1*7
EP 230/3
85-502
vol3
                                230385502C
         United States        Office of Policy,       March 1985
         Environmental Protection     Planning and Evaluation
         Agency          Washington, DC 20460
         Policy Planning and Evaluation	

         Assessment of Incineration

         As A Treatment Method for
         Liquid Organic Hazardous

         Wastes
         Background  Report
         Assessment  of the Commercial
         Hazardous Waste Incineration
         Market

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

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

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

EPA Project Officer:  John Chamberlin

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

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

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

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

Office of Pesticides and
Toxic Substances

Glen Kuntz
Office of Management Systems and
Evaluation

Joe Retzer
Jean Caufield

Office of Research and Development

Glen Shira
Jim Basilico

Office of Water Regulations and
Standards

Alan Rubin
Mark Kohorst

Office of Policy Analysis

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

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

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

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              TABLE   OF   CONTENTS
                                                        Page
                                                       Number
      ACKNOWLEDGMENTS

      EXECUTIVE SUMMARY                                   1

  I.   INTRODUCTION                                      1-1

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

 II.   INCINERATION MARKET PROFILE                      II-l

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

III.   BASELINE INCINERATION SUPPLY AND DEMAND         III-l

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

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

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

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

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

      1.    Projected  Incineration  Demand                IV-1
           Without  Regulatory  Change

           (1)   Demand For  PCB  Incineration              IV-2
                Capacity

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

           (3)   Commercialization  Of Alternative        IV-4
                Technologies

           (4)   Declining Landfill Capacity              IV-6

           (5)   Superfund's Influence                   IV-6

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

           (1)   Land  Disposal  Restrictions               IV-8

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

           (3)   Additional  Waste Listings               IV-18

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

  V.   PROJECTED CHANGES  IN  LOHW INCINERATION             V-l
      CAPACITY

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

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

 VI.   IMPLICATIONS  OF THE MARKET ANALYSIS               VI-1

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                                                       Page
                                                      Number
APPENDIX A - Definition Of Liquid Organic
             Hazardous Wastes

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

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

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

APPENDIX E - Definitions Of Terms Used In The
             Market Analysis

APPENDIX F - References

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

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

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

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

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

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

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

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

  8.   Commercial Incineration  Capacity For  LOHWs       III-6

  9.   Estimated Incineration Capacity Utilization     111-10
       For PCBs

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

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

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

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

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

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

16.   Incineration-At-Sea Capacity                        V-3

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

         An increased demand for PCB incineration capacity

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

         Increased Superfund clean-up activities

         Declining landfill capacity
                           -I-

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         Slowed  commercialization of  alternative  innova-
         tive technologies

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

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

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

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

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

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   ..QMVW3Q SS30X3 310NVH 01 0303-1111
      SdlHS H01VH3III3NI JO U38WnN
    .ONVW30 SS33X3 310NVH 01 03033N
    SHOLVU3NI3NI 03SV8 ONV1 JO U3BWnN
MH01 JO UV3A/SNQ1 3IHJL3W JO SNOI11IIN
               -3-

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

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                     I.  INTRODUCTION
1.  BACKGROUND AND OBJECTIVES

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

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

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

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

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

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

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

2.  METHODOLOGY

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

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

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

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

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

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

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

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

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

3.  LIMITATIONS

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

    (1)  Limitations of a National-Level Analysis

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

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

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

    (2)  Data Inconsistencies and Unavailability

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

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

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

-------
4.  ORGANIZATION OF THE REPORT

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

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

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

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

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

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

1.  MARKET SIZE AND REGIONAL DISTRIBUTION

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

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

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

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

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

2.  INCINERATION TECHNOLOGY AND CAPACITY

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

    Total incineration  capacity for  all  hazardous wastes
(or just  LOHWs)  is  difficult to estimate.   Exact capacity
of  individual units is generally  not known or  the avail-
able  data reflect  respondents1  different  interpretations
of capacity  (e.g.,  hourly  throughput  capacity, heat capac-
ity, annual total capacity).  Operational parametershours
    Data on  incinerator units by  type are  also available
    from  the RIA  National Survey.   However,  as of  this
    writing, efforts are still underway  to  verify and cor-
    rect these data.
                           II-2

-------












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                              EXHIBIT 2
              Distribution  of Operational Hazardous
                    Waste Incinerators by Type
INCINERATOR TECHNOLOGY
Liquid Injection
Hearth/Chamber
Liquids
Solids
Rotary Kiln
Liquids
Solids
Fume (Liquids)
Controlled Air
Combination
Miscellaneous (Solids)3
NUMBER
REPORTED
BY MITRE
137
56
33
23
11
10
1
24
5
31
264
PERCENT
OF
TOTAL
51.9
21.2

4.2

9.1
1.9
11.7
100
a)  Includes ammunition/explosives units, drum burners, and  other solid  units.


SOURCE:  (3).
                                II-4

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

3.  WASTE VOLUMES AND TYPES HANDLED

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

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

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

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

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

-------
                     EXHIBIT 4
Liquid Organic Hazardous Wastes Incinerated In 1981
  By  EPA Waste Code or  RIA  National Survey Waste
                 Combination  Code3
EPA Waste Code or RIA National
Survey Combination Code
DOOO
D001
D002
D003
F001
F002
F003
F005
K001
K015
K016
K018
K036
K083
K085
K093
P063
P068
P074
P106
U002
U003
U023
U031
U043
U044
U053
U056
U074
U080
U098
Ull-7
U122
U123
U133
U154
U188
U196
U220
U223
Amount Incinerated As Liquid
(Metric Tons/Yr)b
19,159.2
227,463.5
10,637.8
12,973.7
33.5
6,003.3
90,112.8
65,705.3
66.9
569.1
3,656.3
5,735.5
301.3
1,963.9
1,472.9
662.1
230.6
148.8
874.1
3.7
1,926.7
9,068.2
941.0
357.1
2,440.0
3.7
93.0
401.7
2,745.0
7.4
7.4
7.4
915.0
3.7
89.3
297.6
4,307.2
3.7
3.7
178.5
                          II-7

-------
                    EXHIBIT  4  (Continued)
  Liquid  Organic  Hazardous Wastes Incinerated  In 1981
    By EPA Waste Code or RIA  National Survey Waste
                     Combination Code3
EPA Waste Code or RIA National
    Survey Combination Code
Amount Incinerated As Liquid
      (Metric Tons/Yr)b
             X001
             X002
             X013
             X015
             X028
             X042
             X072
             X110
             X124
             X175
             X179
             X182
             No  Code
                22.3
               535.6
             2,436.3
             5,545.8
             1,335.3
            23,232.1
             2,640.9
             2,387.9
                 3.7
             1,606.8
                11.2
           300,775.3
            46,326.6
                                               858,431.7

