INDUSTRIAL PROCESS WASTES
    This report (SW-lZOc.l) summarises a final report (SW-lZOc),
  which described work performed for the Federal solid waste management
    program under contract no. 68-01-3241 and which is available
   from the National Technical Information Service as PB-261 287.
The following summary is reproduced as received from the contractor.


     This report has been reviewed by the U.S. Environmental Protection
Agency and approved for publication.  Its publication does not signify
that the contents necessarily reflect the views and policies of the
U.S. Environmental Protection Agency, nor does mention of commercial
products constitute endorsement or recommendation for use by the
U.S. Government.

     An environmental protection publication (SW-130c.l) in the solid
waste management series.


                           TABLE OF CONTENTS


List of Tables                                                         v1
List of Figures                                                       v1i
Acknowledgement                                                      viii

I.   INTRODUCTION                                                      11
     Problems and the EPA Response                                     11
     Objectives and Focus of This Study                                13

The following sections are available from NTIS as report no PB 261-287
     The Concept of Waste Transfer                                     15
     Requirements For a Transfer                                       18
     National Waste Stream Data                                        25
     Industries and Wastes Suitable for Transfer Services              29
     A Sample Area:  Philadelphia                                      31
IV.  TWO TYPES OF TRANSFER ORGANIZATION                                37
V.   SERVICES AND METHODS                                              41
     Services                                                          41
     Operations and Methods                                            42

                      TABLE OF CONTENTS (Continued)
VI.   ORGANIZATION AND FINANCES                                     47

     Staff                                                              47
     Finances                                                           48
     Organizational and Legal Considerations                                  51


VII.  SERVICES AND METHODS                                           53

     Services                                                            53
     Methods for Assessing and Transferring Scrap Wastes                         55


     Operations                                                         59
     Staff                                                              61
     Finances                                                           63
     Organizational and Legal Considerations                                  64


A.   IN FORMATION CLEARINGHOUSES                                   65

     European Models                                                     65
     U.S. Versions of the European Model                                     74
     Operating  Experience                                                 76
     Advertising Wastes in Technical Journals                                  78
     Commercial Variations                                                78

B.   MATERIALS EXCHANGES                                           81

     Characteristics                                                       81
     Two Samples                                                        81
     A New Exchange Concept                                             84

                     TABLE OF CONTENTS (Continued)
C.   DATA AND METHODS                                             87

     Identifying Scrap Wastes and Their Uses                                 87
     A Sample Transfer Area: The Philadelphia SMSA                          89


     Economic Feasibility of a Transfer                                    109
     Economics of Transfer by a Materials Exchange                           116

E.   INSTITUTIONAL ANALYSIS AND OPTIONS                           123

     Influences on Transfer Agents                                        123
     Institutional Sponsorship                                            123

F.   LEGAL ASPECTS OF TRANSFERRING WASTES                       131

     The Potential For Legal Liability                                      131
     Other Legal Considerations                                          135

GLOSSARY OF NAMES AND TERMS                                      137

REFERENCES                                                         141

                                 LIST OF TABLES
Table No.                              Description                             Page

11-1       Requirements for a Transfer                                             20
111-1      Manufacturing Process Wastes from Selected U.S. Industries                 26
III-2      Potentially Transferable Wastes from Selected Industries                    27
111-3      Wastes Generated and Potentially Transferable, Philadelphia SMSA          32
IV-1      Comparison of Clearinghouses and Exchanges                             38
A-1       Waste Information Clearinghouses                                        66
A-2       Sample of Items Listed by U.K. Clearinghouse                             68
A-3       Sample List from German Clearinghouse                                  71
A-4       First List from St. Louis Clearinghouse                                   75
A-5       Sample List from French Clearinghouse                                   79
C-1a      Generation and Potential Uses of Selected Chemical Wastes                 90
C-1b      Generation and Potential Uses of Inorganic Chemical Wastes                91
C-1c      Generation and Potential Uses of Organic Chemical Wastes                  92
C-2       Range of Plant Employment, Philadelphia SMSA                          94
C-3       Summary of Waste Generation by Plant and Industry, Philadelphia SMSA    95
C-4       Summary Information from Telephone Interviews                         98
C-5       Summary Information from Plant Visits                                 102
D-1       Definitions and Units for Economic Analysis                             110
E-1       Internal Characteristics of Waste Transfer Organizations                   124
E-2       External Conditions Influencing Transfer Organizations                   126
E-3       Institutional Sponsorship: Options and Merits                            128

