1*7
EP 230/3
85-502
vol»3
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 demand—only 106 percent of existing com-
mercial incineration capacity (fully utilized).
Exhibit S-l goes a step further to translate the esti-
mated excess demand into incinerator equivalents. Two
incinerator equivalent measures are shown -- the number of
land-based facilities of probable future "average" capac-
ity needed to accomodate the added demand, and the number
of probable future "average" capacity incinerator ships
that would accomodate the added demand. This approach
translates the incremental change in demand for incinera-
tion into the most tangible form of a market response, the
building of facilities and ships. As shown in the exhib-
it, as many as 26 land-based incinerator facilities
(20,000 metric tons each) or 10 incinerator ships (50,000
Each scenario had at least one key assumption for
which a range of possible values was offered by the
sources consulted for the study. All the lower values
of these ranges were used to construct a "low-range"
case, and all the higher values were used to construct
a "high-range" case. The mid-range case was the aver-
age of the lower and higher values.
-2-
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..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.
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The objective of this study is to provide the EPA with
information on the current and probable future conditions
of the commercial industry for incineration of LOHWs,
including PCBs. Starting from a profile of the current
market for commercial incineration of LOHWs, an economic
analysis of commercial LOHW incineration capacity utiliza-
tion is presented. This analysis serves two functions:
to analyze market changes and project industry supply and
demand in response to possible changes in the RCRA regula-
tions, and to provide the EPA with an analytical tool for
future evaluations of alternative scenarios as more and
better data become available.
2. METHODOLOGY
This incineration market assessment is one component
of a larger study being conducted by several EPA offices
and contractors centered on a comparative risk analysis of
land-based and incineration-at-sea of LOHWs. Several of
these other studies are direct inputs to the market as-
sessment. The market assessment itself consists of two
parts—a profile of the current LOHW incineration market
and an economic analysis of the industry to project the
demand for and supply of incineration capacity under al-
ternative regulatory scenarios provided by the Agency.
The market profile was developed from past EPA re-
ports, extensive discussions with EPA staff, and contacts
with leading firms in the hazardous waste management in-
dustry. The profile focuses on market size and partici-
pants' market share, LOHW volumes incinerated, available
technologies, and the EPA's current* regulatory program
for incineration. A particularly intensive area of inves-
tigation, led by the Office of Solid Waste, concerned es-
timating quantities of LOHWs managed by type and technol-
ogy (see Appendices A and B) . The principal source of
these data was the National Survey of Hazardous Waste
Generators and Treatment, Storage, and Disposal Facilities
Regulated Under RCRA in 1981 (the 1981 RIA National Sur-
vey) (1,2).
The economic analysis portion of the market asessment
is an evaluation of LOHW incineration capacity utilization
comparing estimated on-site and commercial LOHW incinera-
tion capacity (i.e., supply) with estimated volumes of
LOHWs to be incinerated (i.e., demand). This comparison
is done for baseline market conditions, and a series of
*Through September, 1984.
1-2
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cases projecting demand and supply in response to several
RCRA regulatory amendment scenarios (developed in consul-
tation with the EPA). Projected trends in demand and sup-
ply are also examined in the absence of any significant
regulatory changes.
Baseline market conditions are established on the
basis of three different estimates of commercial LOHW in-
cineration capacity utilization. These varying estimates
of baseline capacity utilization, reflect uncertainty over
the present relationship of the demand for LOHW incinera-
tion and the supply of LOHW incineration capacity. Chap-
ter III discusses these baseline estimates. In Chapter
IV, the projected impacts of each regulatory amendment
scenario are expressed as incremental increases above
these baseline estimates.
Individual components or modules in the overall as-
sessment were analyzed separately. For example, a module
was devoted solely to estimating incineration capacity for
PCBs. Modules were also developed for each regulatory
amendment scenario. Each module was developed through the
use of a logic diagram through which key data and assump-
tions could be displayed and tracked. Each analytical
"template" visually traces the flow of logic behind the
analysis leading to a final capacity utilization esti-
mate. Its design allows for individual estimates and as-
sumptions to be modified easily to generate new results.
With these modules then, the EPA can perform iterative
assessments as new data become available or as policies
are modified.
