EPA-230/2-86-002
           United States        Office of Policy,       March 1985
           Environmental Protection    Planning and Evaluation
           Agency          Washington, DC 20460
           Policy Planning and Evaluation
>EPA     Assessment of Incineration
           As A Treatment Method for
           Liquid Organic Hazardous
           Wastes
           Summary and Conclusions

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 ASSESSMENT OF INCINERATION AS «A TREATMENT

METHOD  FOR LIQUID  ORGANIC HAZARDOUS WASTES:
           SUMMARY AND CONCLUSIONS
                         U.S. Environmental Protection Agency
                         Region V,  Library
                         230 South Dearborn  Street
                         Chicago, Illinois  60604
                  March  1985
    U.S.  Environmental  Protection  Agency
 Office of  Policy, Planning and  Evaluation
          Washington, D.C.  20460

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,S. Environmental Protection Agency

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              UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                          WASHINGTON, D.C. 20460
                                                       OFFICE OF
                               9 e (OAK         POLICY. PLANNING AND EVALUATION
                               fc 9 HQ9
MEMORANDUM

SUBJECT:  Final Report of the OPPE Incineration Study
FROM:     Milton Russell
          Assistant Administrator for'
           Office of Policy, Planning and Evaluation

TO:       A. James Barnes
          Acting Deputy Administrator

     The Agency-wide assessment of incineration  that  former
Deputy Administrator Alvin Aim requested is complete.   It *
presents a summary of information currently available on the
advantages and disadvantages of incineration as  a commercial
treatment option for managing liquid organic hazardous  wastes
and the issues associated with its use.  It also describes the
Agency's regulatory approach to controlling the  incinerator
burn itself and the handling of hazardous wastes from the
generator or storage site to the burn site.  The central focus
is the detailed comparison of land-based and ocean-based
incineration systems.  Liquid organic hazardous  wastes  are
chosen as a basis for comparison because they represent the
type of waste that can be treated by both systems.

     The regulation of incineration by EPA is complicated
because it occurs in three different programs under three
different statutes.  My office was given the task of  conducting
this study because of our unique perspective as  the Administrator's
policy office, and because we do not directly administer any of
these regulatory programs.

     The purpose of the study is to provide better information
for EPA decision making.  A primary objective is to support
informed Agency decision making on ocean incineration as the
Office of Water develops its regulations and research plans,
and begins to consider permit applications.  The study  will
also assist in implementation of other aspects of EPA's hazardous
waste management program.

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                              -2-
     The study provides an assessment based upon a snapshot of
public concerns and scientific and market data available in the
summer and fall of 1984.  Although some new data were developed
during these months, time and resource constraints required
that most of the study focus on gathering, organizing, and
interpreting existing information.  This means, of course, that
the results are not definitive, include many assumptions, and
acknowledge large data gaps.  We have confronted these data
limitations by being explicit about them:  the market analysis
presents numbers in ranges; the risk assessment includes
extensive sensitivity analysis; and for all areas, further
information needs are highlighted.  Consideration of assumptions
and data limitations is an important responsibility of those
using this report.

     Based on the findings of this study, we feel that
incineration on land or at sea is an environmentally sound
treatment technology and that it offers advantages over current
disposal options for liquid organic hazardous wastes under
some circumstances.  It also may help to meet the anticipated
need for greater treatment and disposal capacity for this
category of wastes in the future.  We also agree with many
citizens who are concerned about protecting our country's
marine environment.  However, given the current evidence
indicating little adverse health or environmental impact from
incineration, the safeguards provided by existing and proposed
regulations, the existence of risks of some degree from other
alternatives, and the need for sound methods of treatment and
disposal for liquid organic hazardous wastes, we believe it is
imperative for the nation to maintain the option of carefully
controlled and monitored incineration activities on land and
at sea.

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                      ACKNOWLEDGMENTS
    Many individuals and orqanizations within EPA contributed
to this study, particularly in developing the detailed inform-
ation provided in the background reports.  We specifically
acknowledge the substantial contributions of the persons
listed below.

     Office of Policy, Planning and Evaluation;

     Tim Baden, Jean Caufield, John Chamberlin, Jackie Ding-
     felder, Fiona Jarrett, Jeff Kolb, Ellie McCann, Matt
     Perl, Joe Retzer.

     Office of Solid Waste;

     Barry Stoll, Marlene Suit.

     Office of Research and Development;

     Jim Basilico, Harry Freeman,  Tin Oppelt, Glen Shira.

     In addition, private companies under contract to EPA were
instrumental in conducting two of the background studies.  For
these efforts we thank the following companies.

     Market Study;  Booze, Allen and Hamilton,  Inc.

     Comparative Risk Assessment:   Industrial Economics, Inc.;
     Applied Science Associates, Inc.;  Arthur D. Little, Inc.;
     and Engineering Computer Optecnomics, Inc.

     Extensive review of all portions of this lengthy study
was provided by a Steering Group composed of representatives
from three EPA regional offices, all major EPA headquarters
offices, and the U.S. Coast Guard.   We express special appre-
ciation to this Steering Group, and to additional reviewers
listed below, for the many days spent reviewing draft reports
and providing useful suggestions for improvement.

Steering Group:

  Bob Allen (Reg. Ill)            Y.J. Kim (Reg. V) 7
  Jim Basilico (ORD)              Dick Morgenstern (OPPE)
  Ron Brand (OPPE)                Jim Paskewich (Coast Guard)
  Tudor Davies (OW)                Conrad Simon (Reg.  II)
  Carl Gerber (ORD)                John Skinner (OSW)
  Marty Halper (OPTS)             Paul Stolpman (OAR)
  Charlie Huber (Coast Guard)      Karen Wardzinski (OGC)
  Ed Johnson (OW)

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                ACKNOWLEDGMENTS (CONTINUED)
Additional Reviewers:

  Tom Devine (Reg.  IV)
  David Flemer (ORD)
  Loren Hall (OTS)
  Glenn Kuntz (OTS)
  Ray Krueger (OPP)
  Jack Lehman (OSW)
  Nancy MacRae (U.S.  DOT)
  Joe Nalevanko (U.S.  DOT)
  Don Oberacker (ORD)
  Henry Onsgard (Reg.  VI)
  Margie Pitts (OW)
David Redford (OW)
Jim Repace (OAR)
Al Rubin (OW)
Stu Sessions (OPPE)
Garrett Smith (Reg. II)
Joel Smith (OPPE)
Marilyn Stone (OPPE)
David Sussman (OSW)
Pat Tobin (OW)
Chris Zarba (OW)

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                      TABLE OF CONTENTS

                                                            Paqe
CONCLUSIONS AND EXECUTIVE SUMMARY   	    1


I.    INTRODUCTION  	    6


II.   OVERVIEW OF FINDINGS	10


III.  REGULATORY APPROACH AND CONTEXT FOR  INCINERATION  .  .   22

      A.  Historical Context for Regulation   	   22
      B.  Federal Regulation of Support  Activities  ....   25
      C.  Comparison of Regulatory  Programs   	   28
      D.  Federal,  State and Local  Responsibilities   ...   33


IV.   DESCRIPTION OF INCINERATION TECHNOLOGY  	   36

      A.  Incinerator Design 	   36
      B.  Incinerator Performance   	   42
      C.  Sampling  and Monitoring	47
      D.  Waste Handling	49
      E.  Continuing and Planned Research   	   53


V.    MARKET CONSIDERATIONS FOR INCINERATION  	   55

      A.  Assessment of the Commercial Hazardous
            Waste Incineration Market   	   55
      B.  Assessment of Emerging Alternative  Technologies   61
VI.   COMPARISON OF RISKS FROM LAND-BASED AND OCEAN-BASED
        INCINERATION  	   68

      A.  Limitations of the Study	69
      B.  Incineration Systems Considered   	   70
      C.  Potential Releases	74
      D.  Human Health and Environmental Effects
            From Releases	81

VII.  PUBLIC CONCERNS REGARDING INCINERATION  	   91

      A.  History of Opposition	91
      B.  Concerns Reported by Citizens   	   94
      C.  Key Issues and Findings	94

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                 CONCLUSIONS AND EXECUTIVE SUMMARY
    The purpose of this study is to provide better information
for EPA decision-making on hazardous waste disposal options
by assessing the use of incineration for treatment of liquid
organic hazardous wastes, including its advantages and dis-
advantages, and the issues associated with its use.  The central
focus is the detailed comparison of land-based and ocean-based
incineration.  A primary objective is to assist in decision-
making on ocean incineration as the Agency develops regulations
and research plans.
                           CONCLUSIONS
    1.  Incineration, whether at sea or on land, is a
        valuable and environmentally sound treatment option
        for destroying liguid hazardous wastes, particularly
        when compared to land disposal options now available.


     The Agency's long-term goals are to reduce waste generation
and encourage recycling.  At the same time we must realisti-
cally deal with the wastes being generated now.  Incineration
destroys more than 99.99 percent of the hazardous constituents
of the waste, and can destroy more than 99.9999 percent of
wastes of special concern, such as polychlorinated biphenyls
(PCBs).  Risk assessments conducted by EPA indicate that
properly designed and operated incinerators which meet the
regulatory requirements for destruction efficiency pose
minimal risks to human health and the environment.  This is
not an endorsement of any particular ocean or land-based
hazardous waste incinerator facility.  Each must be carefully
evaluated as part of the permitting process.


    2.  There is no clear preference for ocean or land
        incineration in terms of risks to human health
        and the environment.

      Because of its greater distance from populated areas, the
human health risk from ocean incineration is significantly lower
than the already low human health risks from land-based inciner-
ation.  On the other hand, there is a remote probability that
ocean incineration operations could result in a ship casualty
and spill of hazardous waste.  Such a spill could be relatively
minor or cause substantial environmental damage, depending on the
location, composition of the wastes, and extent of clean-up
possible.

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    3.  Although current commercial and on-site hazardous
        waste incineration capacities on land are adequate
        to handle existing demand (except for PCBs), future
        demand will significantly exceed this capacity as
        other disposal alternatives are increasingly restricted.

    Market demand from waste generators for the use of incinera-
tion for hazardous wastes will increase substantially in the
coming years due to implementation of new restrictions in the
1984 RCRA amendments, generators' increasing concerns with long-
term liability, increased Superfund clean-up activities, and
declining landfill capacity.  Existing thermal treatment alterna-
tives, such as destruction in cement kilns, may provide some
additional capacity.  However, emerging alternatives such as
the plasma arc process are not expected to be commercially
available on a large scale in the near future.


    4.  Although previous research has verified the destruc-
        tive capabilities of incinerators, and risk studies
        have shown minimal impact on health and the environ-
        ment, a program of continuing research is needed to
        improve our current knowledge of combustion processes
        and effects.

    In particular, additional knowledge is needed about the full
range of combustion by-products, including their quantities,
toxicities, transport, and fate.  For ocean incineration, infor-
mation on potential effects could be significantly strengthened
through improved stack and ambient monitoring, emissions charac-
terization, and laboratory toxicity testing.  The current
research strategy of EPA's Office of Water, when carried to
fruition, will provide much of this additional information.


    5.  In order to better address the concerns of citizens
        regarding incineration, EPA needs to improve its
        public communication efforts and provide more visible
        leadership in the area of hazardous waste management.

    Public opposition to both land and ocean incineration may
decline somewhat if EPA addresses more fully some citizen
concerns regarding national regulatory strategy, local community
impacts, equity of facility siting, and public decision-making
processes.  Clearly many of the public's concerns are also
EPA's concerns, such as the potential health and environmental
impacts from incineration.  But the Agency needs to better
communicate how health and environmental concerns and priorities
are reflected in the Agency's regulations and standards.  Better
communication of EPA's overall regulatory policy, strategy, and
activities for hazardous waste management is crucial in providing

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a context for decisions on proposed permits for individual
incinerator facilities or vessels.  Better public communica-
tion is also important for improving EPA's credibility with
the public, which is a necessary foundation for the effective
accomplishment of the Agency's mission.
                         EXECUTIVE SUMMARY
o  Regulatory Approach

    The current regulatory framework for incineration involves
cradle-to-grave regulation of hazardous waste to be incinerated,
provided jointly by EPA and the Department of Transportation
(DOT).  DOT regulates transportation, transfer and handling of
hazardous waste.  EPA regulates all phases of hazardous waste
management, but focuses primarily on storage and disposal or
treatment.  Incineration is regulated by EPA under three
statutes: the Resource, Conservation and Recovery Act (RCRA),
the Marine Protection, Research, and Santuaries Act (MPRSA),
and the Toxic Substances Control Act (TSCA).

    EPA has now published a proposed regulation to provide
more specific criteria to regulate ocean incineration under
the MPRSA.  In general, the proposed regulation adopts the
most stringent requirements of RCRA, TSCA, and the London
Dumping Convention, an international treaty.  There are also
some differences that reflect certain unigue aspects of the
marine environment or of the MPRSA and LDC.
0 Assessment of Incineration Technology

     Determination of the efficiency of incineration on land and
at-sea is based on performance, not design.  To date, testing
has shown that incinerators are capable of destroying at least
99.99 percent of those compounds used as an indicator of overall
performance.  Critics have raised issues concerning the complete-
ness of this approach, about testing procedures, and about the
reliability of using only selected compounds to represent a
complex emission that has not been fully characterized.  EPA
scientists acknowledge the need to continue researching combustion
processes, but also believe that the current approach is the best
now available and does provide for effective protection of the
environment and human health.

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0 Assessment of the Incineration Market

     The demand for both commercial and on-site incineration
is expected to increase over existing capacity in the short to
midterm due to restrictions in the 1984 RCRA amendments and
other factors such as generators'  increasing concerns with
long-term liability from land disposal options.  Projections
of the specific amounts of additional capacity needed to meet
demand cannot be made with accuracy due to the uncertainty of
data and assumptions.  Future demand for commercial incineration
is expected to increase, but the size of the increase depends
on a number of factors including:  the specific policies and
time frame for new RCRA disposal restrictions; future EPA
actions which may create incentives or barriers for commercral
incineration versus other waste management practices, especially
treatment on-site; and the response of generators in developing
additional on-site waste management capacity rather than relying
on the commercial market.
0 Assessment of Alternative Technologies

     Emerging alternative technologies are seen to have minimal
impact on the incineration market for managing liquid organic
hazardous wastes.  Their greatest impact will be on specialized,
highly toxic waste streams that comprise only two to three
percent of the market.


0 Comparative Risk Assessment

     Several general conclusions can be drawn about the relative
risks to human health and the environment from land and ocean
incineration operations by using generic models of incinerator
facilities developed from combining various components of actual
facilities.  The overall human health and environmental risks of
both the ocean and land-based systems are very low.  The small
amount of human health risk comes from incinerator stack emissions
rather than emissions from transport and handling steps, with
stack emissions accounting for more than 85 percent of all long-
term, statistically expected, system releases from accidental
spills and air emissions.  In the case study developed, the
resulting incremental risk of developing cancer for a hypotheti-
cal "most exposed individual" was on the order of two in a
hundred thousand to one in a million for the various waste
streams and locations.  Human health risks from ocean incinera-
tor stack emissions range from 30 to 40 times less than risks
from land-based stack emissions, due to the greater distance
from populated areas.  Analysis of possible environmental
effects of stack releases from ocean incineration indicated
there would be no measureable effect on the marine ecosystem.

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     For ocean incineration, there are potential risks of spills
during the ocean transportation phase of the operation.  These
risks, while unique to ocean incineration, have only a very remote
probability of occurrinq.  The total probability for casualties
involvinq spills of any size is estimated to be one per 1200
operating years.  For Mobile Bay and the coastal areas, the spill
probabilities are one per 10,000 and 4,000 operating years
respectively.  EPA modelled the effects of hypothetical spills of
ethylene dichloride (EDC) and of PCBs.  While EDC spills would
have relatively minor effects on the ecoystem, a spill of PCBs
may have major effects.


0 Public Concerns

     There has been public concern about, and some very vocal
opposition to, the siting and permitting of both land-based and
ocean incineration operations.  For ocean incineration, opposition
has been regional in scope and has involved a wide range of groups
and individuals.  This is because citizens living along the Gulf
of Mexico believe that any potential impacts on the marine and
coastal environment will affect a very large, multi-state area.
Many citizens who are concerned about ocean incineration are not
completely against an ocean incineration program, but they do want
significant safeguards and guarantees.  For land-based incineration,
opposition has been more localized in the immediate area of the
facility, and has been strongest for off-site commercial facilities
(especially those seeking to burn PCBs), rather than on-site
facilities.

     The immediate impact of citizen opposition has been to impede
the siting of land incinerators or of port facilities for ocean
incinerator ships, and to delay the issuance of permits for
conducting burns on land and at sea.  If opposition persists or
grows, it may be difficult to develop additional commercial
incineration capacity.  More attention to public education,
especially regarding how incineration relates to EPA's hazardous
waste regulatory policy and strategy, may help to alleviate public
concerns.

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                       I. INTRODUCTION
A.  Background

    Each year, industry in the United States generates more
than 264 million metric tons of hazardous waste which must
be safely managed through treatment, storage or disposal.
EPA's regulatory, permitting, and enforcement programs are
gradually restricting the use of management practices deemed
insufficient to protect the environment and human health.
One effect of this is to reduce the available capacity for
managing hazardous waste over the short-term.

    Incineration is a technology which offers several advan-
tages over some existing waste management practices and
may help to meet the anticipated need for greater treatment
and disposal capacity.  However, public opposition to the
permitting of new incineration operations has been strong.
In response to the dilemma of perceived benefits versus
public concerns, the Deputy Administrator requested this
agency-wide assessment of incineration.

     The regulation of incineration by EPA is complicated
because it occurs in three different programs under three
different statutes.  The Office of Solid Waste developed
standards for and permits land-based incinerators under the
Resource Conservation and Recovery Act (RCRA).  The Office
of Toxic Substances developed standards for and approves
the incineration of PCBs on land under the Toxic Substances
Control Act (TSCA).  The Office of Water has issued permits
for ocean incineration under the Marine Protection, Research,
and Sanctuaries Act (MPRSA), and is now proposing standards
for ocean incineration under that Act.
B.  Purpose

    The purpose of this study is to provide better informa-
tion for EPA decision-making on hazardous waste disposal
options by assessing the use of incineration for treatment
of liquid organic hazardous wastes, including its advantages
and disadvantages, and the issues associated with its use.
The central focus is the detailed comparison of land-based
and ocean incineration.  Liquid organic hazardous wastes
are chosen as a basis for comparison because they represent
the type of waste able to be treated by both land-based
and ocean incineration.

    A primary objective is to support decision making on
ocean incineration as the Office of Water develops regulations

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and research plans, and begins to consider permit applications.
The study will also assist in implementation of other aspects
of EPA's hazardous waste management program.

C.  The Analytic Tasks

    Several different EPA offices contributed to the seven
major analytical tasks which are the basis of this study.
Each of the tasks addresses one central question.

(1)  Incineration Technology - How do ocean and land based
     incineration technologies compare in terms of design,
     performance, and waste handling features?  (Office of
     Management Systems and Evaluation)

(2)  Waste Estimates - What volumes of liguid organic hazardous
     wastes are currently generated and stored in the United
     States, and what now happens to these wastes?  (Office of
     Solid Waste)

(3)  Market Analysis - What is the current market for incinera-
     tion of liquid organic hazardous wastes, and what changes
     can be expected due to future regulatory actions?
     (Office of Policy Analysis)

(4)  Assessment of Alternative Technologies -  What new tech-
     nologies are available, or will be available in the
     near future, to treat or destroy liquid organic hazardous
     waste, and how will this affect the market for incinera-
     tion? (Office of Research and Development)

(5)  Risk Assessment - What are the comparative risks to human
     health and the environment from land-based and ocean
     incineration of liquid organic hazardous wastes?
     (Office of Policy Analysis)

(6)  Public Concerns - What are citizens' attitudes and concerns
     that affect the siting and permitting of incinerators?
     (Office of Management Systems and Evaluation)

(7)  Regulatory Context - How do the three incineration
     regulatory programs compare, what other regulatory
     programs affect incineration, and who implements these
     programs? (Office of Managment Systems and Evaluation)

    This paper integrates and summarizes the information
contained in the seven study tasks, and presents conclusions
based on that information.  To aid in presentation, we have
grouped together the findings from the Waste Estimates,
Market Analysis, and Alternative Technologies tasks into
one section on market-related issues.

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    More detailed information can be obtained from the much
longer background reports that are summarized in this paper.
They are:  (1) Description of Incineration Technology, (2)
Assessment of Emerging Alternative Technologies, (3) Assess-
ment of the Commercial Hazardous Waste Incineration Market,
(4) Comparison of Risks from Land-Based and Ocean-Based
Incineration, and (5) Public Concerns Regarding Land-Based
and Ocean-Based Incineration.

D.  Relationship to Other EPA Work on Incineration

    During the course of this study, three related EPA efforts
focused on incineration of hazardous waste have been in
progress.  Two of them address the adequacy of existing
scientific information and the need for further research.
The third activity has been the work of drafting proposed
regulations for ocean incineration.

    At the request of EPA's Administrator, the Environmental
Effects, Transport and Fate Committee of EPA's Science
Advisory Board (SAB) conducted a scientific assessment of
the incineration of liquid organic hazardous wastes at sea
and on land.   The Committee examined scientific data in
five areas to determine if the Agency has considered and
interpreted this data in a scientifically appropriate manner.
The areas were waste transportation, combustion and incinera-
tion, stack and plume sampling, environmental dynamics
and transport, and research needs.  We have kept in close
contact with the SAB committee during their work, and have had
access to draft products.  The SAB report, which will be pub-
lished in the near future, includes specific recommendations
for further research or reconsideration of existing data.

    The Office of Water initiated the development of a
comprehensive research strategy, in order to address the
adequacy of current information on the environmental and
human health effects of ocean incineration.  The strategy
identifies the types of research they believe necessary to
determine the environmental effects of ocean incineration.
When completed, the strategy will be used to guide future
research by EPA and the ocean incineration industry.

