilities or  33 ships.

    Exhibit 18  also shows that  the number of  land-based
facilities  or   ships  needed could   be   far  less  or  far
greater  than is  estimated based on  the  mid-range case  re-
sults.   Not  shown,  however,  are  the  results   of  mixing
low-, mid-, and  high-range case  assumptions in  each of  the
scenario  analyses,  or  the  possibility  of  using combina-
tions of land-based facilities and ships to accomodate  any
projected  increase  in demand.   Land-based facilities  or
ships with  a  larger average  annual  capacity  than assumed
in both  Exhibits 17 and  18  would also mean that fewer of
each or both might be necessary.
                           VI-4

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                                                                      EXHIBIT  18
                                             INCINERATOR EQUIVALENTS ESTIMATED  TO BE NECESSARY TO HANDLE
                                               THE EXCESS DEMAND FOR COMMERCIAL INCINERATION CAPACITY
                                               FOR LOHWs UNDER COMBINATIONS OF 4  REGULATORY SCENARIOS
             3.0
             2.5
             2.0
             1.5
Ul
        s
        in
              1.0
             0.5
                 RANGE OF EXCESS
                   DEMAND OVER
                   FULL CAPACITY
                    UTILIZATION

                                           FULL CAPACITY
                                            UTILIZATION
                                 100% EXISTING
                             'CAPACITY UTILIZATION
                                    (0.252)
                                                    LANDFILL
                                                  AND WASTE-IN-
                                                     BOILERS
                                                  RESTRICTIONS

  •PROBABLE FUTURE AVERAGE ANNUAL CAPACITY FOR NEW FACILITIES = 20,000 METRIC TONS.
 "PROBABLE FUTURE AVERAGE ANNUAL CAPACITY FOR SHIP = 50,000 METRIC TONS.
 LANDFILL. DEEP
WELL INJECTION,
 AND DISPOSAL
 IMPOUNDMENTS
 RESTRICTIONS
     LANDFILL. DEEP
    WELL INJECTION,
DISPOSAL IMPOUNDMENTS,
  AND WASTE IN BOILERS
     RESTRICTIONS

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                          APPENDIX A
         DEFINITION "OF LIQUID ORGANIC  HAZARDOUS WASTES
     A key input  to the incineration market study  was  determining
those wastes that can be included as incinerable or  potentially
incinerable liquid organic hazardous wastes (LOHWs).   Under
Task 1 of the Agency's larger incineration study,  the  Office
of Solid Waste  (OSW)  was responsible for this analysis.
Their definition  for and list of LOHWs are summarized  below.

     An incinerable liquid organic hazardous waste was defined
by OSW for this study as:

     "Any EPA hazardous wastes that has been reported
     incinerated  as a liquid, and/or, according to the EPA
     Engineering  Handbook for Hazardous Waste Incineration,
     is suitable  for liquid injection incineration."

OSW's source for  establishing those wastes "reported to
be incinerated" were data from the National Survey of  Hazardous
Waste Generators  and Treatment,  Storage and Disposal Facilities
Regulated Under RCRA in 1981.  Respondents to the  Survey*
were asked to report  the waste code, physical form,  handling
method, and quantities of wastes managed at their  facilities
in 1981.  Potential incinerability was determined  solely
on the basis of waste rankings (as good, potential,  or poor
candidates) in the Engineering Handbook.

     Applying their definitions, OSW came up with  three
lists of incinerable  LOHWs.   These lists are shown in  Exhibit A-l
List A represents those wastes labeled in the Engineering
Handbook as good  or potential candidates for liquid  injection
*Two survey questionnaires provided data on incinerated wastes.  The TSD
 General Questionnaire asked respondents to report data on each of the 10
 top waste streams handled at their facility. Those facilities also sent an
 Incinerator Questionnaire were asked to provide similar and more extensive
 data for the top five waste streams incinerated.
                            A-l

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                                       EXHIBIT A-l
                    Lists  of  Liquid  Organic  Hazardous  Wastes
                      Developed By The Office of  Solid  Waste
                         For  The  Incineration Market  Study
LIQUID ORGANIC HAZARDOUS WASTES
LIST A: GOOD OR POTENTIAL WASTE CODE CANDIDATES FOR LIQUID INJECTION INCINERATION
F001
F002
F003
F004
F005
KOI 5
K023
K047
P002
P003

DOOO
D001
D002
D003
D004
D005
D006
D007
D008
0009
D010
D011
D012
D013




P005
P020
P022
P028
P039
P041
P042
P063
P068


DOU
D015
D016
D017
F017
F018
F019
K071
K073
K074
K078
K079
K081
K082




P069
P081
P089
P094
P097
PI 02
U002
U003
U004

LIST
K083
K085
K086
K087
K088
K089
K091
K093
K094
K099
K103
K104
K106
POOO
LIST C:



U008
U009
U012
U019
U023
U031
U037
U041
U044

U046
U051
U053
U056
U057
U066
U069
U070
U074

B: SUITABILITY
P123
UOOO
U240
U242
U244
X003
X006
X007
X008
X009
X011
X012
X013
X014
POOR
F006
K001
K016
X015
X016
X017
X020
X021
X022
X023
X024
X025
X026
X028
X030
X031
X032
WASTE CODE
KOI 8
K036
K052
U076
U077
U078
U080
U083
U098
U103
U107
U108

FOR LIQUID
X034
X035
X036
X037
X039
X040
X042
X043
X044
X045
X046
X048
X049
X050
U110
U112
U114
UH7
U123
U124
U130
U133
U138

U140
U154
U155
U156
U159
U161
U162
U169
U180

U196
U209
U210
U213
U220
U223
U226
U227
U228

INJECTION INCINERATION
X051
X052
X053
X054
X059
X062
X063
X069
X070
X071
X072
X075
X076
X077
CANDIDATES FOR
P033
P074
P095
PI 06
U043
U122
X078
X080
X081
X084
X087
X092
X093
X096
X098
X099
XI 06
X110
X111
X1 14
X116
X117
XI 23
XI 27
XT 28
XI 29
XI 30
XI 31
X132
X137
XI 38
X142
X143
X144
U239
X001a
X002
X004
X018
X019
X029
X033
X038

UNKNOWN
X145
X146
X147
X148
XI 49
X151
XI 52
XI 53
XI 55
X158
XI 59
XI 60
X161

X056
X058
X064
X065
X079
X082
X094
X095
X100
X104

XI 63
XI 64
XI 67
XI 68
X169
XI 73
XI 74
XI 75
XI 76
XI 77
XI 78
X181
XI 82

XI 05
X1 13
XI 20
X121
XI 24
XI 25
X150
XI 70
X171
XI 79

XI 83
X184
XI 85
XI 86
X187
XI 89
X191
X194
Y001
Y002
9995b
9998C
9999d

LIQUID INJECTION INCINERATION
U134
U177
U188
U189
U192
U201









a)   "X" code wastes are a coding convention developed for the RIA National Survey to designate combinations
    of EPA waste codes (i.e.,  mixtures).
b)   Survey code for respondents who indicated a waste did not have an EPA waste code.
c)   Survey code for respondents who did not know the right EPA waste code.
d)   Survey code for responses that could not be ascertained.
                                          A-2

-------
incineration.  Most, but not all, of these wastes were reported
as incinerated in 1981.  List B are those wastes OSW determined
to be of "less certain incinerability," but could not exclude
as potentially incinerable.  These wastes include the "D"
wastes, wastes containing "D" wastes, and other wastes not
characterized by incinerability or incineration technology
in the Engineering Handbook.  Some of these wastes were
reported incinerated as a liquid in 1981.  List C wastes
were also reported frequently to be incinerated as a liquid
in 1981.  The Engineering Handbook, however, ranked these
wastes as poor candidates for incineration or not suited
for liquid injection.

     All three lists were considered to constitute the "universe"
of LOHWs for purposes of the incineration market study,
despite some of the inherent uncertainties.  To limit some
of the data development necessary for the study, a waste
categorization scheme was applied to these lists.  This
scheme narrowed the analysis down from 294 individual waste
codes to 16 waste categories.  Exhibit A-2 presents this
categorization scheme.  This scheme itself is an expanded
and modified version of one used by the State of Michigan
in "Hazardous Waste Management in Michigan:  A Status Report
and Review of Future Options."(22)
                             A-3

-------
                                       EXHIBIT A-2
                    LOHW Waste  Code Categorization  Scheme
                Developed  for  the  Incineration Market  Study
    GROUP
                 INCLUSIVE LOHW CODES
   I.   IGNITABLES
  II.   CORROSIVES
 III.   REACTIVES
  IV.   METAL BEARING
   V.   PESTICIDES

  VI.   SOLVENTS
 VII.   ELECTROPLATING

VIII.   MISC. PROCESS

  IX.   INORGANIC PIGMENTS

   X.   ORGANIC CHEMICALS


  XI.   EXPLOSIVES

 XII.   PETROLEUM REFINING

XIII.   IRON & STEEL

 XIV.   INORGANIC CHEMICALS

  XV.   MISC. COMMERCIAL CHEMICAL
       PRODUCTS
DOOO,  D001, X014, X020, X045,  X046, X077, X092, XI29,
X130.  X176, X177, X185. X186,  X187

D002.  X009, X012. X050, X052,  X053, X054, X062, X076,
X093,  X111, X137, XI51, X163,  X178, XI84
D003
D004-D011,  X006, X017, X023,  X025, X026, X035, X036, X037,
X039,  X043, X051, X059, X063, X075, X114, X116, X117, X131,
X142,  X143, X144, X145, X146, X149, X153, X167, X191, X138,
X194

D012-D017,  K036, K099, X158

F001-F005,  X001, X002, X003,  X004, X013, X016, X018,  X033,
X058,  X064, X095, X096, X104, X113, X179, X008, X069, X071,
X078,  X079, X099, X100, X121, X123, X127, X148. X150, X161,
XI68,  XI69, X038

F006,  X007, X024, X040

F010,  K086, K087, K001, X174

X087

K009,  K015, K016, K018, K074, K078, K079, K081, K082,
K083,  K085, K088, K093, K103, K104, X084, XI28, X044

K047,  XI47, XI55
 XVI.  NOT CLASSIFIED
NONE
K071, K073,  K106

P063, P068,  P106, U002, U003, U043, U023, U031, U053, U056,
U196, U220,  U223, U123, U133, U154, U074, U'080, U117, U098,
P074, U188,  U134, U122, X019, X029, X031, X032, X056, X065,
X070, X072,  X080, X082, X094, X098, XI05, XI06, X120, XI24,
X125, X132,  X170, X171, X181, X182, X183, X159, X160, X030

X021, X022,  X028, X034, X042, X048, X049, X081, XI10, X152,
X164, X175,  X189, Y001, Y002, 9995, 9998, 9999, X015, X173
        A-4

-------
                          APPENDIX B

    ESTIMATION  OF  THE  TOTAL  QUANTITY OF  LOHWs  INCINERATED
                     ON-SITE AND OFF-SITE
     Once a "universe" of incinerable LOHWs was set, OSW's
efforts in their Task 1 study shifted to estimating:

          The total quantity of LOHWs managed by technology

          The percentages of LOHWs managed on-site and off-
          site by technology.

This proved to be a complicated piece of analysis for the
incineration market study.  Complications arose in a variety
of forms ranging from statistical uncertainties in the data
to attempting to define an off-site versus on-site definition,
in the context of the RIA National Survey data, suited to
the market study.  This appendix provides some of the background
and analysis behind OSW's data.