The logic diagrams presented in Appendix C trace the
calculations for the most likely estimates for the data
and assumptions in each module, drawn from the best avail-
able sources consulted during the study. In some of these
cases, the most likely estimate is the approximate mid-
point between a high and low bound for individual data/
assumptions as suggested by these sources. These high-
range and low-range estimates within each module are sum-
marized in Appendix D. Given that there is a range of
possible estimates for some of the key data and assump-
tions, a sensitivity analysis has been incorporated into
the economic analysis to capture the range of possible
outcomes to each module calculation.
The sensitivity analysis has been built from the com-
bination of lower and upper bounds for selected key data
and assumptions across all the modules. For example, a
"low-range estimates case" was developed out of the combi-
nation of the lowest estimates provided for these selected
1-3
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data and assumptions within each and every module. Simi-
larly, a "high-range estimates case" was built from indi-
vidual high-range modules that use the higher estimates
suggested for these same key data and assumptions.
Selecting an average between these two bounds is the
"mid-range estimates case", presented here as the most
likely case, if, for any one assumption, either the lower
or higher bound may be correct. However, results of the
low-range and high-range cases are presented along with
the mid-range case analysis throughout the report.
3. LIMITATIONS
Use of a sensitivity analysis in this market assess-
ment emphasizes that certain key limitations of this anal-
ysis should be kept in mind when evaluating its results.
These limitations fall into two, non-exclusive classes,
and each can be corrected for in the future as more and
better data become available to the Agency.
(1) Limitations of a National-Level Analysis
The market assessment presented in this report
has been conducted at the national level. Conceptu-
ally, one can conceive of a regional analysis and, in
fact, such an analysis was contemplated originally. A
regional analysis has several benefits, principal
among these is the ability to assess regional costs
and capacity shortfalls that might otherwise "wash
out" at the national level. These regional impacts
may be quite varied in response to the land disposal
restrictions and other RCRA regulatory amendments.
The 1981 RIA National Survey data available on
regional waste management capacities and quantities of
LOHWs generated and managed by region, however, do
not allow a regional focus for the market analysis.
The absence of reliable LOHW quantity data for a re-
gional analysis reflects the considerable statistical
uncertainty in extrapolating to national level waste
quantity data (acknowledged in the RIA National Survey
report) from limited sample sizes when the data are
cut by EPA region or by some form of service region.
In its place, however, there has been an attempt to
present some limited regional-based information. Com-
mercial incineration facilities have been character-
ized as to their location in four service regions.
Selected firms within these service regions have been
contacted and asked for their general assessement of
1-4
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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.
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4. ORGANIZATION OF THE REPORT
The remaining five chapters of the report follow the
analytical progression from baseline market conditions to
projected, regulatory-induced changes in incineration de-
mand and supply. Chapter II presents a profile of the
current incineration market. This profile includes an
overview of the market's size and regional distribution,
waste volumes and types handled, and the applicable regu-
lations, and a discussion of market shares, prices, compe-
tition, and barriers to market entry.
This information is used in Chapter III to develop
estimates of baseline LOHW incineration demand and sup-
ply. Both on-site and commercial baseline LOHW incinera-
tion capacity utilization is estimated. Also developed in
this chapter are estimates of the volumes of hazardous
wastes managed, on-site and off-site, in landfills, injec-
tion wells, disposal impoundments, and industrial
boilers. These volumes represent those wastes that would
be affected by the RCRA regulatory amendments discussed in
Chapter IV.
Chapter IV looks at probable future demands on incin-
eration capacity. Two forms of this projected demand are
examined. In the first section, increases in demand are
estimated in the absence of major regulatory changes.
Conversations with industry sources indicate that this
nonregulatory-induced increase in demand is likely, but
difficult to quantify. Factors and influences behind this
increase are identified. In the second section, several
regulatory-induced changes in demand are analyzed. Each
of the regulatory scenarios are analyzed separately.
Their effect on demand is assumed to be instantaneous,
that is, the analysis avoids speculating on a schedule of
implementation for these regulations, and no additions to
present capacity are assumed. Mid-range, low-range, and
high-range demand estimates are presented. Included are
scenarios on land disposal restrictions (landfills, injec-
tion wells, and disposal impoundments) and controls on
burning hazardous wastes in boilers.