     Information from the work of the research strategy and
the SAB report has contributed to this incineration study.
Areas of concern identified by the SAB have helped to guide
the work of our risk assessment, and SAB issues are reflected
in our sections on technology, risk, and information needs.
The Office of Water's draft research strategy is reflected
in the section on information needs contained in the tech-
nology description.

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    The third important effort is the development of proposed
regulations for ocean incineration by the Office of Water.
We have worked closely with the requlation writers throughout
this study, and draft products from these efforts have helped
to guide and inform each other.  Many elements of this study
will be used by the Office of Water in making a generic
analysis of the need for ocean incineration prior to making
specific permit determinations.

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                    II.  OVERVIEW OF FINDINGS


     This section presents a brief overview of the findings
of this study, in terms of what we know and what we don1t know
about incineration at the present time.  The discussion provides
highlights about our regulatory approach, incineration technology,
market considerations, health and environmental risks, and
public opposition.


A.   Regulatory Approach to Incineration

     The current regulatory framework for incineration involves
cradle-to-grave regulation of hazardous waste to be incinerated,
provided jointly by EPA and the Department of Transportation (DOT).
DOT regulates transportation, transfer and handling of hazardous
waste.  EPA regulates all phases of hazardous waste management,
but focuses primarily on storage and disposal or treatment of
hazardous waste.  EPA also reguires the companies to provide for
emergency response in the event of unexpected releases.

     Incineration is regulated by EPA under three statutes:
RCRA, MPRSA, and TSCA.  The regulatory program for land-based
incinerators is still fairly new, since final regulations for
the RCRA permitting program were not issued until 1981.  The
MPRSA permitting program for ocean incinerator ships began in
1974.  Since 1974, however, EPA has issued permits for only four
series of ocean burns:  three in the Gulf of Mexico and one in
the Pacific Ocean.  These permits were issued under the authority
of the MPRSA and using the regulations and guidelines of the
London Dumping Convention (LDC).  Making use of this experience
in conducting operational and environmental monitoring, EPA has
now drafted proposed regulations for ocean incineration which
provide more specific criteria and standards for ocean incinera-
tion permits.

     The proposed regulation for ocean incineration has many
similarities to the RCRA regulations for land incineration.
Both land and ocean regulatory programs use the same performance
standard for incinerators, based on a destruction efficiency
or destruction and removal efficiency of at least 99.99%.  Both
measure destruction efficiency using a small number of principal
waste constituents as an index to represent all hazardous consti-
tuents contained in the waste.  Both programs also require a
trial burn to demonstrate that the performance standard will be
met and to identify appropriate operating conditions to be specified
in the operating permit.  In general, the proposed ocean incinera-
tion regulation, recently released for public comment, adopts
the most stringent reguirements of existing regulations under
LDC, RCRA, and TSCA.


                              10

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     While the control of hazardous waste incineration is based
primarily on federal laws and regulations, the responsibility for
implementing regulatory programs affecting incineration involves
all three levels of government.  In addition to broad federal
responsibilities, state and local governments are involved in the
areas of enforcement, facility siting, and emergency response
to accidents.
B.   Incineration Technology

     Incineration is not a new technology and has been commonly
used for treating liguid organic hazardous waste for many years
in Europe and the U.S.  The major benefits of incineration are
that the process actually destroys most of the waste rather than
just disposing of or storing it; it can be used for a variety of
specific wastes and is reasonably competitive in cost compared
to other disposal methods.  In the U.S., there are currently
25-40 commercial land-based incinerator facilities and 200-210
onsite incinerator facilities.  Ocean incineration was introduced
in the United States as a new adaptation of the technology in
1974, with several burns being conducted in U.S. waters.  Currently
in the U.S, one company owns two incinerator ships (now operating
in European waters), another has two ships under construction,
and two companies have developed conceptual designs for ships.

     The most common types of incinerators now in use are liguid
injection and rotary kiln incinerators.  The liguid injection
incinerator is capable of incinerating a wide range of liquids,
gases, and slurries; it is the most common type used on land, and
also the type used in all ocean incinerator vessels.  The rotary
kiln with liquid capability is far less common, but is used by
most major commercial land-based operators because of its ver-
satility in handling solid, sludge, liquid, and gaseous wastes,
either separately or simultaneously.

     There are some important differences in the design of
incinerators used on land and at sea.  Land incineration uses
liquid injection, rotary kiln, or other types of incinerators,
but all types generally include air pollution control equipment
in order to meet air emissions standards for hydrogen chloride
(HC1) and particulates.  Ocean incineration uses liquid injection
incinerators without air pollution control systems, based on the
fact that there are no nearby human populations at risk, and the
expectation that HC1 emissions will be rendered harmless by sea
water.

     EPA believes that incinerator efficiency is best determined
by the ability to achieve acceptable performance levels, and not
by incinerator design.  The performance-based system is used
largely because there are a wide variety of incinerator designs
which are capable of adequately destroying wastes when properly
operated and maintained.

                               11

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     Performance of hazardous waste incinerators is normally
measured in terms of destruction efficiency (DE) or destruction
and removal efficiency (DRE).  Destruction efficiency refers to
the percentage of hazardous constitutents destroyed in the
combustion chamber, while destruction and removal efficiency
accounts for both the destruction in the combustion chamber and
removal of remaining original hazardous constituents by air
pollution control equipment.  The RCRA regulations require a DRE
of 99.99%, while the proposed ocean incineration regulations
require a DE of at least 99.99% for most principal organic
hazardous constituents (POHCs).  The DE required for incineration
of polychlorinated biphenyls (PCBs), dioxins,  and dibenzofurans
is 99.9999%.

     Because many of the wastes to be incinerated are complex
mixtures of many different compounds, EPA uses a system which
selects principal organic hazardous constituents (POHCs) to
serve as indicators for the destruction of all constituents in
the waste feed.  POHCs selected are those considered most diffi-
cult to incinerate, with incinerability based  on a calculation
of "heat of combustion."  Past test results show that properly
designed and operated land and ocean incinerators are capable of
meeting EPA's performance standard requiring destruction efficiency
of 99.99% for POHCs.

     There are a number of technical issues currently under dis-
cussion in the scientific community which relate to the adequacy
of the Agency's current information or regulatory approach.
These issues are briefly outlined below.

     1.  Products of Incomplete Combustion (PICs).  In the process
of combustion, whether burning hazardous wastes or fossil fuels,
incinerators and other combustion devices may cause the formation
and emission of potentially harmful substances that are not
present in the initial feed.  Concern about the creation of
these substances, called products of incomplete combustion,
became acute in the late 1970's with the discovery of chlorinated
dioxins and furans in the emissions of many incinerators burning
municipal refuse and hazardous wastes.

     Because studies to date indicate that reported levels of
PICs from well operated incinerators present very low risks, EPA
has not regulated the emission of PICs.  However, everyone
agrees that more information on PICs is needed.  For example,
the Science Advisory Board report recommends a more comprehensive
characterization of emissions to provide an improved estimate of
risks for both land and ocean incineration.  The risk assessment
prepared for this study analyzes the risks from PICs, but the
studies available to us did not provide the degree of characteriza-
tion recommended by the SAB.


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     2.  The Adequacy of the POHC System.  Some persons have
questioned the utility of the POHC system, particularly the heat
of combustion index.  They claim that it does not allow adequate
determination to be made of the incinerability of complex mixtures
of chemical compounds.  EPA is continuing to assess the reliability
of this system, but believes that the heat of combustion measure
is still the best system currently available.  Also, since the
normal operating temperatures of incinerators are hundreds of
degrees higher than temperatures needed to destroy compounds at
the top of all incinerability hierarchies, the issue of selecting
an ideal system for ranking POHCs is not crucial.

     3.  Maintaining Performance.  Because in some previous tests
EPA only measured performance for short periods during optimum
operating conditions, the Science Advisory Board recommended
that EPA examine more closely the frequency and effects of "upset
conditions" which might result in increased emissions to the
environment.  This year EPA is conducting a series of research
burns to provide information on emissions under abnormal or
"off-design" conditions which might occur from waste composition
anomalies or mechanical failures.  In addition, since current
permitting guidance recommends that trial burns conducted for
permitting be extensive, the burn would normally include short-
term sub-optimal conditions.  Permit conditions therefore include
temperature and other requirements to assure a DRE greater than
99.99% for continuous operating conditions rather than short-term
optimal conditions.  Long-term upset conditions require termination
of hazardous waste fuel feed until the upset condition is corrected.

     4.  Monitoring.  Questions have been raised regarding both
stack emissions monitoring and ambient environmental monitoring.
There have been criticisms that sampling practices have not been
consistent and that analytical techniques have not been adequately
verified for both land and ocean systems.  In addition, monitoring
on ocean vessels presents unique problems because the stack gases
have very high exit temperatures due to the absence of pollution
control equipment.  These issues for stack emissions monitoring
are being addressed in the research programs of the Office of
Research and Development and the Office of Water.  The Office of
Water's research agenda also outlines a program for more thorough
ambient monitoring for ocean incineration than has been conducted
for past burns.


C.  Market Considerations for Incineration

    According to a 1981 EPA survey of hazardous waste generators,
about 264 million metric tons (MMT) of solid and liquid waste
were generated that year.  Less than one percent of these wastes
were liquid wastes that were incinerated.  Of the total liquid
wastes incinerated, only about ten percent, or .14 MMT, were
burned at off-site commercial facilities, while ninety percent
were incinerated by the generators.

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     Our estimates indicate that available on-site and commercial
incineration capacity for liquid waste other than PCBs is not now
fully utilized.  Estimates for utilization of commercial liquid
incineration capacity vary from 40 to 80 percent, with 55 percent
the mid-range estimate.  PCBs are an exception to this findinq.
Since only four off-site firms have received approval for
incineration of PCBs, capacity for PCBs is currently fully
utilized.  Industry sources indicate a 2 to 3 month backlog over
capacity and expect demand to further exceed supply because of
accelerated voluntary phase-out.  PCB capacity could be increased
substantially if current permit applications from two larqe
existing commercial facilities are approved, but this would
decrease capacity for incineration of other liquids.

     Although current land-based commercial and on-site hazardous
waste incineration capacities are adequate to handle existinq
demand (except for PCBs), future demand will significantly exceed
this capacity as other disposal alternatives are increasingly
restricted.  Demand for incineration is expected to increase
substantially in the coming years due to implementation of the
1984 RCRA amendments, generators' increasing concerns with long-
term liability, increased Superfund clean-up activities, and
declining landfill capacity.  While existing thermal alternatives
such as destruction in cement kilns may provide some additional
capacity, emerging alternatives such as the plasma arc process
are not expected to be commercially available on a large scale
in the near future.

     We estimated the effect of regulatory restrictions on liquid
waste incineration demand using four scenarios:  landfill restric-
tions, deep well injection restrictions, disposal impoundment
prohibitions, and waste-in-boilers restrictions.  Because of
uncertainties in estimating the effects of these restrictions,
low, high, and mid-range estimates of increased demand were
used.  If all four scenarios are combined, a mid-range estimate
of demand for commercial incineration would be 7 1/2 times current
capacity, and the commercial capacity shortfall would be 1.65
MMT/year.

     Minor increases in liquids capacity could occur if some
existing incinerators alter waste feeds to burn fewer solids and
more liquids.  Thermal industrial processes involving cement
kilns, lime kilns, and aggregate kilns have also been used for
commercial destruction of hazardous waste, and the potential for
more capacity exists.  Capacity could also be increased through
construction of more land-based incinerators, but incineration
firms reported that public opposition and permitting requirements
cause 3 to 5 year delays in bringing new incinerators on line.  If
three incinerator ships were issued permits to operate in the
U.S. (e.g., the two Vulcanus incinerator ships plus the first
Apollo ship), they would add .25 MMT/year to commercial capacity,
nearly doubling the current commercial capacity.

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     EPA examined the capabilities of a wide variety of emerging
alternative technologies in various stages of design and development
which might prove suitable for treating liquid organic hazardous
wastes.  The processes reviewed were identified through responses
to two national solicitations, from literature reviews, and
contact with experts in the field.  EPA concluded that emerging
alternative technologies will have a minimal impact on the market
for liquid hazardous wastes currently being incinerated.  Their
greatest impact will be on specialized, highly toxic waste streams
that comprise only 2 to 3 percent of the market.  These technologies
would probably be unavailable for commercial use for many years.

     Although the market analysis indicates that demand for
commercial incineration could increase substantially, this
projection cannot be used to predict accurately the amount of
commercial capacity which will be required.  Future demand is
dependent on advances in waste reduction and recycling, the new
RCRA disposal restrictions, and other future EPA actions which
may create incentives or barriers for commercial incineration
versus other waste management practices, especially treatment
on-site.


D.   Comparative Risk Assessment

     As part of the incineration study, EPA developed a risk
assessment case study which compares the human and environmental
exposure and effects likely from releases of land-based versus
ocean incinerators.  The study integrates existing information
and adds new analyses developed from existing methods and data.
No new primary research was completed, so conclusions are limited
by the availability and quality of information on emissions,
transport, fate and effects.

     1.  Incineration Systems Considered.  The study separated
land and ocean-based incineration systems into three and four
separate physical components, respectively.  Both systems include
land transportation, transfer arid storage operations and incinera-
tion.  The ocean incineration system also includes an ocean
transportation step.

     The ocean-based system considered has a configuration similar
to that proposed by Chemical Waste Management, Inc. (CWM), to
operate the Vulcanus II from Mobile, Alabama to the Gulf of Mexico
burn zone.  However, the study assumes that an integrated storage
and transfer facility is located at the port.  The land-based
system is not modeled on any single incinerator, but combines
characteristics of several existing commercial facilities.  Since
the systems reviewed are generic and not specific, the results of
this effort are n<~t sufficient to determine the risks associated
with any s;  -cific land or ocean-base«l incineration proposal.


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     The study does not examine releases on land from major
accidents involving fire or explosion at storage facilities.
The probability of such events occurring is very low, and since
both systems require similar storage facilities, the potential
for events of this type would be the same for both systems.  The
study assumed that incineration would occur for two simplified
waste streams with single hazardous constituents:  one containing
35 percent polychlorinated biphenyls (PCBs) by weight, and a
second containing 50 percent ethylene dichloride (EDC) by weight.

     2.  Quantities of Waste Released.   The starting point for the
analysis was to determine the statistically expected amount of
pollutant released from accidental spills and air emissions.
Considering all releases from each component of the incineration
systems and for both waste streams, the transportation and handling
components accounted for l-ess than 15 percent of expected releases,
while incineration stack releases accounted for more than 85 percent.

     The analysis of land transportation considers two types of
potential losses — spills from vehicular accidents and spills
from enroute container failures.  The study estimates of spills
are based on U.S. Department of Transportation (DOT) data per-
taining to all tank trucks carrying hazardous materials.  Use of
this data with our case study assumptions regarding miles traveled
indicates that accidents releasing any cargo are expected to
occur on the average once every 4 to 5 years, and container
failures once every 3 to 4 years.  Hazardous waste services
firms supplied information which indicates that the DOT average
accident rates are higher than those actually experienced by the
firms.  This is perhaps due to special management practices and
the use of stainless steel tanks more resistent to rupture than
aluminum tanks.  Our expected annual release estimates of 2.1
and 2.7 metric tons per year for the PCB and EDC wastes represent,
on average, about 0.5 percent of annual transportation related
releases of hazardous materials in EPA Region IV.

     The analysis of transfer and storage considers three types
of releases:  spills when unloading wastes from tank trucks;
spills from eguipment at waste transfer and storage facilities;
and fugitive emissions from transfer and storage.  Spills from
transfer and storage components are infreguent events, estimated
to occur at a rate of about .04 to .05 per year for transfer
of wastes from tank trucks, a rate of .03 to .04 per year for
equipment and storage tanks, and a rate of .002 to  .003 per year
for the hose loading wastes to the ship in the ocean system.
Spills of these types are likely to be contained at the facility.
Fugitive emissions would also result in expected releases of 0.6
to 0.7 metric tons per year, resulting in total expected releases
of 1.1 to 1.2 metric tons from transfer and storage.  The total
number of spills from transport and handling would represent, on
average, less than 0.1 percent of the number of spills of hazardous
materials likely from fixed facilities in EPA Region IV.

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     About 320 voyages of incineration ships in the North Sea have
been made since 1972 and no casualties or spills have occurred.
Estimates for spill rates used in this study are based on the
worldwide historical record of tank ships of a similar size and
class.  The historical rates were adjusted to take into considera-
tion the design of the Vulcanus, operating restrictions imposed
by the Coast Guard, and the soft bottom conditions in the Gulf
of Mexico.

     Spills from the vessel would be very infrequent events.  We
estimate that the frequency of all spills for the Vulcanus is
about one per 1,200 operating years.  However, the frequency of
spills estimated for any particular location is less.  For example,
the overall spill rate for the pier and harbor area is about one
per 3,000 operating years; for Mobile Bay about one per 10,000
operating years; for the coastal area about one per 4,000
operating years; and for the burn zone about one per 6,000
operating years.  These estimated spill rates are for all sizes
of spills.  Spills involving two or three or more tanks would be
extremely unlikely events.  For example, the estimated rate for
spills in Mobile Bay involving two. tanks is about one per 67,000
operating years, and about one per 200,000 operating years for
spills in the Bay involving three or more tanks.

     The tonnage carried by the Vulcanus is small in comparison
to commercial shipments of petroleum and hazardous substances in
the Gulf area.  For example, the cargo carried by the Vulcanus
would be only about 0.01 percent of petroleum and hazardous
substances transported in the Gulf area.  Since the Vulcanus has
a lower spill rate than other vessels, the potential for releases
from the Vulcanus is only about 0.002 percent of that from ongoing
shipments of petroleum and hazardous substances in the Gulf area.

     Incineration itself is the major release point in both
systems.  The study estimates total releases of organics and
metals for the PCB wastes is 22.5 metric tons per year for both
systems if one includes both stack releases and scrubber effluent.
Under the assumptions of this case study, metals account for the
largest portion of the releases.

     3.  Effects from Incinerator Releases.  The study estimated
and compared possible human health and environmental effects due
to incinerator releases and fugitive releases from transfer and
storage equipment.

     Our analysis of human health risks estimates the- incremental
risk of developing cancer for a hypothetical "most exposed
individual" (MEI) who resides at the location of the highest
overall risk due to air concentrations resulting from incinerator
stack and transfer/storage fugitive releases.  For the land-based
system, the location of the MEI is based on Census data; whereas
for the ocean-based system the MEI is assumed to reside at that
point on the coast where modelled concentrations are highest
averaged over a year.  These risk e°<- irr.~;t-es assume 70 years of
continuous oy.pcs^ce.

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                            Table 1

  SUMMARY OF INCREMENTAL CANCER RISK TO MOST EXPOSED INDIVIDUAL
                    FROM INCINERATOR RELEASES
                                    PCB Waste      EDC Waste
Ocean-based System*

   Stack (coastline)
   Fugitives (port)
6.37 x 10~7
2.02 x 10~8
1.06 x 10~6
4.97 x 10~10
Land-based System (average of two sites)
   Stack
   Fugitives

   Total
2.74 x 10"5
7.05 x 10"7
3.14 x 10~5
1.69 x 10~8
2.81 x ID'5    3.14 x 10~5
* The ocean system is not totalled because the releases are at
  different locations.
     Table 1 presents the incremental risk of developing cancer
for the most exposed individual due to releases from land- and
ocean-based fugitive (transfer/storage) and stack releases.  As
shown, the incremental risks from land-based incineration releases
are about three chances in one-hundred thousand for the locations
and wastes considered.  Virtually all of the incremental risk to
MEI is due to stack releases, with fugitive releases resulting in
increased risks of less than one in one million.  Incremental risks
to the most exposed individual at the coastline for the ocean-
based system range from one in one million to 6 in ten million.
As shown, the risks from fugitives to the MEI near the port
facility are less than two per one hundred million.

     The data and methods used to generate these incremental risk
estimates are highly uncertain and tend to overestimate expected
human health effects.  Thus, the absolute risks levels indicated
by these figures must be interpreted with caution.  However, a
comparison of the relative risks indicates that for the PCB waste,
land-based emissions create about 40 times more incremental risk
to the MEI than do ocean-based emissions.  For the EDC waste, the
ratio of land to ocean risk is about 30.

     An evaluation of the possible environmental effects of stack
releases was conducted for the ocean-based system.  These analyses
indicated there would be no measurable effect on the marine
ecosystem.  In fact, background atmospheric flux of PCBs into
Gulf waters is two to three orders of magnitude greater than
deposition from incineration of PCBs.

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     4.  Effects from Ocean Transportation Releases.  Alt
the probability of a spill is extremely low, the study ch
ized possible human health and environmental effects fror
at three sites:  Mobile Harbor, over the continental she;
the path to the burn zone, and in the burn zone itself. (
                                                        L
     The study examined possible human health effects due to
volatilization following the extremely unlikely event of the
loss of the entire vessel cargo.  If the loss were to occur in
the harbor within one kilometer of the city of Mobile, short
term dosages exceeding health Threshold Limit Values would occur
for populations directly downwind.  Spills in other locations
would not be expected to cause human health problems.

     EDC spills would have relatively minor effects on the marine
ecosystem.  These small impacts are the result of this compound's
rapid diffusion to low concentration levels and its relatively
low toxicity to marine species.  In addition, bioconcentration of
EDC is not a significant phenomenon.

     In contrast, substantial spills of PCBs would have major
effects on the marine ecosystem.  These effects range from being
quite severe in the Bay (substantial reduction in benthic species
and large bioconcentration effects on fish and shrimp) to less
severe in the burn zone area.  Since PCBs are a persistent
compound such effects are expected to last a long time.  Biocon-
centration effects in commerical and recreational species would
be of most concern in the Bay and contaminated shelf areas.


E*   Public Concerns Regarding Incineration

     There has been public concern about, and some very vocal
opposition to, the siting of both land-based and ocean incinera-
tors.  At the time of our survey in 1984, public hearings had
been held for approximately two dozen land-based incinerator
permits; fourteen involved some degree of opposition.  These
fourteen land-based facilities included three on-site and eleven
off-site facilities, and were located (or proposed) in many
different parts of the country.  For ocean incineration, one
company has applied for operating permits to burn in the Gulf of
Mexico, and a second company has applied for a permit to burn in
the Atlantic Ocean.  Both companies have experienced public
opposition to the siting of port facilities, and there has also
been opposition to the burn site in the Gulf.