1.   Quantities of LOHWs Incinerated

     Quantities of LOHWs incinerated in 1981 were developed
by OSW from responses to the 1981 RIA National Survey.  These
data are the sourc.e of the 0.9 million metric tons  (MMT) low-
range case baseline estimate cited in Chapter III.  Exhibit B-l
presents the quantities of wastes incinerated by LOHW waste code.
The amount of liquid incinerated was drawn from responses
to the Incinerator Questionnaire.  This was an important decision
                            \
because, as Exhibit B-2 illustrates, quantity incinerated
estimates drawn from responses to the TSD General Questionnaire
sum to a larger overall quantity (1.3 MMT).
                              B-l

-------
                EXHIBIT B-l
Quantities of  LOHWs  Incinerated in  1981
      TOTAL A+B+C  =230,791,000 GAL. (0.86 MMT)°
LIST WASTE CODE
A F001
F002
F003
F005
KOI 5
P063
P068
U002
U003
U023
U031
U044
U053
U056
U074
U080
U098
U117
U123
U133
U154
U196
U220
U223
X001
X002
XI 24
XI 79

B DOOO
D001
D002
D003
K083
K085
K093
X013
X015
X028
X042
X072
X110
XI 75
XI 82
9995

SAMPLE SIZE
1
6
22
20
1
5
1
5
2
1
1
1
1
2
1
3
1
2
1
1
7
1
4






1
59
9
9
2
1
1
2
2
2
1
1
1
1
1
13
R-2
AMOUNT LIQUID INCINERATED (103 GAL)
9
1.614
24,227
17,665
153
62
40
518
2,438
253
96
1
25
108
738
2
2
2
1
24
80
1
1
48
6
144
1
6
48,262 (0.18 MMT)a
5,151
61.154
2,860
3,488
528
396
178
655
1,491
359
6,246
710
642
432
80,864
12,455
177,609 (0.66 MMT)a

-------
                              EXHIBIT  B-l  (Continued)
LIST
C








WASTE CODE
K001
KOI 6
KOI 8
K036
P074
PI 06
U043
U122
U188
SAMPLE SIZE
1
1
1
1
1
1
3
6
5
AMOUNT LIQUID INCINERATED (103 GAL)
18
983
1,542
81
235
1
656
246
T.158
                                                                        4.920  (0.018 MMT)£
a)  Assumes 268.8519 gallons per metric ton.
SOURCE:  (1)
                                           B-3

-------
                                                               EXHIBIT B-2
                           Variations  in Estimated Quantities of  LOHWs  Incinerated  in  1981
LOHW Category
Incinerator
Questionnaire
As Data Source
7/84°
Total Incinerated
Quantity (Gallons)
Percent
of
Total
Incinerator
Questionnaire
As Data Source
5/84 & 7/84b
Total Incinerated
Quantity (Gallons)
Percent
of
Total
TSD General
Questionnaire
As Data Source
7/84c
Total Incinerated
Quantity (Gallons)
Percent
of
Total
03
 I
£»•
IGNITABLES
CORROSIVES
RE ACTIVES
METAL BEARING
PESTICIDES
SOLVENTS
ELECTROPLATING
MISC. PROCESS
INORGANIC PIGMENTS
56,061.954
 4,585,490
 3,849,897
   177,734
    81,111
32,146,219

    51,385
25.9
 2.1
 1.8
 0.08
 0.04
14.9

 0.02
66,305,000
 2,860,000
 3,488,000

    81,000
44,323,000

    18,000
28.7
 1.2
 1.5

 0.04
19.2

 0.01
49.829,360
 5,011,298
 3,713,934
   203,480
   178,781
72,992,913

    34,266
     Computer run provided through OSW, 7/30/84.
     kflSW data in draft and final  Task 1 report.
     cComputer run provided through OSW, 7/25/84.
14.2
 1.4
 1.1
 0.06
 0.05
20.7

 0.01
ORGANIC CHEMICALS
EXPLOSIVES
PETROLEUM REFINING
IRON & STEEL
INORGANIC CHEMICALS
MISC. COMMERCIAL CHEMICAL PRODUCTS
OTHER

3,507,380 1.6
-
62,799 0.03
-
-
88,686,950 41.0
27,066,001 12.5
216,276.920
(0.82 MMT)
3,780.000 1.6
-
-
-
-
88,311.000 38.3
21,625,000 9.3
230,791,000
(0.87 MMT)
2,915,454
39.884
8.144,221
-
-
200,595,158
8.348.141
352,006,890
(1.33 MMT)
0.8
0.01
2.3
-
-
57.0
2.4


-------
     Quantities incinerated in 1981 were based on the Incinerator
Questionnaire rather than the TSD General Questionnaire for
four reasons:

          The Incinerator Questionnaire asks for a direct
          estimate of liquids incinerated

          Responses to the Incinerator Questionnaire appear
          to be more consistent on the quantity of wastes
          incinerated relative to other data for those facilities
          who also responded to the TSD General Questionnaire

          None of the Incinerator Questionnaire-derived quantities
          had to be imputed whereas about 20 percent of the
          TSD General Questionnaire-derived data had to be
          imputed (i.e., insufficient data provided)

          Wastewater in tanks was erroneously included as
          incinerated waste at one facility responding to the
          TSD General Questionnaire leading to an overestimate
          of 196 million gallons (0.7 MMT).

While OSW considered the Incinerator Questionnaire to be the
better source of data, they caution that, even so, the
statistical reliability of these data is poor due to small
sample sizes.  In fact, these sample sizes (shown in Exhibit B-l)
are smaller than the TSD facility sample that yielded confidence
intervals of roughly 50 percent at the 95 percent confidence level.

     This statistically-based caution applies to all uses of
the RIA National Survey data in the market analysis.  Questionable
statistical reliability was cited, for example, in OSW's decision
to advise against using the RTA National Survey data to develop
regional waste generation and management estimates.  OSW also
                               B-5

-------
questions the validity of using these data to develop on-site and
off-site (noncommercial v. commercial) splits on the same grounds.
OSW's concerns and cautions are statistically sound and valid.  At
the same time, the RIA National Survey data are the "best" available
usable for an analysis of the incineration market.  Therefore,
while these data have been used and interpreted beyond statistically
valid limits, their use to suggest possible outcomes seems
appropriate.  As more and better data become available, the
market analysis can be adjusted.

2.   Quantities of Wastes Managed By Other Technologies

     OSW provided national-level estimates of all wastes and LOHWs
managed by all other, non-thermal technologies.  These data are
drawn from TSD General Questionnaire responses.  While some of
these technologies were also covered in specific questionnaires
(like the Incinerator Questionnaire) , OSW elected not to utilize
these other data.

     Exhibit B-3 summarizes the data provided by OSW and compares
it with the estimates cited in the report on the 1981 National
Survey results.  This comparison points out two other problems
in interpreting these data correctly:  double-counting and
imputations.  Wastes frequently are subject to multiple process-
ing at a facility.  This means that they can be counted several times
when a respondent provides a figure for the total quantity of wastes
managed.  This is one reason that the by-technology totals exceed
the estimated total of 71.3 billion gallons (264 MMT) of wastes man-
aged in 1981.  The by-technology totals differ between the two sources
as OSW imputed national totals from its survey sample and imputed
data for non-respondents when developing its 1981 National
Survey report.  However, much of the data provided by OSW for
this study reflects the "as responded" totals drawn from the
RIA National Survey data base without the national weights,
imputations, and other adjustments.
                                B-6

-------
                                               EXHIBIT B-3

                        Total Wastes and LOHWs Managed By Management Technology
CO
i
Technology
Treatment Tanks
Treatment Impoundments
Incineration
Other Treatment
Total Treated: -
Injection Well
Landfill
Land Application
Disposal Impoundments
Other Disposal
Total Disposed:
Storage Impoundments
Storage Tanks
Storage Containers
Waste Piles
Other Storage
Total Stored:
vs. Total Wastes Managed3
Quantity of
Hazardous Wastes
Managed3
(109 Gal)
8.7
16.6
0.5
4,6
30.4 (47.5)
8.6
0.8
0.1
5.1
0.2
14.8 (14.7)
14.1
5.1
0.2
0.4
0.3
20.1 (36.5)
65.3 (98.7)
71.3
a. Data taken from 1981 National Survey Report. Numbers
b. Technology totals from 1981 National Survey data base
Quantity of Quantity of LOHWs
Hazardous Wastes Managedb
Managed13 (109 Gal)
(109 Gal)
15.5
11.0
0.4
"
26.9
51.8
0.9
0.1
4.0
56.8
10.7
4.0
0.1
0.2
-
15.0
98.7
in parentheses
for TSDs reporl
N.E.
11.1
0.2
N.E.

51.9
0.9
N.E.
4.0
N.E

10.7
N.E.
N.E.
N.E.
N.E.


are reported technology group
:ing the percentage of wastes r
             from off-site.

       N.E.  =  Not estimated.

-------
3.   On-Site and Off-Site Splits of LOHWs Managed By  Technology

     An initial calculation in nearly  every scenario  analysis
is determining the quantity  of wastes managed,  by technology,
at noncommercial and commercial facilities.   These on-site
versus off-site splits*  become important  later  in each analysis
as each regulatory change  is assumed to  bring about a shift
between managing wastes  on-site and off-site.   This shift
would  supposedly reflect a generator's decision to no longer
manage some or all of its  own wastes, preferring to send
these  wastes off-site to a commercial facility, or, alternatively,
a decision to manage more  of its own wastes  rather than sending
wastes off-site.

     This part  of  the Task 1 data  analysis focused  on adapting
the  RIA National Survey  data to the market analysis definition
of a commercial facility to  establish on-site/off-site splits
for  all wastes and LOHWs managed by technology.  A commercial
facility,  for purposes of  the market analysis,  is defined
as privately owned and operated receiving most  of its wastes
from off-site and other  firms.**  The on-site/off-site split
is determined, therefore,  by setting a threshold, that varies
by technology, where the National Survey data show that most
of the wastes managed by reporting facilities came from
off-site,  and where most of  these off-site-origin wastes
came from other firms.
 *For purposes of this study, the terms "on-site" and off-site" are equated
  to the terms "noncommercial" and  "commercial," respectively.  See Appendix E
  for definitions of these terms.
**This definition differs slightly from the one used in the RIA National Survey
  report.  The key distinction is a commercial facility is defined in the survey
  report as one that receives 50 percent or more of its waste from other firms
  without reference to the on-site or off-site origin of the waste.  This is
  intended to allow for some generation of wastes on-site at the commercial
  facility and for intrafirm shipments between commercial facilities under the
  same ownership.  The definition used in the market analysis, while allowing
  for these exceptions, emphasizes that most of commercial facility's business
  is in the form of other firm's wastes sent from off-site.

                               B-8

-------
     Unfortunately,  Exhibit  B-4  shows  that  establishing  the
on-site/off-site split on the basis of this definition of
a commercial facility is not simple.  It was expected that
as the percentage of wastes received from off-site increased
that the portion of these off-site wastes originating from
other firms would also increase.  This trend can be seen,
but it is not consistent.  The clearest exception can be
seen at the 100 percent from off-site level.  Of this total,
80 percent represents shipments between a generator and its
own captive (i.e., noncommercial) facility that should not
be counted as commercial activity.  Exhibit B-5 shows
that this lack of consistency also appears in attempting
to determine on-site versus off-site splits, for all wastes
managed, by technology.

     Nevertheless,  some  delineation  between quantities of
wastes managed on-site versus off-site needs to be made to
perform the market analysis.  As such, "commercial thresholds"
were set based upon the relationship of the percentage of
wastes received from off-site with the percentages of off-
site wastes received from the same and other firms.  Referring
to Exhibit B-5, for example, these thresholds were set at
60 percent, 10 percent, and 70 percent wastes received from
off-site for all wastes incinerated, landfilled, and injected,
respectively.  These thresholds appear to be reasonable matches
to the market analysis commercial definition.

     These  "commercial"  thresholds establish how much waste
is managed on-site (i.e., at noncommercial facilities) versus
off-site (i.e., at commercial facilities) by technology.
The cumulative percentage of wastes managed up to the threshold
is equated to the percentage of wastes managed on-site;
the remaining percentage becomes the percentage of wastes
managed off-site.  As summarized in Exhibit B-6, these on-
site/off-site splits by technology for all wastes derived
from the RIA National Survey data base are:

                           B-9

-------
                                                        EXHIBIT  B-4
                           Definition  of Commercial  Activity:   Percent  of All Wastes
                         Received By  TSDs  from Off-Site Either  Same-Firm or Other-Firm
                                         Origin  - 1981  RIA National  Survey
a
i
      Percent of Total Wastes
      Managed Received From
            Off-Site
  Cumulative  Percent
    Of Total  Wastes
       Managed
    Same-Firm Origin Wastes -
        Percent of Off-Site
              Total
          Other-Firm Origin Wastes
             Percent of Off-Site
                   Total
0
5
10
15
25
30
40
55
75
90
95
100
82.4
89.9
90.2
90.2
90.7
90.7
90.7
90.7
91.0
91.0
91.1
100.0

100
0
99. 4
58.1
100
0
0
0
100
0
81.1

0
100
0
41
0
100
100
100
0
100
18



.6
.9






.9
      Total Quantity of
       Wastes  Managed
          (109  Gal)
  Total Quantity of
Wastes On-Site Origin
      (109 Gal)
  Total Quantity of
Wastes Off-Site Origin
    (109 Gal)
                                                                                         Quantity of Off-Site Wastes
Same-Firm Origin
   (109 Gal)
Other-Firm Origin
  (109 Gal)
              60. la

      Percent of  all wastes
        managed:
         54.6

         90.8
         5.5

         9.2
      4.3'
                                                          7.2
     1.2C

     2.0
      Percent  of  Off-Site-
        origin wastes:
                                                         78.2
                                                   21.8
      a.  Sum of all wastes managed by TSDs reporting what percent of their wastes was received from off-site.
      b.  Of this total, 4.2 billion gallons were same-firm wastes received by TSDs reporting that 100  percent of the wastes managed were
          off-site-origin wastes.  Further examination showed that 96 percent of this amount was indeed shipments between generators and
          captive TSDs (i.e.,  intrafirm shipments).
      c.  Amount reflects preferred definition of "true" off-site commercial activity.