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

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

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

4.  REGULATORY APPROACH FOR INCINERATION

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

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

5.  MARKET SHARES AND COMPETITION

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

-------



















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

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

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

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

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

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

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

6.  PRICES

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

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

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

7.  BARRIERS TO MARKET ENTRY

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

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

8.  FINANCIAL POSITION AND MARKET STRATEGIES

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

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

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

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

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

         Incineration of  PCBs:  Quantities Incinerated and
         Available Capacity

         Incineration   Demand:   Influence   of   Superfund
         Clean-Up Activities

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

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

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

1.  INCINERATION OF LQHWs;  CURRENT QN-SITE  AND COMMERCIAL
    CAPACITY UTILIZATION

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

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

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

-------












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

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

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

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

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

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

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

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

  Largest 3 Firms
  (5 Incinerator Units)

Second Tier Firms

  2 Mid-Size Firms
  (2 Incinerator Units)

Third Tier Firms

  About 25 Smaller Firms
  (25 Incinerator Units)
       Total All Firms
      0.1593
    0.032-0.036
      0.1136
    0.304-0.308
       0.032-0.036d
           0.113d
       0.256-0.260
a)  Assumes a capacity of 70 million Ibs. per year per unit.
b)  Assumes 30 percent of total capacity for solids,  70 percent  for
    liquids per unit.
c)  Assumes a capacity of 35-40 million Ibs. per year per  unit.
d)  Assumes all of  total capacity is for liquids.
e)  Assumes an average capacity of 10 million Ibs. per year per  unit.
                                III-6

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

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

2.  INCINERATION  OF  PCBS;   QUANTITIES  INCINERATED  AND
    AVAILABLE CAPACITY

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

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

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

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

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

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

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

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

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

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

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

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

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

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

-------



























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

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

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

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

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

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

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

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

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

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

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

                          111-12

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

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

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

1.  PROJECTED INCINERATION DEMAND WITHOUT REGULATORY CHANGE

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

         Increasing demand for PCB incineration capacity

         Slowed commercialization of  alternative  technolo-
         gies

         Questionable  responsiveness  of  "available"   on-
         site incineration capacity

         Declining landfill capacity

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

         Generators'  increasing liability concerns.

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

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

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

    (1)   Demand for  PCB Incineration Capacity

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

-------
 (2)   Availability of On-site Capacity

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

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

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

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

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

(3)  Commercialization of Alternative  Technologies

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

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

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

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

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

 (4)  Declining Landfill Capacity

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

 (5)  Superfund's  Influence

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

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

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

2.  PROJECTED INCINERATION DEMAND AND CAPACITY UTILIZATION
    WITH REGULATORY CHANGE

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

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

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

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

    The RCRA  regulatory  amendment  scenarios analyzed  in-
clude:

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

         Restrictions on  burning and  hazardous wastes  in
         boilers/furnaces

         Additional listings of  organic liquids  as hazard-
         ous wastes.

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

    (1)  Land Disposal Restrictions

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

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

-------
          Restrictions on deep well injection of LOHWs

          A ban on disposing  LOHWs  in  surface impound-
          ments.

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

     1.   Landfill Restrictj.cms

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

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

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

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

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

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

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

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

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

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

2.   Injection Well Restrictions

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

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

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

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                                                                     IV-13

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

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

     3.   Disposal Impoundment Ban

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

                      IV-14

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

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

(2)  Waste-in-Boilers Restrictions

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

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

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

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

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

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

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

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

-------
                                 EXHIBIT 14

                 Quantities of Waste-Derived Fuel Materials
                               Burned By Type
MATERIAL TYPE
Aqueous inorganics
Aqueous organics
Organic solvents
Other organic wastes
Re actives
Corrosives
Other solid residues
Other wastes
QUANTITY BURNED
(10a gallons)
14
65
67
321
<1
57
191
199
PERCENT
OF TOTAL
1.5
7.1
7.3
35.1
0.1
6.2
20.9
21.8
                                          914a
   ^Number is less than the estimate of the total quantity burned in
    1983(924 million gal.)  because respondents reported only six
    materials.
Source:
(15)
                                      IV-17

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

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

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

(3)  Additional Waste Listings

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

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

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                                                                              IV-19

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

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

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

(4)  Lowering the Small Quantity Generator Exemption

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

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

         A ban on landfilling LOHWs

         Restrictions on deep well injection of LOHWs

         Restrictions on disposing  LOHWs  in  surface  im-
         poundments

         Controls on burning hazardous wastes in boilers.

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

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

-------
    V.   PROJECTED CHANGES IN LOHW INCINERATION CAPACITY

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

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

         Use of  remaining  commercial  incineration capacity
         for liquids

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

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

         Development   of   commercial   incineration-at-sea
         capacity.

1.  INCREASED  CAPACITY  UTILIZATION  AND   NEW  LAND-BASED
    CAPACITY

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

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

                            V-l

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

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

2.  DEVELOPMENT OF INCINERATION-AT-SEA CAPACITY

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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             VI-3

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

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

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

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                 VI-5

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                          APPENDIX A

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

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

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

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

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

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

0000
D001
D002
D003
D004
D005
D006
D007
D008
D009
D010
D011
D012
D013




POOS
P020
P022
P028
P039
P041
P042
P063
P068


D014
0015
DOT 6
D017
F017
F018
F019
K071
K073
K074
K078
K079
K081
K082




P069
P081
P089
P094
P097
PI 02
U002
U003
U004

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



U008
U009
U012
U019
U023
U031
U037
U041
U044

U046
U051
U053
U056
U057
U066
U069
U070
U074

B: SUITABILITY
PI 23
UOOO
U240
U242
U244
X003
X006
X007
X008
X009
X011
X012
X013
X014
POOR
F006
K001
KOI 6
X015
X016
X017
X020
X021
X022
X023
X024
X025
X026
X028
X030
X031
X032
WASTE CODE
KOI 8
K036
K052
U076
U077
U078
U080
U083
U098
U103
U107
U108

FOR LIQUID
X034
X035
X036
X037
X039
X040
X042
X043
X044
X045
X046
X048
X049
X050
U110
U112
U 114
U117
U123
U124
U130
U133
U138

U140
U154
U155
U156
U159
U161
U162
U169
U180

U196
U209
U210
U213
U220
U223
U226
U227
U228

INJECTION INCINERATION
X051
X052
X053
X054
X059
X062
X063
X069
X070
X071
X072
X075
X076
X077
CANDIDATES FOR
P033
P074
P095
PI 06
U043
U122
X078
X080
X081
X084
X087
X092
X093
X096
X098
X099
X106
X110
X1 11
X114
X116
X1 17
XI 23
X127
XI 28
XI 29
XI 30
X131
XI 32
XI 37
XI 38
X142
X143
X144
U239
X001a
X002
X004
X018
X019
X029
X033
X038

