FIHAL REPORT
               Prepared for the.

     U.S.  EuvironiRental Protection Agency
          Office of Policy Analysis
               March 31, 1988

   This report was prepared by ICP Incorporated for the Office of Policy
Analysis ^. U.5. Environmental Protection Agency (EPA).  The survey was
conducted by Mr. Geoffrey Back, Mr. Janes Dickson, and Ms. Karen Doarschug.
The EPA Project Officer vas Mr. Son Benioff of the Office of Policy Analysis.

   We would like to acknowledge the cooperation of the firms that participated
in this voluntary survey and provided comments on the draft report. .The EPA
greatly appreciates their continued assistance.             *

   This report has undergone a limited review by the ETA.  Identification of
specific firms or technologies in the report does not constitute endorsement
or approval by the EPA.  Questions about the report, or suggestions on survey
topics <".nd/or other firms to survey, should be addres-ed to:  Mr. Ron Benioff,
Office of Policy Analysis, (PM-220), U.S. Enviro itnantal Protaction Agency, 401
K 5,-reec,  S.W., Washington, D.C., 20460, or to .Mr. Geoffrey G. .Back, ICF
Incorporated, 9300 Lee Highway, Fairfax, Virginia, 22031.

                              TA3L2 C? CONTENTS
               [[[ „ .      i


CHAPTER 1 .  INTRODUCTION .......................................... . .    1-1

   1 . 1  Background .............. . .......... „ ....................... ,    1-1
   1.2  Methodology .................................................    1-1

 „  1.3  Definitions .................................................    1-4

   1.4  Limitations .................................................    1-5

CHAPTER 2 .  INDUSTRY OPINIONS AND PREDICTIONS .......................    2-1

   2.1  T,Tasta "Volume Trends Were Mixed for 1985 through 1937  ........    2-2

   2.2  Traacmer.t of Solids and Sludges Still Saen as
        Principal Growth Market  .....................................    2-3

   2.3  r.ost Comnercial Firras Selievs that an Incineration
        Capacity Shortfall Will No Longer E:;isc Soon  ................    2-7

   2.4  '.-"I --an Offer Mixed Opinions on Other Mr-rket Ef facts
        ... 2 I.and Uans ................................................    1-1
   2.5  Cleanup Business Seen To lie Growing for Many  Firms,
        v.-at Cleanup Policies Will Decide futura  	    2-11

   2.6  :>)ccial Survey Topics  	    2-11

   3.1  These  14 Firms Operated a Total of 83 Facilities
        in  1986 and  1987	    3-1

   3.2  Firms  Surveyed Received 4.2  to 4.6 Million Wet
        Metric Tons  of Hazardous Waste in 1986  and 1987  	    3-3

   3.3  Reported Incineration  Capacity Has Increased
        by  98  Percent Since  1985'	    3-11

   3.4  Hazardous Waste  Prices Stabilized in 1986 and 1987 	    3-18

                              LIST OF EXHIBITS
1-1     A Comparison List of Survey Participants Since the 1981
        Update Survey	     1-3

3-1     Number of Hazardous Waste Management Facilities Operated
        in 1937 by All Firms 	•	     3-2

3-2     Selected Acquisition Attempts Within the Commercial Hazardous
        Waste Management Industry  . . . -.	     3-4

3-3     Volumes Received in 1935, 1986,  and 1987 by All Firms	     3-5

3-4     Comparison of Hazardous Waste Management Prices Quoted by
        All'Firms in 1985,  1986, and 1987 	    3-19
                                   - iii -

   Tne purpose of this report is to communicate information to  the  EFA as
supplied bjz_ the participating firms.  Analysis of the data  has  been limited
strictly--to interpreting responses and to aggregating the data  to avoid
disclose;e"of" confidential information.  Follow-up interviews were  conducted
whenever necessary to verify information, to request additional detail,  or to
discuss discrepancies.

   The snail number of firms surveyed and the need to maintain  the
confidentiality of the responses received means that no  specific information
on regional markets can be presented.  In addition, no statements can be made
about the antire commercial hazardous waste management industry from this
small sample.  However, the firms surveyed this year are believed to operate
ac least 70 percent of the com arcial facilities and control at least 40
p^rconc of the revenue.

   Expectations are that commercial thermal treatment capacity  for  hazardous
va:::.fes vill be r.dequata to meet demand by 1991 if not sooner.   Thermal
trs.'.t.jenc enp.icity among the 14 firms .-surveyed this year increased  by 98
percc-nt over the reported 1985 est5.mata  and is expected  to  increase by 200 to
300 tiarccn.t by the end of this decade.   This year, the majority opinion seems
to 0.3 thac inoir.^.ration capacity shortfalls ars not real or, if they do exist,
will be s'uorr-li :d as more permits are  issued between now  and 1991.  Several
fi.rr.t3 j>u<;go.;c a surplus in incineration  capacity now exists cr  will exist  by
ijS-J or 19°2 av.d. continue through the c,nd of ths C3nf:ury if the permit
a^pli.i.-.c.'-c^o already  in or soon to entsr the pipeline are  finalized fairly
quickly.  L'-ivccal incineration firms raport Chat their backlogs ar-s down  ""
.••.~'pr •>•-;.i.l:l; ••>... i rhit  thay are having trouble soaking up  incr^. '.sed capacity
   r.'-:--.ond.-inrs raporcid  sixteen T&'_J  fixed-based  incinerator unit project-,
nor,- c? l-,a r.diid to existing  facilities  arid 'a'ready  in the permitting
l>~.t; •>.j. L; 2,  thc.t i.iiey expect will inc'rsar.c kiln  c?pacity anywhere from 25 to 150
poccunt d3p«.nding upon the facility.   Tha  majority of thncj new or replacement
kilns had a thermal capacity  of anywhere between 50  and 150 million Btu per
hour.  Significantly, about ten percent  of the fixed incinerator unit projects
were reported by firms r.3t now in  the  commercial hazardous waste incineration.

   The move to increase  incineration capacity  has been a direct response to
the cumulative effects of several  major  RCRA regulations,  including the
various land disposal restrictions.  Even  so,  many of the commercial firms
report it is difficult to predict  market response to these regulations and
that frequently their predictions  are  wrong.   Part of the problem, these firms
report, is whac they feel to  be the  ever-changing rules and requirements under
which they and their clients  must  operate, and the uncertainty attached to
future regulatory decisions.  Prime  examples of  the  latter, they say, are how
hard EPA will push  for permanent cleanups  and  the use of on-site treatment
technologies at Superfund sites, and whether more land disposal restriction
variances will be issued and  current variances extended.  Survey participants

expect that future  land disposal restrictions and the move to more "permanent"
remedies will soon  require that most or all corrective action soils and debris
be treated, before land disposal.

   These firms also aduit, however,  that predicting trends and market response
depends ultimately  on an ability to  predict behavior, especially the behavior
of waste --generators .   Tor example, one must predict how quickly and strongly
generaf>rs^ will  invest resources in  waste minimization.  Many of the firms
surveyed report  that generators are  taking significant steps to minimize  their
waste volumes sent  to off -site treatment/disposal facilities.  One must also
predict the behavior of regulators  in enforcing the regulations and predict
how and when the current impasse in  siting new hazardous waste management
facilities will  be  resolved.

   A total of at least 4.2 million wet metric tons (WMT) of hazardous waster,
was received foe treatment and/or disposal in 1986 by the 14 firms surveyed.
This volume was  down 8 percent from  the adjusted 1985 Survey total of 4.6
million WMT (1935 total volume was  adjusted to exclude volumes for f i .7ns  not
participating in the survey this year and to reflect corrected 1935 results
providsd to IGF) .   In 1987, these same firms received a total waste volume  of
at lecst 4.6 million WMT, an increase of 6.5 percent over 1986.  Only the
vasca volume incinerated did not experience a decline in volume in 1986  as
compared to 1983.   Respondents reported that their volumes incineraced
increased by 30.5 percent in 1986 over 1985 (adjusted).  Waste volumes  sane to
clasp wall  injection in 1986 experienced the largest decline  (-34 percent).

   Tu3 d<2'-lins  across nest of the technologies in waste volx-ties handled in
1?°>6 VMS i.cj/ersad  in 1937.  Again,  the voluraa of vast's incinerated experienced
tha l.ivsesc growth  "in volume (36 percent) ovec tha reported  total for  the
previous year, but  volumes sent to  rer>ot'.rc3 rscovary also wont up
       icjiatly  (25 percent:).  Waste  volumes sant  to landfills  or wastf-;wat?.r
       v.it  facilities both rose by about: 5 percent: in 1937 versus 1935.   T,-'as^2
       s sent  to  comiaercial injection wells increased by less  t.ian 1  norcaat.
       volurr.e managed in 19. .1 by technology for the 14  firms  surveyed is shown
       r.r =c.t^
       be lev/ .
                                                    1 0.4%
Total Volum* = 4.3 Million  WMT
                              6 0%
                                                              "r^ Incirnration

                                                              3b Landfill /1
                                                              Lj Rasourca P.ecov»ry
                                                              C3 Daep Well Injaction

                                                              O Chemical and Biological
                                                          54 2%
       (Note:  A total of 75 thousand WMT of waste  was  reported a stabilized and/or
       solidified in 1987 by  these firms and has been  counted in the volume
       landfilled estimate.)

   Market services listed by respondents this year as growing,  static,  or
declining business areas differed little from their listing for the 1985
Survey.   Once again, the incineration of solids and sludges was mentioned
consistently as a clear growth market for the commercial waste management
industry. _^ Close seconds in the growth market category were the various site
remediation/field services (remedial cleanups, UST cleanups, drum management,
mobile treatment, and lagoon closures), waste minimization consulting
services, snd-various pretreatment technologies like sludge dewatering and
waste stabilization and solidification.  Their candidates for service markets
in decline were deep well injection, PCS liquids treatment and disposal
(peaking by 1990), treatment or disposal in surface impoundments, and land
treatment.  Most respondents predicted that the future of surface impoundments
or land treatment is "bleak" and that these technologies will be stringently
regulated or phased out.  Otherwise, opinions differed on nearly every other
market or service sector: secure landfills, fuels blending, chemical'and
biological wastewater treatment, and solvent recycling.

   There was significant movement in service prices i i 1986 as reported 1y
these 14 firms.  Quoted px'css for some services in 1986 increased as much as
174 percent (oil recovery),  whils prices for other services decreased by 54
percent.  In 1987, prices £ pear to have steadied for some services.  The
avarags nominal price increase for chemical and biological treatment, deep
well injection, transportation, and PCS incineration services rose less than 5
percent over their 1986 levels.  The average nominal price increases for other
waste management services was somewhat greater:  10 to 48 percent for
laruij'i Is; 13 to 34 percent for incineration; and 16 to 97 percent for
L'ssouroa recovery.

   respondents were asked for their comments on a variety of special topics.  .
The majority of firns surveyed believe that most roii'mercial waste manage :ent
finis co not yet have adequate capacity to perform the Toxicity  Characteristic
L^aLr.Jrig Procadure and may not be able to develop arequace capacity  in time.
If the capacity of commercial laboratories to ;arform the test is considered,
however, th--:se firms believs any potential shortfall in testing  capacity is
liksly to be small.