                                LIST OF FIGURES
Figure No.                             Description                              Page

11-1       Hierarchy of Purity Requirements                                       21
V-1       Waste Material Registration Form                                       45
VI11-1     Punched-Card Format for Waste Material Data File                        62
A-1       U.K. Form for Submitting Waste Offers and Requests                      68
A-2       U.K. Forms for Inquiring About Waste Offers and Requests                 72
C-1       Philadelphia SMSA and Neighboring Industrial Areas                       93
D-1       Savings to Generator or to User                                        114
D-2       Economics of a Materials Exchange                                     119
D-3       Economics of Transferring Selected Wastes                              120

    We were assisted in  conducting this study by many persons and organiza-
tions in Europe and  the  United  States. They include industrial firms, industry
and professional associations, and agencies of state and local governments, espe-
cially those concerned with the Philadelphia metropolitan area. Only a few could
be cited in the  text,  but  we are pleased to acknowledge the contributions of all
with thanks.

                    CONVERSION TO METRIC UNITS
     In this report, some units are expressed in U.S. customary units. Conversion
to metric units is easily accomplished by using the following formulae:
          Multiply miles by 1.6092 to get kilometers

          Multiply tons by 0.9072 to get metric tons (103 kg)

          Multiply pounds by 0.4536 to get kilograms

                              EXECUTIVE SUMMARY

                        MAJOR FINDINGS AND NEXT STEPS
     The U.S. Environmental Protection Agency (EPA) estimated in 1976 that 344 million
metric tons (wet basis) of industrial processing residues are generated annually in the United
States. EPA suggests* that plant managers and engineers consider the following sequence of
steps as they develop their waste management strategies:

     (1) Minimize  the quantity  of  waste generated by  modifying  the  industrial
         process involved.
     (2) Concentrate  the waste at the source (using evaporation, precipitation, etc.)
         to reduce handling and transport costs.
     (3) If possible, transfer the waste "as is", without reprocessing, to another facility
         that can use it as a feedstock.
     (4) When a  transfer  "as is" is not possible, reprocess the waste for material
     (5) When material recovery is not possible,

         (a) Incinerate the waste for energy recovery and for destruction of hazardous
             components, or,
         (b) If the waste cannot  be  incinerated, detoxify  and neutralize it through
             chemical treatment.

     (6) Use carefully controlled land disposal only for what remains.

EPA commissioned this one-year study both to  explore the feasibility of the waste transfer
concept (step 3 and to some extent step 4) and to outline the requirements for a successful
waste transfer organization.  The purpose of the transfer approach is to help broaden the
potential markets  for  both  new and  apparently-marginal industrial residues, and thus to
reduce the  quantity  of potentially harmful  wastes which require  disposal into the natural
environment. Hence,  established secondary materials markets were not within the scope of
the study.
*FederalRegister, Vol. 41, No. 161, pp. 35050-1.

     This  study  began by investigating  the several  existing European "waste  exchanges,"
whose purpose is to transfer information about wastes available and wastes sought as feed-
stock. It was  soon discovered, however, that a  few chemical reclamation companies also
offer to transfer waste materials. This led to  the distinction between two types of transfer
agents, the "information clearinghouse" and the  "materials exchange": the former transfers
information only, while the latter accepts residues, analyzes them, identifies new uses, treats
them as necessary, and then actively seeks buyers. Both types of organizations were studied.
                          CONCEPT OF WASTE TRANSFER

     Waste transfer is both similar to and different  from the purchase and re-use of indus-
trial by-products. In both cases, an industrial process generates, in addition to its principal
product, some material  which is not  usable by the generating company, but which can
economically be sold for  reuse by another company. When the material has a well recognized
value which justifies the costs of recovery, handling, and transportation, it is known as a
by-product. When the material has a value which has not been recognized, it is a potentially
transferrable waste. So long as disposal is easy and  inexpensive, disposal is the waste gener-
ator's economically preferred course. Transfer to another plant or industry is economically
attractive only when disposal presents major problems, as will increasingly be the case as
restrictions tighten and costs rise.