-------
                                          EXHIBIT B-5
                      Defining a  "Commercial" Threshold:   On-Site
               and Off-Site  Splits of  All  Wastes Managed By  Technology
Percent of
Wastes
Managed fr<
Off-site









CO
1
I""1
t— *











0
1
2
3
4
6
7
8
10
13
IB
25
33

54
62
64
ft7
O/
73
74
86
90
97
99
too

Quantity of
*, Wastes
Managed
<109 Gal)
324.513,963
3.006,140
4,230,895
7,081,554
140,151

6,178,881

119,439

4.178,258
14,232


2,074.907
1 n^"s M.*,
1 t\JJJ tO*»3


37.076
42,740
512,579
3,133,076

INCINERATION
LANDFILL - INJECTION WELL
Cumulative * of Total * of Total Quantity of Cumulative % of Total * of Total Quantity of Cumulative % of Total % of Total
% of Wastes Offsite-Origin Of fsite-Orlgin Wastes » of Wastes Offsite-Origin Of fsite-Origin Wastes % of Wastes Offsite-Orlgin Offslte-Orlgin
Managed Wastes Received Wastes Received Managed Managed Wastes Received Wastes Received Managed Managed Wastes Received Wastes Received
From Same Firm From Other Firm <109Gel> From Same Firm From Other Firm <109 Gal) From Saw Firm From Other Firm
91.1
91.9
93.1
95.1
95.1

96.8

96.8

98.0
98.0


98.6
OO Q
VO.W


98.9
98.9
99.1
100.0
0
8.3
100
95.6
100

100

96

58
100


0
34



100
100
0
0.1
0 54,111,337 6.1 0 0 51.427,081,724 99.2 0 0
91.7 325.766,562 42.6 11.1 88.9 35,666,223 99.3 6.7 93.3
0
4.4
0
1.970,981 42.8 100 0
0
24,939,175 99.3 100 0
rTMJPQTTAI TVIRF
-------
                                                       EXHIBIT  B-6
                                 On-Site v.  Off-Site National Splits By Technology
                                     For  All Wastes  -  1981  National  Survey  Data
Percent Offsite-
Origin Used to
Technology Define
"Commercial"^


Incineration 60
Injection Well 70
Landfill 10
Disposal Impound- 70
ments
Percent Of All Wastes Managed13
National Survey
Estimates
On-Sitec Off-Sitec

93 7
98.8 1.2
42.8 57.2
96.8 3.2

Market Analysis Estimates
Low-Range Case**
On-Site Off-Site
90. Oe 10. Oe
97.5 2.5
43 57
95 5

Mid-Range Cased
On-Site Off-Site
90. Oe 10-0
97.5 2.5
30 70
95 5

High-Range Case**
On-Site Off-Site
90. Oe 10. Oe
97.5 2.5
16 84
95 5

03
I
M
NJ
     a)  Derived from  the distribution of percent offsite-origin wastes received by technology and the percentages  of  same-
         firm v. other-firm origin for offsite wastes  managed  (see also Exhibits B-4 and B-5).  Commercial thresholds  set
         at the point  where most wastes were received  from off-site and other firms.
     b)  Determined  from cumulative percentage of wastes managed up to commercial threshold (see also Exhibit B-5).

     c)  Are derived from application of commercial threshold  to RIA National Survey data.  RIA National Survey report does
         not make an off-site v. on-site distinction.   (See also Appendix E;  on-site = noncommercial, off-site = commercial),
     d)  Represent three cases as part of sensitivity  analysis of demand for incineration.  Reflect variability in  key
         estimates/assumptions over a lowest to highest possible number range (see also Chapters III. IV,  and VI and
         Appendices  c  and D).
     e)  Are on-site v. off-site splits  assumed as applied to liquid organic hazardous wastes only.

-------
          Incineration -  93  percent on-site, 7 percent  off-
          site

          Injection wells  -  98.8  percent on-site,  1.2 percent
          off-site

          Landfills - 43  percent  on-site, 57 percent off-
          site

          Disposal impoundments  - 96.8 percent on-site,
          3.2 percent off-site.

This exhibit  also compares the Survey-derived  splits with
the splits assumed in each of the  low-range, mid-range, and
high-range regulatory scenarios.   For  three technologies--
incineration,  injection wells, and disposal impoundments--
the Survey-derived on-site/off-site distributions compare
favorably with the distributions assumed in the  market analysis
scenarios.  Lacking any other available  estimates, therefore,
these assumed splits  were used across  all three  sensitivity
analyses* of  the  projected demand  for  commercial incineration
capacity.  Only the landfill restrictions scenario analysis
involved varying  the  on-site/off-site  distribution as  part
of the sensitivity analysis.  This variation reflects  a difference
in estimates  of this  distribution  for  landfills  across available
sources.  The Survey-derived distribution of 43  percent on-
site and 57 percent off-site for landfilled wastes is  one
of these estimates,  and has been used  as part  of the low-
range case in the sensitivity analysis.   Alternatively, a
comparison of the National Survey's estimate of  3.2 million
metric tons of wastes landfilled in 1981 with  an estimate
of wastes landfilled  at commercial facilities  in 1980  (2.7
  A sensitivity analysis was made part of the market analysis given the
  variability and uncertainties in key estimates and assumptions like the on-site/
  off-site distribution by technology.  Chapters I, II, and IV describe in more
  detail how the sensitivity analysis has been constructed; however, the basic
  the basic features  are a low-range, mid-range, and high-range case built
  from the range of possible values for certain estimates and assumptions as
  suggested by the available sources.

                                 B-13

-------
million metric tons) drawn from commercial hazardous waste
management industry surveys, indicates that the distribution
may be as high as 16 percent on-site and 84 percent off-
site.  This alternative distribution has also been incorporated
into the sensitivity analysis as a high-range estimates case.

     Exhibits  B-7  and  B-8  present  some  background  data behind
the on-site/off-site distributions by technology shown in
Exhibit B-6.  Exhibit B-7, in particular, shows the weighted
averages for the on-site/off-site splits by technology for
all wastes.  These averages are those presented in Exhibit B-6.
For comparison. Exhibit B-8 offers similar data, but only
for LOHWs.  The weighted on-site/off-site splits by technology
for only LOHWs are also reasonably consistent with the market
analysis assumptions though some differences are evident.
                             B-14

-------
                                                                 EXHIBIT B-7
                                     On-Site  v.   Off-Site  National  Splits  by  Technology
                                           For  All Wastes  -  1981 National Survey Data

WASTE CATEGORY

IGNITABLES
CORROSIVES
RE ACTIVES
METAL BEARING
PESTICIDES
SOLVENTS
ELECTROPLATING
MISC. PROCESS
INCINERATION
QUANtitY
MANAGED*
(GAL)
56.061 ,954
4,585,490
3.849.897
177,734
81,111
32.146.219
"
51.383
1 OF ALL
WASTES
MANAGED
25.9
2.1
1.8
0.08
0.04
14.9
"
0.02
*
MANAGED
ONSITEb
93
94
98
100
IOC
95
"
35
I
MANAGED
OFFSITE'
7
6
2
0
0
5
"
63
INORGANIC PIGMENTS • '
ORGANIC CHEMICALS
EXPLOSIVES
3.507.380
1.6
100
0

QUANTITY
MANAGED
(GAL)
LANDFILL
» OF ALL
WASTES
MANAGED
15.966,963 1.8
70,635,312 7.9
2,906,346 0.3
131,278,330 16.9
3,740,239 0.4
27,186.450 3.0
55.539,723 6.2


6,383.300 0.7
3,802,302 0.4
12,454,970 1.4
85,594 0.01
PETROLEUM REFINING 62.799
IRON & STEEL

0.03
_
0
.
100
.
INORGANIC CHEMICALS -
MISC. CHEM. PRO-
DUCTS
OTHER
TOTAL
WEIGHTED AVERAGES
88.686.950

27.066.001
216.276.920
,c
41

12.5
98

75
2

25
33,769,670 3.0
138,119.821
17.6
3,906,395 0.7
312,788,720 34.9


35,425,271 3.9
I
MANAGED
ONSITE
20
13
40
10
0
0.1
11

0.3
0
86
100
0.4
10
77
96

45
896,010,008

93
7


43
t
MANAGED
OFFSITE
80
INJECTION WELL
QUANTITY j " "
MANAGED
(GAL)
f OF ALL
WASTES
MANAGED
25,933,972 0.4
87 3,011,690,259 44.2
60
90
100
99.9
89

99.7
100
14
0
99.6
90
23
4

35
614,848,112 9.0
541,629.110 8.0
290,641,973 4.3
438,489 0.01


%
MANAGED
ONSITE
19
99.8
96
98
99.8
0


I
MANAGED
OFFSITE
81
0.2
4
2
0.2
100

DISPOSAL IMPOUNDMENTS
QUANTITY I """" * '
MANAGED
(GAL)
S OF ALL
WASTES
MANAGED
3.312,309 0.1
192.720,506 4.7
597,214 0.01
152.074.247 3.7
7.028,198 0.2
16.406,928 0.4


3.832.877 0.1
-
-
991,390,521 14.6
-
99.8
-
0.2
-
-
1 .066.333 0.03
5.555.434 0.1
- 3.500.000.000 87.3
22,635,650 0.3
80
20
50,912.702 1.3
1.057.379 0.03
350.703.316 3.1


960,366,560 14.1
99.8

99.3
6.810,481 ,962
57


98.8
0.2

0.5
73.406.704 1.8


2.060,868 0.05
»
MANAGED
ONSITE
0.2
90
100
70
100
96

100
-
0
100
100d
5
too
100

41

MANAGED
OFFSITE
99.8
10
0
30
0
4

0
-
100
0
0
95
0
0

59
4.012.031.699
1.2


96.8
3.2
TOTAL QUANTlTl
MANAGED BY
CATEGORY

103.277.198
3.279.651 .767
622.201 .569
845.159.421
3.821 .350
357.002.840
72.385.192

10.267.762
3.802.502
1.008.619.204
5.641 .028
3.333.832.469
231.668.173
6.963.774
825.587.690

1.024.918.700
11.934.801.000

* OF
ILL WASTES
MANAGED

0.9
27.5
5.2
7.1
0.03
3.0
0.6
«j»
O.O9
0.03
8.5
0.09
»jt
*o
1 .9
0.06
6.9

8.6


a.  For all TSDs reporting what percent of their wastes ware received from off-site.
b.  Calculated by applying commercial thresholds for all wastes.
c.  Weighted by categories' percentages of all wastes managed
d.
In the RIA data base, this quantity of wastes is actually Indicated to be 100 percent from off-site. Further examination of this larga quantity, however. Indicated that these wastes wer.
actually same-firm origin wastes that should be classed as noncommercial (I.e.. on-site).

-------
                                                       EXHIBIT  B-8
                                On-Site v. Off-Site  National  Splits  by  Technology
                                  And  LOHW Category  -  1981  National  Survey Data
LOHW CATEGORY
INCINERATION
QuANTlTr"
MANAGED"
(GAL)
^loF
ALL LOHWs
MANAGED
(
MANAGED
ONSlTEb
I
MANAGED
OFFSITE'
LANDFILL
OUANtlTr
MANAGED
(GAL)
1 OF
ALL LOHWs
MANAGED
f
MANAGED
ONSITE
I
MANAGED
OFFSITE
INJECTION WELL
OUANtlTY
MANAGED
IGAL)
f OF
ALL LOHWs
MANAGED
1
MANAGED
ONSITE
r
MANAGED
OFFSITE
DISPOSAL IMPOUNDMENTS
OuANtlTr
MANAGED
(GAL)
I OF
ALL LOHWs
MANAGED
1
MANAGED
ONSITE
i
MANAGED
OFFSITE
TOTAL OUANT IT-
MANAGED BY
CATEGORY
* Of
ALL LOHWs
MANAGED













CO
1
V-*
<"T\
U '
IGNI TABLES
CORROSIVES
RE ACTIVES
METAL BEARING
PESTICIDES
SOLVENTS
ELECTROPLATING
MISC. PROCESS
IHOWGANIC PIGMENTS
ORGANIC CHEMICALS
EXPLOSIVES
PETROLEUM REFINING
IRON & STEEL
INORGANIC CHEMICALS
MISC. CHEM. PRO-
DUCTS
OTHER
56,061,954
4,585,490
3,849.897
177,714
81.111
32,146,219
-
51.385
-
3.507.380
.
62.799
.
.
88,686,950

27,066,001
25.9
2.1
1.8
0.08
0.04
14.9
-
0.02

1.6
-
0.03
-
.
41

12.5
93
94
98
100
100
95
-
35
-
too
-
0
-
-
98

75
7
6
2
0
0
5
-
65
-
0
-
100
-
-
2

25
TOTAL 216,276.920

WEIGHTED AVERAGES:0


93
7
12,689,103
70,655,629
2,906,349
147,441,643
759,274
27,186,504
52,829,235
4.279,159
3,802,503
11,242,229
' -
10,277,575
-
5,906,399
307,292,033