   As to the presenc availability of liability insurance, raspondents noted
that, in general, the availability of liability insurance "is no longer a
problem if you have the money to pay for it."  When asked if they had heard of
commercial firms being apy'oached to operate fixed, initially aedicated,
treatment or disposal fac^_ities at a generator's site, six out  of the eleven
firms responding to this question had never heard of this type of service
arrangement.  Five firms, however, had heard about the idea and  two  firms
reported they had held discussions with three generators though  all  were
unsuccessful.  Still another firm reported a different twist on  this idea:
generators had inquired if the commercial operator would build and operate a
dedicated, off-site waste management facility that would not go  commercial.


                                  CHAPTER 1


   This is the seventh year the U.S.  Environmental Protection Agency (EPA)  has
sponsored a survey of business activity and trends for selected firms in the
commercial hazardous waste management industry.   This survey examines calendar
year 1986 and 1987 for 14 firms,  and follows similar surveys completed
annually since 1981.^

   Each survey is designed to keep EPA aware c? industry's concerns and
developments in Che commercial hazardous waste management market.   For this
year's survey, EPA was interested in these firms' assessment of whether there
are existing shortfalls in commercial hazardous waste management capacity,
especially for thermal treatment.   The data collected through this survey are
expected to prove useful to the EPA in evaluating possible impacts of RCRA

   Office of Management and Budget (OMB) approval of the commercial industry
survey was obtained this year.  The OMB information collection request form
approval code for the survey is 2020-0017.
   The fir.  : industry survey in 1930 was a census of as many commercial
hazardCMS w<.sta management firms as could he identified from service
     t-'Vlas and other sources.   Tne subseqtJnt update surveys of 1981 and
       Raview of Activity of Major Firms in the Commercial Hazardous Waste
     -.'iaenc Indust./:  1981 Update.  Environmental Protection Agency.  Prepared
by Eooz, All .n and Hamilton, Inc.  May 1932.

    Review of Activity of Major Firms in the Commercial Hazardous Waste
Management Industry:  1982 Update.  Final Report.  Environmental Protection
Agency.  Prepared by Booz, Allen and Hamilton, Inc.  August 1983.

    Preview of Activities of Firms in the Commercial Hazardous Waste Management
Industry:  1983 Update.  Final Report.  Environmental Protection Agency.
Prepared by Booz, Allen & Hamilton, Inc.  November 1984.

   Survey of Selected Firms in the Commercial Hazardous Was>:e Industry: 1984
Update.  Final Report.  Prepared by IGF Incorporated.  September 1985.

   1985 Survey of Selected Firms in the Commercial Hazardous Waste Management
Industry.  Final Report.  Prepared by ICF Incorporated.  November 1986.


1982, however, concentrated on interviewing just the top nine firms^ based on
industry data_collected during 1980.

   For th_ar"19"83 and 1984 update surveys, the list of interview candidates was
expanded to. include "major firms" on a technology-by-technology basis.  This
approach was  followed in developing the survey candidate list for the 1985
Survey and again for this year's survey.  Exhibit 1-1 has been provided to
help track survey participants since 1981.

   Out of the 18 firms selected as candidates for the 1986-1987 Survey, the
following 14  firms agreed to participate and responded to all of the survey

   •    Chemical Waste Management;
   •»    Browning-Ferris Industries/CSCOS International;
   a    GSX Corporation;
   «    Rollins Environmental Services;
   *    ENSCO, I ic. ;
   •    Envirosafe, Inc.;
   a    U.S.  Pollution Control, Inc.;
        Chera- Clear;
   a    Kavir-'.te;
   •i    I'.oss  Incineration;
   «    I-'.iivij. inmental Waste Resources;
   •:    V.J.  Laiiiberton/Chemical Resources, Inc.;
   ".    Saf3ty-Kleen; and
    !    Systech.

T-JO firr^s, International Technology  (IT) Corporation and DuPoat Environmental
S^rvicas  (D2J), chose not to participate in the  1936-1987 survey.   U.S.
Ecrlogy, a participant in last year's survey, agreed to participate again this
ycc-ir, but could not complete the survey in ti:ne  for inclusion  in  this  report.
All trhr.. *i f .:.rras, therefore, are not represented  in this year's resulcs  and
h-.vs bf-r. brickad out of the results for the 19-35 Survey in  order  to isolate
tae trua year-to-year volume and capacity trends.  McKesson Envlrosystems,
also a participant in last year's survey, is still included in  the  survuy as
their operations were acquired by Safety-Kleen.

   Firms were interviewed by telephone or provided written  responses
concerning four general topics:

        •     Wastes managed, by technology and type, in 1986 and
     ^  In  the  1981  and 1982  Update  Surveys,  these  nine  firms were:   Chemical
Waste Management, Browning-Ferris Industries,  SCA  Chemical Services, Rollins
Environmental  Services,  IT Corporation,  US  Ecology,  CECOS International,
Conversion Systems,  and Chem-Clear.



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        a _r_ -Capacity, by technology,  in 1986 and 1987;

        a -  Prices chared, by technology and waste type,  in 1986
             and 1987; and

        B    Views of the hazardous waste management market and
             significant business or regulatory trends.

Participants were provided with a list of questions prior to the interview and
were asked questions applicable only to their operations, or that were
consistent with established confidentiality agreements.  . Responses
to each of tha questions were compiled and are presented in the agj^regate to
avoid disclosure of any company's response, unless the information was already
available to the public (e.g., number of operating facilities).
   Considerable ti:ae is spent with each respondent explaining and defining
tanas used in the survey that readers also should keep in mind when
interpreting the survey results.  For example, in the update surveys through
1982, commercial facilities. wera defined as those "engaged in the treatment
and/or dir.po 'si of hazardous waste for a fee," buc did "not include recovery
operations ... or storage and transfer stations."  This definition was changed,
starting with the 1983 Update Survey . to include recovery operations and
Uransear stations.  Also note tnat a firm does not have to be en^-ged solely
or principally in the treatment and/or disposal of hazardous wartas for a fee
to be considered commercial.  That is, a facility that is dedic---ed mostly to
handling ^ generator's own waste (from a single or several production plants),
but prC'C2ss*is some wastes from other generators for a fee, can be considered a
       ciai" facility for this survey.
   One of the more important terras used in the survey is "effective capacity"
(along with the instructions given to firms on calculating and reporting
capacity information).  Initially, each firm was asked to calculate their
"effective capacity" finn-wid.; (by technology or service offered) accounting
for such factors as downtime for repairs and maintenance or limits imposed by
on-site storage capacity or discharge permits.  Each firm was also able to
provide capacity estimates in the units they prefer to use, for example,
millions of Btu per hour for a. rotary kiln incinerator or gallons per day for
a chemical treatment facility.  As is discussed below, 1CF staff then worked
with each firm to convert their estimates into a common unit of measure:
metric tons per year.

   Several technologies/services are given special attention in developing a
consistent definition of "effective capacity" due to the potential for


misinterpretation.  One such technology is secure landfills.   Different
comu -,rcial__firms in the survey prefer to express landfill capacity solely in
terns of the _air space volume remaining in the cell they are operating
currentl/.;~as. the number of years left of permitted air space for disposal
assuming current fill rates, or as the total volume of air space available
assuming they are able to develop and permit (in accordance with all state
and/or federal requirements) all of the land area they plan to commit to
landfilling operations.  Using each of these measures, however, generates a
very differ-at picture of available commercial landfill capacity.  The most
conservative estimate of available capacity would b^ one base'd upon the
remaining air space in an active cell since there are no assurances that
additional cells would be permitted for construction and operation.
Alternatively, the total land area-based measure provides the best estimate of
potential capacity for the disposal of wastes and treatment residuals.

   To date, most of the landfill operators participating in the annual survey
have calculated landfill capacity estimates using the total land area measure.
As a result, this measur ; has been chojen as the standard form for each firm
to report their <  Mamerci.il landfill capacity, i.e., with some firms, ICF staff
must discuss converting a alternative c-ipacity measure to the selected total
land area measure.  ICF staff also convert the total land area-based capacity
e- riraates to a single remaining lifetime estimate (in years) assuming the
total curr .at anr.ual fill rat.; reported by these firms.

   1C? staff also had to disc-iss conversion methods in order to standardize a
response with EPA's preferem.  that capacity numbers be reported in mass
throughput units (see Appendi.: A for several conversion factors used).  For-
example, incineration capacity estimates reported in millions of Btu per hour
vera conve "tad to metric tons per year units using factors for the average I>tu
per pound of waste and number of operating hours per year.  Each respondent
was given the opportunity to choose conversion factors they believed to be
applicable to their operation.  Each firm, therefore, may have selected a
different conversion factor.

   Appendix B lists several other terms and their definitions as used in the
report or as communicated to participants as guidance ir. developing their

   The purpose of this report is to communicate information to the EPA as
supplied by the participating firms.  Analysis of the data has been limited
     -1  Another technology for which alternative capacity estimates were
debated included wastewater treatment where firms could express capacity as
either a hydraulic capacity, as a function of tank storage capacity, or as a
function of permit discharge limits.  In this case, firms were asked to
standardize their response on the basis of hydraulic capacity.

strictly to interpreting responses and to aggregating the data to avoid
disclosure^ or" confidential inform?uion.   As such,  the accuracy of the
information presented is a function of the respondent's understanding of the
questions asked, the accuracy of the data they choose to provide, and ICF's
interpretation of their answers.  Follow-up interviews were conducted whenever
necessary to verify information, to request additional detail, or to discuss
discrepancies (e.g., waste volumes reported handled exceeded the reported
effective capacity).
   The small number of firms surveyed and the need to maintain the
confidentiality of the responses received means that no specific information
on regional markets can be presented.  In addition, no statements can be made
about the entire commercial hazardous waste management industry from this
small sampla.  However, the firms surveyed this year are believed to operate
at least 70 percent of the commercial facilities and control at least 40
percent o£ the revenue.

   The detail of the responses received varied.  Some firms provided
consider ble detail in their responses while other firms did not.  As a
general mla, the least detailed response controlled the degree of detail
presented from responses to any individual question.  Relative changes in the
survey results from year to year, therefore, may also reflect the quality of
responses received in any one year, although this variability cannot be

   Ensuring comparability with the results of earlier surveys is a prin'.iry
concern for each new survey.  There were generally two sources -of
comparability problems this year: (1) differences in the participants list
from 1985 to 1986-37, and (2) firms' modifying earlier survey responses due to
reporting errors or miscalculations.  Of these two, the first had the greater
impact and raquired adjustments to the analysis.  As noted earlier, the
absence of IT Corporation and US Ecology (both members of the original 1981
"major" finas group) and DuPont Envir -amenta! Services in this year's survey
was compensated for by not including past estimates for their operations in
the results shown for the 1985, Survey.

   ICF attempts each year to improve the accuracy of the survey  results.  For
example, we have invested more time  in providing specific guidi.nca on defining
effective capacity, and in reviewing capacity data and assumptions in the
interview.  The result, we believe,  is at least a better understanding of
participants' responses, if not a more accurate picture of available capacity
among these firms.  We also provided each participant with a  summary of his
1985 response on waste volumes and effective capacity by technology.  We
received "corrected" data for 1985 in two cases.  As a further  check, we
contacted each  firm to confirm or correct a significant  (50 percent or more)
increase or decrease in their 1986-1987  results over 1985 for waste volumes,
capacity, or both.  Discrepancies between waste volumes reported received and
capacity in 1986 or in 1987 were  also investigated  and resolved.