     While some transfers occur directly through the initiative of either the waste's generator
or its potential user, large-scale realization of the concept requires a third party or "transfer
agent." This is because the possible uses are not well established, generators and potential
users usually do  not  know about each other, and companies are reluctant to reveal infor-
mation about their processes and materials. A transfer agent is therefore needed to identify
generators and users to each other while at the same time protecting confidential informa-
tion until a promising match  is identified. Still  more transfers can be made if the transfer
agent is able to offer additional services, such as assistance with negotiations, consultation
about uses and reprocessing requirements, or actual handling of the materials.

     The term "waste" has two meanings which are related  but distinct. First, it can refer
to damaged, defective, or  residual material resulting from an industrial process, retaining
some or much of its original value; this is "scrap waste" or "scrap". Second, in everyday
usage "waste" can refer to any kind of refuse, with no value, which can only be thrown
away; this is "trash waste" or "trash". In common  usage of "waste", confusion often arises
because the distinctions between "scrap" and "trash" are not obvious to everyone. What is
considered trash by one person is considered useful by another. This difference between two
values seen in one waste is central to both the economic and the technical viability  of waste
transfer, and creates opportunities for transfer agents.

                       THE TRANSFER AGENT'S FUNCTIONS

     Engineers routinely examine their residues to seek further uses as by-products. In recent
years, stricter waste disposal regulations and the scarcity and rising prices of raw materials
have made it more economically attractive for companies to research further uses for the
valuable  components of their  wastes. Large companies with many processes and  skilled
chemical engineers are likely  to find those recycling opportunities which exist, particularly
within their own manufacturing facilities.

     However, even  engineers in large national  companies are not  likely to  recognize all
waste transfer opportunities outside of their own industry. Moreover, technical discoveries
of new  ways to find value in scrap do not occur in all companies at once. Also, medium-
sized or  small companies  typically lack the time and skills to find reuses for their wastes.

     Therefore, needs exist which a formal, institutional transfer agent can satisfy. Indeed,
the difficulties which many engineers face in  distinguishing between scrap wastes and trash
wastes offer  the opportunities for waste transfer agents to provide useful technical and
economic services. The  transfer agent works at the fuzzy and shifting boundary between
wastes and by-products. If successful, the transfer agent will gradually identify what  can be
described as  a "scrap chemicals market," a small but distinct market  sector containing
materials which are more valuable than trash but less valuable than established by-products.
The transfer agent may also lift some scrap wastes with uncertain value up into the category
of by-products with well recognized value.

     The function of the  transfer agent,  therefore, is to identify and help bring together
the generator, who views the waste  as trash without further value, and the user, who views
it as scrap with re-use value. In this process, the transfer agent identifies scrap materials of
interest to both generators and users.

     To  be economically and technically useful,  a  transfer  service must recognize the
realistic limits of its business or functions. On the one hand, it  cannot afford to accept trash
wastes. On the other, it would serve no unique environmental or public purpose by trying
to deal  in regular flows of process by-products with recognized value which are commer-
cially established; and the organization would not be  a waste transfer service, but instead
one of many competing industrial or chemical brokerages. A transfer agent can  thus offer
useful activities in only a narrow sector of the chemical materials market—the scrap sector.

                        REQUIREMENTS FOR A TRANSFER

     Transfers of scrap can occur only after many conditions have  been established for both
generator and user.  Each, depending upon his own business and perspective  of what  is

important, must consider the following:

     •  Technical feasibility-the matching between  the chemical and physical pro-
        perties of available waste streams and the specifications of raw materials they
        might replace.

     •  Economic feasibility -balancing of disposal costs foregone and raw materials
        costs saved against the administrative and transport costs of implementing a
        waste transfer.

     •  Institutional and marketing feasibility—values at risk,  guarantees of supply,
        guarantees of anonymity, and mutual confidence among  generator, user, and
        transfer agent.