In Chapter V, probable increases in incineration
capacity are estimated. This includes a discussion of
industry's views of their ability to make additional ca-
pacity available over the next three to five years. In
addition, data are presented on the development of incin-
eration-at-sea capacity. It is expected that nearly all
of this added capacity will be for thermal treatment of
liquid wastes.
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The analyses of projected increases in demand and sup-
ply come together in Chapter VI. The key feature of this
comparison is the projected, regulatory-induced excess of
demand over full-capacity supply as translated into land-
based and incineration-at-sea equivalents. Any excess of
the demand for incineration over full-capacity levels
(mid-range estimates of demand only) is equated to an es-
timated number of land-based incinerators of "average"
capacity and an estimated number of "average" capacity
incinerator ships. This provides a consistent basis for
measuring and comparing the supply and demand impacts of
the various regulatory amendments to RCRA on the commer-
cial incineration market. Though not equated to incinera-
tor equivalents, results of the lowand high-range demand
analyses are presented.
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II. INCINERATION MARKET PROFILE
Understanding the potential impact of anticipated reg-
ulatory amendments requires definition of a starting point
or baseline to which comparisons can be made. In this
section, a profile of the current commercial incineration
market is presented as background for baseline estimates
of incineration capacity utilization. General information
is presented on market size and participants, waste vol-
umes handled, available technologies and capacity, and on
the existing regulatory approach for incineration. The
economic structure of the market is described including
estimates of market shares and prices. Also discussed are
competitive pressures, barriers to entry, and growth
strategies. Some information is also developed on the
regional character of the commercial incineration industry.
1. MARKET SIZE AND REGIONAL DISTRIBUTION
Estimates of the number of commercial incineration
facilities range from 25 to 40 (3,4,5,6,7). These are
privately owned/operated facilities that have (or intend
to have) incineration capacity devoted mostly to handling
wastes, for a fee, from other firms.* Far more firms can
provide access to incineration capacity, but only through
other firms that they do not own. Estimates of on-site or
captive incineration facilities range from 200 to 210
firms (3).
The range in the estimated number of commercial facil-
ities reflects growth in the market over time, errors in
the available data, and differences in defining commercial
activity. For example, sources of these estimates cover a
period from December 1980 to July 1984, during which in-
cinerator units have come on-line or gone out-of-service,
Permit status also changes with time. Commercial facili-
ties, whose Part A permit data indicates incineration
This is the preferred definition of "commercial" for
the market study. This definition focuses on wastes
origin- ating from off-site and from other firms.
This defini- tion is intended to include intrafirm
shipments between off-site commercial facilities, but
exclude intrafirm shipments between a generator and a
captive TSD owned by the generator (see also Appen-
dix E) .
II-l
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activity, may later be denied a permit to operate, or they
may discontinue plans to operate a hazardous waste incin-
erator.
The estimated total number of operating hazardous
waste incinerators ranges from 270 to 340 units depending
upon completion of planned construction (3) . Commercial
facilities may account for 30 to 50 of these units, that
is, some 80 percent of hazardous waste incinerators oper-
ate at the generator's site or as part of a captive haz-
ardous waste management facility (3).
Many of the incineration facilities, both on-site and
commercial, and most of the incinerator units, are located
in the Southeast and Southwest as shown in Exhibit 1.
Fewer firms are located in the Middle Atlantic and North
Central regions of the U.S., but commercial firms in these
areas have significant capacity. Even fewer firms are
located in the Western U.S.
2. INCINERATION TECHNOLOGY AND CAPACITY
For handling LOHWs, liquid injection is the primary
incineration technology. Other technologies, such as ro-
tary and cement kilns, can also handle liquids as well as
solids. The Mitre Telephone Survey (3) indicated that 52
percent of all reporting hazardous waste incinerators were
liquid injection units.* In total, some 77 percent of all
the incinerators reporting could handle liquids, including
liquids-capable multiple hearth/chamber units, rotary
kilns, and fume incinerators. Exhibit 2 shows the distri-
bution of operational hazardous waste incinerators by
technology as estimated by Mitre (3). Additional data
obtained by Mitre indicate that while liquid injection
units dominate, newer units tend to be rotary kilns or
fume incinerators. This general trend is confirmed by
industry sources.