   Users o£ -the survey reports are advised to use caution in interpreting the
results. 'JJhile every attempt has been made to ensure the daca are reported
accurately and are reasonably consistent from year to year,  there is a
potential for" error and misinterpretation, especially with respect to the
capacity-related data.  Changes in definitions and assumptions over time as
well as in a respondent's efforts to provide accurate data must be considered.
   The remainder of the report is organized into two chapters.  Chapter 2 --
Industry Opinions and Predictions -- presents largely anecdotal information
supplied by survey respondents on such issues as permitting delays, the
reality of capacity shortfalls, siting difficulties, and the expected market
impacts of the R.CRA land disposal restrictions.  Also covered are the views of
these commercial firms on business trends in their industry including probabla
areas of market growth and decline.

   Chapter 3 -- Waste Volumes, Capacity, and Prices -- highlights trends in
the waste volumes handled, capacity by technology, and prices among all the
firms surveyed, and compares reported results for 1986 and 1985 (adjusted) and
for 1937 and 19S6.  Acquisitions and service expansions by these firms are
also discussed.


                                  CHAPTER 2

   Predicting future trends and market response to major market-shaping
legislation and regulations is even difficult for firms in the commercial
hazardous waste management industry.  Part of the problem, ev.en given the
resources some of the firms commit to market research, is the absence of
reliable or usable data on waste volumes and types generated as has been noted
in several recent studies by OTA, GAO, and others.  Several efforts are now
underway to improve data content and collection through the regulatory system
that may improve the value of these data for market research questions.

   Another part of the problem, these firms report, is what they feel to be
the ever-changing rules and requirements under which they and their clients
must operite, and the uncertainty attached to future regul ,tory decisions.
Prime exanples of the latter, they say, are how hard EPA will push for the
permanent cleanups and the use of on-site treatment technologies at Superfund
sites, and whether more land disposal restriction extensions will be issued
a~id current extensions extended.  Anyone who could answer these questions with
a fair degree of certainty v«ould settle some key variables in the strategic
planning equations of commercial hazardous waste firms s\i"?lyi-nS either  (or
both) "live stream" waste management services or site remediation servicr.s.

   These f'.rms also admit, however, that ultiuately the key to predicting
trends and narkat response is the ability to predict behavior, especially the
behavior of wascs generators.  For example, one must predict how quickly  and
strongly generators will react to regulatory, economic, and liability
pressures towards investing resources in waste miniuization.  Kany of the
fij..:.s survt ^d this year report that they can see direct  and. increasi".?;
ev'-Jenco of "asta minimization by generators.  One must also predict the
behavior of regulators in how stringently they enforce the regulations (e.g.,
pretreatrcent requiremercs for wastewater discharges) and  predict how and when
regulators, politicians, interest groups, and the public  will resolve the
current impasse in siting new hazardous waste management  facilities.

   Against this backdrop then, this chapter sumraar • .zes the opinions and
predictions of the firms surveyed as to market trends, regulatory concerns and
developments, and a variety  of other issues.  The information provided in this
chapter is largely anecdotal and as stated by the firms interviewed.  Both
consensus and minority viewpoints have been presented to  the extent possible
without violating confidentiality arrangements.  The topics covered in this
chapter include:

        •    General changes in waste volumes and types between 1985
             and 1986 and 1986 and 1987, and changes in the balance
             between on-site and off-site waste management;

        •    Observations on growth markets and factors  affecting
         __ -commercial firms'  ability to respond to market growth;

        *-   -Commercial firms'  perceptions of the reality of
          "  rapacity shortfalls,  their plans to expand  capacity,
             and comments on the federal role in facility siting;

        •    Observations on the market effects of various land
             disposal restrictions;

        •    Handling of Superfund wastes and the market effects of
             the SARA amendments and RCRA Corrective Action
             regulations; and

        a    Viewpoints on several special topics, including the
             capacity to perform the TCLP, the availability of
             liability insurance,  servicing small quantity
             generators, and the emergence of the "quasi-
             commercial" waste management industry.


   The ability of firms to retain or expand their throughput was highly varied
for the period of 1985 to 1987.  Many firms were able to expand their
marketing efforts and attract additional wastes to new or existing facilities.
Voluntarily-imposed restrictions,  regulatory suspensions, and permit
limitations, however, caused an overall decline of 22 percent for waste
volumes handled in 1986 as compared to 1985.  This decline was only partially
made up by the 13 percent increase in waste voluie between 1986 and 1987.

   Eleven firms experienced increases in waste volumes received.  One firm
attributed its increased business to their participation in a rapidly growing
market:  disposal of clean up wastes.  Six of the firms  attributed their
growth to their ability to handle more of the available  waste types because of
increases in capacity  (by construction or acquisition).   Two firms attributed
their growth to better marketing,  including new sales offices to service a
widar geographic region.

   A common thread in  the survey responses is that the amount of "clean"
wastes, especially easy to treat aqueous wastes and the higher Btu-content
liquids, has either declined overall or is less available because of
competition for these wastes.  Incineration firms increasingly emphasize the
need to be able to handle wastes with higher solids, but lower heat content.

   Several companies claim that generators of aqueous wastes, particularly the
larger generators, are moving  increasingly to on-site pretreatment to reduce
the volume of waste sent off-site.  Other trends noted were more in-house
solvent recovery, on-site incineration, waste minimization efforts, and waste
solidification.  Most  of the firms believe that the move to on-site treatment
will be lead by the larger generators who want  to  exercise greater control


over the destination of the waste and avoid potential liability.  Larger
companies are also believed to be able to treat their wastes at lower overall
costs.  OiTe firm remarked, however, that generators are still not very
inter este_d-~lri waste delisting, and foresees that they will still need to use
off-site services to dispose of their waste solids and treatment residues.
Most firms expressed the belief that the smaller to mid-sized generators will
make greater use of off-site waste management services in the face of costly
regulatory requirements.

   Three firms suffered major declines in the volumes treated and disposed
because of voluntary limitations on the amount or type of waste they were
willing to accept.  One firm elected to stop accepting wastes containing any
concentration of F001-F005 wastes and also stopped accepting used oil
containing hazardous wastes.  Another firm has chosen to reserve all of its
available chemical treatment and a portion of its landfill capacity to service
its own needs for incinerator ash disposal and leachate/rainwater treatment.
A third suffered a contraction in the volume of wastes from remedial action
sites when it elected not to deeply discount its service prices.


   Market services lisced by respondents this year as growing, static, or
declining business areas differed little from their listing for the 1985
Survey.  Once aguin, the incineration of solids and sludges was mentioned
consistently as a clear growth market for the commercial waste management
industry.  Close seconds in the growth market category were the various site
remeaiatior./field services  (remedial cleanups, UST cleanups, drum management,
mobile trsacaenc,  and lagoon closures), waste minimization consulting
services, and v

Moderate  growth  in  on-site  wastswater treatment services ,  especially on a
regional  or local scale,  was expected by some firus uostly in response to
t'.^htsTiing categorical pretrsatnent standards,  ifot ail  firms agreed with this
assessuftn.Cj however,  labeling aqueous treatment services  as a declining market
overall, -g£V?n vh?it they view a3 little enforcement of the pretreatmenc '
standards ,_ although they expected their market share to  increase.   Smelting
for the recovery of mixed metals from sludges was also mentioned as a likely
growth area.

   At le  st one  respondent  mentioned the following services as among their
candidates for growth markets:  in-hcuse solvent recovery for waste
minimization; the burning of waste fuels (moderate growch) ; secure
Irndfillin-^;  the incineration of ?C.Ti sludges and roils from waste site
cleanups; services  to small quantity generators; and waste collection,
brokerage, and transfer in  some regional markets.  As will be discussed below,
several othsr firms viewed  some of those markets as flac or in decline.

   ? JI-lilLS_LllllS£L£l •   There was no consensus among respondents as to the static
rark°. ; areas.  One  respondent believed fuels burning fall into this category
predicting that  volMiaea vo'.ild stabilize and that thara would be a lot of
excijis capa'lty.  Another respondent labeled the vastewatsr treatment market
«-is "at boat,  flat"  because  any growth due to local tightening of pre treatment
standards would  be  short-lived.

   r?-CO.J^.-?:&J;\L'c3-.tIS.-  Mo . C respondents continue to predict the decline of
~,ur.:.,c.i iiapouric' .ian~ j , land  tre.4t.aant, aad dasp well injsction demand and
c'lp-jc.-.r-y.  A  :T"'T firms are  more upbeat on tha fuc'jre cf  deep well injection,

<:' £it. •'.•;.••> a  c.\i=-rcc :.uj.   The trea^'nnant and disposal  o.i  .1JCIi liquids is projected  'o
.-r.ii'.c '-y .1 'fO  rw.i d.icline rapidly tharaaf-dr.  0-3.'"-.-:if.-j Lolvaat recovery,
r.:.~ "j i.-.il v  for iuilogcr.atsd organic solvents, was  ii.--.:^d by one respondent In
t.V'..- c- .-. :. - < v,--' dues t:c the impact cf generators sub 'Ji..'. cut ire other solvents or
tr.i:i T:; .;c ._,;•;  tu  rfitovcr their solvents oii;ita.   iV.als  blinding was also li • ;ad
I.-? r.-?  '•£>.-• iDri'Jr., it an a declLnir^ norkat ir.  tliy facn; of increasingly cora
r.c -..'.- ,-. .c  .-Cjjulr.cior.s end d'1^ to competition f'ccnj -ch.3  "CS.\ incinerators L'^r
t'.,d l.i^a--vC-i  v/asts liquids to support combustion of the low-flfu waste solids
ci.d sluLg.-s.

   One firia was  particularly confident that the  total  liquids treatment market
has declined  sinca 1985, even though this firm had  increased its market share
competitors failed to get Part B permits or had  to  close temporarily.  Tais
firm believes that enforcement of pretreatment standard -j under the Clean Water
Act could slow  the decline in the liquids treatment market by forcing more
small- and medium- si : ;d generators to discontinue discharging into sewers, but
does not  anticipate the rigorous enforcement needed to completely offset any
general decline  in this market.

   Much as  was  the case in the 1935 Survey, the  future of commercial sec  ce
landfills is  viewed very differently by many of  these  firms.  Some firms
believe that  waste volumes sent to landfills have declined and will decline
even further  as  a function of waste minimization and the effects of land
disposal  restrictions.  Some firms have even imposed commercial waste volume


limits on their own landfills to preserve air space  for handling treatment
residvls (^.g., incinerator ash) from their other facilities  (or from other
units  c the. ^arae facility) .  Some respondents in this group also believe that
EPA wi.Q Hot extend the CERCLA/RCRA soil and debris  variance from the land
disposvilji'estrictions and '..'ill push successfully for on-site treatment at
Superfur.d .sites (both opinions, however, were contestad by other firms).