35,425,271
692,692.906

1.8
10.2
0.4
21.3
0.1
3.9
7.6
0.6
0.5
1.6
-
1.5
-
0.9
44.4

5.1


20
13
40
10
0
0.1
11
0.3
0
66
-
0.4
-
77
96

45

52
80
87
60
90
100
99
89
99
too
14
-
99
-
23
4

55

48
25,936,008
2,963,663,191
614,052,596
540,353,621
-
.9 291,804,238
-
.7
-
-
-
.6
-
-
261,479,526

960,366,560
5,657,655,740

0.5 19
52.4 99.8
10.9 96
9.6 98
-
5.2 99.8
-
-
-
-
-
-
-
-
4.6 99.8

17.0 99.5

98.9
81 5.312,309
0.2 192,720,506
4 597,214
2 152,074,247
-
0.2 7,028,201
16.406,928
3,832,877
-
1,066,333
460,172
621,241
-
1,057,379
0.2 73,253,475

0.5 2,060,868
456,491,750
1.1
1.2
42.2
0.1
33.3
-
1.5
3.6
0.8
-
0.2
O.I
0.1
-
0.2
16.0

0.5


0.2
90
100
70
-
100
96
100
-
0
too
too
-
100
100

41

84
99.8
10
0
30
-
0
4
0
-
100
0
0
-
0
0

59

16
99.999.374
3,231,624,816
621 ,406,056
840.047,245
840.385
358.165.162
69.236.163
8.163,421
3.802,503
15.815,942
460,172
10.961,615
.
6.963,778
730,711,984

1,024,918.700
7.023,117.316

1.4
46.0
8.8
12.0
0.01
5.1
1.0
0.1
0.05
0.2
0.01
0.2
_
0.1
10.4

14.6


a.  For all TSDs reporting what percent of their wastes were received from off-site.
b.  Calculated by applying commercial thresholds for all wastes to LOHW quantities.
c.  Weighted by categories' percentages of all LOHWS managed.

-------
                          APPENDIX  C

     MARKET ANALYSIS MODULES;   LOGIC  DIAGRAMS FOR BASELINE
      MARKET CONDITIONS  AND REGULATORY SCENARIO ANALYSES—
                   MID-RANGE ESTIMATES CASE

     The following logic diagrams trace the key data and
assumptions for the mid-range  estimates case for the baseline
incineration capacity  utilization module,  and each of the
regulatory scenario modules that estimate the demand for
incineration after RCRA  regulatory change.  Preceding each
module is a brief description  of its  objectives and results.
Sources of the data and  assumptions used are referenced.

     The more critical assumption in  each analysis are high-
lighted within dotted-line  boxes in the logic flow.  Variations
in these assumptions are perceived to have the greatest effect
on the projected outcomes.   Appendix  E incorporates these
variations in describing the low-range and high-range estimates
cases that are part of the  sensitivity analysis for each module.
All three cases—the low-range, mid-range, and high-range—are
built from the range of  estimates suggested by the sources
consulted for the key  data  and assumptions.  The sensitivity
analysis results are discussed in Chapter III, IV, and VI.

     Nine mid-range case modules are  presented.  These nine
include logic diagrams on:

          Baseline LOHW  incineration  capacity utilization

               LOHW volumes incinerated on-site and off-site*
               LOHW on-s"ite and off-site incineration capacity
 * As used here, reference to on-site and off-site should be interpreted
  as noncommercial and commercial, respectively.  See Appendix F for
  complete definitions of key terms in the market study.
                             C-l

-------
Incineration capacity utilization for PCBs

     PCB volumes incinerated (use phaseout, failures,
     carryover volumes)

     PCB liquids incineration capacity

Effects of restrictions on landfills

     Wastes landfilled on-site and off-site affected
     by restrictions

     Demand for present incineration capacity after
     restrictions

Effects of deep well injection restrictions

     Wastes injected in on-site and off-site wells

     Demand for present incineration capacity after
     restrictions

Effects of disposal impoundment restrictions

     Wastes disposed in on-site and off-site disposal
     impoundments

     Demand for present incineration capacity after
     restrictions
                 C-2

-------
          Effects of restrictions on wastes-in-boilers

               Hazardous wastes burned in boilers

               Demand for present incineration capacity after
               restrictions

          Addition of incineration-at-sea capacity

               Capacities of individual incinerator ships

               Availability of total land-based and at-sea
               incineration capacity

          Effects of Superfund clean-up activity on RCRA capacity

               Data needs and sources
               Data analysis

          Organic liquids likely to be listed as hazardous
          wastes

               Total estimated volume of organic liquids
          -    Volumes handled by current management methods.

Note that each regulatory scenario analysis module estimates
the demand for on-site and off-site LOHW incineration capacity
under static supply conditions, that is, available capacity is
held fixed for this instantaneous analysis at the practical
maximum commercial LOHW incineration capacity level of 300,000
metric tons (minus 48,000 metric tons of  ;apacity for liquids PCBs)
and 3.1 MMT of noncommercial LOHW inc*1'^ -ation capacity.  Refer
to Chapters II, III, and V for discussions of available capacity
and projected increases in capacity.
                             C -3

-------
       BASELINE LOHW INCINERATION CAPACITY UTILIZATION;
                   MID-RANGE ESTIMATES CASE
OBJECTIVE j
To estimate baseline LOHW incineration
capacity utilization by:
                         Estimating baseline quantities of
                         LOHWs incinerated on-site and off-
                         site

                         Estimating total on-site and off-
                         site LOHW incineration capacity
RESULTS:
On-site baseline incineration capacity
utilization = 40.4%
                    Off-site baseline incineration capacity
                    utilization = 55.3%

                    Net off-site LOHW incineration capacity
                    = 0.252 MMT
KEY DATA:
Total quantity of LOHWs incinerated =1.39 MMT
                    Total quantity of LOHWs incinerated on-site
                    =  1.253 MMT

                    Total quantity of LOHWs incinerated off-site
                    =  0.139 MMT

                    Total off-site LOHW incineration capacity
                    =0.30 MMT

                    Incineration capacity for PCBs = 0.048 MMT
                                C-4

-------
KEY ASSUMPTIONS:    90% of total LOHWs incinerated are
                    incinerated on-site; 10% off-site

  \                 Total LOHW incinerated capacity = 3.4 MMT

                    91.2% of total LOHW incineration capacity
                    is on-site; 8.8% is off-site
                              C-5

-------
                                      LOHW INCINERATION
                   BASELINE CAPACITY UTILIZATION:  MID-RANGE ESTIMATES CASE
INCINERATED LOHW  VOLUMES
 l—
        TOTAL QUANTITY OF
        LOHW INCINERATED
          1.392 MMTa
                                                          TOTAL QUANTITY OF LOHW
                                                          INCINERATED ONSITE
                                                               1.253 MMT
                  TOTAL QUANTITY OF  LOHW
                  INCINERATED OFFSITE
                       0.139 MMT
a)  Estimate based upon  range of estimates for commercial  incineration capacity utilization.
    Range suggested is from about 40 percent (low-range case)  to about 80 percent (high-range
    case) making mid-range case ~60 percent.  At 0.252 million metric tons of net commercial
    incineration capacity, 60 percent capacity utilization,  and 10 percent of total  LOHWs
    incinerated at commercial facilities, gives mid-range  baseline demand shown.

b)  Suggested by industry sources and analysis of RIA National Survey data (see Appendix C).

    LOHW INCINERATION CAPACITY
        TOTAL LOHW
        INCINERATION CAPACITY
              3.4 MMTa
                                                           TOTAL ONSITE LOHW
                                                           INCINERATION CAPACITY
                                                                 3.10  MMT
                  TOTAL OFFSITE LOHW
                  INCINERATION CAPACITY
                      0.300 MMTb
        TOTAL OFFSITE LOHW
        INCINERATION CAPACITY
             0.300 MMT
OFF-SITE CAPACITY
DEVOTED TO PCBs
INCINERATION
  0.048
"NET"  OFFSITE  LOHW
INCINERATION CAPACITY
      0.252 MMT
 a)  Estimate based upon modified  assumptions to Mitre's calculation, p.2-10 through 2-12  in
    the Interim Incineration RIA:  209  facilities x 595.4 gal/hr  x 7200 hr/yr x 0.00378 gal/metric
    ton = 3.4 million metric tons.  7200 hr/yr derived from industry sources.

 b)  Estimate derived from contacts with commercial incineration firms.

 c)  Relationship established by 0.3 MMT-f 3.4 MMT.
 d)  See PCB module.
                                            •BOOZ ALLEN & HAMILTON INC
                                           C-6

-------
                                    LOHW INCINERATION
              BASELINE CAPACITY UTILIZATION:  MID-RANGE ESTIMATES CASE (CONT'D)
CAPACITY UTILIZATION ESTIMATE
    TOTAL QUANTITY OF LOHW
    INCINERATED ONSITE
        1.253 MMT
     40.42 of
     capacity
TOTAL ONSITE LOHW
INCINERATION CAPACITY
     3.10 MMT
    TOTAL QUANTITY OF LOHW
    INCINERATED OFFSITE
      0.139 MKT
-»-   55.32 of
     capacity
"NET" OFFSITE LOHW
INCINERATION CAPACITY
     0.252 MMT
                                        •BOOZ ALLEN & HAMILTON  INC.
                                       C-7

-------
                     PREFACE TO PCB MODULE








     This module was developed principally to estimate commercial



incineration capacity for liquid PCBs so that this capacity



could be subtracted out from commercial capacity for all



LOHWs.  Estimates of the demand for liquid PCB incineration



capacity are presented solely to make this module similar



to the others in this appendix.  In fact, part of the demand



analysis is determined by the estimate for capacity.








     Industry sources and EPA staff were consulted on estimating



commercial incineration capacity for liquid PCBs.  The data



for capacity shown in the module were provided by EPA staff



in May 1984, and reflect permit limits established at that



time.  According to industry sources, these permit limits



have since changed or soon will change, and must be interpreted



carefully as their phrasing often determines the maximum



throughput of PCBs (and their form) alone and/or the throughput



of PCB-contaminated materials.  In the module, capacity expressed



as metric tons of PCBs per year has been equated to metric



tons of PCB-contaminated material per year.  In actuality,



PCBs probably account for 15-20 percent of the total voume



throughput.

-------
         INCINERATION CAPACITY UTILIZATION FOR PCBs*
OBJECTIVE:
To estimate net incineration capacity
for non-PCB LOHWs by:

     Estimating total volumes of  liquid
     PCBs incinerated

     Estimating total incineration capacity
     for PCBs
RESULTS:
Total volume of PCBs incinerated =  0.048 MMT
Total incineration capacity for PCBs  =
0.048 MMT
Net incineration capacity for non-PCB
LOHWs = 0.252 MMT
KEY DATA:
Total volume of PCBs to be incinerated  from
PCB capacitors and askarel =8.9 million  gallons

     3.2 million gallons form use phaseout
     of PCB capacitors and askarel  transformers

     4.1 million gallons from removal of
     mineral oil transformers

     1.6 million gallons from storage

Total incineration capacity  for PCB = 0.048 MMT
KEY ASSUMPTIONS:
Incineration capacity utilization  for  PCBs
is at 100 percent.
 * Does not vary across mid-range, low-range, and high-range estimates cases.
                              C-8

-------
                               INCINERATION CAPACITY UTILIZATION
                       PCB VOLUMES INCINERATED AND INCINERATION CAPACITY

TOTAL PCB VOLUMES  - USE PHASE OUT - CAPACITORS/ASKAREL  TRANSFORMERS
 r

TOTAL POUNDS OF PCBS
FOR "DISPOSAL" FROM
USE PHASEOUT OF PCB
CAPACITORS AND ASKAREL
TRANSFORMERS
16,140.247 LB8
1
1
1
1
1 .
1 '
1
1
1

54.4S FROM PCB CAPACITORS
£ 100S PCBs. 11.6 LB/GALb
45.6JS FROM ASKAREL TRANS-
FORMERS 6 8.75 LBS PCB /GAL
OF FLUID&




TOTAL VOLUME OF PCB FLUIDS
FOR "DISPOSAL" FROM USE
PHASEOUT OF PCB CAPACITORS
AND ASKAREL TRANSFORMERS
1 .598.059 GAL.
TOTAL VOLUME OF PCB
FLUIDS FROM USE PHASEOUT
FPR "DISPOSAL"
1.598.059 GAL.