Total incineration capacity for all hazardous wastes
(or just LOHWs) is difficult to estimate. Exact capacity
of individual units is generally not known or the avail-
able data reflect respondents1 different interpretations
of capacity (e.g., hourly throughput capacity, heat capac-
ity, annual total capacity). Operational parameters—hours
Data on incinerator units by type are also available
from the RIA National Survey. However, as of this
writing, efforts are still underway to verify and cor-
rect these data.
II-2
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EXHIBIT 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 forth—are also so variable
as to be difficult to characterize as "typical". The data
that are available on liquids incinerator unit capacities,
however, are shown in Exhibit 3(3).* A wide range of
throughput capacity is indicated, but the distribution is
skewed towards generally smaller (less than 200 gallons/
hour) units. Using these data, an estimate of total
available baseline LOHW capacity, on-site and commercial,
is developed in Chapter III.
3. WASTE VOLUMES AND TYPES HANDLED
Those waste types that are liquids and incinerated or
potentially incinerable are the target wastes for this
market analysis. Information on the types of waste
streams incinerated comes from the 1981 RIA National Sur-
vey (2) . The Office of Solid Waste (OSTT) has coordinated
the development of this information.
Exhibit 4 summarizes the waste type and volume data
obtained from RIA National Survey. Estimates of the vol-
ume of LOHWs incinerated in 1981 range arou .d 0.9 million
metric tons (MMT).** Most of this amount is accounted for
by three waste code categories: miscellaneous commercial
chemical product wastes, ignitable wastes, and solvents.
According to survey data, 98 percent of these wastes were
incinerated on-site.
* Data in the RIA National Survey can be used to develop
capacity estimates by technology. As of 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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11-13
-------
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
-------
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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III-3
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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
-------
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
-------
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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V-3
-------
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
-------
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
-------
The key feature of the exhibit, however, is how any
remaining excess demand over supply is translated into the
two measures of incinerator equivalents—equivalent "aver-
age" capacity land-based incinerators and equivalent
"average" capacity incinerator ships. For example, at
full capacity utilization, landfill restrictions (mid-
range estimates) are estimated to result in an excess de-
mand of 0.289 MT (0.541 MT - 0.252 MT) . In Exhibit 17,
this difference is shown to be equaled by bringing on-line
14 additional land-based incinerator facilities (at a
probable future average capacity of 20,000 metric tons per
year per new facility) or 6 incinerator ships (at a prob-
able future average capacity of 50,000 metric tons per
year per ship). The largest impact a scenario may have in
terms of incinerator equivalents is estimated to be 26
land-based facilities and 10 ships. This would be needed
if all disposal of LOHWs in injection wells was prohibited
(with only 6.5 percent of the affected wastes incinerated).
Given that several of these regulatory restrictions
may be implemented concurrently by the EPA, Exhibit 18
examines the impact of combinations of the four regulatory
scenarios. Again, any excess in the demand for incinera-
tion over existing available commercial incineration ca-
pacity for LOHWs (fully utilized) is translated into in-
cinerator equivalents. The landfill and wastes-in-boilers
restrictions (mid-range cases) considered together are
projected to result in an excess of demand (0.669 MT -
0.252 MT = 0.417 MT) equivalent to 21 land-based inciner-
ator facilities or 8 incinerator ships. All three land
disposal restrictions (mid-range cases) are estimated to
require 75 land-based incinerator facilities or 30 incin-
erator ships to handle the estimated excess demand. The
addition of wastes-in-boilers restrictions to the three
land disposal restrictions results in only a marginal in-
crease to 82 land-based facilities or 33 ships.
Exhibit 18 also shows that the number of land-based
facilities or ships needed could be far less or far
greater than is estimated based on the mid-range case re-
sults. Not shown, however, are the results of mixing
low-, mid-, and high-range case assumptions in each of the
scenario analyses, or the possibility of using combina-
tions of land-based facilities and ships to accomodate any
projected increase in demand. Land-based facilities or
ships with a larger average annual capacity than assumed
in both Exhibits 17 and 18 would also mean that fewer of
each or both might be necessary.