UNKNOWN
X145
X146
X147
X148
X149
X151
XI 52
XI 53
XI 55
XI 58
XI 59
XI 60
X161

X056
X058
X064
X065
X079
X082
X094
X095
X100
X104

XI 63
X164
XI 67
XI 68
XI 69
XI 73
XI 74
XI 75
X176
X177
XI 78
X181
XI 82

XI 05
X113
XI 20
X121
XI 24
XI 25
X150
XI 70
X171
X179

XI 83
XI 84
XI 85
XI 86
XI 87
XI 89
X191
XI 94
Y001
Y002
9995b
9998C
ggggd

LIQUID INJECTION INCINERATION
U134
U177
U188
U189
U192
U201









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

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

     All three lists were considered to constitute the "universe1
of LOHWs for purposes of the incineration market study,
despite some of the inherent uncertainties.  To limit some
of the data development necessary for the study, a waste
categorization scheme was applied to these lists.  This
scheme narrowed the analysis down from 294 individual waste
codes to 16 waste categories.  Exhibit A-2 presents this
categorization scheme.  This scheme itself is an expanded
and modified version of one used by the State of Michigan
in "Hazardous Waste Management in Michigan:  A Status Report
and Review of Future Options."(22)
                             A-3

-------
                                       EXHIBIT A-2
                    LOHW Waste  Code  Categorization  Scheme
                Developed for  the  Incineration Market  Study
    GROUP
                 INCLUSIVE LOHW CODES
   I.   IGNITABLES


  II.   CORROSIVES


 III.   REACTIVES

  IV.   METAL BEARING
   V.   PESTICIDES

  VI.   SOLVENTS
 VII.   ELECTROPLATING

VIII.   MISC. PROCESS

  IX.   INORGANIC PIGMENTS

   X.   ORGANIC CHEMICALS


  XI.   EXPLOSIVES

 XII.   PETROLEUM REFINING

XIII.   IRON & STEEL

 XIV.   INORGANIC CHEMICALS

  XV.   MISC. COMMERCIAL CHEMICAL
       PRODUCTS
DOOO,  D001, X014, X020, X045,  X046, X077, X092,  X129,
X130,  X176, X177, X185, X186,  X187

D002.  X009, X012, X050, X052,  X053, X054, X062,  X076,
X093,  X111, X137, X151, X163,  X178, X184
D003
D004-D011, X006, X017, X023,  X025. X026, X035, X036, X037,
X039, X043, X051, X059, X063, X075, X114, X116, X117, X131,
X142, X143, X144, X145, X146, X149, X153, X167, X191, X138,
XI94

D012-D017, K036, K099, XI58

F001-F005, X001, X002, X003,  X004, X013, X016, X018,  X033,
X058, X064, X095, X096, X104, XI13, X179, X008, X069, X071,
X078, X079, X099, X100, X121, X123, X127. X148. X150, X161,
XI68, XI69, X038

F006, X007, X024, X040

F010, K086, K087. K001, XI74

X087

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

K047, XI47, X155
 XVI.  NOT CLASSIFIED
NONE
K071, K073,  K106

P063, P068,  P106, U002, U003, U043, U023, U031, U053, u056,
U196, U220,  U223, U123, U133. U154, U074, U'080, U117, U098,
P074, U188,  U134, U122, X019,  X029, X031, X032, X056, X065,
X070, X072,  X080, X082, X094.  X098, XI05, X106, X120, XI24,
X125, X132,  X170, X171, X181,  X182, X183, X159, X160, X030

X021. X022,  X028, X034, X042,  X048, X049, X081, X110, X152,
X164, X175,  X189, Y001, Y002,  9995, 9998, 9999, X015, X173
        A-4

-------
                          APPENDIX B

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

          The total quantity of LOHWs managed by technology

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

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

1.   Quantities of LOHWs Incinerated

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

-------
                EXHIBIT B-l
Quantities  of LOHWs  Incinerated  in 1981
       TOTAL A+B+C =230,791,000 GAL. (0.86 MMT)a
LIST WASTE CODE
A F001
F002
F003
F005
K015
P063
P068
U002
U003
U023
U031
LJ044
U053
U056
U074
U080
U098
U117
U123
U133
U154
U196
U220
U223
X001
X002
XT 24
XI 79

B DOOO
D001
D002
D003
K083
K085
K093
X013
X015
X028
X042
X072
xno
X175
XT 82
9995
SAMPLE SIZE
1
6
22
20
1
5
1
5
2
1
1
1
1
2
1
3
1
2
1
1
7
1
4
1
1
1
1
1

1
59
9
9
2
1
1
2
2
2
1
1
1
1
1
13
AMOUN1 LIQUID INCINERATED (103 GAL)
9
1.614
24,227
17,665
153
62
40
518
2,438
253
96
1
25
108
738
2
2
2
1
24
80
1
1
48
6
144
1
6
48,262 (0.18 MMT)a
5,151
61,154
2,860
3,488
528
396
178
655
1,491
359
6,246
710
642
432
80,864
12,455
                    B-2
                                              177,609  (0.66 MMT)a

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








WASTE CODE
K001
K016
KOI 8
K036
P074
P106
U043
U122
U188
SAMPLE SIZE
1
1
1
1
1
1
3
6
5
AMOUNT LIQUID INCINERATED (105 GAL)
18
983
1,542
81
235
1
656
246
:,158
a)  Assumes 268.8519 gallons per metric ton.
SOURCE:  (1)
                                                                      4,920  (0.018 MMT)'
                                           B-3

-------



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B-4

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

          The Incinerator Questionnaire asks for a direct
          estimate of liquids incinerated

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

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

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

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

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

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

2.   Quantities of Wastes Managed By Other Technologies

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

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

-------
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                                                                     B-7

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

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

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

                               B-8

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

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

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

                           B-9

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

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

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

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

This exhibit  also compares the Survey-derived  splits with
the splits  assumed in each of the  low-range, mid-range, and
high-range  regulatory scenarios.    For  three technologies--
incineration,  injection wells, and disposal impoundments--
the Survey-derived on-site/off-site distributions compare
favorably with the distributions assumed in the  market analysis
scenarios.  Lacking any other available  estimates, therefore,
these assumed splits  were used across  all three  sensitivity
analyses* of  the  projected demand  for  commercial incineration
capacity.   Only the landfill restrictions scenario analysis
involved varying  the  on-site/off-site  distribution as  part
of the sensitivity analysis.  This variation reflects  a difference
in estimates  of this  distribution  for  landfills  across available
sources.  The Survey-derived distribution of 43  percent on-
site and 57 percent off-site for landfilled wastes is  one
of these estimates,  and has been used  as part  of the low-
range case  in the sensitivity analysis.   Alternatively, a
comparison  of the National Survey's estimate of  3.2 million
metric tons of wastes landfilled in 1981 with  an estimate
of wastes landfilled at commercial facilities  in 1980  (2.7
w A sensitivity analysis was made part  of the market analysis given the
  variability and uncertainties in key  estimates and assumptions like the on-site/
  off-site distribution by  technology.   Chapters I, II, and IV describe  in more
  detail how  the sensitivity analysis has been constructed; however,  the basic
  the basic features are a low-range,  mid-range, and high-range case built
  from the range of  possible values for certain estimates and assumptions as
  suggested by the available sources.
                                 B-13