   Not all the firms believe the volume of waste landfilled at commercial
facilities will go down, however.  Their view is that site cleanup wastes will
still need to go to off-site landfills, and that waste stabilization and
solidification will prove acceptable to regulators as treatment for many
wastes leading to greater waste volumes sent to commercial landfills.

   Most agree, however, that landfills will play and have  begun to play a
different role in the waste management system.  Asked whether  they see secure
lane'..-illj solely as "residual repositories", most respondents  said yes,
particularly if waste stabiliz .cion and solidification is  counted among the
treat  ;nt technologies.  Other firms did not agree that secure landfills would
rolcl  function as residual repositories in the future believing that some
haznrcous vaates will meet  the treatment standards without any treatment.

   Ab•'. 15 -.y to Respond_ to__M.-'r1  »t Oco^th.  There has been little change also in
the "factors respondents li^t as limiting their ability to  respond to market
frovtlv -- paraiitting delays, program authorization "flip-flops", regulatory
c.Dn:;t.raI'ir.3 arA uncertainties, public opposition to  siting or  expanding
f ici'L if'.a-,.   Now men-bars to tnis li pc (provided "by one or  more respondents)
•:=JH: tlLi'.: Lcul ies in obtaining financing; complications  i'.i developing new
t -ciinolc^i-iS in the face of changing regulations; the CliRC-A program's unclear
ri&i-.j.\r, en how often on-site treatment technologies  will be selected as part
u.  tiia '.i'.ij remedy; regular.oirs' vnvilliiigness Co act in l::ss  thrn black and
v'.i.Lt£ slLxMtions; and the difficulty of predicting or modsling mark at
r-'Tcticv..-' co the land disposal restrictions.

   Ha <;M ::•-'„ .t" were nlr.o ,.":VM r^ec-'.f ically if any short.-.ga of hazardous or
r.onha;.c.rclou^ lancfill capacity \\-.<\ uee:i a limiting facto?:  for  growth in w?.sti
tr^at'Jient Cervices.  No finrm re-por':ed that hazardous waste landfill capacity
was a irrobiea (although a few hac t.iken steps to ensure that it would not
become a problem), and  only one firm said that shrinking norihazardous landfill
capacity had affected their tre-.trnent operations.  A few  firms did s?.y that
the bigger problem -;as  finding a well-designed and well-operated solid waste
landfill they could approve for use.

   Most firms downplayed the significance of  solid waste  landfill capacity
problems for hazardous  waste treatment firms  for two reasons.   Fi-st, some
firms believed that the competitive disadvantages of treatment services that
produce a delistable residue  (e.g., restrictions on  influent waste
characteristics) would  keep many firms out of this market  in the first place.
They see most firms treating wastes only enough  to send  the residue  to a
hazardous waste landfill.   These firms also believe  that  the value of
delisting will decline  as solid waste landfills become  subject to more
stringent regulation.   Second, several firms  expected that a firm producing a
delisted treatment residue  can afford to offer  the highest bid for limited


solid vante landfill  capacity.

   Perruit*: 1^3. delays  of 3 to 6  years or more were mentioned  by many
r2spcr.dsr.-t-T_ as the  single greatest factor limiting their  ability  to  serve
growirg ox nev iiarkets.   While  some were willing to acknowledge tha  technical
    ] exity-oir the permitting process as a factor in the delays, most blamed
       ate stace penr.-' t program resources, lack of state  and federal agency
coordination,  differing state and federal interpretations of the  same issue,
or high staff turnover  as the sources of the problem.  Opinion was  split on
whether EPA or the  states were  slower in rssponding to permit applications, or
firms saw  little difference between the two.  Several respondents felt the
lack of activity on their permit applications was a function of  the  lower
perMil: ting priority of  their facilities relative to incinerators  and'
landfills, and because  of a shift in priorities to monitor closing  facilities.

   It: vrs  also cl^ar, however,  that there have been iraprov -  -ants  on the
P'irv.i. c-c"'.n.3 front for  several firms.  Some firms have rcachi  i the  draft permit
rc.ije in less than  a  year-and-a-half from permit application; in  some cases,
i *\ li£;.-: than  one year.   Several firms expected final permits sometime in 1983
;"ii;', one facility in <. ir survey has received its Part B permit. A  few firms
rt'.-arked that the permitting process seams to unfold more smoothly  for a new
'.aoilir.y as opposed to  changes  to an exiscing facility, provided  a  new
fr.ci'.xuy can  get through the initial siting proc.. is.

   Hi. porder.t:. vjr'i also askad for their opinions on whether the;  new rules foe
-fv.-.il : noJi Fictions  and transportable tr a fitment "nits represented an
1- "•pir'-.v ae.T. ia choir  ability, to respond t.o narke   :hang«?~ ard growth.  In
^•j-.^r-l, uojt ficris exprassed s. wa:'c-and- as att_   '3, although  several we-ra
uo;j p.jTlcive about: the pernit modification rule o::  fait  the urocess had to
 ;,..• h:;-.'_ri'- 'o.;f.^..i,a  it couldn' C got a^.y wor^sa.  Tl:2 In-^itAtio.i .T^aui.i tu stea
C"'-r. thd (-oncari  ch t implementation of the ru].es will not live  up  to their
f!j;r d --,!••• on p^per.   j.n particular, se-/oral fir-.as bel.ieve  tha- 7,?A and/or the
c'u;... •)-•:' "ed rjt.vtns vill  not ba as flexible as Lhe rials "Langl.u'2e  S'i'ms to inply,
,'..•.   L.'.i til^ct. r.o ta  tioi"'.: strinr  ^nt.  OthoT fiiTac beliove that  scstes will
c,T.i".'..-Ai.; to label  /.'acilicy modiricctior.s ixast'.Kd to raapord tn market changas
f-.a ra.-.jor Codifications  and, therefore, subject to the  full-blown permitting
p i.' 0 C 3 . j S .
   ^ill  th  firas wers also asked for their  a^-rice on the possible roles of the
f -?dii'al gove^ iment towards resolving the  prer, -nt impasse on siting new
fc.cili-iea.   V7hile none of the firms appeared  to believe that much could be
done  until the  situation reached the crisis stage,  some firms did offer
suggestions.   Suggested roles for the  federal  government included: more
aggres  ive public education and outreach  programs;  strictly enforcing the
adequate capacity demonstration requirement under SARA; encouraging states to
control the siting process at the state level  and on the basis of technical
criteria only;  encouraging generators  to  open  up dedicated TSDFs to commercial
use;  and withdrawing RCRA program authorization in states that enact waste
import  bans.   Many firms expressed disappointment over what they view as the
very  limited success of state facility siting  commissions.

                                                            /"* "\ "O A /*~T*T**r **T"t/'*'*l • '"*•* T "'
                                                            CAPACXi/ SM.->I_.. 

disposal and the selection of BDAT for these wastes; (c) whether EPA will
continue to string out some of the variances frcra the land disposal
restrictions.;, (d) how stringently cement and light aggravate kilns and
industrial.boilers are regulated; and (e) how aggressively generators pursue
waste minimization.  In particular, respondents express considerable
uncertainty over what EPA will select as BDAT for the CERCLA/RCRA.soils and
debris and for complex cyanide wastes if these are banned from land disposal.
If incineration is the only or one of several BDAT options, some firms predict
a considerable shortfall in incineration capacity.  Other firms feel that a
move by EPA to scring out the effective dates of the land bans will have a
chilling effect on investment in new incineration capacity and might generate
a capacity shortfall.

   Several firms stressed that they have been able to detect clear evidence of
gains in minimizing waste volumes by generators.  This evidence has come in
the form of handling even larger volumes of solid and sludge wastes and or as
an overall decline in waste voluiT.es shipped off-site for handling.  They
pre<  ,ct that this trend will continue and may negate or softan the impact of
increases  in the demand for incineration services when land ban extensions
expire and che pace of waste site cleanups accelerates.  The market effects of
expiring land ban variances will, however, vary by region cf the country with
tha tfesc: Coast and the Northeast likely to expariance any capacity shortfalls
sooner than the Midwest, Gu] ' Coast, and Southwest.

   Cn the possibility of capacity shortfalls for other tachnologies, survey
respondents had a variety of opinions.  Firms commenting on .the adequacy of
secure' landfill capacity believen that enough capacity exists for  the  next  10
to 15 yv.rs.  Reservations T.-7ere  expressed by thes-2 firms over the pace of -
p--.iT;iitt •' g for new calls and over the inability to site n=».w  facilities.  Som?.
.•cvuoruir-j'icr also mentioned that  "vild cr.rds" In their analysis were  EPA's  or
.i-iat:;s' Decision on the status of municipal waste incinerator ash  and
petroieiiri-cnntaniir.ated soils from U3T cleanups as hazardous wastes,  and the
s.c'-.: i  loliity of land treatment  for oily sludges.  Cther technologies/services
.".•_...  ttS'i  .'s subject to shortfalls in available couioierclal capacity  on either
c. r^ciovivicle or regional Lasis w?-"»: solvent recovery,  aqueous wastewatsr
treatment, and stabilization/solidification of drumm*d wastes.

   The specific expansion and acquisition plans mentioned by  respondents
mirrored their individual views  of growth markets  (see  Section  2.2)  and
capacity shortfalls.  Factors notad by respondents  as significant  in their
plans to expand included:

        •    Increasing demand for commercial waste  management
             services in general and in  particular  off-site
             incineration services, especially  for  waste  solids  and

        M    The expanding  site  remediation and UST cleanup  markets;

        •    Soon-to-be-issued final permits  for  several  of  their


        K    Decisions to enter new markets based upon perceived
             profitability and/cr declines in their historical
         __ -service markets;

        JL~ .An interest in providing more rounded, full-spectrum
          -  -services; and

        *    Forestalling competitors' "greenfields" projects or
             capitalizing on name recognition and business  success
             in particular regions of the country.

Very few acquisition plans were noted by respondents; most  of the service
changes would be brought about by expanding at existing  sites,  although
several "groenfiald" projects were also mf.ationed.  Growth  through
acquisitions vaa noted as likely to be significant, however,  in cases  of noa-
TSD pernit-basp.d service companies offering site remediation  services,
asbestos abatement services, waste minimisation consulting, and mobile on-sit;
treatment units.

   Several survey respondent • not=>d that their efforts would  continue  to
uxp^nd existing landfill capacity by opening new cells meeting  RCRA standards.
rui:;y would ?lso be continuing of cores to pace the rat3 ^u vhich they co '..sums
t.he.ir available air space.  A faw firms reported plans to expand aqueou. and
che-iicAl trn.~tr':ent c^pacity by 50 to 100 nillion gallons per  year fin-  Ida.
f'-iv :::••.! fir.tr, olra-ji^d to add :;igni.JTioant capacity for stabilizing druimed
    •;.; au wcl  as considerable drxrj and tank storage capacity at all or tuosc
    .:eLr exiscing situs.  Other sfiivic.js slated for axpan.sioa by some  firm-
     .;4d:  .oolvcr.t recovery, a variety of servic s for small quantity
     .ics-:c>, .Tujls blending ar.d/or burning, and deep well injaction.
   "e-ipo.:da:it3 T.  ;rs asked sevsr.al quostions  about  the  impact of land disposal
ins :rictLoas on the future of various  land disposal  technologies.   The^e
qur ;j'.ons included:  how EPA should approach possible  land disposal
rsscrictions on RCHA and Superfund corrective  action soils and debris;,  thft
future of land treatment and surface  impoundments; whether the land disposal
bans had altered the timing for when  permit.: would be  pursued, and whether
many or f •/ commercial land disposal  facilicies will be able to meet ,a "no
migration" standard.