ADDED VOLUME FROM SOLVENT
RINSE 6 RATIO OF 1 : 1 c
1 ,598,059 GAL
                                                                   TOTAL VOLUME OF PCB FLUIDS
                                                                   AND SOLVENT RINSE FOR
                                                                   "DISPOSAL" FROM USE PHASEOUT
                                                                          3.196.118 GAL.
a)  Figure for 1984  from Table 46, July 1982 RIA on Use Rule;  number is likely to be too low
    based upon under-estimation of voluntary and mandated phaseout  rate.

b)  EEI/USWAG data
c)  Assumption.
               TOTAL PCB VOLUMES - REPLACEMENT/FAILURE - MINERAL OIL TRANSFORMERS


TOTAL NUMBER OF MINERAL
OIL TRANSFORMERS CON-
TAINING SOME PCBs
/ 1 no i pr\pKI )

25.284,000d









FAILURE RATE = 0.2 S/YR6
*
UNIT LIFE = 30 YEARS




1
1
1
T
1
1
i



TOTAL NUMBER OF UNITS
FOR "DISPOSAL" IN 1984
732,6349




• 1
i
1
|
1
1
1
|

      TOTAL NUMBER OF  MINERAL
      OIL UNITS FOR "DISPOSAL"
      IN 1984
          732.634
47.4 GAL/UNITr
TOTAL FLUID VOLUME OF
MINERAL OIL UNITS FOR
"DISPOSAL"  THAT CONTAIN
SOME PCBs
     34,726.852 GAL
d)  Figure from Table S-1,  July 1982 RIA on Use Rule.
e)  Estimate used in July  1982 RIA on Use Rule.
f)  Estimate used in July  1982 RIA on Use Rule except exclude rebuilding add-on of 30  yeers.
g)  Number from sum of removal and failure estimated 1984  population;  no additional units are
    added from voluntary phaseouts;  losses in 1981-1983 (2,346,155 units) have been handled or
    are in storage.
h)  Derived from Table S-1, July 1982 RIA on Use Rule.
                                           •BOOZ-ALLEN & HAMILTON INC
                                           C-9

-------
                              INCINERATION CAPACITY UTILIZATION
                       PCB VOLUMES INCINERATED AND INCINERATION CAPACITY
                                         (CONTINUED)

TOTAL PCB VOLUMES - IN STORAGE ("CARRYOVER" VOLUMES)

     Estimate of carryover volumes of PCB - containing  fluids could not be obtained from
EPA or industry sources - industry sources do indicate, however, that offsite industry is
at or near current PCB liquids incineration capacity -  from estimated capacity number,  therefore,
and assuming capacity utilization to be 100 percent, have developed estimate of carryover
volume from the following algorithm:

     PCB liquids capacity (MT) x 1002 = PCB liquids supply (MT) x 184 gal/MT = PCB liq. supply
     PCB liquids supply (gal) - use phaseout volume (gal) - mineral oil units volume (gal)
     =  PCB carryover volume  (gal)

     Applying this algorithm, gives an estimate of 1,633,607 gallons (approximates volume
from use phaseout of capacitors and transformers over  1981-83 according to Table 46, July 82
RIA on Use Rule).      v

TOTAL PCB VOLUMES - BY PCB CONCENTRATION RANGE
     TOTAL VOLUME OF PCB FLUIDS
     AND RINSE FOR "DISPOSAL"
     FROM USE PHASEOUT OF PCB
     CAPACITORS/TRANSFORMERS
           3.196,118 GAL
                                 100* OF THESE
                                 UNITS CONTAIN
                                 PCBs  >500 PPM8
TOTAL VOLUME OF  >500 PPM PCB
FLUIDS FROM USE  PHASEOUT OF PCB
CAPACITORS/TRANSFORMERS FOR
"DISPOSAL"
        3.196.118 GAL
TOTAL FLUID VOLUME OF MINERAL
OIL  UNITS  FOR "DISPOSAL" THAT
CONTAIN SOME PCBs
     34,726,852  GAL
                                                      TOTAL FLUID VOLUME  FROM MINERAL
                                                      OIL UNITS THAT HAS  50-500 PPM PCBs
                                                              4.097,769 GAL
                                                      TOTAL FLUID VOLUME  FfWM MINERAL
                                                      OIL UNITS THAT HAS  >500  PPM PCBs
                                                                381,995 GAL
 a) EEI/USWAG data.
                                            •BOOZ ALLEN & HAMILTON INC.
                                         c-io

-------
                             INCINERATION CAPACITY UTILIZATION
                 PCB VOLUMES  INCINERATED AND INCINERATION CAPACITY (CONT'D)
TOTAL PCB VOLUMES - BY PCB CONCENTRATION RANGE (Cont'd)
r-


i_

TOTAL CARRYOVER VOLUME OF
PCB FLUIDS FOR "DISPOSAL"
1 .633.607 GAL

-1
1
!
1
i

1002 OF VOLUME
HAS PCBs >500
PPM






TOTAL CARRYOVER VOLUME THAT
HAS >500 PPM PCBs
1 .633,607 GAL

TOTAL PCB VOLUMES - NEEDING TO BE INCINERATED
TOTAL FLUID VOL.
OF > 500 PPM PCBs
FROM USE PHASEOUT
3.196.118 GAL


TOTAL FLUID VOL.
FROM MINERAL OIL
UNITS > 500 PPM
381 .995 GAL



TOTAL CARRYOVER
VOL >500 PPM
1,633,607 GAL



TOTAL FLUID VOL.
> 500 PPM PCBs
5,211,720
              TOTAL FLUID VOLUME
               >500 PPM PCBs
                5,211,720 GAL
     TOTAL FLUID VOLUME WITH
     50-500 PPM PCBs FOR
     "DISPOSAL"
        4.097,769 GAL
       1008 OF >500 PPM
       FLUIDS MUST BE
       INCINERATED8
                                                               TOTAL PCB FLUID VOLUME
                                                               TO INCINERATION
                                                                   8,899.712 GAL
9% TO APPROVED LANDFILLSb
18 TO TREATMENT5
908 TO APPROVED INCINERATORS6
                                 L_
a)  As specified by regulation.
b)  Assumptions given regulatory option^
                                         •BOOZ ALLEN & HAMILTON INC
                                        c-n

-------
                             INCINERATION CAPACITY UTILIZATION
                 PCB VOLUMES INCINERATED AND  INCINERATION CAPACITY (CONT'D)
PCB INCINERATION CAPACITY

Four units approved for PCB incineration

     Rollins   21.3 x 106  Ibs PCB/yr =  9,660 MT PCBs/yra
     SCA      64.8 x 106  Ibs PCB/yr = 29,388 MT PCBs/yra
ENSCO
GE
              32.4 x 106  Ibs PCB/yr =  14,694 MT PCBs/yr8
               8.1 x 106  Ibs PCB/yr =  3,673 MT PCBs/yra
             126.6 x 106  Ibs PCB/yr  57,415 MT PCBs/yrb
a)  Figures supplied by OPTS
b)  Verified by industry sources as in range.
TOTAL PCBs INCINERATION
CAPACITY
57,415 MT PCBs


ASSUME ALL OF GE
CAPACITY USED BY
GE


TOTAL AVAILABLE PCBs
INCINERATION CAPACITY
53,742 MT PCBs

TOTAL AVAILABLE PCBs
INCINERATION CAPACITY
53,742 MT PCBs

r
1
l
i
r-
i
i
L.

10$ IS PCB SOLIDS CAPACITY0
90$ IS PCB LIQUIDS CAPACITY0

1
l
1
r
i
i
_i

TOTAL AVAILABLE PCB
LiVUiUo INLINE KAI ION
CAPACITY

c)  Assumption.

CAPACITY UTILIZATION ESTIMATES
TOTAL PCB VOLUME
TO INCINERATION
8,899.712 GAL


§ 12 LB/GAL OR 184 GAL/MTC


TOTAL PCB VOLUME TO
INCINERATION
48,368 MT PCBs
     TOTAL PCB VOLUME TO
     INCINERATION
         48,368 MT
 100$ OF CAPACITY*1-*-
                  I
	I
                                                    TOTAL AVAILABLE PCB  LIQUIDS
                                                    INCINERATION CAPACITY
                                                        48,368 MT
 d)  Capacity utilization reported = 100$ by industry sources.
                                          •BOOZ ALLEN & HAMILTON INC
                                        C-12

-------
               EFFECTS OF LANDFILL RESTRICTIONS;
                   MID-RANGE ESTIMATES CASE:
OBJECTIVE:
To estimate incineration capacity utiliza-
tion after imposition of restrictions on
t?.e landfilling of LOHWs
RESULTS:
Demand for on-site incineration after
restrictions are imposed is 42.8% of capacity
                    Demand for off-site incineration after
                    restrictions are imposed id 214.7 % of
                    capacity
KEY DATA:
Total wastes generated =264 MMT
                    Percent of wastes generated going to
                    landfills =1.2%

                    Baseline mid-range estimate of demand for
                    off-site incineration = 0.139 MMT

                    Baseline mid-range estimate of demand for
                    on-site incineration = 1.253 MMT

                    Net baseline off-site incineration capacity
                    =  0.252 MMT

                    Baseline on-site incineration capacity
                    =3.10 MMT
                             C-13

-------
KEY ASSUMPTIONS:    70% of wastes landfilled are landfilled
                    off-site

                    Landfill restrictions affect 50% of wastes
                    currently landfilled

                    30% of restrictions-affected wastes are
                    incinerable

                    84% of incinerable wastes are incinerated
                    at commercial facilities
                             C-14

-------
                             INCINERATION CAPACITY UTILIZATION
                                LAND DISPOSAL RESTRICTIONS
                   LANDFILL RESTRICTIONS  EFFECTS:  MID-RANGE ESTIMATES CASE
LANDFILLED VOLUMES
TOTAL QUANTITY OF WASTES
GENERATED
264 MMTa


PERCENT OF WASTES
GOING TO LANDFILLS
1.2$a


TOTAL QUANTITY OF WASTES
NOW LANDFILLED
3.2 MMTS
     TOTAL QUANTITY OF WASTES
     NOW  LANDFILLED
          3.2 MMT8

TOTAL QUANTITY OF WASTES
LANDFILLED ONSITE
     0.95 MMT
                                                        TOTAL QUANTITY OF WASTES
                                                        LANDFILLED OFFSITE
                                                             2.22 MMT
a)  1981 RIA National  Survey report data.
b)  Are mid-range estimates determined  from low-range estimates = 43? on-sitet 57$ off-site
    (RIA data) and high-range estimates = 16$ on-site;  84$ off-site (commercial industry
    annual survey data).
LANDFILL RESTRICTIONS EFFECTS

TOTAL QUANTITY OW WASTES
1 AtJnPTI 1 m OJ^TTF
0.95 MMT


TOTAL QUANTITY OF WASTES
2.22 MMT

1
1
1
T
i
1
f
i
i
T
1
1
1

PERCENT OF WASTES
ACPPr*TFn RY
RESTRICTIONS
50$a

PERCENT OF WASTES
50$a

--i






1

TOTAL QUANTITY OF ONSITE
0.475 MMT


TOTAL QUANTITY OF OFFSITE
WAbltb Arrtt/TED
1.11 MMT

a)  Range of 25$ to 75$ suggested by EPA staff as possible effects of restrictions.
    Mid-range estimate = 50$.
                                         •BOOZ-ALLEN & HAMILTON INC
                                       C-15

-------
                              INCINERATION CAPACITY UTILIZATION
              LANDFILL RESTRICTIONS EFFECTS:  MID-RANGE ESTIMATES CASE (CONT'D)
LANDFILL RESTRICTIONS EFFECTS (Cont'd)
TOTAL QUANTITY OF ONSITE
yACfpc APPFPTFn
0.475 MMT

TOTAL QUANTITY OF OFFSITE
WASTES AFFECTED
1.11 MMT
^




PERCENT OF AFFECTED
\if\\ |Up THAT TQ
INCINERABLE
30«a

PERCENT OF AFFECTED
VOLUME THAT IS
INCINERABLE
30S6a





TOTAL QUANTITY (ONSITE ORIGIN)
TOM^\/P Tfi TMPTMPPATTrtJ
0.143 MMT

TOTAL QUANTITY (OFFSITE ORIGIN)
TO MOVE TO INCINERATION
0.333 MMT
a)  Assumes that  to  comply with restrictions, most of the wastes affected will be treated
    to still allow these wastes to be landfilled.  Remainder of wastes  that are affected
    but not amenable to chemical/physical/biological treatment will  be  incinerable and incinerated.
     TOTAL QUANTITY OF WASTES
     (ONSITE ORIGIN) TO MOVE
     TO INCINERATION
           0.143 MMT
     TOTAL QUANTITY OF WASTES
     (OFFSITE ORIGIN) TO MOVE
     TO INCINERATION
           0.333 MMT
TOTAL QUANTITY TO MOVE TO
ONSITE INCINERATION
        0.074 MMT
TOTAL QUANTITY TO MOVE TO
OFFSITE INCINERATION