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

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

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

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

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

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

          Baseline LOHW incineration  capacity utilization

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

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

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

     PCB liquids incineration capacity

Effects of restrictions on landfills

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

     Demand for present incineration capacity after
     restrictions

Effects of deep well injection restrictions

     Wastes injected in on-site and off-site wells

     Demand for present incineration capacity after
     restrictions

Effects of disposal impoundment restrictions

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

     Demand for present incineration capacity after
     restrictions
                 C-2

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

               Hazardous wastes burned in boilers

          -    Demand for present incineration capacity after
               restrictions

          Addition of incineration-at-sea capacity

               Capacities of individual incinerator ships

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

          Effects of Superfund clean-up activity on RCRA capacity

               Data needs and sources
               Data analysis

          Organic liquids likely to be listed as hazardous
          wastes

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

Note that each regulatory scenario analysis module estimates
the demand for on-site and off-site LOHW incineration capacity
under static supply conditions, that is, available capacity is
held fixed for this instantaneous analysis at the practical
maximum commercial LOHW incineration capacity level of 300,000
metric tons (minus 48,000 metric tons of  capacity for liquid? PCBs)
and 3.1 MMT of noncommercial LOHW inc1'^ -ation capacity.  Refer
to Chapters II, III, and V for discussions of available capacity
and projected increases in capacity.
                             C -3

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

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

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

                    Total quantity of LOHWs incinerated off-site
                    -  0.139 MMT

                    Total off-site LOHW incineration capacity
                    =0.30 MMT

                    Incineration capacity for PCBs = 0.048 MMT
                                C-4

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

                    Total LOHW incinerated capacity = 3.4 MMT

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

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

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

    LOHW INCINERATION CAPACITY
        TOTAL LOHW
        INCINERATION CAPACITY
              3.4 MMT6
                                                          TOTAL ONSITE LOHW
                                                          INCINERATION CAPACITY
                                                                 3.10 MMT
                  TOTAL OFFSITE LOHW
                  INCINERATION CAPACITY
                      0.300 MMTb
        TOTAL OFFSITE  LOHW
        INCINERATION CAPACITY
             0.300 MMT
OFF-SITE CAPACITY
DEVOTED TO PCBs
INCINERATION
  0.048 MMT*1
"NET"  OFFSITE LOHW
INCINERATION CAPACITY
      0.252 MMT
a)  Estimate based upon  modified assumptions to Mitre's calculation, p.2-10  through 2-12 in
    the Interim Incineration RIA:  209 facilities x 595.4 gal/hr x 7200  hr/yr x 0.00378 gal/metric
    ton = 3.4 million  metric tons.  7200 hr/yr derived from industry sources.

b)  Estimate derived  from contacts with commercial incineration firms.

c)  Relationship established by 0.3 MMT-f 3.4 MMT.

d)  See PCB module.

  	BOOZ-ALLEN & HAMILTON INC-
                                          C-6

-------
                                    LOHW  INCINERATION
              BASELINE CAPACITY UTILIZATION:  MID-RANGE ESTIMATES CASE (CONT'D)
CAPACITY UTILIZATION ESTIMATE
    TOTAL QUANTITY OF LOHW
    INCINERATED ONSITE
        1.253 MMT
40.4Z of
capacity
TOTAL ONSITE LOHW
INCINERATION CAPACITY
     3.10 MMT
    TOTAL QUANTITY OF LOHW
    INCINERATED OFFSITE
      0.139
55.3$  of
capacity
"NET" OFFSITE  LOHW
INCINERATION CAPACITY
     0.252 MMT
                                         BOOZ ALLEN & HAMILTON  INC
                                        C-7

-------
                     PREFACE TO PCB MODULE








     This module was developed principally to estimate commercial




incineration capacity for liquid PCBs so that this capacity



could be subtracted out from commercial capacity for all



LOHWs.  Estimates of the demand for liquid PCB incineration




capacity are presented solely to make this module similar



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



analysis is determined by the estimate for capacity.








     Industry sources and EPA staff were consulted on estimating



commercial incineration capacity for liquid PCBs.  The data



for capacity shown in the module were provided by EPA staff



in May 1984, and reflect permit limits established at that



time.  According to industry sources, these permit limits



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



carefully as their phrasing often determines the maximum



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



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



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



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



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



throughput.

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

     Estimating total volumes of  liquid
     PCBs incinerated

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

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

     4.1 million gallons from removal of
     mineral oil transformers

     1.6 million gallons from storage

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

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

TOTAL PCB VOLUMES -  USE PHASE OUT  - CAPACITORS/ASKAREL TRANSFORMERS
 r
      TOTAL POUNDS OF  PCBS
      FOR "DISPOSAL" FROM
      USE PHASEOUT OF  PCB
      CAPACITORS AND ASKAREL
      TRANSFORMERS
        16.140,247 LBa
54.4$ FROM PCB CAPACITORS
 1008 PCBs.  11.6 LB/GALb

45.68 FROM ASKAREL TRANS-
FORMERS 8 8.75 LBS PCB/GAL
OF FLUID"
TOTAL VOLUME  OF  PCB FLUIDS
FOR  "DISPOSAL" FROM USE
PHASEOUT OF PCB CAPACITORS
AND  ASKAREL TRANSFORMERS
        1.598,059 GAL.
TOTAL VOLUME OF PCB
FLUIDS FROM USE PHASEOUT
FPR "DISPOSAL"
1.598,059 GAL.


ADDED VOLUME FROM SOLVENT
RINSE  RATIO OF 1:1C
1 ,598.059 GAL
                                                                   TOTAL VOLUME OF PCB FLUIDS
                                                                   AND SOLVENT RINSE FOR
                                                                   "DISPOSAL" FROM USE PHASEOUT
                                                                           3,196,118 GAL.
a)  Figure for 1984 from Table 46, July 1982 RIA on Use Rule;  number is  likely to be too low
    based upon under-estimation  of voluntary and mandated  phaseout rate.