     In general, ocean incineration has caused a greater
degree of public opposition than most land-based incinerators.
This is primarily because the perceived impact of land-based
incineration is very localized, whereas ocean incineration is
thought by some citizens to potentially affect an entire region:
the port community, all the communities along the coastline near
the burn site, and the marine environment.  While the source of

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opposition to both ocean and land incinerators has been primarily
from local communities, ocean incineration is unique in also
being actively opposed by some multi-state coalitions of civic,
business, and environmental groups,  and by some national environ-
mental groups.

     For land-based incineration, on-site facilities that directly
serve a single waste generator have  greater public acceptance
than off-site, commercial incinerators that serve multiple genera-
tors in a large market area.  Interviews and public hearing trans-
cripts indicate that many people feel that off-site facilities
do not provide sufficient economic benefits to the local community
to offset the risks associated with  the importation of wastes
from other areas.  On-site facilities are more clearly perceived
as being linked to businesses that are important to the local
economy, and are generally not perceived as being importers of
hazardous waste.  Opposition to land-based facilities has tended
to focus primarily on new, off-site  commercial facilities, which
share many similarities to ocean incineration; and on new appli-
cations to burn PCBs, which critics  view as particularly hazardous.

     For land-based incineration, the two areas of concern cited
most often by critics are potential  health risks from air emis-
sions and potential risks and impacts of spills from routine
transport, handling, and storage.  For ocean incineration, the
concerns mentioned most often are potential risks of spills from
routine transport activities and from catastrophic incidents,
and the feeling that EPA has, in the past, done a poor job of
managing the ocean incineration regulatory program.  While many
people concerned about ocean incineration are not completely
against an ocean incineration program, they do want significant
safeguards built into the regulations.

    The immediate impact of citizen  opposition has been to impede
the siting of land incinerators and  of port facilities for
ocean incinerator ships and to delay the issuance of permits for
conducting burns on land and at sea.  The long-term effect of
continued opposition may make it difficult to develop further
incineration capacity.  Solutions offered by the public to problems
with siting land incinerators have usually been to "put it
someplace else," although many people have suggested that it
might help for EPA or the states to  develop explicit siting
criteria.  Solutions offered for concerns about ocean incineration
focused either on using strict regulations and explicit siting
criteria or on banning incineration  at sea and relying on land
disposal methods.  In either case, critics want EPA to promote
other long-term solutions to hazardous waste management, such as
waste recycling, reduction, and detoxification.

     Public opposition to incineration on both ocean and land may
be reduced somewhat if regulatory agencies more fully address
public concerns regarding basic regulatory policy and strategy,

                              20

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enforcement resources, local community impacts, equity of facility
siting, and public decision-making processes.  In large part this
is a matter of taking the time and effort to better inform the
public about the "big picture" (i.e., the Agency's overall
regulatory policy, strategy, and activities for hazardous waste
management), in order to provide a context for discussions of
permits or siting decisions for individual incinerator facilities.
The fact that EPA has a national hazardous waste management
strategy to encourage long-term solutions is not very helpful if
the public does not know about it.  Improved communication and
more visible leadership from EPA would go a long way toward
resolving many of the issues and public concerns discussed here.
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    III.  REGULATORY APPROACH AND CONTEXT FOR INCINERATION
    Under federal statutes, all incineration facilities
handling hazardous wastes must obtain permits through which
federal requirements are applied to individual incinerators.
Three statutes govern the regulation of incineration, and
these statutes are implemented by two separate permitting
programs.

    EPA regulates land-based incineration in the Office of
Solid Waste under the Resource Conservation and Recovery Act
(RCRA).  Incineration of PCBs is regulated by the Office of
Toxic Substances under the Toxic Substances Control Act
(TSCA).  Ocean incineration is regulated by the Office of
Marine and Estuarine Programs under the Marine Protection,
Research, and Sanctuaries Act (MPRSA) and under the London
Dumping Convention, an international treaty.
A.  HISTORICAL CONTEXT FOR REGULATION OF INCINERATION

    1.   Land-Based Incineration

    Regulation of hazardous waste is a relatively recent
development in the United States.  Early environmental
laws were aimed at controlling the more obvious sources
of pollution of air and surface water.  However in 1976,
Congress passed the Resource Conservation and Recovery Act
to prevent damage to human health and the environment from
the mismanagement of waste, a less obvious source of pollu-
tion of air, surface water and ground water.  RCRA regulates
all waste, including liquid, sludge and solid, hazardous and
non-hazardous, and all methods of management, including
disposal, storage, treatment, and recycling.  RCRA thus
covers  the incineration of liquid organic hazardous wastes,
the subject of this report.

     Incineration is a waste reduction and treatment method
that has been used by industry for a number of years.  But
the regulatory program for land-based incinerators is still
fairly  new, since final RCRA regulations establishing
standards for incineration were not issued until 1981.
Under these regulations, all new and existing land-based
incinerators must receive an operating permit, issued either
by an EPA Regional office or by an EPA-authorized state
agency.

     While the regulatory program was getting underway,
Congress allowed those incinerator facilities already in
existence on November 19, 1980, to operate under "interim
status" until their permit applications are requested by EPA
(or the state) and a decision is made to approve or deny a

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a permit, based on full evaluation of the facility's perfor-
mance.  About 350 existing facilities applied for interim
status.  These facilities included those that consist ex-
clusively of incinerators and those that include incinerators
among several waste management methods.  As EPA has requested
permit applications, some companies have chosen to close
down their incinerator facilities rather than spend the
resources necessary for obtaining a permit and modifying
their operations and equipment to comply with federal
standards.  As of February 1985, the Agency has received
200 permit applications from existing incinerator facilities,
and has issued 23 final permits.

    For new incinerator facilities, the operator must receive
a RCRA permit before starting construction of the facility.
At this time, only four permits have been issued for new
incinerator facilities.

    2.  Incineration of PCBs

    In the same year that RCRA was passed, Congress also
passed the Toxic Substances Control Act, partly in response
to concern about potential health hazards from PCB contamina-
tion.  TSCA imposed a ban on the manufacture of PCBs, and
in 1978 and 1979 EPA issued regulations for proper PCB marking
and disposal, which included high-temperature incineration
as an approved disposal/treatment method.

    If an incinerator operator wants to burn PCBs, he must
receive special approval from EPA headquarters.  PCB approvals
are usually incorporated into RCRA permits issued by EPA
Regional Offices or authorized state agencies, or incorporated
into MPRSA permits issued by EPA headquarters.  However,
existing incinerator facilities with interim status under
RCRA may obtain an approval to burn PCBs before receiving a
final RCRA permit.  So far, EPA has approved PCB incineration
for 15 land-based incinerator facilities and for one research
permit for an incinerator ship.

    3.  Ocean Incineration

    Incineration at sea has been used by some European countries
since 1972, both because of a shortage of land for disposal
and because ocean incineration is considered to be environment-
ally preferrable to most land disposal options for hazardous
waste.  Use of ocean incineration was first proposed in the
United States in 1974, when Shell Chemical Company, prohibited
from continuing to dump liquid organochlorine wastes in the
Gulf of Mexico, hired a Dutch company to incinerate those
wastes in the Gulf.

    In 1972, Congress passed the Marine Protection, Research,
and Santuaries Act, which regulates the transportation of

                             23

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material from the U.S. for the purpose of dumping into ocean
waters, and prohibits ocean dumping of wastes without a
federal permit.  The purpose of this law was to strictly
limit the dumping into ocean waters of any material which
would adversely affect human health, welfare, or amenities,
or the marine environment, ecological systems, or economic
potentialities.  Ocean dumping regulations were issued
in 1973, and Shell was subsequently prohibited from dumping
its untreated organochlorine wastes in the ocean after
November 1973.  Shell then began storing its wastes in above-
ground tanks at its plant in Deer Park, Texas, and in 1974
the company hired Ocean Combustion Services, operating out
of the Netherlands, to incinerate their wastes using the
Vulcanus incinerator ship.

    Initially EPA believed it did not have regulatory
authority over ocean incineration, based on lack of evidence
in the Ocean Dumping Law (i.e., MPRSA) and its legislative
history that Congress intended to deal with airborne pollu-
tants in the ocean dumping act.  However after careful
consideration, including discussions with Congressman Dingell,
a chief author of the MPRSA, and with the National Wildlife
Federation, an organization that took an early interest in this
issue, the Agency decided that it did have jurisdiction over
incinerator ships as "indirect" ocean dumpers.  This interpre-
tation was based on the Agency's concern that the failure to
regulate recently developed waste disposal techniques involving
ocean incineration would frustrate the purposes of the MPRSA
and the London Dumping Convention.  Thus in 1974 ocean
incineration became prohibited without a federal permit.
This was two years prior to regulation of land-based incinera-
tors under RCRA.

    EPA issued the Ocean Dumping Regulations in 1973, thereby
establishing criteria for evaluating permit applications.  But
these regulations do not provide specific technical criteria
for incineration activities.  EPA has therefore issued permits
for ocean incineration using administrative and technical
criteria from both the Ocean Dumping Regulations and the
regulations and technical guidelines of the London Dumping
Convention.

     The London Dumping Convention (officially referred to as
the Convention on the Prevention of Marine Pollution by
Dumping of Waste and Other Matter) was entered into in 1972 to
address the growing concern of several nations that marine
pollution had developed into a serious environmental problem.
The United States was a leader in initiating the Convention,
basing its position on the newly signed MPRSA.  The London
Dumping Convention entered into force in 1975 when the
minimum required number of 15 nations (including the U.S.)
ratified it as an international treaty.  The LDC requires

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each ratifying nation (52 countries at the present time) to
regulate by permit the dumping or incineration of wastes
loaded from its ports.

    After the LDC went into effect in 1975, the parties to
the LDC adopted regulations and technical guidelines for
incineration at sea.  The regulations establish technical
standards, including combustion and destruction efficiency,
operating conditions, and monitoring parameters, and also
administrative standards such as recordkeeping reguirements.
The United States must apply the LDC's regulations and take
"full account of" the technical guidelines in developing
permits.

    Regulatory activities began in October 1974 with a joint
proposal by EPA, the National Wildlife Federation, and Shell
to evalua'te incineration at sea as a viable alternative to
direct ocean dumping, land disposal or land incineration
for highly toxic substances.  During 1974 and 1975, Shell
conducted two research burns and two operational burns in
the Gulf of Mexico.  Based on the data and experience gained
from these initial burns, this first U.S. use of ocean
incineration for the disposal of organochlorine wastes was
rated a success and an environmentally acceptable practice
when closely monitored and regulated.

    Between 1974 and 1982, the EPA issued permits for four
series of burns conducted by the Vulcanus I ship:  three in
the Gulf of Mexico and one in the Pacific Ocean.  Making use
of this additional experience in conducting operational and
environmental monitoring, EPA has now developed proposed
ocean incineration regulations which provide specific criteria
and standards for ocean incineration permits, and criteria
for designating and managing ocean incineration sites.
B.  FEDERAL REGULATION OF INCINERATION SUPPORT ACTIVITIES

    Incineration is the last phase in a "cradle-to-grave"
set of linked activities.  The actual burning of hazardous
wastes reguires support facilities for storage, transporta-
tion, and transfer of wastes.  Current authorities for
regulating the support aspects of ocean and land-based
incineration are summarized in Table 1, and are described
in the following pages.

    1.  Storage Facilities

    The RCRA regulations apply to any waste storage
facilities on land, including those used to support land-
based and ocean incineration.  This includes separate storage
facilities such as Chemical Waste Management's facility at
                             25

-------




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Emelle, Alabama, and any waterfront transfer facility that
involves storage for more than ten days.  If a waste genera-
tor stores wastes on-site for more than 90 days, he must
apply for a RCRA storage permit.  If a transporter stores
wastes at a transfer facility for more than ten days, he
must apply for a storage permit.  If a transporter stores
wastes for ten days or less, the facility is considered
a transfer facility, not a storage facility.  (Local building
codes also regulate certain aspects of storage facilities,
and may require additional safety features for storage of
hazardous wastes.)

    2.  Transportation of Hazardous Wastes

    Transportation of hazardous wastes is regulated by EPA
under RCRA, and by the U.S. Department of Transportation
primarily under three laws:  the Ports and Waterways Safety
Act, 46 USC Ch. 37 (formerly the Port and Tanker Safety
Act), and the Hazardous Materials Transportation Act.  To
integrate the administration and enforcement of these various
Acts, DOT and EPA executed a Memorandum of Understanding in
1980 that delineates areas of responsibility and coordination
in the enforcement of standards applicable to shippers and
transporters of hazardous waste.

    RCRA regulations cover both inter and intrastate land
transportation, and concern recordkeeping, reporting, label-
ing, containers, tracking wastes from generator to ultimate
disposal site through the manifest system, and transporta-
tion of waste only to approved (i.e., permitted) facilities.
HMTA regulations apply to all commercial transportation of
packaged products and bulk shipments, whether interstate or
intrastate, and reguire proper classification of materials,
shipping papers, marking on packages, and safety precautions
for vehicles.  HMTA regulations are enforced by agencies in
the Department of Transportation:  the Materials Transporta-
tion Bureau regulates compliance with packaging standards;
the Federal Highway Administration and Federal Railroad
Administration regulate land transportation; and the U.S.
Coast Guard regulates water-borne transportation.

    Although many EPA and DOT reguirements are similar,
there are some areas over which only EPA or DOT has jurisdic-
tion.  One such area is the EPA requirement that transporters
clean up any accidental discharges of hazardous waste.
Another is the DOT requirement for the installation of
certain safety features on all motor vehicles.

    Either agency, or both, may bring enforcement action
against transporters of hazardous waste.  The two agencies
routinely coordinate investigations and enforcement actions

                             27

-------
in order to avoid duplication.  In practice, the EPA usually
monitors activities at generator and waste management facili-
ties, while DOT monitors all shipping in between, whether by
highway, railroad, air or water.

    The Coast Guard has a particularly important role in the
control of hazardous waste transportation by water, which can
be a supporting link for incineration either on land or at
sea.  This agency has regulatory responsibilities for many
different aspects of hazardous waste transportation under a
wide variety of statutes, as indicated in Table 2.

    The Coast Guard is now in the process of collecting in
one place in the Code of Federal Regulations existing
regulations for the design and construction of incinerator
ships.   A proposed rulemaking to accomplish this will be
issued in 1985.

    3•   Transfer Facilities

    Transfer facilities or activities that are incidental to
transportation activities are regulated under the Hazardous
Materials Transportation Act and the Ports and Waterways
Safety Act.  Thus, land transfer facilities and activities
are subject to all DOT reguirements for proper packaging,
containers, and labelling of hazardous wastes.  Transfer
facilities for loading ships must comply with Coast Guard
reguirements for all waterfront facilities, plus specific
reguirements for ships loading oil products or waste.

    Waterfront or land-based transfer facilities are not
subject to RCRA reguirements unless the wastes are stored at
the facility for more than ten days, in which case the
transporter must apply for a storage permit and meet all
storage reguirements under RCRA.

    4*   Activities in the Coastal Zone

    The Coastal Zone Management Act reguires that anyone
applying for a federal permit for an activity affecting land
or water use in the coastal zone must certify that the proposed
activity complies with federally-approved state coastal zone
management programs.  If an affected state disagrees, the
applicant may appeal that judgment to the Secretary of
Commerce.  EPA cannot issue an incinerator permit until a
final determination is made regarding compliance with state
coastal zone management programs.
C.  COMPARISON OF REGULATORY PROGRAMS FOR INCINERATION

    RCRA regulations specify both performance standards and
administrative standards for land-based incinerators that

                             28

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         Table 2:  U.S. Coast Guard Responsibilities
           Activity

Safety and storage of hazardous
materials at waterfront facilities.

Procedures and pollution prevention
requirements for the transfer of
hazardous materials between facilities
and vessels.

Design, construction, and operation
of vessels carrying hazardous
materials.
Inspection and certification of
vessels carrying hazardous materials.

Supervision of hazardous materials
transfer to vessels.
Vessel movement control through
port area.

Aids to navigation.

Limitations on operational
discharges from ships.
Ocean dumping surveillance of vessels
for enforcement of regulatory and
permit requirements.
  Statutory Authority

  Ports and Waterways
   Safety Act

  Ports and Waterways
   Safety Act
  Clean Water Act
0 46 USC Chapter 37
0 46 App. USC 883
0 Marine Protection,
  Research, &
    Santuaries Act

0 46 USC Chapter 37
0 Hazardous Materials
   Transportation Act
0 Ports and Waterways
   Safety Act
0 Marine Protection,
   Research, &
   Santuaries Act

0 Ports and Waterways
   Safety Act

0 14 USC Chapter 5

0 Act to Prevent Pol-
   lution from Ships
0 Clean Water Act

0 Marine Protection,
   Research, &
   Santuaries Act
Responding to spills of oil and hazard-
ous materials in the coastal areas of
the United States.
0 Clean Water Act
0 Comprehensive
   Environmental
   Response,  Com-
   pensation, and
   Liability  Act
   (i.e.,  Superfund)
                             29

-------
must be met before obtaining a permit.  Incinerator units
are subject to performance standards for: (1) the destruction
and removal efficiency (ORE) of principal organic hazardous
constituents (POHCs); (2) the emissions of hydrogen chloride;
and (3) the emissions of particulate matter.  A trial burn
or alternative source of data is reguired in order to demon-
strate that the incinerator can meet performance standards and
to determine day-to-day operating parameters.  For enforcement
purposes, compliance with the operating parameters specified
in the permit is regarded as compliance with the performance
standards.

     RCRA regulations also establish administrative standards
for hazardous waste management facilities that apply to
incinerator facilities in the following areas:

  - waste analysis plan
  - inspection of eguipment
  - monitoring of operating conditions
  - facility security system
  - personnel training program
  - special controls on iqnitable, reactive, & incompatible
       wastes
  - location constraints based on risk of earthquakes &
       floods
  - contingency plan to respond to fire, explosion, or
       accidental release of wastes
  - manifest system, recordkeeping, and reporting
  - facility closure plan and financial arrangements
  - liability insurance for accidental occurrences

    The PCB technical reguirements for incinerators include
general performance standards, operating conditions, and
monitoring and recordkeeping reguirements.  The TSCA regula-
tions distinguish between liquid and nonliguid forms of
PCBs.  For nonliquid PCBs, a high performance standard which
translates into a 99.9999 percent destruction efficiency
(DE) is established.  For liquid PCBs, a performance standard
of 99.9 percent is specified for combustion efficiency (not
destruction efficiency), coupled with certain required operat-
ing conditions.  However, in practice, the Agency has required
a demonstration of 99.9999 percent DE for liquid as well as
nonliquid PCBs.

    The proposed regulation for ocean incineration has many
similarities to RCRA regulations.  Both the ocean and land-
based regulatory programs evaluate incinerators primarily in
terms of their capability to destroy a high percentage of
the incoming waste.  Both use performance standards rather
than equipment design standards.  Both have chosen the same
standard of 99.99 percent (99.9999 percent for PCBs, dioxins
and dibenzofurans), for destruction efficiency or destruction
and removal efficiency, and measure a small number of principal

                             30

-------
organic hazardous constituents to represent all hazardous
constitutents in the waste stream.  Both programs require a
trial burn to demonstrate that the performance standard will
be met, and to identify appropriate operating conditions to
be specified in the permit.

   In general, the proposed ocean incineration regulation
that was recently released for public comment adopts the
most stringent requirements of existing regulations under
the LDC, RCRA, and TSCA.  In spite of many similarities,
however, the ocean incineration program differs from the
land-based program in several respects.  The major
differences are summarized in Table 3.  One important
difference, discussed below, regards the demonstration of
"need" for ocean incineration.

    1.  "Need" for Ocean Incineration;  Hazardous Waste
        Management vs. Marine Resource Protection

    A statutory requirement unique to MPRSA involves
determining a need for ocean incineration and ocean dumping
in evaluating permit applications.  Not only must the permit
applicant demonstrate that all standards and environmental
impact criteria have been met, but the Agency must consider
the need for ocean incineration.  This consideration of
need is also part of the London Dumping Convention require-
ments that alternative land-based methods be examined prior
to issuing ocean dumping permits.

    As explained in the preamble to the proposed Ocean
Incineration Regulation, in determining need, the environmental
and human health risks of ocean incineration will be compared
to those associated with practicable land-based alternatives,
taking into consideration technical feasibility and economics.
Need will be presumptively demonstrated if ocean incineration
poses less or no greater risks than practicable land-based
alternatives.

    The preamble also describes EPA's approach to making the
determination of need.  The Agency will draw on this study
and other sources to prepare a generic needs analysis, which
will be made available to the public for review and comment.
The analysis will be revised every five years to take into
account new technologies.  In determining the need for a
particular permit, EPA will compare the risks of an applicant's
operation with those identified in the Agency's generic
needs analysis.  Only where information is submitted or is
available to the Agency which indicates that an applicant's
operations are unique from those considered in the generic
analysis or which demonstrate that the information on which
the Agency based its assessment has significantly changed
will the issue of need be reconsidered.
                             31

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                                                          32

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    Whether the needs criterion  implies that the ocean  should
be treated as a specially protected resource continues  to be
a source of disagreement.  Those who favor the special  pro-
tection approach argue that the oceans are a unique resource
where cleanup is difficult if not  impossible, and  that  our
scientific understanding of the fate and effects of pollutants
is very limited.  Others believe that because of the remote-
ness of incineration sites from populated areas, the dispersal
capacity of the atmosphere, and the vast dilution, dispersal,
and assimilation capacity of the open seas, the oceans  offer
a significant waste management option which involves little
or no health or environmental risk.
D.  FEDERAL, STATE AND LOCAL RESPONSIBILITIES FOR
    IMPLEMENTING REGULATORY PROGRAMS AFFECTING INCINERATION

    While the authority to control incineration  is based on
federal laws and regulations, the implementation of these
and other regulatory programs that affect incineration
involves all three levels of government.  Table 4 outlines
the parties responsible for implementing various regulatory
activities that relate to each of the phases of cradle-to-grave
waste management ending with incineration.  The following
discussion highlights implementation areas that have been of
particular interest or concern to some citizens.