        0.402 MMT
a)  Assumes that on the margin, the majority of generators originally managing their wastes
    on-site will elect to send these wastes to commercial facilities to  be  incinerated after
    the restrictions are in place.  Decision will actually vary on basis of generator's waste
    management capabilities and perceptions of liabilities.  Assumes that those wastes originally
    sent to commercial facilities will principally remain at commercial  facilities to be
    incinerated.
                                           •BOOZ ALLEN & HAMILTON INC
                                         C-16

-------
                            INCINERATION CAPACITY UTILIZATION
              LANDFILL RESTRICTIONS EFFECTS:  MID-RANGE ESTIMATES CASE (CONT'D)
CAPACITY UTILIZATION ESTIMATES
TOTAL BASELINE LOHW
QUANTITY INCINERATED
ONSITE
1 .253 MMT



TOTAL QUANTITY OF
RESTRICTED WASTES
TO MOVE TO ONSITE
INCINERATION
0.074 MMT


TOTAL QUANTITY INCINERATED
ONSITE AFTER RESTRICTIONS
1 .327 MMT

     TOTAL QUANTITY  INCINERATED
     ONSITE AFTER RESTRICTIONS
              1.327 MMT
42.82 of
Capacity
TOTAL ONSITE LOHW
INCINERATION CAPACITY
     3.10 MMT
TOTAL BASELINE LOHW
QUANTITY INCINERATED
OFFSITE
0.139 MMT



TOTAL QUANTITY OF
RESTRICTED WASTES
TO MOVE TO OFFSITE
INCINERATION
0.402 MMT


TOTAL QUANTITY INCINERATED
OFFSITE AFTER RESTRICTIONS
0.541 MMT

     TOTAL QUANTITY INCINERATED
     OFFSITE AFTER RESTRICTIONS
         0.541 MMT
214.1% of
Capacity
"NET" OFFSITE LOHW
INCINERATION CAPACITY
    0.252 MMT
                                         •BOOZ ALLEN & HAMILTON INC
                                            ,J
                                       C-17

-------
         EFFECTS OF DEEP WELL INJECTION RESTRICTIONS;
                   MID-RANGE ESTIMATES CASE
OBJECTIVEi
RESULTS:
To estimate on-site and off-site incineration
capacity utilization after imposition of
restrictions on underground injection of LOHWs

On-site incineration capacity utilization
after restrictions = 53.5% of capacity
                    Off-site incineration capacity utilization
                    after restrictions = 306.2% of capacity
KEY DATA:
Total wastes generated = 264 MMT
                    Percent of wastes generated going to injection
                    wells « 12.1%

                    Baseline demand  for on-site incineration
                     (mid-range)  =  1.253 MMT

                    Baseline on-site incineration capacity
                    =3.1 MMT

                    Baseline demand  on off-site incineration
                     (mid-range)  =  0.139 MMT

                    Net baseline off-site  incineration capacity
                    =  0.252 MMT
                             C -18

-------
KEY ASSUMPTIONS:    97.5% of wastes injected are injected into
                    on-site wells

                    Restrictions affect 50% of wastes injected

                    93.5% of affected wastes are non-incinerable

                    6.5% of affected wastes are incinerable
                    either directly or as a result of pretreatment

                    60.9% of incinerable wastes are incinerated
                    off-site
                            C-19

-------
                              INCINERATION CAPACITY UTILIZATION
                                 LAND DISPOSAL RESTRICTIONS
                INJECTION WELL RESTRICTIONS EFFECTS:  MID-RANGE ESTIMATES CASE
DEEP WELL  INJECTION VOLUMES
TOTAL QUANTITY OF WASTES
GENERATED
264 MMTB


PERCENT OF WASTES
GENERATED TO DEEP
WELL INJECTION '
12.1«a


TOTAL QUANTITY OF WASTES
NOW INJECTED TO WELLS
32 MMTa
o)  WESTAT  report, April 1984.
b)  Assumed estimates comparable to estimates derived from RIA data  (see Appendix C).
          TOTAL QUANTITY OF WASTES
          NOW INJECTED TO WELLS
                 32 MMT
TOTAL QUANTITY OF WASTES NOW
INJECTED TO ONSITE WELLS
        31.15 MMT
                                                         TOTAL QUANTITY OF WASTES NOW
                                                         INJECTED TO OFFSITE WELLS
                                                                 0.799 MMT
EFFECTS OF DEEP WELL  INJECTION RESTRICTIONS
, 	
PERCENT OF
RESTRICTED
1 QUANTITY THAT
n IS DIRECTLY
/ INCINERABLE
1 /
TOTAL QUANTITY OF PERCENT OF / PERCENT OF
WASTES NOW INJECTED INJECTED V RESTRICTED
TO ONSITE WELLS ~~ WASTES IT QUANTITY THAT
31.15 MMT RESTRICTED 1 IS INDIRECTLY
	 50$ c 11 INCINERABLE
i . \
i \
( I PERCENT OF
1 U RESTRICTED
[ 1 QUANTITY THAT
| IS. NOT
1 INCINERABLE
1 658 d

1
i
I
1

PERCENT AFTER
TREATMENT TO
INCINERATION

PERCENT AFTER
TREATMENT NOT
INCINERABLE
952 e

r
i
i


j
TOTAL QUANTITY WASTES
(ONSITE ORIGIN) TO
MOVE TO INCINERATION
1.012 MMT
i

QUANTITY OF POST-
TREATMENT WASTES TO
INCINERATION
0.234 MMT


\
QUANTITY OF "WASTES"
THAT CANNOT BE
INCINERATED
14.56 MMT


 c)   Range of estimates suggested by EPA staff = 252 to 752.  Mid-range = 502.
 d)   Assumes most of effected wastes are not incinerable,  small percentage ere directly  incinerable,
     and some are incinerable if treated first.
     After treatment, volume to be incinerated is assumed  to be small.
                                           •BOOZ ALLEN & HAMILTON INC
                                             C-20

-------
                              INCINERATION CAPACITY UTILIZATION
                INJECTION WELL RESTRICTIONS:  MID-RANGE ESTIMATES CASE (CONT'D)

EFFECTS OF DEEP  WELL INJECTION RESTRICTIONS (CONT'D)
TOTAL QUANTITY
OF WASTES NOW
INJECTED TO
OFFSITE WELLS
0.799 MMT
I

-


PERCENT OF
INJECTED
WASTES
RESTRICTED
50ZC

PERCENT OF
RESTRICTED
1 QUANTITY THAT
1 IS DIRECTLY
II INCINERABLE
II 5*d
1
1 PERCENT OF
I RESTRICTED
h* QUANTITY THAT
| IS INDIRECTLY
1 INCINERABLE
'1 30JSd
•—i
1
1
I
1 ,^_
1
1
I
1
1 	


1 1
1 1
1 PERCENT OF
1 RESTRICTED
| QUANTITY THAT
IS NOT
INCINERABLE
! 1 65*d

PERCENT AFTER
TREATMENT TO
INCINERATION
5«e

PERCENT AFTER
TREATMENT NOT
INCINERABLE
95$e

-T
— 1 — »-

TOTAL QUANTITY WASTES
(OFFSITE ORIGIN) TO
MOVE TO INCINERATION
0.026 MMT

,
QUANTITY OF POST-
TREATMENT WASTES TO
INCINERATION
0.006 MMT



!

QUANTITY OF "WASTES"
THAT CANNOT. BE
INCINERATED
0.773 MMT


c)
d)

e)
    Range of estimates suggested by EPA staff  =  25$ to 75JS.  Mid-range = 50JS.
    Assumes most of affected wastes are not incinereble, small percentage are directly incinerable,
    and some are incinerable if treated first.
    After treatment, volume to be incinerated  is assumed to be small.
     TOTAL QUANTITY (ONSITE ORIGIN)
     TO MOVE TO INCINERATION
           1.012 MMT
     TOTAL QUANTITY (OFFSITE ORIGIN)
     TO MOVE TO INCINERATION
           0.026 MMT
                                                                  TOTAL QUANTITY TO MOVE TO
                                                                  ONSITE INCINERATION
                                                                          0.406  MMT
                                                                  TOTAL QUANTITY TO MOVE TO
                                                                  OFFSITE INCINERATION
                                                                          0.632  MMT
 f)   Assumes that on the margin, the majority of generators originally managing their wastes
     on-site will elect to send  these wastes off-site  to be incinerated after  restrictions are in-
     place.  Wastes originally sent off-site will remain off-site.
                                            •BOOZ ALLEN & HAMILTON INC
                                               C-21

-------
                             INCINERATION CAPACITY UTILIZATION
            INJECTION WELL RESTRICTIONS EFFECTS:  MID-RANGE ESTIMATES CASE  (CONT'D)
CAPACITY UTILIZATION ESTIMATES
   TOTAL BASELINE LOHW  QUANTITY
   INCINERATED ONSITE
        1.253 MMT
ADDED LOHW QUANTITY TO MOVE
TO ONSITE INCINERATION FROM
DEEP WELL INJECTION
        0.406 MMT
      TOTAL QUANTITY OF LOHW
      INCINERATED ONSITE AFTER
      DWI BAN/RESTRICTIONS
               1.659 MMT
       TOTAL ONSITE LOHW
       INCINERATION CAPACITY
              3.10 MMT
   53.58 Of
   Capacity
TOTAL QUANTITY OF LOHW INCINERATED
ONSITE AFTER DWI BAN/RESTRICTIONS
         1.659 MMT
TOTAL BASELINE LOHW QUANTITY
INCINERATED OFFSITE
0.139 MMT


ADDED LOHW QUANTITY TO
MOVE TO OFFSITE
INCINERATION FROM DWI
0.632 MMT


TOTAL QUANTITY OF LOHW
INCINERATED OFFSITE AFTER
DWI BAN/RESTRICTIONS
0.771 MMT
        "NET" OFFSITE  LOHW
        INCINERATION CAPACITY
             0.252 MMT
   306.2% Of
   Capacity
TOTAL QUANTITY OF LOHW INCINERATED
OFFSITE AFTER DWI BAN/RESTRICTIONS
             0.771 MMT
                                         •BOOZ ALLEN & HAMILTON INC-
                                        C-22

-------
             EFFECTS OF A DISPOSAL IMPOUNDMENT BAN;
                   MID-RANGE ESTIMATES CASE
OBJECTIVE:
To estimate on-site and off-site incineration
capacity utilization after imposition of a
ban on disposing LOHWs in surface impoundments
RESULTS:
On-site incineration capacity utilization
after ban = 52.1%
                    Off-site incineration capacity utilization
                    after ban =  288.2% of capacity
KEY DATA:
Total wastes generated =264 MMT
                    Percent of wastes generated going  to disposal
                    impoundments  = 7.2%

                    Baseline on-site incineration demand
                     (mid-range) = 1.253 MMT

                    Baseline on-site incineration capacity
                    =3.10 MMT

                    Baseline off-site incineration demand
                     (mid-range) = 0.139 MMT

                    Net baseline  off-site incineration capacity
                    0.252 MMT
                              C-23

-------
KEY ASSUMPTIONS:    95% of wastes to on-site disposal impoundments

                    10% of wastes in disposal impoundments are
                    incinerable

                    50% of incinerable wastes are incinerated

                    61.7% of wastes incinerated are incinerated
                    off-site

                    Complete prohibition of practice
                             C-24

-------
                              INCINERATION CAPACITY UTILIZATION
                                 LAND DISPOSAL RESTRICTIONS
                 DISPOSAL  IMPOUNDMENTS BAN EFFECTS:  MID-RANGE ESTIMATES CASE
DISPOSAL IMPOUNDMENT VOLUMES
TOTAL QUANTITY OF WASTES
GENERATED
264 MMT8


PERCENT OF WASTES
GENERATED MANAGED IN
DISPOSAL IMPOUNDMENTS
7.22*
                                                              TOTAL QUANTITY OF WASTES
                                                              MANAGED  IN DISPOSAL
                                                              IMPOUNDMENTS
                                                                    19 MMT°
     TOTAL QUANTITY OF WASTES
     MANAGED IN DISPOSAL
     IMPOUNDMENTS
           19 MMT
a)  WESTAT Report,  April 1984.
b)  Analysis of 1981 National Survey data (see Appendix C).
EFFECTS OF A BAN ON WASTE DISPOSAL IMPOUNDMENTS0
                                                             TOTAL QUANTITY OF WASTES
                                                             MANAGED IN ONSITE DISPOSAL
                                                             IMPOUNDMENTS
                                                                     18.058 MMT
                                                              TOTAL QUANTITY OF WASTES
                                                              MANAGED  IN OFFSITE DISPOSAL
                                                              IMPOUNDMENTS
                                                                      0.950 MMT
TOTAL QUANTITY OF WASTES
POSAL IMPOUNDMENTS
18.058 MMT


102 OF BANNED
WASTES ARE
INCINERABLEd



50* OF
INCINERABLE
WASTES ARE
INCINERATED6
                                                                    TOTAL QUANTITY (ONSITE-
                                                                    ORIGIN) TO MOVE TO
                                                                    INCINERATION
                                                                          0.903 MMT
                                                                     TOTAL QUANTITY (ONSITE-
                                                                     ORIGIN) NOT INCINERATED
                                                                          17.16 MMT
TOTAL QUANTITY OF WASTES
MANAGED IN OFFSITE DIS-
POSAL IMPOUNDMENTS
0.950 MMT