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

TOTAL NUMBER OF MINERAL
OIL TRANSFORMERS CON-
TAINING SOME PCBs
1 1 0R 1 PTIPN I

25,284,000d







FAILURE RATE = 0.2 S/YRe
_*
UNIT LIFE = 30 YEAR?



f
1
1
T
1
1
j


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



- ^
i
I
l
1
i
i
j

      TOTAL NUMBER OF MINERAL
      OIL UNITS FOR "DISPOSAL"
      IN 1984
          732,634
  47.4 GAL/UNIT11
TOTAL FLUID VOLUME OF
MINERAL OIL UNITS FOR
"DISPOSAL" THAT CONTAIN
SOME PCBs
     34.726,852 GAL
d)  Figure from Table S-1,  July 1982 RIA on Use Rule.
e)  Estimate used in July 1982 RIA on Use Rule.
f)  Estimate used in July 1982 RIA on Use Rule except exclude rebuilding add-on of 30 years.
g)  Number from sum of removal and failure estimated 1984 population;   no additional units are
    added -trom voluntary phaseouts;  losses in 1981-1983 (2,346,155 units)  have been handled or
    are in storage.
h)  Derived from Table S-1,  July 1982 RIA on Use Rule.
                                            BOOZ ALLEN & HAMILTON INC
                                           C-9

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

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

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

     PCB liquids capacity (MT) x 1008 = PCB liquids supply (MT) x 184 gal/MT = PCB liq. supply
     PCB liquids supply (gal) - use phoseout volume (gal) - mineral oil units volume (gal)
     =  PCB carryover volume  (gal)

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

TOTAL PCB VOLUMES - BY PCB CONCENTRATION RANGE
     TOTAL VOLUME OF PCB FLUIDS
     AND RINSE FOR "DISPOSAL"
     FROM USE PHASEOUT OF PCB
     CAPACITORS/TRANSFORMERS
           3,196,118 GAL
                                 100SS OF THESE
                                 UNITS CONTAIN
                                 PCBs  >500 PPM8
TOTAL VOLUME OF  >500 PPM PCB
FLUIDS FROM USE  PHASEOUT OF PCB
CAPACITORS/TRANSFORMERS FOR
"DISPOSAL"
        3,196.118 GAL
TOTAL FLUID VOLUME  OF MINERAL
OIL  UNITS  FOR "DISPOSAL" THAT
CONTAIN SOME PCBs
     34.726,852  GAL
                                                      TOTAL FLUID VOLUME FROM MINERAL
                                                      OIL UNITS THAT HAS 50-500 PPM PCBs
                                                              4,097,769 GAL
                                                      TOTAL FLUID VOLUME F.TOM MINERAL
                                                      OIL UNITS THAT HAS  >500 PPM PCBs
                                                                381,995 GAL
a) EEI/USHAG data.
                                            BOOZ ALLEN & HAMILTON  INC
                                        c-io

-------
                             INCINERATION CAPACITY UTILIZATION
                 PCB VOLUMES  INCINERATED AND INCINERATION CAPACITY (CONT'D)
TOTAL PCB VOLUMES - BY PCB CONCENTRATION RANGE (Cont'd)
     TOTAL CARRYOVER VOLUME OF
     PCB FLUIDS FOR "DISPOSAL"
         1,633.607 GAL
1002 OF VOLUME
HAS PCBs >500
PPM


TOTAL CARRYOVER VOLUME THAT
HAS >500 PPM PCBs
1,633,607 GAL
TOTAL PCB VOLUMES - NEEDING TO BE INCINERATED
TOTAL FLUID VOL.
OF > 500 PPM PCBs
FROM USE PHASEOUT
3.196.118 GAL


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



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



TOTAL FLUID VOL.
>500 PPM PCBs
5,211,720
              TOTAL FLUID VOLUME
                >500 PPM PCBs
                5,211,720 GAL
     TOTAL FLUID VOLUME WITH
     50-500 PPM PCBs FOR
     "DISPOSAL"
        4,097.769 GAL
       1008 OF >500 PPM
       FLUIDS MUST BE
       INCINERATED8
                                                               TOTAL PCB FLUID VOLUME
                                                               TO INCINERATION
                                                                   8.899.712 GAL
9% TO APPROVED LANDFILLS5
1g TO TREATMENT15
90% TO APPROVED INCINERATORS11
                                 L_
a)  As specified by regulation.
b)  Assumptions given  regulatory option-:
                                          BOOZ ALLEN & HAMILTON INC
                                                 J
                                         c-n

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

Four units approved for PCB incineration

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


TOTAL AVAILABLE PCBs
INCINERATION CAPACITY
53,742 MT PCBs
TOTAL AVAILABLE PCBs
INuINtKAl 1UN UArAUl 1 1
53,742 MT PCBs

1
1
I,
f
1
1
1
10? IS PCB SOLIDS CAPACITY0
908 IS PCB LIQUIDS CAPACITY0



_1
TOTAL AVAILABLE PCB
Ll^XJlDo INCINERATION
CAPACITY
4o,.5c>o Ml PCBs
c)  Assumption.

CAPACITY UTILIZATION ESTIMATES
TOTAL PCB VOLUME
TO INCINERATION
8,899,712 GAL


@ 12 LB/GAL OR 184 GAL/MTC


TOTAL PCB VOLUME TO
INCINERATION
48,368 MT PCBs
     TOTAL PCB VOLUME TO
     INCINERATION
         48,368 MT
                             I	
                                1002 OF CAPACITY*1'
                                             	I
TOTAL AVAILABLE PCB LIQUIDS
INCINERATION CAPACITY
    48,368 MT
d)  Capacity utilization reported = 1002  by industry sources.
                                          BOOZ ALLEN & HAMILTON INC.
                                        C -12

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

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

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

                    Net baseline off-site incineration capacity
                    = 0.252 MMT

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

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

                    Landfill restrictions affect 50% of wastes
                    currently landfilled

                    30% of restrictions-affected wastes are
                    incinerable

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

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


PERCENT OF WASTES
GOING TO LANDFILLS
1.2$a


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

     TOTAL QUANTITY OF WASTES
     LANDFILLED ONSITE
          0.95 MMT
                                                        TOTAL QUANTITY OF WASTES
                                                        LANDFILLED OFFSITE
                                                             2.22  MMT
a)  1981 RIA National Survey report data.
b)  Are mid-range estimates determined from low-range estimates = 43$ on-site, 57$ off-site
    (RIA data) and high-range estimates = 16JS on-site: 8455 off-site (commercial industry
    annual survey data).
LANDFILL RESTRICTIONS EFFECTS
                               r-
TOTAL QUANTITY OW WASTES
0.95 MMT


TOTAL QUANTITY OF WASTES
LANUrlLLtD Urhbilt
2.22 MMT

1




PERCENT OF WASTES
RESTRICTIONS
50?a

PERCENT OF WASTES
50Za






TOTAL QUANTITY OF ONSITE
UIACTPQ APPPPTPH
0.475 MMT


TOTAL QUANTITY OF OFFSITE
1.11 MMT
                               I	
--J
a)  Range of 25? to 75Z suggested by EPA staff as possible effects of  restrictions.
    Mid-range estimate = 508.
                                          BOOZ-ALLEN & HAMILTON INC
                                        C-15