     •  Legal and regulatory—potential transfer must be handled confidentially,  be
        allowed by law, and be unlikely to lead to liability suits.

     Accurate information about wastes being produced by industrial processes is difficult
and expensive to obtain. The first national estimate was compiled by EPA for Congress in
1973. More detailed  national estimates by industry were developed in 1974-1976 by a
series of  14 EPA-commissioned studies, of which  11  were reviewed for this report.8"18

     The quantity of manufacturing processing wastes generated in those industries amounts
to about 206 million metric tons/year on a wet weight basis. Those wastes having potential
value for transfer and reuse total about three percent, or about six million metric tons/year
(wet basis). In  selected industries, however, the percentage can be much higher: up to 95
percent in Pharmaceuticals (SIC 2831), at least 25 percent in organic chemicals (SIC 286),
at least  10 percent in  petroleum refining (SIC 2911), about 40 percent in paints and allied
products (SIC 285), and as much as 20 percent in small industrial  machinery (SIC 355).

     Wastes generally recognized as having components of potential value include:

     •   wastes having high concentrations of recoverable metals
     •   solvents
     •   alkalis
     •   concentrated acids
     •   catalysts
     •   oils
     •   combustibles (for fuel)

Available  data cover only about one-third of the manufacturing industries which might
participate in waste transfers.  But they suggest  that significant fractions of wastes from
other industries may have value which is not now being extracted. The easiest  method  for
testing  the hypothesis  would  be an inexpensive transfer service for an industrial  region
having many chemical plants,  one or more petroleum  refineries, and a mixture of other
industrial plants.

     All industries  which manufacture chemicals or use  chemicals  as  raw materials are
potential clients  of transfer agents.  Potential participants in and beneficiaries of waste
transfer are concentrated in five industry groups:

     •  Pharmaceutical (SIC 2831 and 2833)
     •  Paints and  allied products (SIC 285)
     •  Organic chemicals (SIC 2865 and 2869)
     •  Petroleum  refining (SIC 2911)
     •  Small industry machinery (SIC 355)

Their wastes  with the highest  reuse and transfer potential include solvents, still bottoms,
and spent catalysts.  In general, transfer will take place:

     •  from larger  companies  using continuous processes to  smaller  companies
        using batch processes;

     •  from basic  chemical manufacturers to  formulators; and,

     •  from industries with high purity requirements  (e.g. pharmaceutical) to those
        with lower purity requirements (e.g. paints).

In addition, almost any industry which needs fuels or cleaning solvents, for example, machine
shops and boat builders, is  a potential user of scrap wastes. Moreover, reclaimers  would
naturally become clients of a transfer organization in order to expand their business.

     Most potential clients  will  demand reasonably large amounts of regularly-produced
scrap wastes. There is some potential for transfer of smaller amounts of wastes produced
occasionally,  such as spilled or ruined batches of paint or other chemicals. While many
such wastes can be  anticipated, their total tonnage, and hence their economic and environ-
mental impact on the area, is not likely to be large.

     The economic gains from each potential transfer depend upon the waste generator's
savings on disposal costs and the  user's savings on raw materials costs. The total gain must

cover such  transfer costs as transportation, administration, and possibly reprocessing.
Generally, scrap wastes valued at less than one cent per pound cannot be transferred eco-
nomically over a distance greater than 50 miles.

     A transfer organization which serves several industries has a greater chance of identify-
ing new transfer opportunities than does one serving only one industry.  Thus, while the
chemical industry is expected to be the mainstay of any  transfer service, participation by
customers of the chemical industries should be expected  and encouraged. Such customers
or major users  of chemicals include the textile,  paper,  wood products, printing,  rubber
and plastics, leather, ceramics, machinery, and electronics industries.

     No government agency, whether federal or state or local, whether a line agency or a
special-purpose authority, should try to operate or sponsor a waste transfer service directly.
The potential conflicts between their promotional and regulatory  roles would render the
service unacceptable to its intended industrial clients, and thus largely ineffective. None-
theless,  governments retain an indirect interest because  of their public health and environ-
mental protection responsibilities. They can provide significant general support, notably
by encouraging  waste  inventory and market research studies, offering technical assistance
to organizers and sponsors of clearinghouses, encouraging  generators to keep wastes  separa-
ted and to analyze their  characteristics, controlling disposal and thereby raising its costs,
and clarifying the questions and uncertainties which now surround legal liabilities of genera-
tors and handlers of hazardous wastes.