102 OF BANNED
WASTES ARE
INCINERABLEd



502 OF
INCINERABLE
WASTES ARE
INCINERATED6
                                                                    TOTAL QUANTITY (OFFSITE-
                                                                    ORIGIN) TO MOVE TO
                                                                    INCINERATION
                                                                           0.048 MMT
c)  Impoundments used for treatjpent  and storage are not
    considered.  Cleanup of "old"  disposal impoundments not included.
d)  Analysis of RIA National Survey. Represents percentage of LOHWs in disposal
    impoundments out of all wastes managed in disposal impoundments.
e)  Range of estimates suggested by  EPA staff = 252 to 752.  Mid-range = 502.
                                                                    TOTAL QUANTITY (OFFSITE-
                                                                    OR1GIN)  NOT INCINERATED
                                                                            0.902 MMT
                                           •BOOZ ALLEN & HAMILTON INC-
                                           C-25

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                              INCINERATION CAPACITY UTILIZATION
             DISPOSAL IMPOUNDMENTS BAN EFFECTS:  MID-RANGE  ESTIMATES CASE (CONT'D)

EFFECTS OF A BAN ON WASTE DISPOSAL IMPOUNDMENTS (CONT'D)
     TOTAL QUANTITY  (ONSITE-ORIGIN)
     TO MOVE  TO INCINERATION
             0.903 MMT
     TOTAL QUANTITY  (OFFSITE-ORIGIN
     TO MOVE  TO INCINERATION
             0.048 MMT
                   TOTAL QUANTITY  TO MOVE
                   TO ONSITE INCINERATION
                         0.364 MMT
                   TOTAL QUANTITY TO MOVE
                   TO OFFSITE INCINERATION
                         0.587 MMT
CAPACITY UTILIZATION ESTIMATE
     TOTAL BASELINE LOHW QUANTITY
     INCINERATED ONSITE
           1.253 MMT
     TOTAL BASELINE LOHW
     QUANTITY INCINERATED
     OFFSITE
          0.139 MMT
 TOTAL QUANTITY TO
 MOVE TO ONSITE
 INCINERATION
    0.364 MMT
 TOTAL QUANTITY TO
 MOVE TO OFFSITE
 INCINERATION
      0.587 MMT
    TOTAL QUANTITY OF  LOHW
    INCINERATED ONSITE AFTER
    DISPOSAL IMPOUNDMENT  BAN
          1.616 MMT
    TOTAL QUANTITY OF  LOHW
    INCINERATED OFFSITE AFTER
    DISPOSAL IMPOUNDMENT BAN
           0.726 MMT
     TOTAL ONSITE  LOHW INCINERA-
     TION CAPACITY
            3.10  MMT
52.18 Of
Capacity
TOTAL QUANTITY OF LOHW
INCINERATED ONSITE AFTER BAN
          1.616 MMT
     "NET"  OFFSITE LOHW INCINERA-
     TION CAPACITY
           0.252 MMT
288.22 Of
Capacity
TOTAL QUANTITY OF LOHW
INCINERATED OFFSITE AFTER BAN
        0.726 MMT
                                          •BOOZ ALLEN & HAMILTON INC.
                                        C-26

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           EFFECTS OF WASTES-IN-BOILERS RESTRICTIONS;
                   MID-RANGE ESTIMATES CASE
OBJECTIVE:
RESULTS:
To estimate on-site and off-site incineration
capacity utilization after imposition of
restrictions on the burning of hazardous
wastes in industrial boilers

On-site incineration capacity utilization
after restrictions = 42.2% of capacity

Off-site incineration capacity utilization
after restrictions = 106.3% of capacity
KEY DATA:
Total hazardous wastes burned in boilers
=0.7 MMT
                    Baseline on-site incineration demand
                     (mid-range) = 1.253 MMT

                    Baseline on-site incineration capacity
                    =3.10 MMT

                    Baseline off-site incineration demand
                     (mid-range) = 0.139 MMT

                    Net baseline off-site incineration capacity
                    = 0.252 MMT

KEY ASSUMPTIONS:    35% of boiler population affected by
                    restrictions
                              C-27

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KEY ASSUMPTIONS:    All boilers in population have same capacity
(Continued)
                    75% of wastes from restriction-affected
                    boilers are incinerated

                    70% of incinerated wastes are incinerated
                    off-site
                              C-28

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                             INCINERATION CAPACITY UTILIZATION
              WASTES-IN-BOILERS RESTRICTIONS EFFECTS:  MID-RANGE ESTIMATES CASE
WASTE-IN-BOILERS RESTRICTIONS EFFECTS

TOTAL QUANTITY OF WASTES
NOW BURNED IN BOILERS
0.7 MMTa

r •
1
L
1
1
1
L

PERCENT OF BOILERS
AFFECTED BY EMIS-
SIONS RESTRICTIONS
352

1
I
1
1
1
1
1

PERCENT OF WASTES
THAT MUST MOVE TO
INCINERATION
752b

-
TOTAL QUANTITY
THAT MOVES TO
INCINERATION
0.184 MMT
a) -Estimate derived  from EPA wastes-in-boilers study.
b)  Range of estimates suggested by EPA staff = 502 to  100$.  Mid-range
ONSITE VS. OFFSITE VOLUMES
             752.
     TOTAL QUANTITY OF LOHW THAT
     MOVES TO INCINERATION
           0.184 MMT
TOTAL QUANTITY OF LOHW THAT
MOVES TO ONSITE INCINERATION
         0.055 MMT
TOTAL QUANTITY OF  LOHW THAT
MOVES TO OFFSITE INCINERATION
         0.129 MMT
a)  Assumes that most of wastes will have to be incinerated off-site.
TOTAL BASELINE LOHW
QUANTITY INCINERATED
ONSITE
1.253 MMT


TOTAL QUANTITY OF LOHW
THAT MOVES TO ONSITE
INCINERATION
0.055 MMT


TOTAL QUANTITY OF LOHW
INCINERATED ONSITE AFTER
RESTRICTIONS
1 .308 MMT
TOTAL BASELINE LOHW
QUANTITY INCINERATED
OFFSITE
0.139 MMT


TOTAL QUANTITY OF LOHW
THAT MOVES TO OFFSITE
INCINERATION
0.129 MMT


TOTAL QUANTITY OF LOHW
INCINERATED AFTER
RESTRICTIONS
0.268 MMT
                                         •BOOZ-ALLEN & HAMILTON INC.
                                        C-29

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                            INCINERATION CAPACITY UTILIZATION
          WASTES-IN-BOILERS RESTRICTIONS EFFECTS:  MID-RANGE ESTIMATES CASE  (CONT'D)

CAPACITY UTILIZATION ESTIMATES
     TOTAL QUANTITY OF LOHW
     INCINERATED ONSITE AFTER
     RESTRICTIONS
        1.308 MMT
42.28 Of
Capacity
TOTAL ONSITE LIQUIDS
INCINERATION CAPACITY
   •3.10 MMTa
     TOTAL QUANTITY OF LOHW
     INCINERATED OFFSITE AFTER
     RESTRICTIONS
        0.268 MMT
106.3? Of
Capacity
"NET" OFFSITE LOHW
INCINERATION CAPACITY

     0.252 MMTa
a)  Assumes no change in "net" capacity and that all of capacity IK available.
                                         •BOOZ-ALLEN & HAMILTON INC
                                        C-30

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                  INCINERATION-AT-SEA CAPACITY
OBJECTIVE:
To estimate the probable incineration-
at-sea capacity that could be added to
land-based incineration capacity
RESULTS:
Total incineration-at-sea capacity
0.297 MMT/yr
KEY DATA:
Metric tons/voyage for six incinerator
ships
                     Estimated turn-around times for six
                     incinerator ships
KEY ASSUMPTIONS!
Operate at full capacity each voyage
                     Number of voyages per year are two less
                     than maximum possible on basis of estimated
                     turn-around times
                              C-31

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                     INCINERATION CAPACITY UTILIZATION
                       INCINERATION-AT-SEA CAPACITY
 VULCANUS I & II (Ocean Combustion Services - Chemical Waste Management)
 VULCANUS I:   3,600 MT/voyage x 16 voyages/yrc

 VULCANUS II:  3,600 MT/voyage x 16 voyages/yr'
57,600 MT/yr

57,600 MT/yr
                                               115,200 MT/yr
 a)  derived from information supplied by OWRS; permit application
    indicates plan to burn 350,000 MT over 3 years between the two
    ships,  an estimated turn-around time of 3 weeks (5 days in-
    transit, 10 days to burn, 5 days to reload), 2 units on Vulcanus
    I, 3 units on Vulcanus II, each unit with throughput of (per unit)
    1,650 gal/hr @ 10 Ib/gal, 240 hrs of burning; assume
    loss of 1 voyages/yr off maximum of 17 (52 wks -f 3);
    termed reasonable by OWRS, likely even fewer given logistics
    problems, seasonal limitations on operation, etc.
APPOLLO I & II (At-Sea Incineration Inc.)


APPOLLO I:  1.31  x 10  gal/voyage%6000 MT/voyage x 22 voyages/yr  =132,000 MT/yr
                                                                 I 132,000 MT/yr
 b) derived from information supplied ,by OWRS; estimated
    turn-around time of  2 weeks  (2 days in-transit, 10
    days to burn,  2 days to reload), 2 units each on both
    ships, 2,750 gal/hr/unit, @  10 Ib/gal, 240 hrs. of
    burning; assume loss of 4 voyages/yr off maximum
    of 26 (52 wks-S-2);   termed reasonable by
    OWRS, likely even fewer given logistics problems,
    seasonal limitations on operations, etc.
                                    •BOOZ ALLEN & HAMILTON INC-
                                  C -32

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     EFFECTS OF SUPERFUND CLEAN-UP ACTIVITY ON RCRA CAPACITY
OBJECTIVE:
To estimate quantity of wastes that are
incinerable and are incinerated from past
and future Superfund remedial and removal
actions
RESULTS:
None
KEY DATA:
None directly available
KEY ASSUMPTIONS:
None
                              C-33

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                INCINERATION CAPACITY UTILIZATION

    EFFECTS OF-SUPERFUND CLEAN-UP ACTIVITIES ON  RCRA  CAPACITY
      Little  technology-specific and waste type-specific data
 are  directly available concerning present and/or future waste
 quantities removed from Superfund sites to RCRA facilities.
 Data sources with this information are not collected in one
 place,  and are inconsistent in their degree of detail (e.g.,
 lack waste type information).   A compilation of these sources
 is recommended.

      Some information has been analyzed and made available
 for  this market study.  Waste quantities incinerated are not
 known.

      Wastes  excavated and disposed off-site from Superfund
 remedial sites3 = 178,697 metric tons (235,127 cu.yds @
 0.76 metric  tons per cu. yds.)

 EPA  Region       Waste Quantity Disposed Off-Site (metric tons)

      I                                 7,883
     II                                 4,115
    III                                16,671
     IV
      V                                28.869
     VI                                14,440
    VII
   VIII
     IX                               106,719
      X                                   ~
                                      178,697
 a) Sites that have a signed Record of Decision,  where  excavation and disposal
   off-site was cost-effective remedial alternative.   Disposal means land
	fli?posal onlY-	BOOZ ALLEN & HAMILTON INC-
                              C-34

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               ORGANIC LIQUIDS LIKELY TO BE LISTED
OBJECTIVE:
To estimate quantity of wastes added
from the listing of organic liquids as
hazardous wastes
RESULTS:
Total added quantity could be 1.2 MMT/yr

23% of these wastes are currently incinerated

90% of these organic liquids are presently
managed on-site
KEY DATA:
Quantities of organic liquids likely to
be listed as a result of the Industry
Studies Program
                     Quantities managed on-site and off-site
                     by technology
KEY ASSUMPTIONS:
49% of organic liquids studied in the
Industry Studies Program are likely to
be listed .
                     Industry Studies data base contains data
                     on 59% of the total industry

                     Likely impact small as most of these wastes
                     are already managed at RCRA permitted
                     facilities
                                C-35

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                       INCINERATION CAPACITY UTILIZATION
                    ORGANIC LIQUIDS LIKELY TO BE LISTED AS
                   A RESULT OF THE INDUSTRY STUDIES PROGRAM3
An estimated 1.2 million metric tons of organic liquids could be added to
hazardous waste volumes.  Presently, 23 percent of these liquids are
incinerated, most on-site.
   MANAGEMENT
TECHNOLOGY/METHOD
                      QUANTITY MANAGED  QUANTITY MANAGED
                           ON-SITE          OFF-SITE
                       (metric tons/yr)  (metric tons/yr)
 TOTAL QUANTITY
(metric  tons/yr)
Treatment
Treatment
Recovery
Reuse
Sales
Landfill
Burned in
in Tanks
in Surf. Impd.