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

TOTAL QUANTITY OF OFFSITE
WASTES AFFECTED
1.11 MMT
^




PERCENT OF AFFECTED
vni IMP THAT TC;
INCINERABLE
30?a

PERCENT OF AFFECTED
VOLUME THAT IS
INCINERABLE
30Ja





TOTAL QUANTITY (ONSITE ORIGIN)
TOMOVE TO INCINERATION
0.143 MMT

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

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

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



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


TOTAL QUANTITY INCINERATED
ONSITE AFTER RESTRICTIONS
1.327 MMT

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



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


TOTAL QUANTITY INCINERATED
OFFSITE AFTER RESTRICTIONS
0.541 MMT

     TOTAL QUANTITY INCINERATED
     OFFSITE AFTER RESTRICTIONS
         0.541 MMT
214.7$ of
Capacity
"NET" OFFSITE LOHW
INCINERATION CAPACITY
    0.252 MMT
                                         BOOZ ALLEN & HAMILTON INC
                                       C-17

-------
         EFFECTS OF DEEP WELL INJECTION RESTRICTIONS;
                   MID-RANGE ESTIMATES CASE
OBJECTIVE;
To estimate on-site and off-site incineration
capacity utilization after imposition of
restrictions on underground injection of LOHWs
RESULTS:
KEY DATA:
On-site incineration capacity utilization
after restrictions = 53.5% of capacity

Off-site incineration capacity utilization
after restrictions = 306.2% of capacity

Total wastes generated = 264 MMT

Percent of wastes generated going to injection
wells = 12.1%

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

Baseline on-site incineration capacity
=3.1 MMT

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

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

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

                    Restrictions affect 50% of wastes injected

                    93.5% of affected wastes are non-incinerable

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

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

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


PERCENT OF WASTES
GENERATED TO DEEP
WELL INJECTION
12.18


TOTAL QUANTITY OF WASTES
NOW INJECTED TO WELLS
32 MMT8
a)  WESTAT  report, April 1984.
b)  Assumed estimates comparable to estimates derived  from RIA data (see Appendix C).
          TOTAL QUANTITY OF WASTES
          NOK INJECTED TO WELLS
                 32 MMT
                                                        TOTAL QUANTITY OF WASTES NOW
                                                        INJECTED TO ONSITE WELLS
                                                                 31.15 MMT
                                                          TOTAL QUANTITY OF WASTES NOW
                                                          INJECTED TO OFFSITE WELLS
                                                                 0.799 MMT
EFFECTS OF DEEP WELL  INJECTION RESTRICTIONS

/
PERCENT OF /
INJECTED tf_
WASTES r~
RESTRICTED \
50SC \\

i\
1
1
1
L.
PERCENT OF
RESTRICTED
QUANTITY THAT
IS DIRECTLY
INCINERABLE
58d

PERCENT OF
RESTRICTED
QUANTITY THAT
IS INDIRECTLY
INCINERABLE

PERCENT OF
RESTRICTED
QUANTITY THAT
IS. NOT
INCINERABLE
[_658d
i
i
I
1

PERCENT AFTER
1 TREATMENT TO
A INCINERATION

y PERCENT AFTER
^ TREATMENT NOT
958 e



r
i
i



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

QUANTITY OF POST-
TREATMENT WASTES TO
INCINERATION
0.234 MMT


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

c)
d)

e)
    Range of estimates suggested by EPA staff = 258 to 758.  Mid- range =  508.
    Assumes most of affected wastes are not  incinerable,  small percentage ere directly incinerable,
    and some are incinereble if treated first.
    After treatment, volume to be incinerated is assumed  to be small.
                                           BOOZ ALLEN & HAMILTON INC-
                                             C-20

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

EFFECTS OF  DEEP  WELL INJECTION RESTRICTIONS (CONT'D)


TOTAL QUANTITY
OF WASTES NOW
INJECTED TO
OFFSITE WELLS
0.799 MMT

I
1

-n


i

PERCENT OF
INJECTED
WASTES
RESTRICTED
50c
PERCENT OF
RESTRICTED
QUANTITY THAT
IS DIRECTLY
INCINERABLE
                                 PERCENT OF
                                 RESTRICTED
                                 QUANTITY THAT
                                 IS INDIRECTLY
                                 INCINERABLE
                                     305^
                                 PERCENT OF
                                 RESTRICTED
                                 QUANTITY THAT
                                 IS NOT
                                 INCINERABLE
                   PERCENT AFTER
                   TREATMENT TO
                   INCINERATION
                   PERCENT AFTER
                   TREATMENT NOT
                   INCINERABLE
                                                                          TOTAL QUANTITY WASTES
                                                                          (OFFSITE ORIGIN) TO
                                                                          MOVE TO INCINERATION
                                                                                 0.026 MMT
QUANTITY OF POST-
TREATMENT WASTES TO
INCINERATION
      0.006 MMT
                                          QUANTITY OF "WASTES"
                                          THAT CANNOT. BE
                                          INCINERATED
                                              0.773 MMT
c)  Range of estimates  suggested by EPA staff = 25$  to 75JS.  Mid-range = 508.
d)  Assumes most of affected wastes are not incinerable, small percentage are  directly incinerable,
    and some are incinerable if treated first.
e)  After treatment, volume to be incinerated is assumed to be small.
     TOTAL QUANTITY (ONSITE ORIGIN)
     TO MOVE TO INCINERATION
           1.012 MMT
     TOTAL QUANTITY (OFFSITE ORIGIN)
     TO MOVE TO INCINERATION
           0.026 MMT
                                  TOTAL QUANTITY TO MOVE TO
                                  ONSITE INCINERATION
                                          0.406  MMT
                                  TOTAL QUANTITY  TO MOVE TO
                                  OFFSITE INCINERATION
                                          0.632 MMT
 f)  Assumes that on the margin, the majority of generators originally managing their wastes
    on-site will elect to send these wastes off-site to be incinerated after restrictions are in-
    place.  Wastes originally sent off-site will remain off-site.
                                            BOOZ-ALLEN & HAMILTON INC
                                               C-21

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                              INCINERATION CAPACITY UTILIZATION
            INJECTION WELL RESTRICTIONS EFFECTS:  MID-RANGE ESTIMATES CASE (CONT'D)
CAPACITY UTILIZATION ESTIMATES
   TOTAL  BASELINE LOHW QUANTITY
   INCINERATED ONSITE
         1.253 MMT
ADDED LOHW QUANTITY TO MOVE
TO ONSITE INCINERATION FROM
DEEP WELL  INJECTION
        0.406 MMT
       TOTAL QUANTITY OF  LOHW
       INCINERATED ONSITE AFTER
       DWI BAN/RESTRICTIONS
               1.659 MMT
        TOTAL ONSITE LOHW
        INCINERATION CAPACITY
              3.10 MMT
   53.5$  Of
   Capacity
TOTAL QUANTITY OF LOHW INCINERATED
ONSITE AFTER DWI BAN/RESTRICTIONS
          1.659 MMT
TOTAL BASELINE LOHW QUANTITY
INCINERATED OFFSITE
0.139 MMT