     When generators  and users cannot satisfy all requirements  for a transfer by  them-
selves, they may seek help elsewhere. Their first recourse is to informal networks of colleagues.
The second is to professional societies and advertising columns of technical journals.

     The third is  to  an information clearinghouse, which serves  the  limited function of
linking  interested  trading partners.  A clearinghouse  transfers only information.  It plays
only a passive role in the transfer process, because it leaves generators and users to negotiate

     The fourth recourse is to a dealer, reclaimer, or materials exchange equipped to handle,
treat, and certify the characteristics of chemical materials. Such agents play an active role,
because they stand as intermediaries between generator and user. Of course, many companies
reclaim  materials with well-recognized reuse value. Only a few small companies in Europe
and the United States now seem to be offering, or interested in offering, the full range of ser-
vices needed to transfer scrap  chemicals.

     Most existing transfer organizations are operated by the chemical industry associations
or governments of European countries as wholly- or partially-subsidized information clear-
inghouses. Only a few waste transfer agents operate now in the United States; two follow
the European pattern, and two take more active roles in identifying matches and negotiating
transfers,  although  they do not physically handle the materials.  Several small materials
exchanges were identified, one in Europe and the rest in the United States.
                              Information Clearinghouses

     The  functions of  an information clearinghouse  are very limited:  to offer a central
point for collecting and displaying information, and to introduce interested potential trad-
ing partners to each other. They do not actively seek customers, negotiate  transfers, set
values, process materials,  transport materials, or provide legal advice. Any such functions
required to transfer a  specific material are performed by generators, users, or middlemen

     The  basic clearinghouse service is to  receive offers of waste materials  and requests
for scrap materials, list both anonymously,  and publish the lists to members and interested
nonmembers of their  sponsor association.  Interested  potential  traders then contact the
clearinghouse, which refers them to each other, but takes no further active role in negotia-
tions which may lead  to  transfers. Most  clearinghouses try to learn whether transfers  in
fact were completed, but with only limited returns.

     All existing information clearinghouses are subsidized by their sponsors.  Some charge
nominal listing fees. An information clearinghouse requires little capital investment and can
be operated at an annual cost of between  $10,000 and $90,000 per year, depending on
industry response and the degree of active promotion of its service. Financial self-sufficiency
could be achieved once the information transfer service has shown its usefulness to industry,
by building a large circulation and by setting realistic listing and subscription fees. A partici-
pating company could  probably recover such fees with  one successful  transfer  a year.

     Experience of the older European clearinghouses suggests that about 10  percent  of
scrap wastes listed will actually be  transferred. Approximately one-half  of  those wastes
transferred went to waste brokers and reprocessing companies (i.e., solvent recovery, etc.).
The remainder were transferred to manufacturers.

     The best sponsor for a clearinghouse is a local or regional industry association, or an
organization equally responsive to industry's needs, for three major reasons. First, to be
successful, clearinghouses  must obtain the  support of industry, especially plant managers
and engineers faced with waste disposal problems. Second, it is not likely that clearinghouses

will be self-supporting until industry learns about the assistance which clearinghouses offer.
Finally, they must keep identities and waste generation data confidential.

     Although information clearinghouses can assist industry, their importance should not
be overemphasized. When clearinghouses began in Europe, they received many listings. The
initial influx of wastes included many  continuous  waste streams.  In most cases after the
first 12-to-18 months of operation, the number of listings declined. Presumably as plant
managers either negotiated transfers or decided that their wastes had no value in the current
market, they discontinued their listings.

     However, in addition to facilitating transfers of specific wastes, clearinghouses provide
two useful general services. First, both their existance and listings of available wastes help to
educate industrial engineers  about the  increased opportunities for transferring and using
scrap wastes. Second, their series of lists can gradually build an inventory, incomplete but
also inexpensive, of industrial processing wastes.