   Reaction to whether there has been market effects tied to the land disposal
bans outside of the growth of incineration services, so far, has been mixed.
Three firms said they, have seen no changes,  and anticipate little or no  effect
in the future.  Two of the firms believe  that  the  effects of the bans will
continued to be delayed, either through a regulatory extension or by lack of
enforcement.  Five firms, however, had either  altered their own plans (or had
seen generators accelerate their plans) to use or  develop alternative
treatment technologies, especially stabilization of  aqueous or inorganic
wastes and incineration of solids and sludges.  A  few firms had reacted to the

   Ca«j',c.&!)u  KG  Siological Treatment
   With tha- expectation that waste volumes received for chenical/biological
treatment will remain flat, several firms in the survey have  slowed their
growth in ^re'atinent capacity.  Reported chemical/biological treatment capacity
did increase by 7 percent between 1986 and 1985  (from an  adjusted total of
2,698 thousand WMT to 2,879 thousand WMT) , but  increased  less than one percent
in 1937.  This  increase  in capacity coupled with an eight percent decrease
overall  in volumes treated since  1985  resulted  in  capacity utilization
dropping from 42  percent in  1985  (adjusted)  to  35  percent in 1-887.
                         Chemical  and Biological  Treatment
                          (Capacity  and Capacity  Utilization)
       30CO -r
       2oOO  •  "Jw4


   Nine firms In the 1936-1987 Survey offer waste solidification/stabilization
services-i however, only four firms provided capacity data.  These  four firms
had a reported capacity of 178 thousand Wttl in 1986 and  291 thousand WMT in
1987 -- a 64 percent increase.  This was  the next largest  one-year increase in
capacity behind the increase in incineration capacity.   Capacity utilization
over this period declined from 37 percent in 1986 to 26  percent in 1987.
                            Solidlf 1 cst Ion/Stab II !zf,tl on
                          (Capacity  and Capacity Utilization)


   There lils-been little reported change in the resource recovery capacity
operated-^y the firms participating in this year's survey since 1935.
Capacity utilization has fluctuated slightly over this period, but has  also
remained fairly constant -- between 43 and 50 percent as shown in the exhibit
below.  Several firms expect thac resource recovery volumes  and capacity will
rise over the next few years as  generators look to minimise  waste sent  to  land
disposal, however, a few firms expect  there will be a drop  in the commercial
solvent recovery  business  as more generators will  recover  their  own solvents.
                               Resource  Recovery
                         (Capacity and  Capacity Utilization)


   ReportaS- commercial  landfill  capacity  operated by these firms has declined
 each year  since  1985, with  the biggest  drop  occurring between 1986 and 1985
 (16 percent),  even though the volume  landfilled has  changed little since 1985.
 Landfill capacity was estimated  to be 30,673 thousand WMT in 1987 as compared
 to the  adjusted  total of 39,205  thousand  WMT in 1985 (a drop of 22 percent).
 There was  a  reported 7  percent decline  in landfill capacity between 1987 and
 1986 with  volumes landfilled increasing by 5 percent over the same period.
 Assuming a fill  rate equal  to the estimated  1987 waste volume landfilled
 (2,473  thousand  WMT), current landfill  capacity would be expected to .last for
 12 years.  This  is down from the previous remaining  lifetime estimate of 15 to
 16 years.  Pleaders should remember that these estimates are based upon the
 assumption that  all land area each firm plans to commit to landfill operations
 car. be  developed.  At any one time, however, the available landfill capacity
 is much less as  only a  portion of a landfill site is permitted to receive

   While landfills continue to fill up  and with few  facility expansions or ne-.'
 facilities r.ermitted, the estimated loss  of  commercially available landfill
 capacity reported this  year is overstated.  Several  firms '.ndicated that  they
 had withdraw, available landfill capacity from the "direct-1 disposal market  Co
 ensure  capacity  would be available to handle treatment residuals from their
 othsr  operations.
                         (Capacity  and Ca  aelty  Utilization)
500CC -•

4COCC -•

30000 ••

20000 ••

          V-•>«*%&* f^,
          ^ •. tf?**,^ \
          ^ VX' "?•• ""V^v
           ^.-S; *i
                            D CAPACITY H VOLUME  I

   Beep Hell Injaction

   Commercial deep well injection capacity operated by these  firms  declined
eight percent between 1985 and 1986, but rose two percent between 1986  and
1987.  Total'sffective capacity estimated for 1987 (1,118 thousand  WMT)  is now
only slightly less than the estimates for 1983 through 1985  (around 1,1190
thousand WMT).  Ov-.r this same period, how-aver, volumes received for deep well
injection daclined by 42 percent as several facilities were unable  to accept
wastes.  Capacity utilization in 1986 and 1987, therefore, was  estimated to be
around 25 percent, down from 35 percent in 1985.
                                      Wall  Injection
                          (Capacity and  Capsclty Utilization)
                                                              11 18


   Pricesi'jfor transporting, treating, or disposing of hazardous wastes can
vary substantially depending on the level of regional competition,  costs
incurred in handling the wastes, and the risk of handling the waste.   Prices
for a single waste stream vary with the composition of waste.  This
variability would make it difficult to present detailed price data even if
survey participants were willing to shara that information.   Survey
participants will provide, however, price range data and/or information on
price tre .ds for some very general waste types across the major treatment and
disposal cechnologies.

   The price information provided in Exhibit 3-4, therefore, does not capture
region."! differences, quantity discounts, or waste stream variability, and
should Li interpreted cautiously.  These are instead "typical" prices charged
for hazardous waste management services by all firms surveyed in 1985, 1986,
and 1987.  The price ranges shown in the exhibit were calculated as the
average of the low-end and high-end prices provided by individual firms.  Also
shown in Exhibit 3-4 are the expected price changes reported for 1988.  The
maximum prica range reported by these firms is not shown in the exhibit, but:
has been reported in the sections on each technology below (i.e., the low
and/or high end of any one firm's price range for a specific waste category
may fall out-ide the "average" price range).

   From 1984 through 1985, respondents had reported price increases of 30 to
100 percent for land disposal services, and from 60 to 400 percent for
treatment services with incineration services garnering the highest price
increases.  The rate of price increase was also significant; in some cases,
prices increased by 50 percent every 4 to 6 months.  Among these firms,
however, there was wid spread belief that the market had seen a one-shot pr : •;
jump and that prices would stabilize.

   The price information for 1986 and 1.937 di not confirm across-the-board
stabilization in prices, except for  a faw services.  There was significant
movement in service prices in 1986 as reported by these firms.  Quoted pric-..;
for some services in 1986 increased  as much as- 174 percent  (oil recovery),
while prices for other services decreased by 54 percent.  In 1987, prices
appear to have stead'.ed for some services.  The average nominal price increase
for chemical and biological treatment, deep well injection,  transportation,
and PCS incineration services rose less than 5 percent over  their 1986 levels.
The average nominal price increases  for other waste management services was
much greater:  10 to 48 percent for  landfill; 13 to 34 percent for
incineration; and 16 to 97 percent for resource recovery.

   Price trends for each waste management technology are discussed further
below.  Prices for surface impoundments/land treatment and waste
solidification/stabilization could not be included as the participating  firms
offering these services did not provide price data.


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   From 1984 -to 1985, landfill prices  increased an average o£ 30 to 100
percent. -jFxpm 1985 to 1986, however,  landfill prices increased only 15
percent for .bulk disposal and fell almost 10 percent for drum disposal.
Typical bulk-disposal prices in 1986 ranged from an average of $86 to $154 per
ton (full price range: $70-$250/ton).   Prices for drum disposal ranged from an
average of $44 to $125 per drum (full price range: $40-$250/drum).  In 1987,
average prices for drum disposal jumped 48 percent to $64-$186 per drum (full
price range: $40-$330/drum).  Bulk disposal prices rose an additional 10
percent to $96-$165 per ton (full price range: $75-$250/ton) ..  Quoted prices
for waste solidification or stabilization services ranged from $70-$270 per
ton in 1986 and 1987.

   Competition was mentioned as the primary reason behind the drop in drum
disposal prices in 1986.  As in previous years, the reasons behind the
increase in landfill costs, and therefore prices, included:  more waste
solidified prior to disposal; increases in state waste taxo..;; costs for
corrective actions; and higher insurance costs. One additional factor
nentioned was the realization by landfill operators that permitted disposal
calls are not assured to ue a replaceable commodity at existing sites through
che current permitting process.  If they can be replaced, it will only be so
at significantly higher costs at some uncertain future time.  Operators will
increas ; their prices, therefore, as a means to conserve valuable landfill
capacity for the future, especially if that airspace is needed to handle
residuals (e.g., ash or sludges) from the firm's own waste  treatment
(especially incineration) operations.   Only tvo respondents reported their
expected change in landfill prices in 1988;  one said that prices would remain
constant while the other predicted an increase of 10 percent.

   Deep Yfell Injection

   The average deep well injection price for toxic liquids  fell 54 percent  in
1936  (CO. 15  - $0.63 p.ir gallon) with shifts in both the low end  (up) and  the
high  end (down) of the quoted price range (full price range: $0.03-
$1.00/gal.).  The price per gallon for toxic liquids remained unchanged in
1987,  The price range for oily wastewaters remained unchanged at $0.08 -
$0.50 per gallon, and this was also the price range for the new waste  type
category added this year: aqueous organics.  One deep well  injection firm
expected that their prices for toxic liquids would increase by 10 percent in


   In 1985, nominal  incineration prices rose  for  all waste  categories  anywhere
from  60 to 400 percent.  In 1986, average incineration prices increased for
one waste category -- clean, high Btu-content  liquids  --  by 60 percent (full
price range: $0.15-$1.93/gal.).  This was surprising given that  these  wastes
are in  demand to help support  the combustion  of  the  lower Btu-content  solids
and sludges.  Equally surprising was the drop  in prices  --  by 25  percent  or
more  --in  1986 for  low-Btu content liquids  (full price  range:  $0.83-
$5.84/gal.), toxic liquids  (full price range:  $1.58-$5.84/gal.),  and PCS


solids (full price range: $0.30-$!.50/lb.),  with a significant drop in the
high end of the price range for each waste type.  The full price range quoted
for solids_ and sludges (non-PCB) in 1986 was $0.40 to $1.00 per pound, and
$2.50 to $4.75 per gallon for PCS liquids.

   In 1987-; nominal incineration prices were mostly up except for PCB liquids
incineration given the decline in that business area.  The price to incinerate
toxic liquids registered the greatest increase (34 percent), however, the
average price charged was still lower than was estimated for 1985.  The full
1987 price range quoted for each waste category were: $0.12-$2.09 per gallon
of high-Btu content liquids; $0.83-$5.84 per gallon of low-Bt^i liquids; $1.67-
$7.91 per gallon for toxic, non-PCB liquids; $0.50-$1.25 per pound for sludges
and solids; $2.09-$3.75 per gallon for PCB liquids; and $0.50-$1.50 per pound
for PCB sludges and solids.  Firms providing incineration services expect that
incineration prices in 1988 will remain constant or drop'slightly due to

   Chemical and Biological Treatment

   New waste type categories were used this year to characteriz« prices for
chemical and biological treatment services.   It is not possible, therefore, to
compare the price quotes for 1986 or 1987 with those for 1985.  As a result,
the price comparison covers changes between 1986 and 1987 only.