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


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

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

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

                    Baseline on-site incineration capacity
                    =3.10 MMT

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

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

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

                    10% of wastes in disposal impoundments are
                    incinerable

                    50% of incinerable wastes are incinerated

                    61.7% of wastes incinerated are incinerated
                    off-site

                    Complete prohibition of practice
                             C-24

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


PERCENT OF WASTES
GENERATED MANAGED IN
DISPOSAL IMPOUNDMENTS
7.22a


TOTAL QUANTITY OF WASTES
MANAGED IN DISPOSAL
IMPOUNDMENTS
19 MMT8
     TOTAL QUANTITY OF WASTES
     MANAGED IN DISPOSAL
     IMPOUNDMENTS
           19 MMT
                                                       	I
a)  WESTAT Report.  April  1984.
b)  Analysis of 1981  National Survey data (see Appendix C).
TOTAL QUANTITY OF WASTES
MANAGED IN ONSITE DISPOSAL
IMPOUNDMENTS
        18.058 MMT
TOTAL QUANTITY OF WASTES
MANAGED IN OFFSITE DISPOSAL
IMPOUNDMENTS
         0.950 MMT
EFFECTS OF A BAN ON WASTE DISPOSAL IMPOUNDMENTS0
TOTAL QUANTITY OF WASTES
POSAL IMPOUNDMENTS
18.058 MMT


102 OF BANNED
WASTES ARE
INCINERABLEd



502 OF
INCINERABLE
WASTES ARE
INCINERATED6

\
TOTAL QUANTITY ( ONSITE -
ORIGIN) TO MOVE TO
INCINERATION
0.903 MMT
i i
                                                                     TOTAL QUANTITY  (ONSITE-
                                                                     ORIGIN) NOT INCINERATED
                                                                          17.16 MMT
TOTAL QUANTITY OF WASTES
MANAGED IN OFFSITE DIS-
POSAL IMPOUNDMENTS
0.950 MMT


102 OF BANNED
WASTES ARE
INCINERABLEd



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

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

EFFECTS OF A BAN ON WASTE DISPOSAL  IMPOUNDMENTS (CONT'P)
TOTAL QUANTITY (ONSITE-ORIGIN)
TO MOVE TO INCINERATION
        0.903 MMT
                                     | --------- i
                                     1                 I
                                        40% To Onsite
TOTAL QUANTITY TO MOVE
TO ONSITE  INCINERATION
      0.364 MMT
TOTAL QUANTITY (OFFSITE -ORIGIN
TO MOVE TO INCINERATION
0.048 MMT

j^fl
L

/ >^
5* To Offsite.^
1
J

TOTAL QUANTITY TO MOVE
TO OFFSITE INCINERATION
0.587 MMT

CAPACITY UTILIZATION ESTIMATE
     TOTAL BASELINE  LOHW QUANTITY
     INCINERATED ONSITE
           1.253 MMT
     TOTAL BASELINE  LOHW
     QUANTITY INCINERATED
     OFFSITE
          0.139 MMT
                                   TOTAL QUANTITY TO
                                   MOVE TO ONSITE
                                   INCINERATION
                                     0.364 MMT
                                   TOTAL QUANTITY TO
                                   MOVE TO OFFSITE
                                   INCINERATION
                                       0.587 MMT
    TOTAL QUANTITY OF  LOHW
    INCINERATED ONSITE AFTER
    DISPOSAL IMPOUNDMENT  BAN
          1.616 MMT
     TOTAL QUANTITY OF  LOHW
     INCINERATED OFFSITE AFTER
     DISPOSAL IMPOUNDMENT BAN
            0.726 MMT
     TOTAL ONSITE LOW  INCINERA-
     TION CAPACITY
             3.10 MMT
                                  52.1$ Of  -*-
                                  Capacity
TOTAL QUANTITY OF LOHW
INCINERATED ONSITE AFTER BAN
          1.616 MMT
     "NET" OFFSITE LOHW  INCINERA-
     TION CAPACITY
           0.252 MMT
                                  288.2% Of -*-
                                  Capacity
TOTAL QUANTITY OF LOHW
INCINERATED OFFSITE AFTER BAN
        0.726 MMT
                                           BOOZ ALLEN & HAMILTON  INC
                                        C-26

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           EFFECTS OF WASTES-IN-BOILERS RESTRICTIONS;
                   MID-RANGE ESTIMATES CASE
OBJECTIVE:
To estimate on-site and off-site incineration
capacity utilization after imposition of
restrictions on the burning of hazardous
wastes in industrial boilers
RESULTS:
On-site incineration capacity utilization
after restrictions = 42.2% of capacity

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

                    Baseline on-site incineration capacity
                    =3.10 MMT

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

                    Net baseline off-site incineration capacity
                    = 0.252 MMT

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

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

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

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

TOTAL QUANTITY OF WASTES
NOW BURNED IN BOILERS
0.7 MMT8

r -
1

L

PERCENT OF BOILERS
AFFECTED BY EMIS-
SIONS RESTRICTIONS
35$

T
1
1
1
1
1
i
1

PERCENT OF WASTES
THAT MUST MOVE TO
INCINERATION
75$b

"
TOTAL QUANTITY
THAT MOVES TO
INCINERATION
0.184 MMT
a)  Estimate derived from EPA wastes-in-boilers study.
b)  Range of estimates suggested by EPA staff = 502 to 1002.
  Mid-range = 75$.
ONSITE VS. OFFSITE VOLUMES
     TOTAL QUANTITY OF LOHW THAT
     MOVES TO INCINERATION
           0.184 MMT
TOTAL QUANTITY OF LOHW THAT
MOVES TO ONSITE INCINERATION
         0.055 MMT
TOTAL QUANTITY OF LOHW  THAT
MOVES TO OFFSITE INCINERATION
         0.129 MMT
a)  Assumes  that most of wastes will have  to be incinerated off-site.
TOTAL BASELINE LOHW
QUANTITY INCINERATED
ONSITE
1.253 MMT


TOTAL QUANTITY OF LOHW
THAT MOVES TO ONSITE
INCINERATION
0.055 MMT


TOTAL QUANTITY OF LOHW
INCINERATED ONSITE AFTER
RESTRICTIONS
1.308 MMT
TOTAL BASELINE LOHW
QUANTITY INCINERATED
OFFSITE
0.139 MMT