VI-4
-------
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VI-5
-------
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
-------
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
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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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B-16
-------
APPENDIX C
MARKET ANALYSIS MODULES; LOGIC DIAGRAMS FOR BASELINE
"MARKET CONDITIONS AND REGULATORY SCENARIO ANALYSES—
MID-RANGE ESTIMATES CASE
The following logic diagrams trace the key data and
assumptions for the mid-range estimates case for the baseline
incineration capacity utilization module, and each of the
regulatory scenario modules that estimate the demand for
incineration after RCRA regulatory change. Preceding each
module is a brief description of its objectives and results.
Sources of the data and assumptions used are referenced.
The more critical assumption in each analysis are high-
lighted within dotted-line boxes in the logic flow. Variations
in these assumptions are perceived to have the greatest effect
on the projected outcomes. Appendix E incorporates these
variations in describing the low-range and high-range estimates
cases that are part of the sensitivity analysis for each module
All three cases—the low-range, mid-range, and high-range—are
built from the range of estimates suggested by the sources
consulted for the key data and assumptions. The sensitivity
analysis results are discussed in Chapter III, IV, and VI.
Nine mid-range case modules are presented. These nine
include logic diagrams on:
Baseline LOHW incineration capacity utilization
LOHW volumes incinerated on-site and off-site*
LOHW on-s"ite and off-site incineration capacity
* As used here, reference to on-site and off-site should be interpreted
as noncommercial and commercial, respectively. See Appendix F for
complete definitions of key terms in the market study.
C-l
-------
Incineration capacity utilization for PCBs
PCB volumes incinerated (use phaseout, failures,
carryover volumes)
PCB liquids incineration capacity
Effects of restrictions on landfills
Wastes landfilled on-site and off-site affected
by restrictions
Demand for present incineration capacity after
restrictions
Effects of deep well injection restrictions
Wastes injected in on-site and off-site wells
Demand for present incineration capacity after
restrictions
Effects of disposal impoundment restrictions
Wastes disposed in on-site and off-site disposal
impoundments
Demand for present incineration capacity after
restrictions
C-2
-------
Effects of restrictions on wastes-in-boilers
Hazardous wastes burned in boilers
- Demand for present incineration capacity after
restrictions
Addition of incineration-at-sea capacity
Capacities of individual incinerator ships
- Availability of total land-based and at-sea
incineration capacity
Effects of Superfund clean-up activity on RCRA capacity
Data needs and sources
Data analysis
Organic liquids likely to be listed as hazardous
wastes
Total estimated volume of organic liquids
Volumes handled by current management methods.
Note that each regulatory scenario analysis module estimates
the demand for on-site and off-site LOHW incineration capacity
under static supply conditions, that is, available capacity is
held fixed for this instantaneous analysis at the practical
maximum commercial LOHW incineration capacity level of 300,000
metric tons (minus 48,000 metric tons of 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
50«c
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
-------
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
-------
EFFECTS OF A DISPOSAL IMPOUNDMENT BAN:
MID-RANGE ESTIMATES CASE
OBJECTIVE:
To estimate on-site and off-site incineration
capacity utilization after imposition of a
ban on disposing LOHWs in surface impoundments
RESULTS:
On-site incineration capacity utilization
after ban = 52.1%
Off-site incineration capacity utilization
after ban = 288.2% of capacity
KEY DATA:
Total wastes generated =264 MMT
Percent of wastes generated going to disposal
impoundments = 7.2%
Baseline on-site incineration demand
(mid-range) = 1.253 MMT
Baseline on-site incineration capacity
=3.10 MMT
Baseline off-site incineration demand
(mid-range) = 0.139 MMT
Net baseline off-site incineration capacity
0.252 MMT
C-23
-------
KEY ASSUMPTIONS: 95% of wastes to on-site disposal impoundments
10% of wastes in disposal impoundments are
incinerable
50% of incinerable wastes are incinerated
61.7% of wastes incinerated are incinerated
off-site
Complete prohibition of practice
C-24
-------
INCINERATION CAPACITY UTILIZATION
LAND DISPOSAL RESTRICTIONS
DISPOSAL IMPOUNDMENTS BAN EFFECTS: MID-RANGE ESTIMATES CASE
DISPOSAL IMPOUNDMENT VOLUMES
TOTAL QUANTITY OF WASTES
GENERATED
264 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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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.
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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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