    1.  S i t i ng

    Siting of waste management facilities has historically
been a local decision, although two states, New Jersey and
California, have now developed siting criteria and exercise
site approval authority before issuing operating permits.
Local siting authority is based on zoning ordinances.
Since difficulty in siting incinerators and other hazardous
waste facilities is a continuing problem, and may to some
extent hamper implementation of a national hazardous waste
management program, there may be a growing need for EPA to
become involved in the siting issue.  Some members of the
public have suggested that EPA ought to develop national
siting criteria for land incinerators and for waterfront
transfer facilities.  Currently EPA's only involvement in
siting is the designation and management of ocean burn sites.

    2.  Enforcement

    As discussed earlier, EPA and DOT together have regulatory
and enforcement authorities covering cradle-to-grave hazardous
waste management activities.  EPA's enforcement authority
may, for the most part, be delegated to EPA approved state
agencies.  Either EPA or DOT, or both, may bring enforcement
action against land transporters of hazardous waste.  Enforce-

                             33

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                                                                  34

-------
ment of regulations for truck traffic is usually done by
state police, while regulations for railroad transport are
enforced by the Federal Railroad Administration.  For water-
borne transportation, the Coast Guard is solely responsible.
Regulations for waste storage, waste content, and incineration
are enforced by EPA or authorized state agencies.

    3.   Emergency Response

    The party responsible for a spill is required to be
financially responsible for its cleanup.  Both EPA and the
Coast Guard, as federal On-Scene Coordinators (OSC) , encourage
the responsible party to initiate the cleanup and to carry
out these activities until mitigation is completed to the
satisfaction of the OSC.  EPA has emphasized this by requiring
contingency plans as part of the permitting requirements.
The Coast Guard requires pollution response equipment to be
available for oil transfer facility operations.

    Local governments generally respond immediately to
pollution incidents because of their close proximity and
responsibility for public safety within their jurisdictions.
In this regard, many city, county and state governments have
created special hazardous material response teams to deal
with and coordinate immediate "first aid" and mitigation of
the public safety aspects of these incidents.  However,
federal authorities (EPA and Coast Guard OSCs) have respon-
sibility to ensure that necessary actions are carried out to
mitigate the effects of a spill in order to protect public
health and welfare or the environment.

    4.   Coordination

    There is ongoing close coordination between EPA and DOT.
These two agencies coordinate the development of regulations,
such as the adoption by EPA of DOT's regulations for transpor-
tation of hazardous wastes.  These agencies have also agreed
on a division of duties for enforcement, and have developed
mechanisms for coordination, including formal agreements
and processes for interagency review of proposed permits.
Coordination with state and local agencies is achieved
through the review process for proposed regulations and
proposed permits, and through the National Contingency Plan.

    Superfund and the Clean Water Act require the development
of a National Oil and Hazardous Substances Pollution Contingency
Plan (NCP), which clearly delineates federal agency responsi-
bilities for oil and hazardous materials pollution response
activities.  The NCP also mandates that this coordination
and role identification be further documented for federal
and state roles in Regional Contingency Plans.  This coordina-
tion is continued at the local level in Local Contingency
Plans,  which describe the roles of state, county and municipal
departments and the federal On-Scene Coordinator.

                              35

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        IV.  DESCRIPTION OF INCINERATION, TECHNOLOGY

     This section provides an explanation of.the technical
aspects of land-based and ocean incinerators used for burning
liquid hazardous waste.  It describes the key design, perform-
ance and waste handling features, and discusses similarities,
key differences, and major issues raised regarding the two
technologies.  Information presented here is taken from two
sources: a background report, "Description of Incineration
Technology," prepared by the Office of Management Systems
and Evaluation; and the draft report on incineration by the
Science Advisory Board.

     Incineration technology has been used extensively for
managing liquid organic hazardous wastes.  A major benefit of
incineration is that it destroys most of the waste, thereby
vastly reducing the volume of waste that must be ultimately
absorbed by the environment.  Incineration can be used effectively
for a variety of waste streams.  Land-based incinerator
systems have been applied for both on-site and off-site use,
while ocean incineration systems are designed for off-site
management of wastes.

     On land, the most common types of hazardous waste incinera-
tors currently in use are liquid injection and rotary kiln
incinerators.  The liquid injection incinerator, the most
common type of hazardous waste incinerator on land, is also
the type used in all ocean incinerator vessels.  The rotary
kiln with liquid capability is far less common, but is used
by most major commercial land-based operators.  For ocean
incineration, the ship designs discussed are the Vulcanus I
and II, owned by Chemical Waste Management, Inc., and the
two Apollo ships being built for At-Sea Incineration, Inc.
Two conceptual designs utilizing containerized systems are
also discussed briefly.  These systems have been proposed by
Seaburn, Inc., and Environmental Oceanic Services, Inc.


A.  INCINERATOR DESIGN
    1.  What is Incineration?

     Incineration is a controlled oxidation process that
uses flame combustion to combine hazardous wastes with oxygen,
thus converting the wastes to less hazardous materials.  The
specific products of incineration vary depending on the
types of wastes that are burned.

     Incineration of simple, non-halogenated organic wastes
involves the oxidation of carbon and hydrogen molecules to
form carbon dioxide and water.  If conditions for complete
combustion are not present, carbon monoxide is also formed,
but this product can be minimized by carefully controlling
temperature, turbulence and oxygen during combustion.  Because

                             36

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of this characteristic of the combustion process, the presence
of excessive carbon monoxide in the flue gas is commonly used
as a measure of incinerator performance.

     Incineration of more complex organic wastes creates
additional chemical products.  Many industrial processes gen-
erate liguid hazardous wastes containing halogenated materials,
with chlorinated compounds being the most common.  (Halogenated
compounds are those that contain the elements fluorine,
chlorine, iodine, bromine, or astatine.) When chlorinated
organic wastes are burned,, the products include hydrogen
chloride and small amounts of chlorine, as well as carbon
dioxide and water.  Other liquid hazardous wastes may contain
metals, sulfur, or organically-bound nitrogen.  When
incinerated, they produce oxides of metals, sulfur and
nitrogen.

     An important consideration for hazardous waste incin-
eration is the heating value of the wastes.  To maintain stable
combustion, the heat released from burning wastes must in turn
be able to ignite incoming wastes, thus providing the energy
needed for oxidation to occur.  The heating value of an organic
waste decreases as the percentage of water or chlorine increases.
Liquid wastes with low heating values require auxiliary fuel
or blending with wastes that have higher heating values.

    2.  Basic Design Features for Land-Based Incinerators;

     All waste incinerators on land consist of a waste feed
system, an air or oxygen-fed burner system, a combustion
chamber, combustion monitoring systems, and, if required,
equipment for air pollution control and ash removal.  (The
simplified flow diagram in Figure 1 illustrates the relation-
ships of these basic elements of incinerator design.)  These
elements are applied somewhat differently in liquid injection
and rotary kiln systems.

     The liquid injection system is capable of incinerating a
wide range of liquids, gases and slurries.  The combustion
system has a very simple design with virtually no moving parts.
A burner or nozzle atomizes the liquid waste and injects it
into the combustion chamber where it volatilizes and is in-
cinerated.  A forced draft system supplies the combustion
chamber with air to provide oxygen for combustion and turbulence
for mixing.  The combustion chamber is usually a cylinder lined
with refractory (i.e., heat resistant) brick, and nay be
fired horizontally, vertically upward, or vertically downward.
The specific configurations are designed to satisfy the
needs of the owner.

     Rotary kiln systems are capable of incinerating solid,
sludge, liquid and gaseous hazardous wastes either separately
or simultaneously.  In general, commercial rotary kiln operators
utilize high Btu liquid wastes in conjunction with lower Btu
solids in order to enhance combustion.  Because of their

                             37

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           FIGURE  1:   COMPARISON OF A GENERALIZED


           INCINERATION SYSTEM ON LAND  AND OCEAN
                                LAND
 LIQUID
 WASTE
AUXILIARY
  FUEL
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                   RESIDUE
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                                 38

-------
versatility, rotary kilns have been use-1 for large commercial
facilities.  A rotary kiln is a slowly ro.t--Vot:q, refractory-
lined cylinder that is mounted at a slight ir,ci ir.e frcni the
horizontal.  Solid wastes enter at the high end of the kiln,
and liquid or gaseous wastes enter through atomizing nozzles.
Rotation of the kiln exposes the solids to the  heat, vaporizer,
them, and allows them to combust by mixing with air.  The
rotation then causes the ash to movo to the lower end of fch?
kiln where it can be removed.  Rotary kiln systems usually
have a secondary combustion chamber or afterburner following
the kiln to ensure more complete combustion of  the wastes.

    3.  Basic Design Features for Ocean Incinerators

     Ocean design also utilizes liguid injection incinerators.
Design elements include a waste feed system, a  combustion
air or oxygen system, a combustion chamber and  combustion
monitoring systems.  Ocean incinerators do not  have eguipment
for air pollution control.  Figure 1 illustrates the relation-
ships of these basic elements.

     The Vulcanus ships employ vertically-mounted liquid
injection incinerators, each having three rotary cup vortex
burners, firing into a cylindrical, refractory-lined combustion
chamber.  The Vulcanus I has two incinerators mounted on its
stern, and the Vulcanus II has three incinerators.  The Apollo
ships will each be equipped with two vertically-mounted liquid
injection incinerators in the stern.  The Seaburn design would
make use of an oceangoing barge, towed by a tug, and carrying
144 mobile stainless steel containers stored above the main
deck in vertical cells.  Incineration would be provided by
two horizontally-mounted liquid injection incinerators.

    4.  Design Issues

     The major issues directly related to design are discussed
below.  Note that there are several significant differences
between land-based and ocean incineration design.  (Table 1
provides a comparison of key design features.)

   ° Atomizing Burner

     Maintaining atomizing burners in good operating condition
     is an issue for both land and ocean incinerators.   In
     normal operation, atomizing burners in liquid injection
     incinerators are subject to corrosion and plugging which
     may impede atomization.   Several measures should be taken
     to prevent this from occurring: (1)  selection of a design
     appropriate to the specific incinerator geometry and
     waste characteristics,  and (2) frequent visual inspection,
     monitoring of feed pressure,  and cleaning and replacement
     when necessary.
                             39

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Some critics have claimed that the rotary cup burners
employed by the Vulcanus are inadequately designed to
ensure complete combustion.  EPA believes this criticism
is unfounded.  Industry burner designs vary greatly, and
EPA has measured acceptable incinerator performance for
a wide range of burner designs, including the rotary cup
burner observed throughout the Vulcanus monitoring activi-
ties.  Conseguently ,  EPA has focused regulation on
incinerator performance rather than burner design.

Combustion Chamber

A few critics of the Vulcanus have argued that the com-
bustion chamber design is inadequate because it does not
provide sufficient turbulence for mixing of the waste with
oxygen or enough residence time for complete combustion.
EPA believes that the appropriate test of any incinerator
system, including the Vulcanus, is its performance
characteristics rather than the design features.  EPA
has evaluated a wide range of chamber designs with
varying residence times and has found that most of them
will perform satisfactorily with proper operating tempera-
tures, feed rates, and maintenance.  Although chamber
design affects performance, no clear formula exists for
linking any particular chamber design to destruction
efficiency .

          ControlDevic e s
Land-based incinerator design generallv incorporates scrubbers
to meet particulate and acid gas standards.  As a result,
acid gas and particulate emissions are reduced, but scrubber
water is generated and must be managed as a hazardous waste.

Since ocean incinerator design on the Vulcanus and Apollo
ships does not include scrubbers, there is no scrubber
water to be managed.  The proposed designs by Seaburn
and Environmental Oceanic would be equipped with seawater
quench devices which only serve to dilute the plume and
cause it to mix with the sea more rapidly.  Critics
claim that the lack of scrubbers results in the re-
lease of acid gases and particulates which may endanger
the environment and human health.  Monitoring from
previous burns as well as modelling indicates that acid
gases are adequately neutralized by the ocean and
that particulate emissions can be kept at safe levels
by requiring limits on the metal content of the wastes
to be incinerated.

Heat Recovery

Approximately 25 percent of land-based incinerators
currently employ heat recovery equipment, while ocean
incinerators do not.  Critics claim that ocean incineration

                          41

-------
     therefore results in a loss of potential energy.  Ocean
     incineration design does not include mechanisms for heat
     recovery because the energy that would be generated
     could not be utilized at sea, and because the high
     concentration of hydrogen chloride (HC1) in ocean incinerator
     emissions would damage heat recovery eguipment.  Major
     land-based commercial competitors for highly chlorinated
     wastes also do not currently employ energy recovery.


B.  INCINERATOR PERFORMANCE

    1.  The Concepts of Destruction Efficiency and Destruction and
        Removal Efficiency

     EPA believes that incinerator efficiency is best
determined by the ability to achieve acceptable performance
levels, and not by incinerator design.  The performance-based
system is used largely because there are a wide variety of
incinerator designs which are capable of adequately destroying
wastes when properly operated and maintained.

     Performance of hazardous waste incinerators is normally
measured in terms of destruction efficiency (DE) or destruction
and removal efficiency (DRE).  Destruction efficiency refers
to the percentage of hazardous constitutents destroyed in the
combustion chamber, while destruction and removal efficiency
accounts for both the destruction in the combustion chamber
and removal of remaining original hazardous constituents by
air pollution control equipment.  The RCRA regulations require
a DRE for most principal organic hazardous constitutents
(POHCs) of 99.99%, while the proposed ocean incineration
regulations require a DE of at least 99.99% for most POHCs.
The DE required for incineration of polychlorinated biphenyls
(PCBs), dioxins, and dibensofurans is 99.9999%.

    2.  The Principal Organic Hazardous Constituents (POHCs) System

     Because many of the liquid hazardous wastes to be
incinerated are complex mixtures of many different compounds,
the RCRA program developed a system whereby the overall
performance of an incinerator is measured by tests on a
small number of waste constituents or individual hazardous
compounds.  The Office of Water has also adopted this approach
for the ocean incineration program.

     The testing system uses a small number of principal
organic hazardous constitutents to represent the many
compounds found in a complex waste.  In order to use POHC
surrogates to represent many compounds, EPA developed a system
to rank compounds on the basis of how difficult they are to
burn.  Incinerability is measured by "heat of combustion," a
                                42

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theoretical calculation of energy released when waste molecules
are combusted.  Compounds with a lower heat of combustion are
presumed to be more difficult to burn than those with a higher
heat of combustion.

     Some persons have questioned the utility of the POHC system,
and particularly the heat of combustion index.  They claim that
it does not allow adequate determination to be made of the inciner-
ability of complex mixtures of chemical compounds.  In addition,
recent data obtained by the Office of Research and Development
(ORD) does not substantiate the heat of combustion and concentra-
tion-based method for ranking compounds.  Evidence seems to be
mounting that any or all organics may be destroyed essentially
equally under a given condition.

     The issue of selecting the appropriate measure for a POHC
ranking system becomes less important when one considers that
normal operating temperatures which organic compounds are subjected
to in land and ocean incinerators are several hundred degrees
higher than temperatures needed to destroy any compounds at the
top of all investigated or considered hierarchies.  EPA is continuing
to assess the reliability of this system, but believes it to be
the best system currently available.

    3.  Performance Results for Land-Based Incinerators

     Past test results from land-based incinerators show
that performance levels for DRE on compounds chosen as POHCs
and on PCBs are achievable.

     During the 1970's, EPA conducted a series of test burns
in land-based incinerators to measure destruction efficiency.
The tests involved liquid injection and rotary kiln incinerators
(as well as other thermal technologies), and demostrated that
99.99 percent DE was achievable.  These test burns became the
basis for the selection of the 99.99 percent DRE standard in
the RCRA regulations.

     In order to develop further information on incinerator
performance in conjunction with an incinerator Regulatory
Impact Analysis (RIA), EPA conducted additional test burns.
The tests involved a wide variety of incinerator designs,
control devices, waste types, and operating conditions.  These
second test burn results provide strong additional support for
the capability of achieving DREs of 99.99 percent.

     Because the RIA tests only measured performance for
short periods during optimum operating conditions, the Science
Advisory Board recommended that EPA examine more closely the
frequency and effects  of "upset conditions" which might result
in increased emissions to the environment.  In 1985, EPA is
conducting a series of tests at its Combustion Research Facility
in Arkansas which will address this issue.  A series of
research burns will provide information on emissions under

                               43

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abnormal or "off-design" conditions which might occur from
waste composition anomalies or mechanical failures.  In
addition, current permitting guidance recommends that trial
burns conducter for permitting be extensive enough to include
short-term suboptimal conditions.  Permit conditions therefore
include temperature and other requirements to assure a ORE
greater than 99.99% for continuous operating conditions
rather than short-term optimal conditions.  Long-term upset
conditions require termination of hazardous waste fuel until
the upset condition is corrected.

     Data from many trial burns of liquid polychlorinated
biphenyls provide evidence that the thermal destruction
of PCBs in incinerators, in accordance with PCB regulations,
can be accomplished with efficiency and minimal emissions
of undestroyed PCBs.  These trial burns have demonstrated
that incinerators with a variety of designs can achieve a
destruction efficiency of greater than 99.9999% for PCBs.

    4.  Performance Results for Ocean Incinerators

     Since 1974, the Vulcanus I has been involved in four
series of test burns under the Ocean Dumping Regulations.
EPA participated in an additional series of test burns for
the Vulcanus II held in the North Sea in 1983.   EPA scientists
believe the test burn results indicate that destruction
efficiencies of greater than 99.99% are achievable.  For
example, an August 1982, Vulcanus I test burn in the Gulf of
Mexico of an organochlorine mixture showed DEs  greater than
99.99 percent for several POHCs, including hexachlorobenzene,
the POHC with the lowest heat of combustion of  those tested.
Similarly, a February 1983 test burn for the Vulcanus II in
the North Sea resulted in DEs of greater than 99.99 percent for
several POHCs, including carbon tetrachloride.   Tables 2 and
3 provide more details on the test burns.

     Many past test burn results have been questioned because
of the sampling practices and analytical methodologies used.
This issue is addressed under sampling and monitoring.

    5.  Products of Incomplete Combustion (PICs)

     In the process of combustion, whether burning hazardous
wastes or fossil fuels, incinerators and other  combustion
devices may cause the formation and emission of potentially
harmful substances that are not present in the  initial waste
feed.  Concern about the creation of these substances, called
products of incomplete combustion (PICs), became acute in the
late 1970's with the discovery of chlorinated dioxins and furans
in the emissions of many incinerators burning municipal
refuse and hazardous wastes.

     Because of the potential hazard from emissions of
chlorinated dioxins or furans, EPA has studied  this issue
closely.  In 1980, EPA sampled five municipal incinerators

                              44

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-------
for dioxin emissions and found both the emissions and human
health risk from the emissions quite low.  At the same time,
EPA evaluated the formation of dioxins and furans during the
incineration of PCBs at the ENSCO and Rollins incinerators in
El Dorado, Arkansas, and Deer Park, Texas.  Although low
levels of both PICs were found, a worst case risk analysis
showed the incremental human health risk for cancer to be in
the range from 0.1 to 0.8 per million population, based on
the point of maximum ambient air concentration in a residential
area.  EPA also examined PIC formation during the test burns
conducted in 1981 for the Regulatory Impact Analysis.  In
ocean test burns, EPA found only trace amounts of dibenzofurans,
and in one instance, dioxin at O.09 nanograms per cubic
meter.  Other potential PICs were not investigated.

     Because studies to date indicate that reported levels of
PICs from well operated incinerators present very low risks,
EPA has not regulated PICs.  However, everyone agrees that
more information on PICs is needed.  In particular, the
Science Advisory Board report recommends that EPA take steps
to characterize incinerator emissions more completely, specifying
the identity of all chemicals released to the environment.  A
more comprehensive characterization of emissions would provide
an improved estimate of risks for both land and ocean
incineration.  The risk assessment prepared for this study
does analyze the risks from PICs, but the available studies
did not provide the degree of characterization recommended by
the SAB.

     Both the RCRA program and ORD are continuing research
into the factors affecting PIC formation and control, and the
potential effects of PICs on human health and the environment.
The ocean incineration program is proposing that measurement
and analysis of PIC emissions be done during research permit
burns.
C.  SAMPLING AND MONITORING

    1.  Monitoring to Determine Compliance with Performance
        Standards

     For both ocean and land-based incinerators, compliance
related sampling and monitoring involves two phases:  the
trial burn and normal operations.

     Comprehensive sampling and monitoring is conducted during
a trial burn to determine the range of operating parameters
for which the incinerator is capable of achieving the required
performance levels.  Sampling techniques and analysis methods
must be in accordance with 40 CFR part 60, Appendix A (Methods
1-5), and Text Methods for Evaluating Solid Waste: Physical/
Chemical Methods (SW-846, Second Edition, July 1982), or in
                             47

-------
Sampling and Analysis Methods for Hazardous Waste Combustion
(A.D. Little, Inc., EPA-600/8-84-002, February 1984).   In
order to calculate destruction efficiency, the mass  input
and emissions of POHCs are measured.  In addition, key  operating
factors such as temperature, carbon monoxide emissions,  and
waste feed rate are determined.  Land-based incinerators
also require monitoring sufficient to provide computation  of
particulate emissions and hydrogen chloride (HC1) removal
efficiency (if emissions exceed 1-H  kilograms HC1 per hour).

     Based upon the results of the trial burn, final operational
parameters are established   ~ht re.* "it designates operating
requirements which are ~;o<=c ^ '-"io tri each waste feed burned,
and which reflect the range of operating conditions  shown  to
achieve acceptable performance levels.  During normal
operations, concentration and mass emissions of POHCs are  not
measured, but indicator £;uch as temperature and carbon
monoxide are measured crr.uinucusly.  Due to London Dumping
Convention requirements, there are slight variations in  the
parameters monitored cr * :::^. and at  sea.