TOTAL QUANTITY OF LOHW
THAT MOVES TO OFFSITE
INCINERATION
0.129 MMT


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

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                             INCINERATION CAPACITY UTILIZATION
          WASTES-IN-BOILERS RESTRICTIONS EFFECTS:  MID-RANGE ESTIMATES CASE (CONT'D)
CAPACITY UTILIZATION ESTIMATES
     TOTAL QUANTITY OF LOHW
     INCINERATED ONSITE AFTER
     RESTRICTIONS
         1.308 MMT
42.2* Of
Capacity
TOTAL ONSITE LIQUIDS
INCINERATION CAPACITY
    3.10 MMT8
     TOTAL QUANTITY OF LOHW
     INCINERATED OFFSITE AFTER
     RESTRICTIONS
        0.268 MMT
106.3$ Of
Capacity
-NET" OFFSITE LOHW
INCINERATION CAPACITY

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

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

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                      INCINERATION CAPACITY UTILIZATION
                        INCINERATION-AT-SEA CAPACITY


 VULCANUS I & II (Ocean Combustion Services - Chemical Waste Management)


 VULCANUS I:  3,600  MT/voyage x  16 voyages/yr3 =  57,600 MT/yr

 VULCANUS II: 3,600  MT/voyage x  16 voyages/yr3 =  57,600 MT/yr
                                                115.200 MT/yrj
 a) derived from information  supplied by OWRS; permit application
    indicates plan to burn 350,000 MT over  3 years between the two
    ships, an estimated turn-around  time of 3 weeks  (5 days in-
    transit, 10 days to burn,  5 days to reload), 2 units on Vulcanus
    I, 3 units on Vulcanus II, each  unit with throughput of (per unit)
    1,650 gal/hr @ 10 Ib/gal,  240 hrs of burning; assume
    loss of 1 voyages/yr off maximum of 17  (52 wks -5-3);
    termed reasonable by OWRS, likely even  fewer given logistics
    problems, seasonal limitations on operation, etc.
APPOLLO I & II (At-Sea Incineration  Inc.)


APPOLLO I:  1.31 x 10  gal/voyaged6000 MT/voyage x  22 voyages/yr  =132,000 MT/yr
                                                                   132,000 MT/yr
 b) derived from information supplied >y OWRS;  estimated
    turn-around time of 2 weeks (2  days in-transit, 10
    days to burn, 2 days to reload),  2  units each on both
    ships, 2,750 gal/hr/unit,  @ 10  Ib/gal, 240  hrs. of
    burning; assume loss of 4 voyages/yr off maximum
    of 26 (52 wks-^2);  termed reasonable by
    OWRS, likely even fewer given logistics problems,
    seasonal limitations on operations, etc.
                                    BOOZ ALLEN & HAMILTON INC
                                  C -32

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     EFFECTS OF SUPERFUND CLEAN-UP ACTIVITY ON RCRA CAPACITY
OBJECTIVE:
To estimate quantity of wastes that are
incinerable and are incinerated from past
and future Superfund remedial and removal
actions
RESULTS:

KEY DATA:
None
None directly available
KEY ASSUMPTIONS;
None
                              C-33

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                INCINERATION CAPACITY UTILIZATION

    EFFECTS OF-SUPERFUND CLEAN-UP ACTIVITIES ON  RCRA CAPACITY


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

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

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

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

     I                                  7,883
    II                                  4,115
   III                                16,671
    IV
     V                                28,869
    VI                                14,440
   VII
  VIII
    IX                                106,719
     X                                   -
                                      178,697
a) Sites that have a signed Record of Decision, where excavation and disposal   I
   off-site was cost-effective  remedial alternative.  Disposal means land     /
   disposal only.                r>x-Nx-v-     r-v i r\   . . . .._--^.. . .. .*-,   _^/
                             BOOZ ALLEN & HAMILTON INC.-
                             C-34

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               ORGANIC LIQUIDS LIKELY TO BE LISTED
OBJECTIVE:
To estimate quantity of wastes added
from the listing of organic liquids as
hazardous wastes
RESULTS:
Total added quantity could be 1.2 MMT/yr
                     23% of these wastes are currently incinerated

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

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

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                       INCINERATION CAPACITY UTILIZATION
                    ORGANIC LIQUIDS LIKELY TO BE LISTED AS
                   A RESULT OF THE INDUSTRY STUDIES PROGRAM6
An estimated 1.2 million metric tons of organic liquids could be added to
hazardous waste volumes.  Presently, 23 percent of these liquids are
incinerated, most on-site.
   MANAGEMENT
TECHNOLOGY/METHOD
QUANTITY MANAGED  QUANTITY MANAGED
     ON-SITE         OFF-SITE
(metric tons/yr)   (metric tons/yr)
 TOTAL QUANTITY
(metric tons/yr)
Treatment in Tanks
Treatment in Surf. Impd.
Recovery
Reuse
Sales
Landfill
Burned in Boilers
Incineration
Injection Well
Land Application
TOTALS
10,028
104,874
188,922
69,280
N.A.
698
423,321 .
266,449
22,329

1,085,901
0
871
45,275
N.A.
53,982
5,596
756
7,505
2,909

116,894
10,028
105,745
234,197
69,280
53,982
6,294
424,077
273,954
25,238

l,202,795b
(0.8)
(8.8)
(19.5)
(5.8)
(4.5)
(0.5)
(35.3)
(22.8)
(2.1)


N.A. = Not applicable


a)  Data provided through OSW.  Assumes that:
                           (Numbers in parentheses
                            are percents of total)
       60% of Industry Studies manufacturers who provided waste management
       data also reported waste  quantities
       Industry Studies data base  contains data on 59% of total industry

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

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

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                          APPENDIX  D

       LOW-RANGE AND HIGH-RANGE ESTIMATE CASE SUMMARIES


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

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

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

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

1.392
55

1.856
74

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

  25
   30:70

   50
    16:84

    75
C.  DEEP WELL INJECTION  RESTRICITONS
    EFFECTS

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

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                           APPENDIX E


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

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

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

                Is privately owned and  operated

                Receives  a fee for its  services

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

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

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

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

Noncommercial Facility.  A noncommercial facility
is either:

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

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

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

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

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

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

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

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                        APPENDIX F


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

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

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

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

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

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

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

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

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

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

11. Confidential telephone contacts with commercial
    incineration firms.

12. Booz, Allen & Hamilton, Inc.  "Review of  Activities of
    Major Firms in the Commercial Hazardous Waste
    Management Industry:'  1982 Update."  August 1983.
    Prepared for the Office of Policy Analysis.
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                REFERENCES CITED  (cont'd)
13. Office of Pesticides and Toxic Substances.  Regulatory
    Impact Analysis of the Use Rule for PCB-Containing
    Electrical Equipment.  July 1982.

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

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

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

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

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

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

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

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

22. Michigan Department of Natural Resources, Hazardous
    Waste Division.  Hazardous Waste Management in
    Michigan - A Status Report and Review of Future
    Options.  Draft Report.  March 1984.
                                  U.S. GOVEHNMEKT PRINTING OFFICE!  1985-526-778/30376

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