     In  the next  few years,  several more clearinghouses may begin in the United States.
Even though subsidized clearinghouses can be operated in areas with a low density of indus-
try,  they  will facilitate  a  greater  number and higher percentage  of transfers in heavily-
industrialized areas, such as Houston, Chicago, and  Philadelphia, having a large number and
variety of industries within relatively small geographic regions.

     The scope of the typical clearinghouse in Europe is national, and in two cases interna-
tional. The likely American pattern will be a network of regional clearinghouses, with
arrangements to cooperate in cases in which the value of the scrap waste is great enough
to cover costs of transporting it between regions.
                                 Materials Exchanges

     The services of exchanges are  more complex and expensive than those of clearing-
houses. Exchanges buy or accept  wastes, analyze their properties, identify potential uses,
reprocess them as needed, and sell at a profit. They transfer information only as a courtesy
to clients or in the course of paid consulting services. Whereas a clearinghouse needs only a
part-time staff and office space, an exchange needs highly-competent technical, managerial,
and marketing skills, as well as storage and processing facilities.

     Financial success depends upon brokering matches to completion. Because of trans-
portation costs, most transfers can occur within about 50 miles only. Exchanges must, for
economic reasons, concentrate on those scrap wastes of most value and most likely to find
buyers. A materials exchange requires a capital investment of from $200,000 to $350,000,

and annual operating costs are expected to fall in the range of $50,000 to $150,000 per
year. Economic analysis indicates that a materials exchange service is not likely to become
profitable, unless offered  together with a range of other established  services to chemical
industries, such as handling surplus chemicals.

     1.  Detailed data are needed from one  or more  operating clearinghouses in
        order to guide the creation of clearinghouses elsewhere. Such data should
        include  listing activity,  costs, and manpower used, and should  not  over-
        look the value of contributed volunteer professional time.  These operating
        data must be  collected without  impairing  the anonymity guaranteed to

     2.  Although the role of the public sector must be only indirect, it is nonetheless
        important in providing support  services, notably by encouraging studies of
        operating experience and inventories of available wastes.

     3.  Emphasis should be given to the needs of potential scrap users. Waste gener-
        ators quickly recognize the potential usefulness of the information clearing-
        house service.  Moreover, success  of the  waste transfer concept  depends
        ultimately upon the demands of users of acceptable scrap wastes. Examples
        of new  recycling technologies and successful  new types of transfers should
        be brought to the attention of potential scrap users through technical journals
        and professional societies.

     4.  Information about the waste transfer concept and  practice should be dissem-
        inated widely, to satisfy  the interest which is now so evident. Useful techni-
        ques include  publications,  regional conferences,  and  technical  assistance.
        Various institutional  and legal  arrangements for  clearinghouses should be
        examined and perhaps tested.

     5.  A  definitive study of legal liability issues is  needed in order to  clarify the
        many questions, and  to  dispel some of the fears, which now present major
        barriers  to participation in waste transfers by generators and potential users.
        Topics addressed  should  include transfer of title to wastes, residual liability,
        variations  in law  and  practice among states,  and developing trends both in
        legislation and in court decisions.

6.  One or  more  subsidized clearinghouses should be  encouraged in order to:

    •    demonstrate the effectiveness of the transfer concept,
    •    identify the existence of transfer opportunities,
    •    generate detailed operating data,
    •    educate potential transfer participants in industry, and,
    •    identify the potential for financial self-sufficient clearinghouses.

7.  A  financially  self-sufficient clearinghouse should be designed and  demon-
    strated over a period of  two-to-three years. Various combinations  of rela-
    ted services and various forms of institutional sponsorship should be examined.

8.  Materials exchange services should  be offered and operated only  by  the
    private sector. But the public sector  should provide general encouragement
    through technical and information services.