   Prices charged for chemical and biological treatment can vary considerably
depending on the cost of the unit processes involved and the h .zardous nature
of any remaining residue that must be managed.  The average price range quoted
for these services in 1986 and 1987 was anywhere from $0.25 to $3.50 per  -
gallon depending on the waste type treated or recovered (the more toxic and/or
reactive the waste the higher the price).   The full price range quoted for
aqueous inorganic liquids in 1986 was $0.14-$3.25 per gallon and $0.17-$3.25
per gallon in 1987.  In both 1986 and 1987,  the full price range quoted for
inorganic solids and sludge.; was $0.30-$6.00 per gallon.  With volumes
leceiv'id and capacity expected to remain flat, firms offering these services
predict price increases of only 10 percent in 1988.
   Resource Recovery

   New waste type categories were also used this year to characterize resource
recovery prices.  The new waste type categories were:  aqueous organics, non-
aqueous organics, and aqueous inorganics;  only the oils category was kept from
previous surveys.  From 1985 to 1986, the average prices for oil recovery rose
174 percent from $0.00 - $0.42 per gallon to $0.33 - $1.00 per gallon  (full
price range in 1986: $0.05-$2.25/gal.).  An additional average price increase
of 16 percent was reported in 1987.  The average price range for oils  in 1987
was $0.20 to $1.13 per gallon with a full price range of $0.20 to $2.58 per
gallon.  Respondents attribute this increase to the cost of the regulations
governing waste oil that came out in December 1985.

   The average price quoted for recovery of aqueous organics did not change
between 1986 and 1987 staying at $0.40 to $1.00 per gallon  (full price range:
$0.35-$l.25/gal.).  The average price range for non-aqueous organics,  however,


rose 97 percent in 1987 over 1986 levels To $0.38 to $2.44 per gallon (full
1986 price range: $0.25-$1.20/gallon;  full 1987 price range:  $0.35-
$3. 67/gallon.)..  No price information was reporred for the recovery of aqueous
iriorganioL._  No firm provided information on their 1988 price changes.


   Several of the 14 firms surveyed provide for transportation of hazardous
wastes to their facilities.  Transportation price data provided by these firms
indicate that, in 1986, average prices on a per ton-mile basis rose 10
percent, and, in 1987, increased another 5 percent.  These prices represent
full-truckload shipments; prices for less-than-truckload shipments would be
considerably higher.  The 1986 full price range quoted for transportation
services on a. loaded mil* basis ($3.20-53.78) rose five cents on the low end
and remained unchanged on the high end in 1987.  Transportation prices in 1988
were noc expected to rise significantly.  The participating firms mention
competition as the main factor behind fairly stable prices for transportation

                 APPSHDI2 A

              IN VET IffiTRIC TONS

                                 APPENDIX A

                              IN WET METRIC  TONS
   The same assumptions and definitions used in tabulating the data for the
1980-1985 survey reports with one exception were also used for this survey.

   The estimates for volume presented in this report refer to the estimated
quantities of hazardous waste actually treated or disposed of by the
commercial hazardous waste management industry.  The estimates for effective
capacity refer to the practical maximum amount of hazardous waste which could
be treated at existing facilities without undertaking major capital
expenditures and considering routine downtime and other factors.  Since the
effective capacity of a facility often depends on the types of wastes being
treated or disposed, the current mix of hazardous waste is assumed in defining
capacity.  Several additional assumptions were made during the course of this
analysis that are important to the proper interpretation of the results.
These assumptions are necessary to convert data to a consistent basis,  wet
metric tons (WMT),  when conversion factor estimates were not available:

       *    Volumes reported in gallons are transformed into wet
            metric tons assuming that the waste has the density of
            water at 8.34 pounds/gallon or 0.00378 metric

       u    Volumes reported in cubic yards were converted into wet
            metric tons assuming that the waste has a density of
            0.90 metric tons/cubic yard.  This conversion factor was
            used sui'^ey assuming that no liquids are now landfilled
            and more wastes are stabilized before placement in

       M    Capacity reported in acres is reconverted to wet metric
            tons by assuming each acre has 430,000 cubic feet of
            available capacity and 12,100 MWT can be disposed of in
            each acre.  In general, four interrelated factors
            influence the capacity, as measured in wet metric tons, .
            that can be disposed of per acre:

                 The overall size of the landfill.  This defines how
                 much can be utilized for disposal and how much must
                 be used as buffer.  The smaller the landfill, the
                 greater the proportion of acreage that must be used
                 as buffer.

                 The size of the trenches.  A typical trench may have
                 surface dimensions of 100 by 200 feet and have an
                 average depth of 30 feet.

          -- "-•-   The percentage .utilization within a trench.  The
          'J~- -     percentage of the trench utilized for hazardous
                  waste disposal depends on the materials being.
                  disposed and the spacing practices of Che operator.

                  The density of the material.  There is significant
                  variability depending on the actual wastes being

The assumption of 12,100 MWT per acre is based on the advice of several landfill
operators rather than explicit assumptions about each of the parameters that
affect landfill capacity.

      AT2ESDIX Ji



                                  AT'PEHDIX B

                            CEI'lTflTICNS TG8. SURVEY
Hazardous v.-.stes:
Biological treatment:
Chemical, traatment:
     *;•"- ?. f j O7'.:
:>U Oif L zi.-l.o-n/qtabL1 iiatio
T)eBQ V'-ll ir.i action:
Lard treat- *nt:
Wastes regulated as hazardous ur.der the federal
and/or a state's RCRA program, plus PCB wastes.

The use of the metabolic processes of
microorganisms to break down organic hazardous
constituents into non-hazardous substances.

A group of processes utilizing neutralization,
precipitation, oxidation, and other
chamic lly-ban>'d techniques to treat or
immobilize hazardous constituents in a waste
stream.  Can occur iri tanks or surface

The thermal destruction of a hazardous wasta  in
either a. liquid injection unit, rotary kiln unit,
or a csment kiln (although the lattar is more
conmonly refsrred to as energy recovery).

The reclamation, via s oaration and purification,
of usable substances from hazardous waste; and
the r-e-use of these substances (in this  report,
resource recovery includes solvent and netals
raeovcjry, bu~ not energy recovery, which has  b  -
included uni ^r incineration to avois disclcs.ia^
ccnfidfincial inforinauion; futv.re  surveys may
t-.xr.flnd this market sc r.-ciis cac.e^ory to sepac-'C>.
cut: these very different suLuaika ca) .

111° containment of hazardous waste in on-ground
or below-ground repositories that are lined vlf.
layers of impermeable material.

The conversion of liquid hazardous constituent-.
into immobile solid forms by chemical or
evaporative processes.

The disposal of high-concentration liquid wastes
in otherwise unusable underground aquifers via
pressurized wells.

The placement of hazardous waste  on or in a
surface layer of soil  (to render  it non-hazardous
through biological decay).

Solar evn.'OQr_?,;ii_Qn:
Land Qiaoosr.'i. or Disposal:
Capacity, or Effactive
The process of dewaterir.g hazardous wastes in  a
surface impoundment by evaporation of the wacer
fraction of the wastes.

Includes all thermal and non-thermal treatment
technologies including stabilization/

Includes all other non-treatment technologies
except storage and transportation.
Measured as (or converted to) the annual mass
throughput of hazardous waste through  a  treatmarxc
or disposal technology or system according  to
practical operating maxiiauias for these systems
considering routine down time for repairs and
maintenance, discharge limits in various permits,
electrical outages, and ocher factors  as defined
by the respondent.

The ratio of commercial volumes processed by a
technology in that year to effective capacity,
both expressed in mass units, and represented  . •••
& percantage.

The wastes originating from  cleanup  ---tctivitias   ; •.
hazardous v.-vjte sites wher^.  thasa ac':iviLio-j iv ;
funded by Supsrfund monies.


land bans by irrtposing  their own  restrictions  on the waste types they would
r.ccept for landfill ing,  some  as  a  measure  to  conserve space for disposal of
thair owruwaste treatment residues.

   Hose 4raspondsnts predicted that the  future of surface impoundments or land
treatment Is""bleak" and that these  technologies will be stringently regulated
or phased out.  At  the  same time,  however,  these firms had widely different
opinions about the  need j.or using  surfac?  impoundments and land treatment to
manage hazardous wastes.  A few  firms felt that thers will be a continuing
need for and use of these technologies,  but could not agree on which
technology would be the more  likely  to  survive.  Five firms Relieved that land
tr^atrnent was a viable  or necessary  technology that will survive, although
operators would face increased restrictions to manage fewer wastes. 'One firm
expects that new surface impoundments will be constructed, but many more
respondents said thac  surface impoundments will be replaced by treatment in
   Ac present, fairly  large volumes  of RCRA and CERCIA corrective action soils
and debris are disposed of in  secure landfills with little or no pvetreatment.
Survey participants  expect, however,  that future land disposal restrictions
and the move  to more "permanent"  remedies will soon require that most or all
corrective aocion  soils and debris be treated before land disposal.  If true,
i.:or~ rtiST'onrtiiiics believe  that  there  is currently inadequate capacity to meet
the y<-.t-.c.i'cti'l r.sed to  trsac RC2A  and GERCLA correc" .ve action soils and
ur.br1' i.  I lest eor.ipanlas are not: confident about correcting any near-tarm
.,r;.r".:"j.Ll i.i  trs.itatint capacity for  soils and debris quickly.  One firm stated
i.'.c,c .u-ay Fxru.; have arid  are building, transport bla treatment units to meet
iil>.- C";\c.~ \ or.) rfui iiee'i,  and several noted that on-sita treatment units will
l:e. the lor.£-i-'jr-i solution to land disposal restrict' ons.   Tbe firms differed
.1,1 %'i ;*.-., >c oxi:u4 r. i.ons  or  axtansions  should be allowed because cf the potential
':.;pacicv .;hortfnil.  A fftw firms  fael that there should be extensions granted
I; c ".Approved" Ir.r.vifills  and thac additional land dijpo^al capacity should be
i;~j-il'i.'.^J. \-.u  hriiule  clie potantial volumes.  Oi;her finns fsel 'cl'.at excrjnsions
^i.cu ..i nut be ^::^.'',t -.''•.  f-ne firm  stated thi'.t r.^.ara should not Le exf.casions
gi--n %>i uicr-jiy b'.u:'u.-« of the  origin of wascc.-..   Anoth-r firm statsd that
<'ap^-_ity h-~s  been  coining  on line  and will continue to do so, but that adequate
capacity will not  be placed in^o  operation unless and until the bans are
enforced arid  firms actually see the  demand.