     An important safet- feature of  ooth land and ocean
systems is the required automatic waste feed cutoff  system
which shuts off the was:;-  feed to the incinerator whenever
certain operating pararet?" c- deviate from the limits set  in
the permit.  Both the ] ar.r erd ccea~" program require frequent
testing of the cutoff sy^ce---..

     Questions have been raised as to whether state-of-the-art
techniques for emissions sampling, analysis and monitoring
have been used on ocean incinerators, and whether or not
these procedures are actually applicable to ocean incinerators
due to short stacks ar.c Mnh stack gas temperatures.  In
evaluating past burns, EPA scientists believe that destruction
efficiency data is acceptable based on present technology
for only three of the burr.s.  In earlier burns, proper  destruction
efficiencies may have been achieved, but sampling and analysis
techniques used then did not provide sufficient information
based on current standards of evaluation.

     The draft research strategy prepared by the Office  of
Water addresses three tec'-,; ic=.l areas where additional
analytical studies r.houl-i V..^ conducted during research  burns.
The first is more vigorous uft^ting of performance through
longer sampling times, t > rivei-sing the stack, and quantifying
particulate patter,  rh.p ->tnor areas of concern are  a more
complete characterization -f emissions and potential chemical
changes as hot effluent gases enter  the cooler atmosphere.

    2.  Ambient Monitoring

     Under RCRA and TSCA,  no ambient monitoring is required
for lanu-Ldoed i,,c iner?4-^^^.  All routine monitoring is  for
stack emissions.  In some cases, scutes may require  ambient
monitoring under the Clean Air Act.

                             48

-------
     Based upon risk studies, EPA scientists believe that if
stack emissions are within regulatory limits, there will be no
adverse environmental effects.  Furthermore, EPA scientists
believe that accurate and reliable tenting for ambient air
effects around land-based incinerators is generally not feasible
due to extremely low concentrations and interference from
other industrial activities.

     For ,ocean incineration, some environmental studies have
been conducted during past ocean burns.  EPA has used ships
and planes to follow and sample incinerator plumes in order to
model the dispersion of the emissions over the ocean, and
water samples were analyzed for possible emission constituents.
Organisms have also been caged in the incinerator ship area
to determine if any effects could be observed.  In these
studies, EPA has not detected any increase in background
levels of any emission products in ambient air, water, or
marine biota samples collected.

     In its review of the scientific literature on incineration,
the Science Advisory Board acknowledged the difficulty of
linking environmental effects to incinerator emissions through
field monitoring, particularly because of the widespread
burning of fossil fuels for heating, transportation and
industrial processes.  Also, the SAB agreed with EPA that there
is as yet no evidence that the operation of liguid hazardous
waste incinerators has produced adverse ecological effects.
At the same time, however, the SAB encouraged EPA to expand
its work on the transport, fate, and effects of incinerator
emissions by using a combination of laboratory and field
studies.  The draft research strategy for incineration at
sea developed by the Office of Water embodies many of the
approaches suggested by the SAB.
D.  WASTE HANDLING

    1.  Waste Handling Aspects of Land-Based Incineration

     Figure 2 illustrates a typical process flow for a land-
based commercial incinerator.  In practice, many variations
occur, especially among on-site and smaller facilities.  In
this illustration, incoming wastes are delivered to the
facility either as liquids in tank trucks or in drums and
other types of containers.  If the wastes have not been
previously identified, they are tested to determine content,
viscosity, and combustion value.  Then the wastes are pumped
into temporary storage tanks which are set up to accommodate
compatible waste streams.  Some incinerator operations may
also utilize a blending tank to prepare an optimal mixture
for burning.

     When incineration begins, wastes are pumped from the
storge tanks or the blending tank to the incinerator at feed

-------
Figure 2:   Simplified Process Flow for a Land-Based Incinerator
            and an Existing Infrastructure Ocean Incineration
            System
           Incoming
            Liquid
           Waste in
           Drums and
          Containers
                         Incoming
                        Liquid Waste
                            in
                          Tankers
          DeDrumming
           Facility
Liquid
 Waste
Receiving
    &
 Testing
          Decontamination Rinsate
            Metal
            Scrap
Liquid
 Waste
                              Temporary
                            Storage Tanks
                            Blending Tank
                             (Optional)
     Land-Based
     Incineration
   Residuals and
   Scrubber Water
    Management of
    Residuals and —
    Scrubber water)
_On-site or
 Off-site

JWastewater
 Treatment Plant

_Hazardous Waste
 Landfill

 Underground
                      Injection Well

(LAND-BASED INCINERATION)
                                               Truck  or Rail
                                                 Transport
                              Dockside
                            Loading Area
                  Incinerator
                 Vessel Travels
                  To Burn Site
                Ocean
             Incineration
                    Residuals In-
                    cinerated at
                    Sea or Disposed
                    of on Land
                          (OCEAN  INCINERATION)
                                 50

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rates which provide for optimum combustion and which do not
exceed the maximum thermal input (BTU per hour) allowed by
the permit.  If necessary, supplementary fuel is fed into the
incinerator to enhance combustion.

     Following incineration, scrubbers are employed to remove
acid gases and particulates before they can be released from
the stacks.  The process creates scrubber water which is
classified as a hazardous waste.  Options for managing the
scrubber water include underground injection wells, treatment
and release to surface waters under an NPDES permit, and
settling and removal of sludge for disposal in a hazardous
waste landfill.

    2.  Waste Handling Aspects of Ocean Incineration

     Three logistical systems have been proposed for managing
waste handling aspects of ocean incineration.  These are
no-infrasturcture, integrated, and existing infrastructure
systems.

     0  No-Infrastructure System;  This system minimizes the
        use of fixed facilities.  Wastes accumulate at their
        sources and are stored in truck or rail tanks or
        portable liquid containers.  Filled containers are
        transported to an existing port transfer facility
        which is not dedicated solely to incinerator ship
        operations.  The wastes are then pumped or the con-
        tainers lifted directly onto vessels.  With portable
        containers, each container has a direct feed to the
        incinerator, and the wastes never leave the container
        until actual incineration of the wastes begins at sea.

     °  Existing Infrastructure System;  An existing infra-
        structure system is similar to a no-infrastructure
        system in that it makes use of port transfer facilities
        which are not dedicated solely to incinerator ship
        operations.  It differs from the no-infrastructure
        system primarily in that it allows for blending, pre-
        paration, and storage functions to be performed at
        existing, centralized facilities which are separate
        from the port facility.  Figure 2 illustrates a
        process flow for ocean incineration using an existing
        infrastructure system.

     0  Integrated System;  An integrated system involves the
        siting of a specialized port facility dedicated pri-
        marily to incinerator ship operations.  The facility
        receives waste from generators and has the capacity for
        analyzing, blending, and storing them.
                             51

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    3.  Key Differences in Waste Handling

     Although there are many variations among the different
systems, the key differences between ocean and land-based
incineration are in the transport of the wastes and disposal
of residuals.

     On land, the wastes are pumped directly from the blending
tanks or temporary storage tanks to the incinerator.  In
contrast, an existing ocean infrastructure system, such as
that proposed for the Vulcanus, would reguire an additional
transfer and transport leg to haul wastes from the blending
site to the port site.  In all of the ocean systems there is
an additional transportation step from the port site to the
ocean burn site.

     The other key handling differences are in the disposal
of residuals.  Land-based facilities must handle scrubber
water resulting from their processes.  Current ocean incinera-
tion operations are not faced with managing scrubber water,
since they do not use scrubbers.  Under the proposed SeaBurn
system there is still no scrubber water residual, since sea
water used in the guench system is returned directly to the
ocean.

    4.  Key Waste Handling Issues

     Critics are concerned that the mixing of incompatible
waste could lead to runaway chemical reactions, fires or
explosions, but compatibility tests are a routine part of
system safeguards for land and ocean operations.

     For example, in preparation for ocean incineration,
Chemical Waste Management (CWM) routinely tests incoming
waste for blending compatibility at its facility in Emelle,
Alabama.  Only after the wastes are found to be compatible
are they blended.  CWM reports that blended wastes are held in
storage tanks for a minimum of several days before loading
into tank trucks for transport to the Vulcanus.  Any reaction
that could occur would occur by this time.

     For land-based incinerators, permits indicate the scope
and freguency of sampling of incoming waste to determine
whether it is within permit-specified physical and chemical
composition limits, and to prevent the mixing of incompatible
wastes.  It is in the best interest of land and ocean incinerator
operators to ensure that adeguate testing of incoming waste
is done as a safeguard to protect their own investments.

     An additional concern involves the potential for spills
and fugitive emissions during the collection, transport,
pumping, and storage of the wastes.  In the absence of concrete
data, the SAB and others have speculated that releases from
handling and storage might be large.  The risk assessment
conducted for this study, however, indicates that such releases
are probably very small compared to stack emissions.

                              52

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E.  CONTINUING AND PLANNED RESEARCH

     The Agency's Office of Research and Development has a
continuing incineration research program that is applicable
to land and ocean incineration.  This program focuses on
destruction efficiency through extensive field testing on
different types and sizes of incinerators.  Through this
research, extensive incinerator performance data have been
developed in support of RCRA regulations, regulatory impact
analyses, and Regional and State programs.

     The goal of this research program is to fulfill the need
for scientific and operating data to assure compliance and
safe operation of thermal destruction systems on land and at
sea.  Specific efforts include the following:

     0 Work is continuing on assessing performance capabilities
       of existing hazardous waste thermal destruction devices
       (incinerators, industrial kilns, boilers, etc.).
       Resulting data will provide additional technical
       grounding for Agency policies and regulations on
       thermal destruction as a hazardous waste disposal
       option.

     0 Research underway at the EPA Combustion Research
       Facility (CRF) in Arkansas and at the EPA Center Hill
       research facility in Cincinnati is developing an
       understanding of thermal destruction chemistry and the
       engineering of thermal processes.  This is a first
       step in characterizing and assessing the performance
       of full-scale thermal destruction devices and in
       extrapolating performance information from one waste
       or scale of eguipment to another.

     0 Laboratory and limited field evaluation of stack-gas
       sampling trains for volatile organics will be done,
       and methodologies updated.  In addition, a stack
       sampling train for semi-volatile organics will be
       evaluated, and the revised method validated.

     0 In early 1985, the Arkansas facility will embark on
       a series of burns of typical liquid and solid organic
       hazardous waste streams to determine the emissions
       under abnormal or "off-design" conditions, such as
       transient conditions which can occur during startup,
       shutdown, waste composition anomalies, or mechanical
       failures.

     0 Work will be done to define easily monitored incinerator
       operating parameters which correlate with system
       performance.  This will allow rapid, reliable, and
       economical determination by enforcement officials of
       compliance with permit conditions, and facilitate
       preventive or corrective actions.
                              53

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     0
       Efforts will continue to investigate the performance
       capabilities of innovative thermal destruction processes
       which may be capable of handling hazardous wastes not
       suitable for current systems, more cost effective
       than current systems, or capable of attaining higher
       or more reliable performance than existing processes.

     In addition to this general research program, EPA's
Office of Water has developed a research strategy specifically
directed at gathering additional scientific information
related to incineration at sea.  This strategy, completed in
February 1985, will provide direction to EPA's ocean incinera-
tion research program, including research burns which are
expected to begin in the summer of 1985.  These burns will
provide opportunities for more complete emissions characteriza-
tion, evaluation of emissions toxicity, additional testing
and validation of emissions monitoring methods, further
analysis of plume dispersion, and environmental monitoring
at the burn site.

     The Science Advisory Board's review of past incineration
research efforts also resulted in a series of recommendations
for gathering additional or improved information.  The SAB
notes that incineration is a valuable means for destroying
hazardous wastes and that its recommendations are designed to
strengthen the already existing programs.  The major focus of
the SAB report is the development of additional information
to refine EPA's analyses of the potential impacts of incinera-
tion on human health and the environment.  For example, the
SAB recommends that future research activities include:
A more
their
              complete identification of emissions, including
             physical form and important characteristics;
     0 An assessment of releases to the environment from
       all phases of incineration operations, including
       waste handling and transportation;

     0 Further validation of sampling methodologies;

     0 Improving simulations of atmospheric and aguatic
       transport and fate of emissions, including better
       use of local meterological conditions and considera-
       tion of possible ocean microlayer impacts;

     0 Additional efforts to analyze the toxicities of
       incinerator emissions, including laboratory toxicity
       studies and field assessments.

     In general, these recommendations are consistent with
EPA's current and planned research efforts described previously.
In addition, the risk assessment prepared for this study
addresses in detail the SAB concern with releases during
transport, storage, and handling phases of incinerator opera-
tions .
                              54

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       V.  MARKET CONSIDERATIONS FOR INCINERATION
     This section presents an overview of current and future
conditions of the market for incineration of liquid organic
hazardous wastes (LOHWs).  It profiles the current market,
establishing baseline estimates for volumes of LOHWs presently
incinerated, and estimates the degree to which existing
incineration capacity is currently being utilized.  Also
presented are projections of incineration demand and capacity
in response to possible changes in the RCRA regulations.
finally, alternative technologies are assessed in order to
judge their comparability to incineration for managing LOHWs,
and their possible effects on the market for incineration.

     Information contained in this section is taken from the
background report, "Assessment of the Commercial Hazardous
Waste Incineration Market," prepared by Booz, Allen and Hamilton
Inc. for EPA's Office of Policy Analysis, and from the background
report, "Assessment of Alternative Technologies," prepared by
EPA's Office of Research and Development.

A.  ASSESSMENT OF THE COMMERCIAL HAZARDOUS WASTE INCINERATION
    MARKET

    Two key limitations of the market assessment should be
kept in mind when evaluating and using these results.  First,
this market assessment has been conducted only at the national
level, although a regional analysis would have increased the
usefulness of the results.  But the limited sample size of the
database prevented an analysis of regional impacts of land
disposal restrictions and other RCRA amendments - impacts that
might vary significantly by Region.

     Secondly, the numerous sources of data used were often
inconsistent or not in an easily accessible form.  The principle
source of data was the National Survey of Hazardous Waste
Generators and Treatment, Storage, and Disposal Facilities
Regulated Under RCRA in 1981.  This was supplemented with other
reports, discussions with EPA staff, and contacts with leading
firms in the hazardous waste management industry.  Attempts
were made to reconcile and corroborate estimates and assumptions,
but this was not always possible, so we have often had to use
ranges rather than exact numbers.  The study does, however,
reflect a general consensus that estimates and assumptions are
reasonable.

     Each of these limitations to the study may be overcome
in the future as more and better data become available to
the Agency.
                            55

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   1.  Profile of the Incineration Market

    According to EPA's 1981 survey of hazardous waste generators,
about 264 million metric tons (MMT) of solid and liquid waste
were generated that year.  Less than one percent of these wastes
were liquid wastes that were incinerated.  Of the total liquid
waste incinerated, only about ten percent, or .14 MMT, was
burned at off-site commercial facilities, while ninety percent
were incinerated by the generators.

    Estimates of commercial* incineration facilities range
from 25 to 40, with 30 used as the best estimate for this
analysis.  There are approximately 200 to 210 on-site or captive
incineration facilities.  Because some facilities may have
multiple incinerators, estimates of the number of operating
incinerator units is somewhat higher: 30 to 50 commercial and
240 to 290 on-site.

    Most of the incineration facilities are located in the
Southwest and Southeast; however, commercial firms in the
Middle Atlantic and North Central regions of the country have
significant capacity.  Very few firms are located in the Western
U.S.

    Liquid injection units are the most common type of
incinerator, but newer units tend to be rotary kilns or fume
incinerators.  Precise estimates of throughput capacity are
difficult to make due to lack of information and different
ways of defining throughput.  One data source shows that of
operational liquid hazardous waste incineration units, 55%
have capacity of up to 200 gallons per hour, 39% have capacity
of 201-2000 gallons per hour, and 5% have capacity of 2001-10,000
gallons per hour.

    Estimates of volumes of LOHWs currently incinerated vary
deoending on the source.  The estimated quantity used for this
analysis is l."92 million metric tons (MMT) per year.  Most of
this amount ib accounted for by three waste code categories:
miscellaneous commercial chemical product wastes, ignitable
wastes, and solvents.  There is general agreement between
industry sources anil the RIA National Survey data that about
90% of. these wastes are incinerated on-site and 10% off-site.

    Industry sources view commercial incineration as becoming
increasingly cost-competitive with land disposal due to changes
in the RCRA program and potential long-term liability costs
associated with land disposal.  Industry also envisions a trend
toward increased competition among commercial incineration
firms to capture larger market shares.


*As used in this report, the terms "commercial and "off-site"
 are synonomous.

                            56

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     Incineration firms cited public opposition and requlatory
permitting requirements as being the most significant barriers
to market entry, creating 3 to 5 year delays in bringing new
incinerators on-line.  Large capital investment was also cited
as a potential barrier.

     There is a lack of consistent information on unit costs
of incineration and other current hazardous waste management
practices.  Unit costs vary widely depending on such factors
as: 1) the physical state, the Btu content, ash content, and
the toxicity of the particular waste 2) the form of the waste
(i.e. drum versus bulk), and 3) the competition at the regional
level among alternative waste management facilities.

     Reliable estimates of costs for ocean incineration are
further complicated because the availability of ocean incin-
eration capacity has not yet been firmly established in the
commercial market.  For all hazardous waste management practices,
costs are also affected by changes in the Federal regulatory
program.

     The following table presents very rough unit cost figures
for various waste management practices and is useful only for
making general comparisons.

Type of WasteType or FormPrice 1981
 Management	of Waste	$/me trie tonne

Landfill (a)              - Drummed                    $ 168 - 240

                          - Bulk                       $  55 -  83

Deep Well Injection (a)   - Oily wastewater           4$  16 -  40

                          - Toxic rinse water          $ 132 - 264

Chemical Treatment (a)    - Acids/alkalines            $  21 -  92

                          - Cyanides/heavy metals,     $  66 - 791
                            and highly toxic waste

Land Incineration (a)     - Liquids                    $  53 - 237

                          - Solids and highly          $ 395 - 791
                            toxic liquids

Ocean Incineration (b)    - Chlorinated hydrocarbons   $ 200 - 250

	- Polychlorinated biphenyls  $ 500 - 800

a. Source: Booz, Allen and Hamilton, Inc.- Based on interviews
   conducted with major commercial firms in February 1982.
b. Source: Kidder, Peabody and Company, Inc.- Based on Kidder,
   Peabody estimates, April 1982.

                              57

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    2.   Baseline Incineration Capacity 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 incineration
capacity utilization may vary from AO to 80  percent depending
upon the baseline estimate used for quantities of waste
incinerated.  For the market assessment, low, mid-range and
high estimates were used.   The following conditions of base-
line supply and demand reflect the mid-range estimates.

  o Demand:

    -Total quantity of LOHWs incinerated    =     1.392 MMT/year
    -On-site/off-site split = 90% on-site/10% off-site
    -Total quantity incinerated on-site     =     1.253 MMT/year
    -Total quantity incinerated off-site    =     0.139 MMT/year
     (including PCBs)
  o Capacity (Supply):

    -Total LOHW Incineration Capacity          =
    -On-site/off-site split = 91.2% on-site/8.8%
    -Total on-site LOHW incineration capacity  =
    -Total off-site LOHW incineration capacity =
     (including PCBs)
                         3.4   MMT/year
                        off-site
                         3.1   MMT/year
                         0.252 MMT/year
  o Capacity Utilization:

    -On-site capacity utilized
    -Off-site capacity utilized
           40%
           55%
     For PCBs alone, it is estimated that 48,368 metric tons
(.048 MMT) per year are currently incinerated off-site by four
firms.  Full capacity is being utilized (100%).   Considering
2-3 month backlogs, it can be said that demand currently exceeds
supply.  Furthermore, with accelerated voluntary phaseout of
capacitors and transformers containing PCBs occurring, demand
could exceed supply by as much as 3-4 times.

     Waste quantities currently managed under other land disposal
practices are estimated as:
                                           Total Quantity of Waste
                          Split:           Managed (MMT/year):
Management Practice     On-site/Off-site    On-site     Off-site
-Landfills
30%
 •Injection Wells       9^.5%

 -Disposal Impoundments   95%
 70%

2.5%

  5%
 0.95

 31.1

18.06
2.22

 0.8

0.95
                            58

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    3.  Projected Changes in Incineration Demand and Capacity
        Utilization

     Commercial incineration firms forecast a growing market for
their services over the next three to five years, even in the
absence of any regulatory changes.  These firms estimate that
demand for incineration could increase from 5 to 20 percent,
primarily due to:

     o Increased demand for PCB incineration capacity as
       voluntary phasing out of PCB-contaminated products
       accelerates.

     o Possible lack of availability of on-site incineration
       capacity based on the assumption by commercial firms
       that few generators can and/or desire to go through the
       complex regulatory process, and absorb the costs and
       possible delays involved in expanding their capacity.

     o Lack of availability of competitive alternative tech-
       nologies to significantly affect the market for incin-
       eration over the next five years. (See Section B on
       Assessment of Emerging Alternative Technologies.)

     o Declining net landfill capacity resulting from site
       closures and slow addition of new landfills.

     o Added volumes of Superfund wastes resulting from ongoing
       clean-up activities.

     o Generators'  increasing concerns over the liabilities of
       land disposing wastes as opposed to incinerating them.

     The projections of market growth if RCRA regulatory changes
are implemented show that significant additional quantities of
wastes would become available.  This would result in an increased
demand over the short to mid-term, with on-site and commercial
incineration unable to meet demand.  It is speculated that the
degree to which commercial facilities can meet the increased
demand depends primarily on their ability to bring new facilities
on-line and the speed with which regulatory changes are enacted.

     The effect of regulatory restrictions on on-site and
commercial incineration (using the mid-range or average case)
is estimated for four regulatory scenarios.  The scenarios are
assumed to be implemented immediately, and it is assumed that
current incineration capacity does not increase.

     It is also assumed that, of the additional wastes that
become available for incineration due to the regulatory
restrictions, a proportionally larger percentage of these wastes
would move into the commercial incineration market rather than
remaining on-site to be incinerated or otherwise managed.  This
                            59

-------
is based on the presumption that, on the margin, most generators
would elect to have commercial facilities incinerate their
additional wastes rather than expand their own capacity.