                                I.  INTRODUCTION

                        PROBLEM AND THE EPA RESPONSE

     The U.S. Environmental Protection Agency (EPA) estimated in 1976 that 344 million
metric tons (wet basis) of industrial processing residues are generated annually in the United
States. This is almost twice the  quantity of municipal wastes and more than thirty times
the amount of sewage sludge generated annually.1 *

     As ocean dumping is decreased  and water pollution and air pollution controls are
tightened, these  materials  will increasingly be concentrated into solids and sludges for dis-
posal on land. EPA estimates that 25 million tons of hazardous wastes are annually disposed
of on land. Furthermore,  EPA  projects that this quantity  will double during the next

     Section 212 of the Solid Waste Disposal Act as amended required EPA to investi-
gate the problem of  hazardous  wastes and study the concept  of national disposal sites
for storage and disposal of these  materials.3 The EPA did this, but recommended  that any
action on a national disposal site system be made part of a larger strategy based on improved
regulatory controls.4

     The EPA's  report was submitted to the President and the Congress in 1973. It con-
cluded that:

     •  Current  practices of hazardous waste management are inadequate.

     •  This is  because adequate treatment and disposal are expensive  and, except
        in the case of radioactive wastes, are not mandated by law.

     •  What  is lacking  is appropriate  legislative authority over land disposal of
        non-radioactive  materials.  Existing authorities are  adequate to protect  the
        air, surface waters, and probably  ocean waters from hazardous materials,
        but not  land and groundwaters.

     •  The  technology  of hazardous  waste management is  generally adequate.

     •  A national  disposal site system would be expensive, requiring investments
        of about $940 million  and annual operating costs  of about  $620 million.
'References are listed at the end of the report.

     •  The private sector is capable of assuming most  or all  of the responsibility
        for hazardous waste management, and a small private-sector hazardous waste
        management industry has in fact begun to develop.

The strategy recommended in the report is first to establish appropriate regulatory controls,
then to monitor the response of the private sector, and only later to take further govern-
ment action if that is found necessary.5

     EPA currently proposes the following  order of preference  and sequence of steps for
handling industrial waste streams:6

     (1) Minimize the amount  of waste  generated, by modifying the industrial
         process involved.

     (2) Concentrate  the  waste  (through  evaporation,  precipitation,  etc.) at the
         source to reduce handling and transport costs.

     (3) If possible  transfer the waste  as is to another industry which can use it
         as a feedstock.

     (4) When a  transfer "as is"  is not possible, reprocess the waste  for material

     (5) When material recovery is not possible,

         (a) Incinerate the waste for energy recovery and for destruction of hazard-
             ous materials.

         (b) If the waste cannot be incinerated, detoxify and  neutralize it through
             chemical treatment.

     (6) Use carefully controlled land disposal only for what remains.

The  present study is concerned with Step 3 and to  some extent Step 4. It explores the
feasibility of the  concept of "waste exchange" and outlines the requirements for  success-
ful waste transfer operations.

     The study is  intended  to  further the strategy recommended in the  1973 EPA report
by outlining one way in  which industry can reduce its waste disposal needs. The study
is  also responsive to the goals of the National Academy of Science, whose 1966 study of
waste management identified recovery  and re-use of pollutants as the strategy with highest
probable long-term utility  in alleviating the nationwide pollution problem.7


     This study has two major objectives: (1) to assess the feasibility and potential impact
of transferring wastes in the United States, and (2) to provide guidelines for the organization
and operation of a waste transfer organization. The conclusions are based on a review of the
activities of existing transfer organizations; analysis of the technology, economics, and insti-
tutional  aspects  of waste transfer; and extensive discussion of the concept with industries
generating and potentially using wastes.

     This report will interest  primarily existing and potential operators of waste transfer
services. The main questions addressed are:

     •   How do  existing  transfer organizations  operate, using what procedures,
         and with what results?

     •   Where can such an organization operate best?

     •   Who are the most likely clients? What are their needs? How do they behave?

     •   How can clients best be identified, contacted, and attracted?

     •   Will their demand for transfer services grow, or  at least remain stable over

     •   What proportion of transferable wastes are likely to find exact matches—that
         is, find uses without chemical treatment?

     •   What skills and resources are required to run a transfer organization success-

     •  What are the economics of transferring wastes?

     •  What legal problems may arise?

     •  What competition might a transfer service face?

     Other readers of this report will include potential sponsors or subsidizers of transfer
organizations, generators of wastes, and potential users of wastes having reuse value.



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