   Even wich  required  treatment of RCRA and CERCLA con active action soils and
debris, a few firms  still expect  that the impact on land disposal volumes will
be minor, however.   Several firms expect that more landfill capacity will be
permitted, especially  to  accommodate disposal of high volume wastes for which
there are no  alternative  technologies, or, because the treatment residues will
still require disposal, expect that  the volume of waste going to landfills
will actually rise.

   Only five  firms responded to the  question of whether they operate a land
disposal unit capable  of  meeting  the "no migration" standard that will allow
them to continue disposing untreated hazardous wastes.  One firm stated only
that they meet the RCRA minimum technology requirements and would not answer


•whether it meets the no migration standard.  Three firms "believe that it will
be virtually impossible to file a petition that will be approved.  Only one
firm intends--to sv.bmit the application by the hammer deadlines.  Even so, the
firm believes the petition requirements are inappropriate,  inasmuch as they
place tod. high a reliance on a. manipulable computer model,  rather than any
development of hard data.
   Many of the survey participants also have divisions or groups that
specialize in site remediation and field services.  Although this aspect of
their business mix was not a subject for this survey, several questions vere
asked that touched -upon their participation in ar.d views of the site cleanup
mar leat.  For example, respondents were asked in they handled any Superfund
cleanup, non-Superfund cleanup, or RCRA corrective action cleanup wastes in
1986 or 1987.  About half of the firms surveyed did not handle Superfund
cleanup  -as ess in either 1986 or 1987.  A handful of firms had handled
Superf'oul cleanup wastes during 1986 and 1987, and about an equal number had
also handled wastes in both years from non-Superfund cleanups.  Only one firm
reported handling wastes from a RCRA corrective action site.  The majority of
firms reported that handling sita cleanup wastes had not caused delays in
handling wastes from their "live stream" custoiaers, but two firms did rsport
uinor delays, especially for "third party" wastes received from brokers.

   A.lthov^h only a few firms had "handled wastes from cleanup sites in 1986 or
1937, more firsts said they were planning to get inco this business in the near
future.  Most firms said they expected the site cleanup business to experience
.significant growth rates over the near-tern, a tread borne out by the recent
experiences of several firms that had handled cleanup wastes previously.  One
fi.-u r.ot?d that it had handled four tines the volume of sits cleanup vastes in
1937 -v-srsun 19S6.  Another firm notad that waste volv  ^s had increased 10 to
.'0 f.\r.z -ac over th.'.t saje period, and still another firm reported steady
volo e iiicr arises each year since 1S'32.  Tha experience of other firms was not
. 3 positive: thair cleanup waste volumes had increased, but at a rate less
than hid l-itn predicted and &T. lower profit margins.

   When askeu about the market effects of the SARA amendments, the survey
participants either had no comment or stated that they had yet to detect any
effects,  die respondent insisted that the principal effect had been, to slow
down site cleanup work.  Many respondents stated that they had anticipated
undertaking more on-site treatment projects by now, but had not seen much
movement in this direction and were concerned about whether EPA would elect to
pursue on-site treatment remedies.  Several firms noted that the promise of
the Superfund cleanup program for them hinged upon how aggressively EPA would
pursue permanent cleanups through the use of on-site treatment technologies
like transportable incinerators.

   More respondents wer« upbeat about the future  growth of the non-Superfund
site cleanup market.  They reported considerable  activity by responsible
parties to clean up sites before  that site might be  considered for inclusion


on the federal or a state's priority list.  Many firns also expected that the
RCRA corrective action market would be very big, but were r.ot sure of its
profir.abili.sy-.  Several firms expected that this cleanup market would be
highly compel:itive and subject to lower profit margins.

   Survey participants were also asked about the market effects of EPA's Off-
Sita Policy.  Only a few firms chose to comment and their opinions were very
negative.  Although no numbers were cited, these few respondents said that
this policy had resulted directly in delaying cleanups, in a considerable loss
of revenue, and generally in "mass confusion".


   Each year EPA includes a group of special interest topics in the commercial
industry survey.  In years past, survey participants wera asked for their
views on topics such as the waste oil regulations debate, and for sevrval
y^ars have been asked about the availability of liability insurance and
servicing staall quantity generators.

   The list of special interest survey topics this year included the
following: (a) commercial waste management firms' capacity to perform tha
Toxicity Characteristic Leaching Procedure (TCLP),  (b) the availability of
liability insurance, (c) servicing the small quantity generator market, and
(d) the emergence of the "quasi-commercial" waste management s rvices

   .1.   Capacity to Perfora the Toxicity Character is C;tc Leaching Procedure

   The majority of firms survey .d believe that most commercial wasta
management firms do not yet have adequate capacity and may not be able to
davelop adequate a pacity in time.  Although" the lai j;er firms generally see
th^aselves as capable of either performing the tasc now or developing the
capacity to perform- the test fairly quickly, several firms expressed tha
belief that "smaller" commercial firms may not be able to perform the test.
If the capacity of comaercial laboratories to perform the test is considered,
however,  these firms believe any potential shortfall in testing capacity is
likely to be small.   Several firms anticipate that imposing the TCLP will
extend the testing time and increase costs to generators.

   b.   Availability of Liability Insurance

   Respondents to this question noted that, in general, the availability of
liability insurance "is no longer a problem1 if you have the money to pay for
it."  Six firms stated they now see more offerers of insurance to commercial
waste management firms.  Another firm believes that there has been a
"relaxation in insurance for waste haulers", which have been able to qualify
for higher coverage limits, apparently at affordable rates.  Two firms stated
that they have not been able to obtain as much insurance as they need or want.
One has obtained only one-tenth the insurance it wants, and the other must


self-insure because it is unable to obtain the minimum insurance required by
the state and federal governments.

   c.   Servicing Snail Quantity Generators

   Generators of between 100 to 1000 kilograms of hazardous waste per month --
 small quantity generators (SQGs)  --  require much in the way of waste
management services and still only a few commercial firms in the survey said
they actively seek SGQ business directly.   Even so, it appeared that more
firms this year talked of their interest in looking at this "market than was
the case in the 1985 Survey.

   Firms participating in the SQG services market say it requires extensive
less-than-truckload transportation capabilities, a strong quality control
program, a willingness to supply the additional recordkeeping services
required, effective logistical planning, and an awareness of the liabilities
that can be incurred, especially when an off-spec waste is received.  Firms
that can meet these demands and do so fairly inexpensively consider the SQG
market to be a major growth market and potentially quite 'ucrative.  Several
firms commented that they have been surprised by the unexpectedly high growth
rate of services to SQGs.

   Other firms either .iandle no or only a "trickle" of SQG waste directly, or
do so only through waste brokers as they cannot supply the necessary service';
for a price SQGs can afford or they are scared of the potential liabilities.
Many firms, even those who do service SQGs, are also critical of the lack of
enforcement effort invested to date in SQG compliance.  The potential demand
will never be realized and commercial firms will remain unwilling to invest In
services to SQGs, they say, until cheaper disposal optic, j are foreclosed Co
SQGs.  Several firas also spoke of the need for more local storage and
transfer facilities to help handle SQG business since just the waste
transportation price is enough of a problem'for many smaller generators.

   d.   Suargence of the "Q-iasi-Cowaercial" Waste Management Indust.-y

   Press articles discussing waste management service firms that will come  in
and build, permit, and operate a fixed treatment/disposal  facility3 for  the
generator prompted EPA to inquire about the emergence of this "quasi-
commercial" waste management industry.  In particular, EPA was interested in
unconfirmed reports that some of these service arrangements were being made
     ^  The  term  small  quantity generator is now officially reserved by the
USEPA for  generators  cf less  than 100 kilograias of waste per month, but has
been used  here  to represent the 100-1000 kilogram per month generator as  this
is the more  typical reference used by the commercial firms.

     ^ Not included in  this definition would be transportable or mobile units
for on-site  treatment,  or  fixed, transportable, or mobile units built and
operated as  part  of a waste site cleanup.


with an eye towards opening the treatment/-".isposal facility for at least
partial commercial operation at some later date.   A related development also
of interest -to EPA were reports that generators planning to build and operate
their ovm-_tareatnnenc/disposal facilities were willing to allow commercial
access to these facilities.

   Six out of the eleven firms responding to this question had never hen.rd of
the idea of commercial firms operating fixed, initially dedicated, treatment
or disposal facilities at a generator's site.  Five firms, however, had heard
about the idea and two firms reported they had held discussions with three
generators though all were unsuccessful.  Still another firm'reported a
different twist on this idea: generators had inquired if the commercial
operator would build and operate a dedicated, off-site waste management
facility that would not go commercial.

   Those firms that reported receiving inquiries from generators about
building and operating dedicated on-site fixed facilities said that generator :
had different objectives in pursuing the idea, including potential cost
savings, liability protection, and access to guaranteed capacity.  Most of
these negotiations had failed, they said, because generators were unwilling  co
pay enough to allow the commercial operator to make a good return on his
1 lives'. -:nt.  One firm commented that they saw some potential in this idea for
the very large waste generator that lacked the internal capabilities to
operate  the facility, but doubted there were many generators who fit this

   More firms, of course, had heard of generators willing to open up their ovn
incinerators or chemical treatment facilities to other generators since
several state facility siting facilities have entertained this idea as a
solution for capacity shortfalls and siting woes.  These firms believed,
however, that few generators would do so or that the permitting hurdles would
prove fatal to the idea.  They stressed that generators are more likely to run
their evn show and that it made no sense for- a generator to assume the
liability that made them discontinue using commercial facilities in the first
place.  Another firm noted that most mid-sized waste generators will find that
the economics favor using commercial service firms.  Even so, other firms did
nets that the profitability of commercial waste management services could
still be a sufficient lure for generators to enter the market.
   The next chapter discusses the quantitative results of the survey
concerning waste volumes received, capacity operated, and prices charged by
all firms in 1986 and 1987.  These results are also compared to results from
the 1985 Survey  (as adjusted).


                                  CHAPTER 3

        j"~"         UASTE VOLUMES,  CAPACITY,  AKD PRICES

   This chapter discusses results of the 1986-1987 survey concerning:  the
number of facilities operated by the 14 firms  and the services offered;  recent
acquisitions;  waste volumes received;  effective capacity and capacity
utilization; and service prices.  Unlike previous survey reports,  only
occasionally will distinctions be made in the  results between firms that have
participated since the first survey  and firms  included more recently:  The
fourteen firms participating in the  survey this year were:

   a    Browning-Ferris Industries/CECOS International;
   *    Chem-Clear;
   j    Chemical Waste Management;
   »    Envirosafe, Inc.;
   t.    ENSCO, Inc. ;
   x    Envirite;
   u    Environmental Waste Resources;
   M    GSX Corporation;
   a    Rollins Environmental Services;
   9    Ross Incineration;
   a    Saf ety-Kleen/'.cKesson Envirosystsrs;
   H    Systech;
   «    U.S. Pollution Control, Inc.;  and
   n    W.J. Lamberton/Chemical Resources, Inc.

   Excluding transfer facilities,  the 14 firms surveyed operated 83 treatment
or disposal  :acilities in 1986.  The distribution of waste management services
offered at these facilities is shown in Exhibit 3-1.  Significantly, these 14
firms report that more of their facilities nov or soon will offer thermal
treatment services for hazardous wastes than they reported in 1985.  There was
also a drop in the number of landfill facilities, but this reflected a
correction of past errors.  Four firms opened or acquired a total of eight new
facilities in 1987.  Only two companies reported closing facilities in 1986 or
1987, although a few facilities were closed temporarily for some portion of
this period.