          Excess of Demand Over Existing Incineration
          Capacity (expressed as a % of current capacity)

Regulatory Scenario             On-site            Off-site

-Landfill Restrictions            40%               215%

-Deep Well Injection              54%               306%
 Restrictions

-Disposal Impoundments            52%               288%
 Prohibitions

-Waste-In-Boilers                 42%               106%
 Restrictions

     Additional listings of hazardous wastes and lowering the
small generator exemption could have further effects on the
demand for incineration; however these are not projected in
the analysis.

    4.  Projected Changes in Available LOHW Commercial
        Incineration Capacity

     The availability of additional land-based or ocean capacity
is seen to offer some moderation of the capacity shortfalls
anticipated, depending on how rapidly this capacity is added
to the commercial market.  Current LOHW incineration capacity
could increase from using currently available, but unused
land-based incineration capacity, and from altering waste
feeds to burn less solids/sludges and more liquids.  Capacity
could also increase by making three existing incinerator ships
available.  (They have a combined capacity of 247,000 metric
tons/year, as compared to approximately 250,000 metric tons/year
from existing land-based capacity.)

    5.  Implications of the Market Analysis

     Using the projections of excess demand for commercial
incineration created by the four regulatory changes, estimations
of incinerator equivalents that would be required in order to
meet such demand can be drawn.  Such projected excess demand
could be met by either 82 additional land-based incinerators
(20,000 metric ton per year average capacity), or 33 additional
incinerator ships (50,000 metric ton per year average capacity).
                            60

-------
       This type of projection is highly subjective because it
  depends upon two key factors which are open to debate:   1)  the
  response of LOHW generators to the restrictions in terms of
  either developing additional on-site LOHW management capacity
  or relying on the commercial market, and 2) the policies of
  EPA in phasing in the new restrictions, encouraging the develop-
  ment of other waste management alternatives, and creating
  incentives or barriers to onsite versus commercial incineration.

       We conclude that although current commercial and on-site
  hazardous waste incineration capacities on land are adeguate to
  handle existing demand (except for PCBs), future demand will
  significantly exceed this capacity as other disposal alterna-
  tives are increasingly restricted.  However, it cannot be
  predicted with accuracy how much additional commercial capacity
  will be reguired.
B.  ASSESSMENT OF EMERGING ALTERNATIVE TECHNOLOGIES
       This section reviews available information on tech-
  nologies, both existing and new, that offer suitable alter-
  natives to conventional incineration of liguid hazardous
  wastes.*  Existing and emerging alternative thermal, chemical
  and biological processes for the treatment or destruction
  of liguid hazardous wastes are reviewed in order to address
  three guestions:

       1) What technologies other than incineration are now
          available, or may be in the near future, to treat,
          destroy or recycle combustible liguid hazardous waste?

       2) What is the likely commercialization rate of each of
          these technologies?

       3) How do these technologies compare to incineration in
          terms of cost, capability, benefits, and environmental
          and human health impacts?
  Conventional incineration processes include land-based, ocean
   and improved incineration technologies, such as fluidized bed
   incinerators or mobile incinerators.
                              61

-------
     The processes reviewed are those that currently exist,
or may exist in the next five years.  They are not incineration
processes, but can be used to treat or destroy the same types
of liquid organic waste streams that are presently destroyed in
incinerators.  Existing alternative technologies are defined
as those processes other than conventional incineration that
are in existence today, are suitable for treating or destroying
liguid hazardous waste streams, and are available for commercial
use.  Emerging alternative technologies are innovative processes
that are suitable for treating or destroying liguid hazardous
waste streams, but have not yet been adopted for commercial use.

     Each alternative technology is described and discussed in
terms of the types of waste the system is capable of accepting,
throughput/capacity of the process, operational cost, anticipated
environmental impact, and anticipated date of commercialization
(for emerging technologies).

     Only existing and emerging thermal processes were deter-
mined to be potential alternatives to conventional incineration.
Theoretically, liguid organic hazardous waste streams can
be treated in various thermal, chemical and biological processes,
however, no significant use of biological or chemical treatment
for combustible liguid hazardous waste is anticipated in the
forseeable future.  Many biological processes are only in
the initial stages of development and their potential environ-
mental impacts are numerous and hard to predict.  There are
also several barriers to the application of chemical processes,
including cost, environmental considerations and the fact
that combustible liguid hazardous wastes are generally bad
candidates for chemical treatment.
    1•  Existing Alternative Technologies

     The existing thermal alternatives believed to be most
suitable are industrial processes (cement kilns, lime kilns
and aggregate kilns) and co-combustion in industrial boilers,
These are summarized in Chart A.  Currently, substantially
more hazardous waste is burned in industrial boilers than in
incinerators.
    2.  Emerging Alternative Technologies

     Currently, there are many new processes in various stages
of development for treating and destroying all types of
hazardous wastes.  The processes discussed are compiled from
responses to two national solicitations for new hazardous
waste treatment ideas, from several literature reviews, and
through contact with experts in the field.
                            62

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     Twenty-five emerqinq technologies were considered for
inclusion in the report usinq the following criteria:

     1) Is the process designed for a liquid organic waste
        stream?

     2) Is the process at the developmental stage to be
        available within five years?

     3) Is the process innovative, or is the process just a
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        0 High Temperature Electric Reactor
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reliable cost figures for all of the alternative processes
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  0 The reclamation of energy value in existing alternative
    processes (industrial kilns and power boilers) reduces their
    overall costs to a level below that of incineration.  Also,
    the use of existing facilities lowers capital investment.
                            64

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  0 The costs for the emerging processes Wet Air Oxidation,
    High Temperature Electric Reactor and Molten Salt appear
    at least comparable to conventional incineration.

  0 The costs of Supercritical Water, Plasma Arc and Molten
    Glass will probably exceed incineration.  However, each
    of these technologies may offer advantages over conventional
    incineration processes for specific waste streams that
    could justify the higher costs.

     Existing alternative technologies are capable of treating,
recycling or disposing of significant amounts of liquid hazardous
wastes.  The Agency is now developing standards for these
processes similar to those for hazardous waste incinerators.
The potential market impact of these standards was addressed
earlier in this chapter.

     Emerging alternative technologies will have a minimal
impact on the liquid hazardous waste load currently destroyed
in conventional processes.  Although all of the emerging
processes evaluated offer some technical advantages, their
commercial adoption will not significantly affect the market for
conventional incineration.  It is expected that these processes
will only be used on the most toxic wastes, representing only
2% to 3% of the liquid combustible waste streams.

     More testing will be needed to determine the environmental
effects of both existing and emerging alternative technologies.

  0 The environmental effects of the existing alternative
    technologies are currently being assessed.  RCRA regula-
    tions are being proposed for industrial boilers to assure
    that their operating performance is protective of human
    health and the environment.

  0 The environmental impacts of most emerging alternative
    technologies have not been tested.  In many cases,
    their effects are expected to be roughly comparable to
    those of conventional incineration.
                            67

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VI.  COMPARISON OF RISKS FROM LAND-BASED AND OCEAN-BASED INCINERATION


    This chapter presents a summary of the comparative risk
assessment.  The work was performed under contract and directed
by EPA's Office of Policy Analysis (OPA).  OPA worked with
Industrial Economics, Incorprated (lEc)  to develop a comparative
assessment of the risks posed by land-based and ocean-based
incineration systems.

    Due to the complex, cross-program nature of the task, this
work has been extensively reviewed by experts throughout the
Agency.  Substantial assistance in reviewing the methodology and
substance of the study was provided by the following offices:

        The Office of Research and Development,
        The Office of Water,
        The Office of Solid Waste,
        The Office of Toxic Substances,
        The Office of Air, Noise, and Radiation, and
        EPA Regions II, III,  IV, V, and  VI.

In addition, the U.S. Department of Transportation, including
the Coast Guard, provided a detailed review and substantial
assistance in the analysis of transportation releases.

    Ocean and land-based incineration systems have different
physical characteristics and affect different locations and
ecosystems.  As a result, structuring a  consistent comparison is
difficult.  This report integrates existing information and adds
new analyses developed using existing methods and data.  No new
primary research has been completed.  While the analysis will
assist efforts to evaluate incineration  and other technologies
for hazardous waste management, it is important to understand
that the results of this effort are not  sufficient to determine
the advisability of any specific land-based or ocean incineration
proposal.

    This chapter is divided into four major sections.  The first
section alerts the reader to limitations of this study in terms
of the scope of its coverage and uncertainties in the methods and
data used.  Section B identifies the key elements of the case
study employed.  It provides a description of and rationale for
the incineration system components and waste streams selected.

    The final two sections present the heart of the analysis.
Section C describes the quantities and locations of potential
releases for all aspects of the incineration systems, including
transportation and handling.   Probabilities are calculated for
releases due to accidents, spills, or other infrequent events.
Section D addresses the potential human  health and environmental
impacts for the various types and locations of releases.

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A.   LIMITATIONS OF THE STUDY

     All of our analyses are subject to many limitations
and caveats due to uncertainties in the data and methods
that were used.  These limitations and caveats are explained
fully in the chapters and appendices of this report.  All
of our results should be interpreted with caution, and with
a_ complete understanding of all of these limitations.  Some
of the general limitations of the analyses are described
below.

     1.  By design this analysis is limited to considering
         only incineration systems.  It does not consider
         potential environmental or economic risks or
         benefits from use of other methods of hazardous
         waste treatment, storage or disposal.

     2.  The analyses reported here are applicable only
         to the specific land- and ocean-based cases
         examined.  Results for other locations,
         wastes and technologies could vary substan-
         tially.

     3.  We have attempted to structure incineration
         systems and wastes typical of actual or likely
         practice so as to generate an expected rather
         than a best or worst case analysis.  However,
         data limitations have reguired use of many
         conservative assumptions in our estimates of
         release guantities, and the methods for estimating
         effects of releases generally err on the side
         of overestimation.   Thus, our overall
         results overestimate releases and resulting
         effects.

     4.  We have not considered a number of effects which
         might result from releases from the ocean- and
         land-based  systems.  In particular, we have not
         analyzed the possible effects of releases on
         terrestrial ecosystems.

     5.  Our analysis of the guantity of and effects from
         stack releases for both systems is based on
         assumptions about incinerator and scrubber
         performance and waste composition, and on results
         from EPA-sponsored trial burns.  The data on PIC
         generation developed from the trial burns is
         extremely uncertain and subject to debate.  This
         limitation may be overcome in the future as more
         and better data become available.

     6.  The estimates of the effects of spills into
         the marine environment system releases assume
         that no mitigating activities are completed.

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    In view of the above, the absolute release and effects
estimates for land- and ocean-based systems are less meaningful
than the relative differences shown between the two systems.  Our
results are particularly sensitive to factors (such as PIC
emissions, scrubber efficiency, and so forth) that alter the
relative performance of the two systems considered.


B.  INCINERATION SYSTEMS CONSIDERED

    1.  Incineration System Components

    We separate land- and ocean-based incineration systems into
three and four separate physical components, respectively.  Roth
land- and ocean-based systems include:

    0   Land Transportation:  transport of wastes by truck
        from the generator site to the incinerator or
        pier,

    0   Transfer and Storage:  transfer and storage operations
        at the land-based incinerator, pier, or other storage
        facilities, and

    0   Incineration:  incineration of the waste.

In addition to these steps, ocean-based incineration systems
include:

    0   Ocean Transportation:  transport of the wastes by
        ship from the pier facility to the burn zone.

At each of these stages, wastes and hazardous by-products (for
example, volatilized fractions or products of incomplete combustion)
can be released to the environment.  The nature of these releases
varies from relatively unlikely releases of large quantities of
waste (such as spills from truck or ship accidents) to very likely
releases of smaller guantities of waste (such as stack emissions,
minor pump leaks, and so forth).  We attempt to guantify losses
from all of these possible release points.

    Our analysis is a case study of one land and one ocean-
based system which are similar to existing systems, but are
not exact duplicates of them.  The system elements are detailed
in Table 1.  The ocean-based system is similar to that
proposed by Chemical Waste Management, Inc. (CWM), to operate
the Vulcanus II from Mobile, Alabama to the Gulf of Mexico
burn zone.  However, we assume that an integrated storage
and transfer facility is located at the port.  Our land-
based system is not based on any single incinerator but
combines characteristics of several facilities.
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     As Table 1 shows, land transportation assumptions for
the ocean- and land-based systems are similar.  We assume that
wastes are transported 250 miles from generator to land-based
incinerator or pier.  Tank trucks are the assumed mode of land
transport in both cases; and weather, road, and other driving
conditions are assumed to be "average."  While wastes destined
for land- or ocean-based systems might travel different distances,
changes in the 250 mile trip length do not alter  our  results
significantly.

     Transfer and storage characteristics for each case
are assumed to be similar and are determined primarily
by the configuration of equipment used for handling and
storing  wastes.  Ocean-based incineration reguires one
extra loading  step  — pumping  wastes  from  an onshore
storage facility or from tank trucks through a fixed piping
system into the incinerator ship.  The type of storage
tanks used also is critical,  since the emission character-
istics of alternate tanks differ greatly.  Our analysis
considers both accidental spills during transfer and storage
and continuous "fugitive" losses from storage tank vents,
pump seals, and so forth.   We have not considered releases
from major accidents involving fire or explosion at storage
facilities.   The probability of such events occurring
is very low and,  because both land- and ocean-based systems
require similar storage facilities, the potential for
events of this type would be about the same for each system.

     Ocean transportation characteristics are unigue to the
ocean-based system, and have been drawn directly from CWM1s
proposed plan for operations through Mobile Harbor from
Chickasaw, Alabama.   These operations will reguire an 800
kilometer transit through Mobile Harbor, across the continental
shelf near the mouth of the Mississippi River, and on to the burn
zone.

     Finally, Table 1 shows the assumed characteristics of
the incinerators themselves.  Both land-based and ocean-based
incinerators are assumed to be liquid injection units with
capacities up to 70,000 metric tons per year.  This capacity was
selected based on the characteristics of the Vulcanus II.
Although this capacity is greater than any commercial land-based
facility, incinerators of this size are feasible and, in operation
at some on-site facilities.  Consistent with current practice the
land-based unit is assumed to employ scrubbers, while the ocean-
based unit does not.   We assume that these units achieve
destruction and removal efficiencies (ORE) of 99.99 to 99.9999
percent depending on the waste burned.   In effect, we assume that
either system will meet current permit requirements concerning
ORE and other operating parameters.


                              71

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                           Table 1
          SUMMARY OF INCINERATION SYSTEM COMPONENTS
Component
 Ocean-based
  System	
 Land-based
  System
Land
Transportation
Transfer
and Storage
Ocean
Transportation
Incineration
Tank trucks
(5000 gallons)

250 miles

"Average" weather,
roads,  etc.

Storage at pier in two
floating-roof tanks.
One truck unload.

One load to vessel.

800 km (500 miles) to
burn zone.

Specific path from
Mobile to zone.

Vessel specifications
and operations plan as
per CWM for Vulcanus II

Liquid injection, no
scrubber.

DE = 99.99 percent
or 99.9999 percent
for PCBs.

Throughput to
70,000 MT/year.
Tank trucks
(5000 gallons)

250 miles

"Average" weather,
roads, etc.

Storage at incinerator
in two floating-roof
tanks.

One truck unload.

N.A.

None.
Liquid injection
with scrubber.

ORE = 99.99 percent
or 99.9999 percent
for PCBs.

Throughput to
70,000 MT/year.
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2.   Waste Streams

     The environmental transport of wastes and by-products and
their ultimate fate and effects depend strongly on the precise
composition of the mixture released.  In general, adequate data
do not exist to predict the transport, fate and effects of
mixtures released to the environment.  In view of this, we
assume two "simplified" waste streams with single hazardous
constituents in this analysis.

     1.   A waste containing 35 percent by weight of
          polychlorinated biphenyls (PCBs) .  Arochlor 1254 is
          assumed to be the specific PCB, and the remaining
          65 percent of the waste stream is assumed to be
          non-hazardous.  Each system is assumed to burn
          56,000 metric tons of this waste stream each year,
          based on historical burn rates for PCB wastes.
     2.   A waste containing 50 percent by weight of
          ethylene dichloride (EDC) and 50 percent non-
          hazardous  substances.  Each system is assumed to
          burn  68,400 metric tons of this waste stream each
          year, based on historical burn rates for similar
          chlorinated organic wastes.

In addition, each waste stream is assumed to include 100 ppm each
of arsenic, cadmium, chromium and nickel.  These metals are among
those specifically limited in the Agency's proposed regulation
for ocean-based incineration, and each has been designated a
human carcinogen by EPA's Carcinogen Assessment Group.
Although all four have been found in a variety of actual
waste streams, it is likely that our assumption overstates
the average concentration of carcinogenic metals in
incinerable wastes.

    Commercial incinerators handle many waste streams of
varying composition.   Four considerations caused us to assume
the simplified wastes described above.  First, CWM has requested
a permit to burn PCB-containing wastes and thus the possible
release, transport and effects of these compounds are of
particular interest to EPA.  Second, EDC is a common component in
many hazardous waste streams currently incinerated and is typical
of a large volume of wastes generated by the organic chemicals
industry.  Third, the physical characteristics and resulting
transport behavior of PCBs and EDC in the marine environment are
quite different, illustrating how fundamentally different
waste components might behave.  Fourth, human cancer potency
factors are available for both PCBs and EDC and information
is available on the toxic and bioaccumulative effects of
the materials in marine organisms.

                              73

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     POTENTIAL RELEASES
     1.  Overview of Potential Release Quantities

     Tables 2 and 3 present our estimates of the "expected"
annual average release quantities from ocean-based and land-based
incineration for the PCB and EDC wastes,  respectively.  For
releases due to accidents, spills and other infrequent events,
these estimates represent the long-term average release, which
includes years with no release and years with one or more
releasing events. As a result, actual releases in any single year
for these events could range from zero to relatively large
quantities if, for example, a truck is involved in an accident
that results in a spill.  Our calculation of expected quantities
released is a statistical artifact which accounts for both
the probability of a release and  the resulting magnitude of
waste lost.  Annual averages are used primarily for comparative
purposes.  They enable us, for example, to compare releases
over the course of a year from incinerator emissions with a
highly improbable but potential one-time event such as a
spill due to an accident at sea.

     Each table shows the expected quantity of release for
each component of the land- and ocean-based systems.  All figures
have been rounded to the nearest 100 kilograms (0.1 metric tons).
For convenience, a subtotal is provided for releases from
transport and handling steps and for incinerator stack releases.
Metals included in scrubber effluent are also reported.

     Overall, comparison of the expected releases from the ocean-
based versus the land-based systems for these two wastes shows
that expected release quantities from the transportation and
handling components range to roughly 15 percent of the long-term
average release expected.  The extra transport and handling steps
required by ocean-based systems do not add significantly to the
long-term expected release,  but they do create the remote
possibility of a major accident and subsequent release of waste.

     Incineration itself accounts for the major release of wastes
and hazardous by-products for both wastes and systems considered.
The quantities released by incineration are a function of
assumptions about metals content and the performance of the
incinerator and scrubber.  Available estimates of PIC generation
are very uncertain.  Releases from each component are further
discussed below.  While expected annual releases in the 25 to
50 ton range may appear large in the abstract, such releases
are very small when compared to many industrial operations,
such as power plants burning fossil fuels,


                              74

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                         Table 2
     SUMMARY OF EXPECTED QUANTITIES RELEASED PER YEAR*
                        PCB Waste
                  (metric tons per year)
Release Point

Land Transportation

Transfer and Storage

Ocean Transportation
Ocean-based
   System

   2.1

   1.2

   0.6
Land-based
  System

    2.1

    1.1
   Subtotal

Incineration

   Undestroyed Waste
   PICs
   Metals
   3.9
   0.1
   0.0
  22.4
    3.2
    0,1
    0,0
    4.5
   Subtotal (Stack)

Scrubber Effluent
   Metals

Total Organics and Metals**
  22.5
  26.4
    4.6


   17.9

   25.7
    For releases due to accidents, spills, and other uncertain
    events, these estimates represent the long-term average
    release which includes years with no release and years
    with one or more releasing events.
**  When these total releases are compared to the 56,000 metric
    tons of PCBs incinerated per year in this case study, the
    release per metric ton incinerated is about 0.0005 metric
    ton for each system.
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                         Table 3
      SUMMARY OF EXPECTED QUANTITIES RELEASED PER YEAR *
                         EDC Waste
                   (metric tons per year)
Release Point
         Ocean-based
             System
Land-based
  System
Land Transportation

Transfer and Storage

Ocean Transportation


   Subtotal

Incineration

   Undestroyed Wastes
   PICs
   Metals


   Subtotal  (Stack)

   Scrubber Effluent
     Metals

Total Organics and Metals
             2.7

             1.2

             0.8


             4.7
             6.8
            20.6
            27.4
            54.8
    2.7

    1.1
**
            59.5
    3.8
    6.8
    0.6
    5.5
   12.9


   21.9

   38.6
*   For releases due to accidents, spills and other uncertain
    events these estimates represent the lonq-term average
    release which includes years with no release and years
    with one or more releasing events.

**  When these total releases are compared to the 68,400 metric
    tons of EDC incinerated per year in this case study, the
    release per metric ton incinerated is about 0.0009 metric
    ton for the ocean-based system and about 0.0006 metric ton
    for the land-based system.
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     2.  Land Transportation Releases

     Tables 2 and 3 show that the expected release from
land transportation will average 2.1 and 2.7 metric tons (MT) per
year for the PCB and EDB wastes, respectively.  Again, these
estimates represent long-terra averages.  Releases in any year
would vary from zero to larger guantities if a spill occurred.
The slightly greater release estimated for the EDC waste reflects
the larger guantity of this waste assumed to be handled by each
system.   Because land transportation has the same configuration
in each system, there is no difference in the release guantities
expected for the land- versus ocean-based system.