Boilers
Incineration
Injection
Well
10,
104,
188,
69.
N

423,
266,
22,
028
874
922
280
.A.
698
321 .
449
329
0
871
45,275
N.A.
53,982
5,596
756
7,505
2,909
10,
105,
234,
69,
53,
6,
424,
273,
25,
028
745
197
280
982
294
077
954
238
(0.
(8.
(19
(5.
(4.
(0.
(35
(22
(2.
8)
8)
.5)
8)
5)
5)
.3)
.8)
1)
Land Application - - -
TOTALS
1,085,
901
116,894
1,202,
795b


N.A. = Not applicable
a)  Data provided through OSW.  Assumes that:
                                                 (Numbers in  parentheses
                                                   are percents of total)
b)
   60% of Industry Studies manufacturers who provided waste management
   data also reported waste quantities

   Industry Studies data base contains data on 59%  of total industry

   49% of organic liquids studied in the Industry Studies  Program are
   likely to be listed  (weight basis).

Represents possible additional waste volume added to current  LOHW
totals.  In actuality, may only be some fraction of this as some
of wastes already handled at RCRA TSDs.
                                  •BOOZ ALLEN & HAMILTON INC
                                 C-36

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                          APPENDIX  D

       LOW-RANGE AND HIGH-RANGE ESTIMATE CASE SUMMARIES
     For several of the key data and assumptions in this market
analysis, sources consulted have suggested that the available
data are too uncertain or incomplete to support a single "best"
estimate.  Instead, they suggest, there may be a range of likely
estimates that should be incorporated into the analysis.  This
has been accomplished through a sensitivity analysis that
examines variations in the demand for incineration under each
regulatory scenario, based upon the range of likely estimates
provided.

     In Appendix c, logic diagrams that trace the key data,
assumptions, and results in each module have been constructed
using the mid-range or mid-point value of the estimate ranges
suggested.  These mid-range estimates results are considered the
best average assuming, that for any one assumption, either the
lower or higher estimate suggested may actually be "correct."
Chapters II, III, and IV also use these mid-range estimates re-
sults, as does the incineration equivalents analysis in Chapter
VI, however, results of the sensitivity analysis have been
included in these discussions.

     Variations to the mid-range estimates case are summarized
in this appendix.  Only those key data and assumptions for
which sources have suggested a possible lower and higher value
are covered.  All other data and assumptions were held fixed
across the low-range, mid-range, and high-range estimate cases.
Results of the low-range and'high-range estimate cases are not
presented here, but are covered in Chapters II, III, and IV.
These alternate values can be used in place of the mid-range
estimates in the logic diagrams in Appendix c to calculate alter-
nate incineration capacity utilization outcomes.
                              D-l

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                                    EXHIBIT D-l
                  Variations In Key Assumptions/Data Across
                  Sensitivity Analysis Cases For  Each  Market
                                 Analysis  Module
    Market Analysis  Module
  Low-Range
Estimates Case
  Mid-Range
Estimates Case
  High-Range
Estimates Case
A.  BASELINE INCINERATION CAPACITY
    UTILIZATION
. Total LOHWs incinerated (MMT)* 0.928
Percent commercial capacity 37
utilization
1.392 1.856
55 74

B.  LANDFILL RESTRICTIONS EFFECTS
       Percent wastes  presently
       landfilled on-site:off-site
       Percent wastes  affected by
       restrictions
  43:57
  25
   30:70

   50
    16:84

    75
C.  DEEP WELL INJECTION  RESTRICITONS
    EFFECTS

       Percent injected  wastes            25
       affected by restrictions
D.  DISPOSAL IMPOUNDMENTS  BAN EFFECTS
                      50
                     75
       Percent of  incinerable wastes
       that are incinerated
  25
   50
    75
E.  WASTE-IN-BOILERS RESTRICTIONS
    EFFECTS
       Percent of wastes  from affected    50
       boilers that are incinerated
                      75
                    100
*Established as a function  of  the range of estimates suggested  by sources for commercial
 incineration capacity utilization  ( 40-80%) against a fixed  total incineration capacity
 for LOHWs = 3.4 MMT,  and a fixed "net" commercial incineration capacity for LOHWs
 = 0.300 MMT.
                                           D-2

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                           APPENDIX E


              DEFINITIONS OF SELECTED TERMS USED IN
                       THE MARKET ANALYSIS
     How  terms  such  as  a "commercial"  facility or "off-site"
wastes  are defined  can  influence what gets counted or considered
in the development of each market analysis estimate or assumption.
More commercial capacity gets counted, for example, if a commercial
facility, handling mostly other firm's wastes,  can be either
privately or publicly owned and operated rather than only pri-
vately owned and operated.  Differences in terminology may
also be behind apparently dissimilar estimates  for the same
parameter in different sources.

     The  following defines  how  individual  terms have  been
used in the incineration market analysis.  These  definitions
apply unless noted otherwise.  How these terms  may differ in
their usage than in  other sources cited (e.g.,  the RIA National
Survey report) is also explained.

          Commercial or Off-site  Commercial  Facility.   A commer-
          cial  facility or  off-site  commercial facility refers
          to  a  hazardous waste management  facility that:

                Is privately owned and  operated

                Receives a  fee for its  services

                Receives "most"  of its  wastes  managed  from
                firms or other facilities  that are not associated
                by ownership (i.e.,  "other"  firms)

                Receives other firm wastes  assumed to  have
                been  generated and shipped  from off-site.

          This  definition  excludes  facilities that  mostly
          handle wastes from other  firms  for  a fee, but are
          publicly owned and operated  (see definition of a
          noncommercial facility).   Determination of  what
          threshold  constitutes  "mostly"  other firm wastes
          varies by  technology  (see  Appendix  B),  however,
          it  is  interpreted to  not  exclude the possibility
          of  intrafirm shipments  of  wastes between  commercial
          facilities under the  same  ownership.  As  used here,
          this  definition  of-a  commercial  facility differs
          little from the  primary definition  used in  the RIA
          National Survey  report.*   The  RIA National  Survey's
*Section 5.3, p.83.  A different definition is used in the report in Section 8.1
 p213.
                               E-l

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definition does set a threshold of at least 50 percent
in defining "mostly" other firm wastes.  Both the
market analysis and the RIA National Survey definitions
exclude commercial components to a noncommercial
facility's business.

Noncommercial Facility.  A noncommercial facility
is either:

     A publicly owned and operated -hazardous waste
     management facility that, for a fee, handles
     mostly wastes received from other firms, or

     A publicly or privately owned and operated
     hazardous waste management facility that handles
     mostly wastes received from the same firm,
     i.e., firms and/or facilities that are associated
     by ownership.

In most cases in the report, the latter of these
definitions tends to apply, and such facilities
are referred to as on-site or captive facilities.
This assumes that these facilities are located on
or quite near the site where the wastes were generated,
and that the firm generating the waste owns the
facility.  This, usage, however, does not exclude
the possibility that these captive facilities
may receive same-firm wastes originating at some
distance from them, or that they may have some business
that could be classified as commercial.

Liquid Organic Hazardous Waste (LOHW).  These are
a a group of wastes defined by the Office of Solid
Waste as "any EPA hazardous waste that has been
reported incinerated as a liquid or, according to
the EPA Engineering Handbook For Hazardous Wste
Incineration, is suitable for liquid injection incinera-
tion."  These wastes are discussed in Appendix A.
Reference to an "incinerable liquid waste" should
be equated to LOHWs. An "incinerable liquid waste" may
be either a liquid, solid, or sludge-type waste.
A "waste" is defined by the context in which it
is used, but usually this term has been used in
reference to LOHWs.

Quantity Incinerated Off-site or Quantity Incinerated
At Off-site Facilities.  These phrases are used
interchangeably in  the report in reference to the
incineration of LOHWs at a commercial facility where
these wastes were generated and shipped from off-
site.  The origin of these off-site wastes may be
a firm that is or is not associated with the commercial
facility by ownership.
                      E-2

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Off-site Wastes.  These are wastes that have been
generated mostly by other firms (i.e., firms not
associated with the facility by ownership), and
shipped from a location off-site to a commercial
facility.  The term off-site facility is considered
to be a commercial facility handling mostly off-
site wastes.

On-site Wastes.  These wastes that have been generated mostly
by the same firm (i.e., a firm associated with a
noncommercial facility by ownership), and sent to
a noncommercial facility, whether or not that facility
is located near the site of waste generation.  The
term on-site facility is considered to a noncommercial
facility handling mostly on-site wastes.
                  E-3

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                        APPENDIX F


                     REFERENCES CITED
 1. Westat, Inc. "Final Report:  EPA Incineration
    Study - Task 1, Waste Estimates.  Prepared for the
    Office of Solid Waste.  July 25, 1984.

 2. Westat, Inc. National Survey of Hazardous Waste
    Generators and Treatment, Storage and Disposal
    Facilities Regulated Under RCRA in 1981.  Final
    Report.  Prepared for the Office of Solid Waste.
    April 20, 1984.

 3. Mitre Telephone Survey as cited in Industrial
    Economics, Inc. "Interim Report on Hazardous Waste
    Incineration Risk Analysis."  Draft Report.  Prepared
    for the Office of Solid Waste.  August 2, 1982.

 4. Computer printout of Part A data for commercial
    facilities from the Hazardous Wastes Data Management
    System.

 5. Keller, J.J. and Associates, Inc.  Hazardous Waste
    Services Directory.

 6. Environmental Information Ltd. Industrial and
    Hazardous Waste Management Firms.  1984.

 7. Putnam, Hayes & Bartlett, Inc. and Booz, Allen &
    Hamilton, Inc.  Hazardous Waste Generation and
    Commercial Hazardous Waste Management Capacity;  An
    Assessment.  December 1980.

 8. Monsanto Research Corporation.  Engineering Handbook
    for Hazardous Waste Incineration.  July 1981.

 9. Office of Management Systems and Evaluation.  "The
    Current Regulatory Approach for Incineration - Draft
    Report."  Incineration Study - Task 2B.  May 8, 1984.

10. Confidential telephone contacts with commercial waste
    management industry representatives.

11. Confidential telephone contacts with commercial
    incineration firms.

12. Booz, Allen & Hamilton, Inc.  "Review of Activities of
    Major Firms in the Commercial Hazardous Waste
    Management Industry:'  1982 Update."  August 1983.
    Prepared for the Office of Policy Analysis.
                           F-l

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                     REFERENCES CITED  (cont'd)
     13.  Office of Pesticides and Toxic Substances.  Regulatory
         Impact Analysis of the Use Rule for PCB-Containing
         Electrical Equipment.  July 1982.

     14.  The Edison Electric Institute and the Utility Solid
         Waste Activities Group.  Comments.and Studies on the
         Use of Polychlorinated Biphenyls in Response to an
         Order of United States Court of Appeals for the
         District of Columbia Circuit - Vol. III.  Report of
         the Study of PCBs in Equipment Owned by the Electric
         Utility Industry.  Prepared by Resource Planning
         Corporation.  February 12, 1982.

     15.  Preliminary results of the responses to the Burner
         Questionnaire of the U.S. EPA's Survey of Used or
         Waste Oil and Waste-Derived Fuel Material.  April 30,
         1984.  Provided by the Office of Solid Waste.

     16.  Booz, Allen & Hamilton, Inc.  "Review of Activities of
         Major Firms in the Commercial Hazardous Waste
         Management Industry:  1981 Update."  May 1982.
         Prepared for the Office of Policy Analysis.

     17.  Office of Research and Development and the Office of
         Environmental Engineering and Technology.  "Assessment
         of  Emerging Alternative Technologies - Draft Report."
         Incineration Study - Task 4.  June 6, 1984.

     18.  Savant Associates, Inc. and Booz, Allen & Hamilton,
         Inc.   "Pilot Study to Identify the Major Determinants
         in  Firms'  Selection of Treatment/Disposal Options for
         Hazardous Wastes."  May 11, 1984.  Prepared for the
         Office of Policy Analysis.

     19.  Preliminary results of the responses to the Burner
         Questionnaire (see citation 16)  and discussions with
         Office of Solid Waste staff, September, 1984.

     20.  Information supplied by the Office of Solid Waste from
         the Industry Studies Program data base.

     21.  Information supplied in discussions with staff of the
         Office of Water Regulations and Standards.

     22.  Michigan Department of Natural Resources, Hazardous
         Waste Division.  Hazardous Waste Management in
         Michigan - A Status Report and Review of Future
         Options.   Draft Report.  March 1984.

U.S. Environmental Protection Agency
R6SJOn V Lib:'ai'V                         V-B- GOVERNMENT PRINTING OFFICE:  1985-526-778/30376
230 South Dearborn Street           F-2
Chicago, Illinois  60604

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