   Acquisition activity by these firms picked up in 1986 and 1987 as expect ;-d.
In 1986, much of the acquisition activity involved GSX Corporation.  GSX
Corporation, and its parent corporation Genstar, were first acquired by Imasco
Ltd.  Imasco quickly elected to sell GSX Corporation, both the solid and
hazardous waste operations, to Laidlaw Transportation Ltd.  Later, GSX
Corporation acquired a liquid injection incinerator and a waste transfer
operation in the Southeast. For a while, Laidlaw contemplated selling the
hazardous waste operations of GSX, but, according to., recent reports, will


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apparently keep this portion of the business.

   Exhibit 3_-2 provides a list of selected acquisitions sines 1983 by firms in
the commercial hazardous waste management industry.   Safety-Kleen's
acquisition of McKesson Envirosysterns in 1987,  as noted in Chapter 1,
shortened .the. list of survey candidates from eighteen to seventeen firms.
Additional acquisition -ictivity not covered in this  list involved business
areas such as asbestos abatement services,  consulting and engineering
services, and UST cleanup and other remediation/field services.  Most
observers predict servic-e diversification and consolidation trends to continue
for the near future in the commercial hazardous waste management industry.

        HAZARDOUS WASTE IN 1986 AND 1987

   A total of at least 4.2 million wet metric tons (WMT) of hazardous wasta.3
was received for treatment and/or disposal in 1986 by the 14 firms surveyed.
This volume was down 8 percent from the adjusted 1985 Survey total of 4.6
million WMT (1985 total volume was adjusted to exclude volumes for firms noc
participating this year and to reflect corrected 1985 results provided to
IGF).  In 1987, these same firms received a total waste volume of at least 4.6
million WMT, an increase of 6.5 percent over 1986.  While the total waste
volume handled by these commercial firms appears to be holding fairly steady,
several firms experienced significant increases or declines in volume received
over the 1986-1987 period.

   Total volumes received by technology and the percr.itag-i changes from  19-85
thror ,h 1987 are shown in Exhibit 3-3.°  As the table shows, only the waste
voluiuj incinerated did not experience a decline in volume in 1986 as compars-l
co 1985.  Respondents reported that their volumes incinerated increased by
30.5 percent in 19!3i over 1985 (adjusted).   Waste volumes sent to deap well
injection in 1986 experienced the largest decline (-34 percent).

   Over half of the firms reported that waste volumes received in 1986 went
down as compared to 1985.  The percent change in volumes received by
individual firms in 1986 versus 1985 covered a very broad range -- from  an
increase of as much as 73 percent to a decrease of 91 percent.  The average
change in volume was about -4 percent.  Reasons for the decline in volume
included permanent or temporary facility closures (due to regulatory or
enforcement action), regulatory limits on volumes received at certain
facilities, self-imposed restrictions on volumes received in order to conserve
land disposal capacity, and slowdowns in certain service markets  (e.g.,
wastewater treatment).  Firms reporting an increase in volume cited such
     "  Excluded from these results are the waste volumes sent to land
treatment or surface impoundments as there were numerous problems with the
results provided this year.  These results were not provided as any
observations based upon these data would have been unreliable and misleading.
Reported separately for the first time this year are the waste volumes
stabilized or solidified.


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factors as growth in their site cleanup and lagoon closure business;  growth in
their wasta pretreatment and treatment services due to the land disposal
restriction^.;, the ban on disposing of bulk liquids in landfills;  the
tightening__of Clean Water Act pretreatment standards; growth in the waste
fuels marRetj and an increase in tank closure and cleaning services.

   The decline in waste volumes handled by technology were all reversed in
1987.  Again, the volume of waste incinerated experienced the largest growth
in volume (36 percent) over the reported total for the previous year.  Volumes
sent to resource recovery increased by 25 percent over the reported 1986
total.  In contrast to 1986, over half of the firms surveyed*reported an
increase in the total volume of waste handled in 1987 as compared to  the
previous year.  Again, the percent change in volume received in 1987"versus
1986 by each firm varied markedly -- from up 233 percent to a decline of 85
percent -- with an average of a 20 percent increase.

   Respondents were not asked this year to provide waste volume totals by
waste type.  Each firm was asked instead to list those waste types they do noo
accept either by choice or because of their permit conditions.  The majority
of firms surveyed do not accept dioxins, explosives, radioactive wastes,
infectious wastes, heroicides, pesticides, and gas cylinders.  Several firms
do accept PC3 wastes for treatment and/or disposal while otherj do not.

   Each of the following sections discuss the waste volume trends for each
technology in more detail.


   Waste volumes reported as landfilled by the commercial hazardous waste
finas surveyed fell from 2,424 thousand WMT in 1985  (adjusted) to 2,366
thousand WMT in 1986 -- a decrease of about 2 percent.  This decline in vol1-. • -.
was followed by an increase of 4.5 percent in 1987 over 1986 to a reported
total of 2,473 thousand WMT.  Survey participants reporting an increase in cr.:
volume of waste landfilled had seen greater volumes of site cleanup wastes, a
rise in wasta stabilization and solidification, and/or more business due to
the closure of several competitors' facilities.  Waste volumes were  down for
some finas reportedly due to declines in their remedial cleanup business
and/or self-imposed limits on the amount of commercial waste accepted for
disposal in order to save landfill capacity for their own treatment  residua"1?.
      2500 T
      2000 ••
      1500 ••
      1000 ••
       500 ••


    As shown -in the exhibit below, the volume of waste incinerated by firms in
 the survey has grown rapidly.  From 1983 to 1987, the volume of hazardous
 waste incinerated by these firms has increased from 167 thousand WMT to 476
 WMT.  This is an increase of some 185 percent.  From 1986 to 1987 alone, the
 volume of waste reported incinerated increased by 36 percent.  Volumes of
 waste incinerated were reported as up in 1986 and 1987 for all the firms in
 the survey offering thermal treatment services.  The principal factors cited
 by respondents as driving up incineration demand were the various land
 disposal restrictions and generators' growing preference for total
 destruction.  Additional observations about incineration demand are discussed
 in Sections 2.1 and 2.2.
     500 T
     400 -f
     300 -i
     200 +
     100 -f

    Chemical and Biological Treatment

    In 1986.7- the firms surveyed reported treating 958 thousand WMT of hazardous
 wastes, excluding wastes stabilized or solidified prior to land disposal (see
 below).  THis" volume was down 15 percent from 1,131 thousand WMT treated in
 1985 (adjusted).  Waste volumes treated in 1987, however, increased by 6
 percent (to 1,011 thousand WMT) over the previous year, but this was still
 below the adjusted 1985 volume.  The performance of individual firms in this
 service sector was highly variable.  Four firms reported an incriase in
 volumes treated while several others reported significant decreases due to
 self-imposed  business restrictions and loss of market share or overall
 declines in their regional markets.  These results mirrored respondents'
 expectations, discussed in Section 2.2, that the wastewater treatment market
 will likely remain flat at best or decline unless there is a significant
 investment  in enforcing the Clean Watsr Act pratreataent requirements.
                        Chemical  and  Biological  Treatment
     1000 j,"1
:<;viT   GOO •;•


      200 -
                                                             101 1

   Solldlf Icatlon/S tabilizaticn

   SsveraP-firms reported wasta volumes stabilized or solidified separately
from their chemical treatment or landfilled volumes for the first time this
year.  Nine respondents in the survey are known to offer these services, but
only four provided volume data for 1986 and 1987.   In 1986, these four firms
reported solidifying and/or stabilizing a total of 66 thousand WMT of wastes.
TV :ir reported 1987 volume for this technology rose 13 percent as compared to
1936 -- to 75 thousand WHT.  These volumes are not shown separately-in Exhibit
3-3 as these firms preferred to count these volumes only once under their
volum-3 landfilled.  IGF assumes that the other firms offering these services,
but who did not report these volumes separately, also included any waste
volume solidified or stabilized in their landfill volume total.

       10 --

        0 •*-

         co Tieeovery

   For th±a. .survey, this service sector encompasses the recovery of spent
solvents-,- oils, and metals from hazardous wastes,  as well as the blending (but
not burning) "of hazardous wastas as fuel (energy recovery).  In 1986,
respondents reported that waste volumes handled by resource recovery
operations dropped 17 percent,  from 316 to 264 thousand WMT.  However, in
1987, resource recovery saw a resurgence in waste volumes handled, increasing
over 1986 levels by 25 percent to 330 thousand WMT.  Most of this increase was
attributed to growth in fuel blending activity to support the. demand for
hazardous wastes as fuels by cement kilns and industrial furnaces.  Smaller
volumes of halog-nated solvents were handled by recyclers in both 19&6 and
                              Resource  Recovery
     ; 0 0
    100 -•

   The vo'l-cme of waste reported handled at commercial deep veil injection
facilitie-s in the survey decreased by 34 percent -- to 271 thousand. WMT --
over the period of 1935 through 1987.  The exhibit below also shows that dnep
well injection volumes have declined steadily since 1983 for the firms
participating in this annual survey.  Some of the decline can be attributed to
the temporary closures of a few of the deep well Injection facilities during
at least a portion of this two-year period.  Most respondents expected furtha :
declines in volumes sent to commercial deep well injection facilities,
although several firms expected to recover some of their lost market share.
                            Deep  Well  Injection
   800 -

                  UTCTSZ2ATIOH CAPACITY B&3 IHC12ASZD B7 98 PSRCEET SliTCS 1935

    Commercl-al incineration capacity operated by several of the firms surveyed
 increased by-98 percent from 1985 to 1987.   As shown below,  total capacity in
 1985  was  raportsd to ha 318 thousand WMT and in 1987 has risen to an estimated
 631 thousand tfMT.  Over cwo-thirds of the increase in capacity occurred in
 1987  with four firms increasing their capacity in 1986 and three in 1987.
 Between 1985 and 1936,  respondents raportsd increasing incineration capacity
 by 24 percent, and between 1987 ar.d 1986 by nearly 60 percent.  Some of the
 increase  in capacity has been brought about by de-bottlenecking existing
 capacity, but several firas expanded, opened, or acquired incinerator units in
 1986 and/or in 1987.  Even greater capacity increases -- anywhere from 200 to
 300 percent -- are expected between 1988 and 1991 (see Section 2.3).

    Incineration capacity grew at a faster paca than the increase in waste
 volumes received for incineration ovar this period.  Estimated incineration
 capacity  utilization was 85 percent in 1985, rose .;lightly to 89 percent in
 193S, and stands at 75 percent in 1987.   A few firms reported that backlogs
 wars down appreciably at their facilities and that they were having trouble
 soaking \rp their increased capacity.  Incineration capacity utilization for
 individual finas in IS 87 ranged from 62 to 100 percent (average: 85 percent)  .
 as compared to a range of 71 to 94 percent in 1986 (average: 86 percent).
                        (Capacity  end Capacity  Utilization)
700 -•

600 -•

500 -•

400 ••

300 ••

200 ••

100 ••

  0 --
                           El CAPACITY  M  VCLUME