    Our analysis of releases from land transportation considers
two types of potential losses — spills from vehicular accidents
and spills from enroute container failures.  We base our
estimates of the freguency of such events and of the size of the
resulting spills on data provided by the U.S. Department of
Transportation (DOT).  These data pertain to all tank trucks
carrying hazardous materials.  Use of the DOT data with our
assumptions regarding miles travelled results in an expected .18
and .26 releasing vehicle accidents per year for the PCB and EDC
wastes, respectively.  The annual number of container failures is
estimated at .23 and .32 for the PCB and EDC wastes.  The average
fraction of cargo released in vehicular accidents is about 40
percent.  In contrast, spills from container failures typically
release only about 4 percent of the cargo in the container.

    Information supplied by hazardous waste services firms
indicates that the DOT accident rates are higher than those
experienced by these firms.   This probably is due to management
practices undertaken by such firms to reduce the probability of
accidents and to their use of stainless steel tanks that are more
resistant to rupture than are aluminum tanks.  Thus, we believe
that our analysis overestimates releases from land transportation,
These estimates represent, on average, about 0.5 percent of
the number of annual transportation-related releases of
hazardous substances in EPA Region IV.

     3.  Transfer and Storage Releases

     Our analysis of wastes released from transfer and storage
considers three types of releases:  spills when unloading wastes
from tank trucks; spills from eguipment at waste transfer and
storage facilities; and fugitive emissions from transfer and
storage.  As shown in Tables 2 and 3, the expected guantity
released from transfer and storage activities is slightly over
one metric ton per year for both systems and waste streams
considered.  These release estimates are based on information
developed by Arthur D. Little, Inc. and DOT.

     Spills from the transfer and storage component are fairly
infreguent events.  They are estimated to occur at a rate of

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about 0.04 to 0.05 per year for the transfer of wastes from tank
trucks and at a rate of about 0.03 to 0.04 per year for equip-
ment and storage tanks.  The ocean incineration system has
one additional component — the loading hose to transfer wastes
to the ship.   We estimate the rate of spills from the hose
at about 0.002 to 0.003 per year, with the average spill
size about 6 to 7 MT.  It is likely that spills of this
type would be contained either on the deck of the Vulcanus
or by booms placed around the vessel during loading.  Spills
from truck unloading or from equipment or storage tanks
are also likely to be contained in the facility.  Fugitive
emissions would account for about 0.6 to 0.7 MT per year
of this  amount.  The number of spills expected from
this component of land- or ocean-based incinerators would
represent, on average, less than 0.1 percent of the number
of spills of hazardous material likely from fixed facilities
in EPA Region IV.

4.  Ocean Transportation Releases

    The ocean transportation component of ocean-based incinera-
tion is the only major component of the system that has no
parallel in a land-based operation.  Therefore, potential
releases from ocean transportation are of special interest
when comparing the relative risks of land- and ocean-based
incineration systems.

    Incineration ships have operated off the coast of Europe in
the North Sea since 1972.  About 320 voyages have been made and
about 650,000 metric tons of hazardous waste have been
incinerated.  No casualties such as collisions, groundings,
rammings, or fires have occurred, nor have there been any spills
from loading these ships in port.  Although a very good safety
record has been established, the number of voyages completed is
too small to be used directly in estimating statistically the
probability of spills.

     In view of this, EPA asked Engineering Computer Optecnomics,
Inc. (ECO) to develop estimates of spill rates based on the
worldwide historical record of tank ships of a similar size
class.  Spill rates were developed for three impact type
accidents (collisions, groundings, and rammings) and for non-
impact accidents (fires,  explosions, structural failures,
and capsizings).  Spill rates were developed for four locations
of interest — pier and harbor, Mobile Bay, coastal area, and
burn zone.  Estimates were also developed of the percentage of
spills likely to involve one, two, or three or more tanks — 80
percent, 15 percent, and 5 percent, respectively.

     The historical spill rates were adjusted to take into
consideration the design of the Vulcanus (double hull, double
bottom construction and the use of a controllable pitch propeller
and bow thruster), operating restrictions to be imposed by the

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Coast Guard (escorts by tug boats and a Coast Guard vessel,
imposition of a 300 foot movinq safety zone, and limitation of
transits to daylight hours and in conditions of above average
visibility), and the soft bottom conditions in the Gulf.  The
precise effect that these factors may have in reducing spill
rates is difficult to determine.  ECO's adjustments were based on
published studies,  observed differences in spill rates, kinetic
energy levels likely for accidents in different locations, and
professional judgment.

     The expected annual releases of 0.6 MT for PCBs and of 0.8
MT for EDC shown in Tables 2 and 3 are relatively small and
represent average releases expected over a very long time.
Spills from the vessel would be very infrequent events.  We
estimate that the frequency of all spills for the Vulcanus is
about one per 1,200 operating years.   However, the frequency of
spills estimated for any particular location is less.  For
example, the overall spill rate for the pier and harbor area
is about one per 3,000 operating years; for Mobile Bay about
one per 10,000 operating years; for the coastal area about
one per 4,000 operating years; and for the burn zone about
one per 6,000 operating years.  These estimated spill rates
are for all sizes of spills.  Spills involving two or three
or more tanks would be extremely unlikely events.  For example,
the estimated rate for spills in Mobile Bay involving two
tanks is about one per 67,000 operating years, and about
one per 200,000 operating years for spills in the Bay involving
three or more tanks.

    The preceding estimates of releases are conservative, in
that we assume that any tank involved in a spill releases its
entire contents and that the entire ship's cargo is released
in accidents involving three or more tanks.  In addition,
the estimates do not reflect the effects that remedial
actions may have in removing wastes from the marine environment.
Hazardous waste operators are required to develop a contingency
plan for handling spills as a condition of the permit.
Efforts to contain and recover spills are most likely to be
successful in enclosed areas or in shallow waters, such as the
pier and harbor area and Mobile Bay.  However, estimating the
effectiveness of remedial actions was beyond the scope of
this study.

     The  tonnage carried by the Vulcanus is small in comparison
to commercial shipments of petroleum and hazardous substances in
the Gulf area.  For example, the cargo carried by the Vulcanus
would be only about 0.01 percent of petroleum and hazardous
substances transported annually in the Gulf area.  Since the
Vulcanus has a lower spill rate than other vessels, the
potential releases from the Vulcanus are only about 0.002
percent of that from ongoing shipments of petroleum and
hazardous substances in  the Gulf area.
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    5. Incineration Releases

    Incineration itself is the major release point in both
systems.  Metals account for the largest releases when burning
the PCB waste, with undestroyed wastes providing a minor
contribution. A/  Our estimates of undestroyed wastes for both
systems assume 99.9999 percent destruction of the PCB waste
stream.  Our estimates of metals emissions result from our
assumptions about metals concentrations in the waste.  Metals are
transferred to scrubber effluent in the land-based case by use of
a  scrubber which is assumed to remove from 50 to 90 percent of-
the four metals considered.  Thus, stack emissions of organics and
metals in the land case are about 20 percent of those predicted
for the ocean-based case.

     Tables 2 and 3 present the expected annual average
release quantities for the incineration component of both
systems.  Total organics and metals released from incineration of
the PCB wastes is 22.5 metric tons per year for both systems if
one includes both stack releases and scrubber effluent.  Total
organics and metals released by the ocean-based incinerator for
the EDC waste is more than 50 percent greater than that expected
for the land-based case (54.8 MT compared to 34.8 MT).  This
difference is due primarily to the higher level of PIC release
estimated for the ocean case.

     Products of incomplete combustion (PICs) are not expected in
significant quantities for the PCB waste based on EPA's trial
burn data.  However, the results of these trial burns are subject
to large uncertainty and considerable debate because of the
procedures used and the limited number of PIC compounds that were
considered.  Thus, our estimates of PIC emissions for the PCB
waste  (.000000006 metric ton per year and .00002 metric ton per
year for the ocean and land cases, respectively) could be in
error by many orders of magnitude.  In addition, we do not know
of any complete explanation for the lower level of PIC generation
found for ocean-based PCB incineration and the higher level found
for ocean incineration of general organic waste relative to
incineration on land.  Alternate estimates of PIC generation and
the resulting human health effects are analyzed in later chapters
and appendices of this report.
_!/  Note that if incinerated waste streams contain signifi-
cantly less carcinogenic metals than we have assumed, the
total quantity of stack emissions released from each
system would drop dramatically.  Further, releases from
the transportation and transfer/storage components would
become the major contributors to total release.
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    in addition to the compounds reported in these tables, we
also analyzed the release of chlorine at incinerators in both
systems and the disposition of the chlorine to the atmosphere
and, for the land-based system, to scrubber effluent and sludge.
Our results show that 10,505 and 25,034 metric tons of hydro-
chloric acid (HC1) will be released from the incineration of
the PCB and EDC wastes, respectively.  In the ocean case all HC1
is released to the  atmosphere.  In the land-based case the
scrubber captures 99 percent of the HC1 and neutralizes it.  Thus,
most chlorine in the land case is disposed as scrubber sludge or
effluent.
D.  HUMAN HEALTH AND ENVIRONMENTAL EFFECTS FROM RELEASES
    1.   Human Health Effects From Stack Releases and Fugitive
        Air Emissions

    Our analysis of human health risks estimates the incremental
risk of developing cancer for a hypothetical "most exposed
individual" (MEI) who resides at the location of the highest
overall risk due to air concentrations resulting from incinerator
stack and transfer/storage fugitive releases.  For the land-based
system, the location of the MEI is based on Census data.  For
the ocean-based system the MEI is assumed to reside at that
point on the coast where modelled concentrations are highest,
averaged over a year.   These risk estimates assume 70 years of
continuous exposure.  In the ocean case different areas are
affected by- stack emissions (the coastline downwind from the burn
zone) and transfer/storage fugitive releases (the area around the
port),  while for the land-based case the same area is affected.
Our calculations of risk for the land-based system consider two
alternative sites for the incinerator, in Texas and Arkansas.

     We chose to estimate risks to the most exposed individual in
order to assess the largest risks likely to be suffered by any
person due to the releases considered.  While we could have
considered the average incremental risk across the entire human
population affected by each system, this metric requires
estimation of the total exposed population and all levels of
exposure -- a difficult and controversial task given the long
distances and persistence of some compounds considered here.  In
general, other risk analyses have found that average population
risks range from one to four orders of magnitude lower than the
risk to the MEI.

     Table 4 presents the incremental risk of developing
cancer for the most exposed individual due to releases from
land- and ocean-based fugitive (transfer/storage) and stack
releases.  As shown, the incremental risks from land-based
incineration releases are about three chances in one-hundred
thousand for the locations and wastes considered.  Virtually

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                         Table 4
SUMMARY OF INCREMENTAL CANCER RISK TO MOST EXPOSED  INDIVIDUAL
                  FROM INCINERATOR RELEASES
                              PCS Waste             EDC Waste

Ocean-based System*

  Stack (coastline)          6.37 x 10~7           1.06 x  10~6
  Fugitives (port)           2.02 x 10~8           4.97 x  10~10



Land-based System (average of two sites)

  Stack                      2.74 x 10~5           3.14 x  10~5
  Fugitives                  7.05 x 10~7           1.69 x  10~8
  Total                      2.81 x  10~5           3.14  x  10~5
     The ocean system is not totalled  because  the  releases
     are at different locations.
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all of the incremental risk to the MET is due to stack releases,
with fugitive releases resulting in increased risks of less
than one in a million.  Incremental risks to the most exposed
individual at the coastline for the ocean-based system range
from one in one million to 6 in ten million.  As shown, the
risks from fugitives to the MET near the port facility are
less than two per hundred million.

    The data and methods used to generate these incremental risk
estimates  are highly uncertain and tend to overestimate expected
human health effects. Thus, the absolute risk levels indicated by
these figures must be interpreted with caution.  EPA has completed
studies of incremental risks from other hazardous pollutant
releases using similar methods with similar uncertainties and
biases.  For example, a recent study on toxic air pollutants found
that, on average, individuals in the U.S. face incremental cancer
risks of about 4 to 6 chances in ten thousand..?/ Using this
estimate as the base for comparison, incremental risks to the
persons most exposed by the incineration systems considered here
would be one to three orders of magnitude lower.

     Table 5 presents more detailed information concerning
the sources of the incremental cancer risks for the incineration
systems considered.  This table reports the contribution of
principal organic hazardous constituents (POHCs), PIC and metals
emissions to the total incremental risks suffered by the MEI.  For
convenience, risks due to fugitive emissions from transfer and
storage operations are not included in the figures in Table 5.

     The estimates in Table 5 show the relative magnitudes of
incremental risk caused by each stack component for both wastes
and systems considered.   As shown, POHC and PIC releases cause
risks that are from one to five orders of magnitude less than
risks from metals.  Thus, metals account for from 90 percent
to virtually all of the incremental risks calculated for
stack emissions.  (As noted earlier, however, it is likely that
our assumptions overstate the average concentration of carcin-
ogenic metals in liquid incinerable wastes.)  Risks from POHC
releases are less than 1 per billion for the ocean system
and less than 2 per 10 million for the land system.  Risks
from PIC releases are less than 4 in one billion for the
ocean system and less than 2 in 1 million for the land-based
system.  Thus, risks from both PICs and POHCs in each system
are low.

     Table 6 presents the ratio of the incremental risks from
land-based versus the ocean-based stack releases.  The figures
in this table were calculated by dividing the land-based risk
2/ EPA, "The Magnitude and Nature of The Air Toxics Problem in
the United States," Draft Report, office of Air and Radiation
and Office of Policy, Planning and Evaluation, 1984.

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                           Table  5
      INCREMENTAL CANCER RISK TO MOST  EXPOSED  INDIVIDUAL
                   BY TYPE OF STACK RELEASE
                               PCB Waste             EDC Waste

Ocean-based System

   POHCs                      1.45 x  10~10           5.51 x 10~10
   PICs                       1.68 x  10-12           3.36 x 10-9
   Metals                     6.37 x  10~7            1.06 x 10~6
   Total Stack               6.37 x  10~7            1.06 x 10~6
Land-based System (average of two sites)


   POHCs                      5.13 x  10~8           1.43 x 10~7
   PICs                       1.79 x  10~6           2.59 x 10~8
   Metals                     2.56 x  10~5           3.12 x 10~5
   Total Stack                2.74  x  10~5           3.14 x 10~5
                           Table  6

               RATIO OF INCREMENTAL  CANCER  RISK
          FOR LAND- VERSUS OCEAN-BASED  INCINERATORS
                   BY TYPE OF STACK  RELEASE
                              PCB  Waste           EDC Waste

POHCs                               354                 260

PICs                          1,070,000                   8

Metals                               40                  29


Totals                               43                  29


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estimates in Table 5 by those shown for the ocean-based
system.  Thus, the figures in Table 6 indicate the relative
size of risks estimated for the land-based versus the ocean-based
system considered.  For example, Table 6 indicates that, for
the PCB waste, land-based emissions create about 40 times more
incremental risk to the MEI than do ocean-based emissions.  For
the EDC waste, the ratio of land to ocean risk is about 30.

     Tables 5 and 6 show that, given our assumptions, there
is roughly 30 to 40 times more incremental risk from metal
released from land systems.  Changes in the type and concentration
of metals in the waste could reduce these risk estimates by
several orders of magnitude but would not change the relative
performance of the land and ocean systems.  Different assumptions
about the performance of the land-based scrubber in removing
metals, or about the atmospheric transport of metals over the
ocean could affect the relative performance of the two systems
considered.  While different assumptions could broaden or narrow
the differences in metals risk, it is unlikely that ocean-based
systems would generate more incremental risk than land-based
systems.

     These tables also show that the land-based system
generates more incremental risk from POHC emissions, but
that the risks are low from both systems.  The transport
behavior of PICs is similar to that of POHCs and thus, for
similar quantities and toxicities of release, PIC risks
should show the same ratios.  However, our analysis of trial
burn data indicates that land- and ocean-based systems can
generate very different quantities of PICs.

     EPA's trial burn data indicate wide variation in PICs
generated by different incinerators from different waste streams.
The results of these burns are subject to great uncertainty and
considerable debate.  For the PCB waste, our analysis uses a PIC
generation rate for the ocean-based system that is 10,000 times
lower than that used for land since this rate is derived from
trial burn data.  When combined with the additional advantage of
the ocean-based system in being further from human populations,
the land-based unit generates over 1 million times the risk of
the ocean system for PICs.  Thus, our relative estimates of PIC
generation from the PCB waste would have to be in error by a
factor of one million for the land and ocean systems to present
equivalent risks from PICs.  Again, note that the absolute risks
estimated for PICs from both systems are very low.

     Our assumption regarding the amount of PICs from EDC wastes
is quite different.  For this waste, trial burn data suggest that
the ocean-based unit will generate about 30 times more PICs than
the land system.  Despite the ocean system's exposure advantage,
this lowers its ratio of risk compared to the land system to a
factor of 8.  While changes in relative PIC generation that are
greater than an order of magnitude could make PIC risks from land
and ocean systems equivalent or show land systems to be safer, we
believe that such changes are unlikely.

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     Although the absolute numbers reported in Tables 4 and 5
are uncertain and biased to overestimate incremental risks,
the relative differences shown in Table 6 are more certain
and would be altered only by changes in the relative performance
of the ocean- and land-based systems.  Overall these results
generally indicate that the human health risks posed by either
system are relatively low,  with the risk from the ocean-based
system about one to two orders of magnitude less than from the
land-based system.   This general result was expected, since the
burn zone is about 200 kilometers distant from the coast,
allowing residual emissions to disperse and to partly settle
out before reaching land/ and since the plume emitted during
trial burns has never been detected at the shoreline.

     Along with incremental risks due to inhalation of hazardous
compounds, we also considered incremental risks due to ingestion
of foods contaminated by wastes or hazardous by-products from
ocean- and land-based stack emissions.  Although data and methods
in this area are extremely limited, we found insignificant
incremental risks from this ingestion route of exposure.


     2.  Environmental Effects From Incinerator Stack Releases

     In addition to the human health effects summarized above,
we considered the possible environmental effects that might
result from incinerator stack releases.  For the ocean-based
case, we asked Applied Science Associates, Inc. (ASA), to
estimate the deposition of stack releases to the ocean surface,
the transport of these materials in the water column and
sediments and resulting effects on the marine ecosystem.
ASA's analyses indicate that no measurable effect on the
marine ecosystem is expected due to stack releases from the
EDC waste.  The analysis of the PCB waste is complicated by
the persistence of the compound and by scientific uncertainty
about the role of the ocean's surface (the "microlayer") in
capturing and concentrating atmospheric pollutants and providing
these materials to the marine ecosystem.  Notwithstanding
these uncertainties,  ASA's analyses indicate that long-term
continuous burning of the PCB waste at the levels assumed
here would not result in a measurable effect on the marine
ecosystem.  Information developed on the background atmospheric
flux of PCBs into the Gulf waters indicates that it would be
about two to three orders of magnitude greater than that
from incineration of PCBs.

     We were unable to complete a similar analysis of the effects
on terrestrial ecosystems caused by land-based stack releases.
However we did consider the possible environmental effects from
the release of scrubber effluent and sludges from the land-based
system.  Because discharge of scrubber effluent and sludge is
regulated by the Clean Water Act and the Resource Conservation


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and Recovery Act, respectively, disposal of these materials would
have to be carried out in a manner approved by environmental
permitting authorities.  Thus, we assume environmental damage
from these discharges is minor.


     3.  Human Health Effects From Ocean Transportation Releases

     In addition to the effects from incinerator stack and
fugitive releases,  we also characterized possible human and
environmental effects resulting from spills in the marine
environment.   Although the probability of a spill is very low,
the magnitude of the resulting effects is of interest in public
deliberations about ocean- versus land-based incineration
systems.  We considered the likely effects of release of cargo
from the vessel at sites within Mobile Harbor, over the
continental shelf on the path to the burn zone, and in the burn
zone itself.

     Table 7 presents information about the potential for
human health consequences from loss of the entire vessel cargo.
Volatilization of such a spill could expose human populations to
high concentrations of hazardous constituents for short periods
of time.  Because of the acute nature of these exposures, we
compared the estimated dosage received by human populations in
the first 24 hours after a spill to the Threshold Limit Value
(TLV) for PCBs and EDC.  The TLV represents the dosage to which a
worker can be exposed with no adverse health effects such as
coughing, dizziness, and longer-term health damage.  We adjusted
the TLVs to account for continuous exposure rather than exposure
for only eight hours per day.  In all calculations we assume
that the human population is directly downwind from the spill
site and that the entire cargo of the vessel is released.

     As shown in Table 7, we estimated the ratio of 24 hour
dosages to adjusted TLV's for spills in Mobile Harbor at one and
15 kilometers from the city of Mobile, for spills over the
continental shelf near the mouth of the Mississippi River, and
for spills in the burn zone.  The results show that spills of the
entire cargo of either waste one kilometer from the city of
Mobile could cause human health problems.  Spills at the other
locations are not expected to cause acute human health problems.


     4.  Environmental Effects From Ocean Transportation Releases

     Table 8 presents a summary of the potential effects to
the marine ecosystem from spills of half a tank in the three
locations described previously.    The ecosystem effects are
summarized by changes in biomass levels and in bioconcentration
levels for PCBs and EDC.   For PCBs we considered both floating and
sinking cases,  since this compound, although heavier than water,

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                         Table 7
             SUMMARY OF HUMAN HEALTH EFFECTS FROM
                    LOSS OF ENTIRE VESSEL*
          (ratio of 24 hour dosage to adjusted TLV)
Release Location

Mobile Harbor

  1 Kilometer

 15 Kilometers

Continental Shelf

Burn Zone
PCB Waste



   1.3

   0.06

   0.019

   0.0019
EDC Waste



   1.9

   0.12

   0.002

   0.0004
     The probability of a spill involving three or more tanks
     of the vessel in any location is about one in 24,000
     per year, and in the pier, harbor, and bay area is about
     one in 50,000 per year.
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                            Table 8

    SUMMARY OF MARINE ECOSYSTEM EFFECTS FROM SPILLS OF HALF A TANK
Release Location
	PCB Waste	
Effect         Rioconcen-
on             tration
Biomass        Levels
                Effect
                on
                Biomass
         •EDC Waste	
            Bioconcen-
            tration
            Levels
Mobile Bay

  Floating Case




  Sinking Case
Small overall,  3 to 5 orders
severe reduc-
tion for
benthos

Uncertain
of magnitude
Uncertain
Not         Not
Considered  Considered
Minor
Minor
Continental Shelf

  Floating Case
  Sinking Case
Uncertain
Small overall,
substantial
for benthos
Uncertain
2-3 orders
of magni-
tude
Not         Not
Considered  Considered
Minor
Minor
Burn Zone
  Floating Case
  Sinking Case
Uncertain
Minor overall,
substantial
for benthos
Uncertain
1-2 orders
of magni-
tude for
benthos and
demersal fish
Not         Not
Considered  Considered
Minor
Minor
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might float if entrained in lighter-than-water materials.  For
EDC, we consider only a sinking case, which results in rapid
diffusion since this compound is soluble in water.  We also
modelled the effects of larger spills of 2 tanks and 8 tanks.
As noted earlier/  for modelling purposes we assumed no
actions were undertaken to contain and remove the spill.

     Table 8 indicates that EDC spills would have relatively
minor effects on the marine ecosystem.  These small impacts are
the result of this compound's rapid diffusion to low concentration
levels and its relatively low toxicity to  marine species.  In
addition, bioconcentration of EDC is not a significant phenomenon.
The same results hold for larger size spills.

     In contrast, spills of PCBs are modelled to have major
effects on the marine ecosystem.   These effects range from being
quite severe in the Bay (substantial reduction in benthic species
and large bioconcentration effects on fish and shrimp) to less
severe in the burn zone area.   Since PCBs are a persistent com-
pound, such effects are expected to last a long time.  Biocon-
centration effects in commercial and recreational species
would be of most concern in the Bay and contaminated shelf areas.
In the event of larger or smaller spills, the magnitude of
bioconcentration effects is approximately linear with regard
to quantity released.

     Estimating the effects of spills of persistent compounds
such as PCBs in the marine environment is an imprecise science at
best.  Because of substantial uncertainties regarding the long
term fate of PCBs in the marine environment and the biological
mechanisms involved in the food web, the results of the modelling
effort should be viewed as a general indication of potential
effects rather than as a precise measure of those effects.
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         VII.  PUBLIC CONCERNS REGARDING INCINERATION
    This section identifies and compares public concerns and
objections to ocean and land-based incineration.  The concerns
described are based on a representative sample of those
members of the public who have been most vocally opposed to,
or at least concerned about, specific land-based and ocean
incineration operations.

    The information presented here summarizes information
contained in the background document, "Public Concerns Regard-
ing Ocean and Land-Based Incineration," prepared by the
Office of Management Systems and Evaluation (OMSE).  Informa-
tion contained in the OMSE study is based on a review of
public hearing transcripts, and on interviews with citizens,
EPA regional officials, state officials, and incinerator
companies.

    It should be emphasized that the OMSE study is not an
exhaustive survey of public opinion on incineration, but
rather a study which catalogs the concerns reported by those
citizens opposed to incineration, or at least worried about
some aspects of it.  Furthermore, these concerns were docu-
mented in the summer of 1984, and primarily reflect opponents'
concerns from that time and earlier.  Since that time, EPA
has taken a number of actions to address many of the public's
concerns about ocean incineration.  We have issued proposed
regulations, developed a comprehensive research strategy,
and gathered more information, particularly on comparative
risk, through this Agency-wide study.  Nevertheless, it is
still important to document citizens' concerns in this impor-
tant area of public policy.
A.  HISTORY OF OPPOSITION
    1.  Incineration Facilities Studied

    For ocean incineration, there are only two case histories
to examine, and both companies involved have experienced public
opposition.  All of the Agency's permitting experience is
with one company, Chemical Waste Management, Inc.  A second
company, At-Sea Incineration, Inc., has progressed to the
stage of applying for a research burn permit and searching
for a port site.  This study examined public opposition to
proposed permits for Chemical Waste Management, Inc., to
burn in the Gulf of Mexico, and the proposed siting of a
port facility by At-Sea Incineration, Inc., in the Newark, N.J.
area.

    For land-based incineration, there were a total of
fourteen cases where there has been some degree of public

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opposition.  Opposition tends to occur when public hearings
are held on proposed RCRA permits or PCB approvals.  At the
time of our survey in 1984, public hearings had been held
for about 24 land-based incinerator facility permits.  Of
the fourteen facilities experiencing some opposition,
three were handling primarily on-site wastes, while eleven
were commercial facilities for waste generated off-site.
Ten of those cases were examined in more depth.  These ten
included the three on-site facilities, which were all
proposed facilities, plus seven off-site facilities, of
which three were proposed and four were existing facilities
with interim status.

    2.  Parties Involved and Intensity of Opposition

    For both ocean and land-based incinerators facilities,
the core of opposition has come from local citizens.  For
both types of facilities, local opposition has included
not only environmental groups but also broader-based civic
associations and local government officials.

    It is difficult to estimate the overall extent of local
opposition to land-based incinerators.  EPA regional officials
report that in some cases a majority of local residents
appeared to be opposed, while in others the opposition
seemed to stem from a relatively small but highly vocal
segment of the local population.

    Opposition to ocean incineration has been more regional
in scope, since an incinerator ship is perceived by many
citizens to have multi-state impacts.  Opposition to ocean
incineration has also involved a significantly wider range
of people, including congressmen and governors, farmworkers
and fishermen, scientists and local residents, and land-based
incinerator operators.  While the major concerns of each
group may differ somewhat, they seem united by their opposi-
tion to facilities that they believe would significantly
harm their communities, jobs and lifestyles.  Ocean incinera-
tion has also involved active opposition by some national
environmental groups.

    3.  Impacts of Opposition to Land-Based Incineration

    Regulations for land-based incinerators have been in
place since 1981, but experience so far with implementing
the program has been limited.  Of the 200 existing incinera-
tor facilities that have applied for RCRA operating permits,
only 23 have been issued final permits as of February
1985.  Only four new incinerator facilities have been
issued final permits.  For the fourteen incinerator facili-
ties that have had public opposition, the general  impact
has been to delay the siting and permitting process, and
may result in some facilities never becoming operational.

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    The ten case studies on land-based incinerators with
public opposition showed the following site-specific differ-
ences:

     0  On-site facilities (i.e., those that accept waste
        generated on the same site) have experienced the
        least public opposition.  In addition, on-site faci-
        lities have had the greatest degree of public
        acceptance when off-site waste was not brought in,
        the company had a favorable record, and the company
        provided other benefits to the community.

     0  New, off-site facilities (i.e., commercial incinera-
        tors that accept wastes generated elsewhere) have
        had the greatest public opposition.  In many ways,
        this situation is analogous to that of ocean incine-
        ration, since all incinerator ships are essentially
        new, off-site facilities.

     0  For existing, off-site facilities, the amount of public
        opposition has varied, but has generally been highest
        when PCB approval is requested.

    As EPA continues to issue permits for land-based incinera-
tors, public opposition is likely to continue in a similar
pattern, although opposition to existing facilities may
decrease over time.  When asked to suggest solutions to
their concerns, the public by and large offered no final
solution except to site the facility elsewhere (i.e., not
in my backyard).  However, many people also expressed the
need to have better, more explicit criteria for making
decisions on siting incinerators.

    4.  Impacts of Opposition to Ocean Incineration

    Citizen opposition has had impacts on both the national
regulatory program and on the local siting activities of the
companies.  A major impact nationally has been to persuade
EPA to delay consideration of new operational permits until
regulations and standards are promulgated.  EPA has also delayed
consideration of new research permits until the Agency has
completed a comprehensive research strategy.

    A second impact has been to make it difficult to obtain
local approval to site port facilities for the storage
and transfer of hazardous wastes.  In Alabama, use of Chemical
Waste Management's port site has been hampered because of
local public opposition.  A recent change in the local
zoning ordinance now makes getting approval for storage of
hazardous waste at that port more difficult, although loading
of the ship from tanker trucks is not hampered.  In New
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Jersey, siting of a port facility by At-Sea Incineration
has been delayed while the state develops siting criteria,
and public opposition there may diminish the chances of
siting a port facility in New Jersey.

    Citizen opposition to ocean incineration has been more
wide ranging and intense than opposition to land-based
incineration.  Due to the scope of citizens' concerns, some
amount of opposition to ocean incineration is likely
to continue.  Solutions offered by the critics tend to focus
on either strict regulations and explicit siting criteria,
or abandoning the program and relying on existing alternative
disposal/treatment methods such as land incineration.  In
either case, the public wants EPA to promote long-term solutions
that it feels are more appropriate, such as waste recycling,
reduction, and detoxification.
B.  CONCERNS REPORTED BY CITIZENS WHO ARE OPPOSED TO (OR AT
    LEAST WORRIED ABOUT) INCINERATION

    For ocean incineration, the two areas of concern cited
most often by citizens are: (1) the potential risk, and
related impacts on health and the environment, of spills on
land and water from routine activities and catastrophic
incidents; and (2) perceived poor management of the ocean
incineration regulatory program by EPA in the past.

    Many people concerned about ocean incineration are not
completely against an ocean incineration program, but they
do want significant safeguards and guarantees.  As one Alabama
resident summed up the situation: "In general, the concerns
are not about the technology but about the management aspects.
It's a people issue.  It's a question of who's running the
regulatory program and who's running the ships."

    For land-based incineration, the concerns cited most
often are:  (1) the potential risk to human health from
fugitive air emissions and stack emissions; and (2) the
potential risk of spills on land from routine transport,
storage and handling, and accompanying health and environ-
mental impacts.

    Table 1 provides a comparison of major concerns
reported by citizens regarding ocean or land-based incinera-
tion.
C.  KEY ISSUES AND FINDINGS

    Analysis of public concerns regarding incineration has
brought to light a number of underlying issues that may
have been acting as barriers to the use of incineration as

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TABLE 1: COMPARISON OF  CONCERNS REPORTED BY CITIZENS
                 IN OPINION  SURVEY
OCEAN INCINERATION
0 Risk of spills on land and water from routine
transport, storage and handling, and accompanying
health and environmental Impacts.
° Inadequate public participation in the siting and
permitting process.
0 Insufficient state and federal resources for ef-
fective monitoring and enforcement of regulations.
° Unsultabillty of Gulf burn site and of port sites
in Mobile and Newark.
0 Lack of credibility of incinerator operators.
0 Uncertainties about incineration technology, and
concern about level of environmental protection
afforded by a 99.99 percent destruction efficiency
0 Adverse economic impacts on local fishing, tourism
and property values.
" Inadequate local emergency response capability for
accidents on land, and inadequate technology for
cleanup of spills in ports and on open water.
0 Risk to the marine environment from air emissions.
° The importation of outside wastes into local areas
is inequitable.
0 Difficulty of enforcement and compliance monitor-
Ing and of environmental monitoring of long-term
Impacts on the ocean.
0 Risk of catastrophic spills in ports and on open
water.
0 EPA's poor management of the regulatory program
for ocean incineration.
0 Regulatory controls are not stringent enough on
scrubber requirements and other technical
issues.
° Lack of a national strategy for managing hazardous
waste in order to provide the basis for a decision
to either promote or abandon ocean Incineration.
* The ocean is a public resource which should re-
ceive special protection.
° Ocean incineration would inhibit development of
better methods for managing hazardous waste.
(Not reported for ocean.)
LAND-BASED INCINERATION
° Risk of spills on land from routine trans-
port storage and handling, and accompanying
health and environmental Impacts.
° Same .
" Same.
0 Unsuitablllty of incinerator sites.
0 Same.
0 Same.
° Adverse economic Impacts on local property
values and lack of Increase In local employ-
ment.
° Inadequate local emergency response
lity in the event of accidents.
capabi-
0 Risk to human health from air emissions.
° Same.
( Not reported for land.)
( Not reported for land.)
( Not reported for land.)
( Not reported for land.)
( Not reported for land.)
( Not reported for land.)
( Not reported for land.)
° Nuisances such as noises, odors and
Irritating gases.
eye-
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a waste treatment/disposal method.  These issues are
discussed below in some detail, followed by overall findings.

    1 •   Issue;  Dissatisfaction with the Public Hearing
        Process

    At  the point in the regulatory pracess when public hear-
ings are conducted for both ocean and land-based incinerator
permits, EPA officials typically discover that they have very
different perspectives and specific concerns than those
voiced  by the public at such hearings.   This has led to
misunderstandings and citizens' dissatisfaction with public
hearings and with the permitting process in general.

    In  hearings on proposed permits, the primary focus of
the EPA staff is on compliance of the proposed permit with
regulations and performance standards.   This is because EPA
officials accomplish their jobs of protecting the environment
and human health through the diligent application of regula-
tions and standards.

    The public, on the other hand, is often concerned about
broader or nontechnical issues, such as site selection,
enforcement plans and capability, company credibility, and
potential health risks.  Most of these  issues are ones that
either EPA believes were resolved prior to the proposed
permits (e.g., that incineration is an  environmentally sound
technology), or that EPA has no jursidiction over, such as
the siting of land-based incinerators.   Likewise, the incin-
erator operator's past performance record, while of serious
concern to. EPA, does not preclude the granting of a permit
as long as all conditions and requirements of the regulations
are met.

    Part of the problem is that each group has different
expectations for public hearings on proposed permits.
Federal and state regulatory agencies,  and the company,
expect  to discuss technical issues, and are often perplexed
by both the vehemence of public concern and the broad
range of issues raised by citizens.  Government regulatory
officials have already carefully evaluated a company's
proposal in terms of its adequacy in meeting technical and
administrative requirements.  Company officials, in turn,
present technical studies to show that  the proposed facility
meets all regulations.  In contrast, community opponents
talk in terms of potential health risks, inequity of siting
decisions, and adverse local economic impact.  When EPA
and the state agen'cy respond only to technical and permit-
specific issues, the public perceives the regulatory agencies
as being biased in favor of the company and being generally
inflexible and unresponsive.
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    The perspective of regulatory agencies and most incinera-
tor operators is that they are doing as much or more than is
necessary to comply with what is required .by law.  They
believe that through the public comment and hearing process,
citizens are given a fair chance to voice concerns and be
heard.  Regulatory agency staff also claim, however, that
they are not able to respond to concerns that are not techni-
cal in nature or that go beyond the scope of the regulations,
and that full application of regulatory restrictions is
not sufficient in dealing with citizens' general fears about
toxic pollutants.

    in the case of ocean incineration, EPA focused its dis-
cussion at public hearings primarily on the performance
capabilities of the technology and on the risks and impacts
at the ocean burn site.  But the public was concerned about
cradle-to-grave regulation, the potential health risks,
environmental and economic impacts outside the burn site,
and the ability of regulatory agencies to adequately enforce
its regulations.  This difference in scope of concerns re-
flects a lack of understanding by citizens that the scope
of permit hearings is limited to the proposed permit, that
technical requirements for an incinerator permit reflect
underlying concerns for protecting health, and that other
activities such as transportation are controlled by a
different set of regulations.

    2.  Issue;  Siting Decisions

    A number of issues relating to the siting of incinera-
tion facilities stand out as influencing public opposition.
The siting process itself is a source of frustration.
Comments from the public indicate that the siting process
isn't clearly defined and that the public is left out of
siting decisions.  They feel that criteria for selecting
sites do not exist or are rudimentary at best.  Certain
aspects of any site seem to inevitably generate opposition,
such as the transport route of waste to the site, the
proximity of the site to schools, residential areas, or
recreational areas, and the prior existence and impact of
industries or hazardous waste facilities in the area.

    EPA officials point out that they are being unfairly
criticized by the public for siting decisions, since EPA
has no authority over the selection of sites for land in-
cinerators or port facilities.  However, EPA does select
ocean burn sites for incinerator ships.

    The underlying public concern regarding siting is the
question of equity in the original siting decision:  why
should their community be chosen to bear such a large share
of the potential environmental costs of modern industry?
This is reflected by the common reaction of "not in my back-
yard".

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    3.  Issue: Credibility of Government and Industry

    Public trust or distrust of regulatory agencies and
companies strongly influences the acceptability of incinera-
tion regulatory programs in general, and the siting of indi-
vidual facilities specifically.

    State and federal regulatory agencies are judged by the
public according to their past record in enforcement,
permitting, monitoring, inspection capability, and cleanup
activities.  The public believes that there is a lack of
sufficient federal and state resources to maintain and expand
effective permitting, monitoring and enforcement programs.
This view is based on publicized budget cuts at federal and
state levels, and on their perceptions of an inadequate past
record of regulatory agencies in these areas.  EPA's poor
public image with opponents of ocean incineration largely
resulted from their perception that the program was being
managed in a very ad hoc manner.

    Companies intending to incinerate hazardous waste have
come under intense public scrutiny.  Their credibility is
measured by their past experience in the community, their
expertise in managing hazardous waste, and their past per-
formance and safety record.  In general, there is a very low
degree of public trust of incinerator operators.  It is
often felt that the companies do not provide the public with
information that is accurate and readily available, thus
creating the perception that the company is not dealing
"openly" with the public.

    4.  Issue;  Heightened Public Awareness of Hazardous
        Waste Problems

    There are basic fears by the public of any activity
associated with hazardous waste, and according to citizens
interviewed, there is a general lack of readily available
public information on issues of hazardous waste management
other than through the news media.  One of the major findings
of a 1979 study by EPA* is that there has been a widespread
increase in public opposition to the siting and operating of
hazardous waste management facilities of any kind, and that
this increase can be traced to the national publicity
given to the hazardous waste problem.  "This publicity",
says the report, "is focused almost exclusively on the
disastrous results of improper management of hazardous
wastes.  The public is therefore unable or unwilling to
distinguish between patently improper sites for hazardous
waste disposal...and properly managed sites."
   "Siting of Hazardous Waste Management Facilities and Public
   Opposition," U.S. EPA SW-809, November  1979.
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    Public fears have been heightened by news of ocean oil
spills, discoveries of illegal hazardous waste dumps, and
contamination caused by leaking landfills and other shoddy
hazardous waste disposal operations.  These fears, which
have been described by some companies as irrational or
fears of the unknown, tend to act as a unifying force
among much of the opposition.

    5.  Issue:  Public Acceptability of Risks

    A related issue is that of the level of risk accept-
able to the public.  Risk assessments show that risks from
hazardous waste incineration do not pose a significant
threat to the public and are considerably less than risks
associated with common daily activities such as driving an
automobile.  However valid this may be, a segment of the
public seems to be saying that any additional risks are
unacceptable, especially when there is a probability,
however minimal, of a catastrophic event occurring which
could have serious environmental or health consequences.

    In addition, people seem to accept risk more readily
if it is imposed voluntarily rather than involuntarily.
Thus citizens tend to accept the risks of driving a car or
smoking cigarettes more easily than the risks of environ-
mental pollution, even though the risks to health from
driving cars is statistically higher than the risks from
certain types of environmental pollution.  In the case of
incineration, the relatively low risks to health are not
acceptable to some people because the risk-taking is
perceived as not of their choosing and not under their
control or influence.

    The amount of risk "acceptable" to the public also
varies according to the amount of perceived community
benefit from the incinerator facility.  With some excep-
tions, off-site commercial incinerator companies are
generally unknown to the local community, or, if known,
may be associated with problems at their facilities in
other communities.  In contrast to local manufacturing
businesses, the community envisions few benefits from a
proposed commercial incinerator facility: a few jobs and
perhaps some tax revenues.  In contrast, potential risks
are often seen as overwhelming: polluted air or water
supplies threatening the entire community, decades of
uncertainty, and hundreds of trucks carrying thousands of
drums of hazardous waste on local roads.  When local com-
munities perceive the risks to be great and the benefits
small, they tend to demand that the probability of some-
thing going wrong be low, or more often, nonexistent.
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    6.  Issue;  Need to Protect the Ocean as a "Public
        Resource"
    Many citizens view the ocean as a public resource that
must be protected, rather than as a handy dumping area
which is "out of sight, out of mind."  In other words, the
ocean is perceived to be everybody's backyard rather than
nobody's backyard.  Consequently, ocean incineration has
gained the status of a national issue.

    7.  Issue;  Need for Link between Incineration Regulation
        and a National Hazardous Waste Management Strategy

    Another issue unique to ocean incineration was the re-
quest from citizens and state officials that EPA develop
and/or communicate a national hazardous waste strategy
that provides a framework for either promoting or abandoning
ocean incineration as a viable and environmentally sound
technology.

    8.  Overall Findings

    The overall findings of this study of public concerns
suggest that ocean incineration has given rise to a greater
degree of public opposition than most land-based incinerator
operations (either proposed or existing).  This is primarily
because the perceived impact of land-based incineration is
very localized, whereas ocean incineration is felt by some
citizens to potentially affect an entire region: the port
community, all the communities along the coastline near the
burn site, and the marine environment.  However, some off-
site land-based operations, which have many characteristics
in common with ocean incineration, have also received
substantial opposition.

    The findings also suggest that for land-based incinera-
tion, on-site facilities that directly serve a single
waste generator have greater public acceptance than off-site,
commercial facilities that serve multiple generators in a
large market area.  This is because people feel that off-site
facilities do not provide sufficient economic benefits to
the local community to offset the risks associated with
importing wastes from other areas.  On-site facilities are
perceived as linked to businesses that are important to
the local economy, and are generally not perceived as
importers of hazardous waste.

    Public opposition to incineration on both ocean and
land may be reduced somewhat if regulatory agencies more
fully address public concerns regarding basic regulatory
policy and strategy, enforcement resources, local community
impacts, equity of facility siting, and public decision-making
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processes.  In large part  this  is  a  matter of  taking the
time and effort to better  inform the public about the "big
picture"  (i.e., the Agency's  overall regulatory policy,
strategy, and activities for  hazardous  waste management),
in order to provide a context for  discussions  of permits
or siting decisions for  individual incinerator facilities.
The fact that EPA has a  national hazardous waste management
strategy to encourage long-term solutions  is not very
helpful if the public does  not  know  about  it.   Improved
communication and more visible  leadership  from EPA would
go a long way toward resolving  many  of  the issues and
public concerns discussed  here.
  £U.S. GOVERNMENT PRINTING OFFICE:  l 9 8 5
                           527 371 301*57
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                             DATE n«
U.S  Environmcn..-!  Pr: icction Agency
Region V, Librcry
230 South Dearborn Street
Chicago,  Illinois  €0604

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