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TABLE OF CONTENTS
Part Page
A EXECUTIVE SUMMARY 1
B VOLUME OF WASTE SOLVENTS AFFECTED BY
THE LAND DISPOSAL RESTRICTIONS 4
Summary of Data Gathering Methodology 4
Land Disposal Practices 5
Identification of Waste Solvent Physical
and Chemical Characteristics 8
Other Capacity Requirements 17
C EVALUATION OF REQUIRED TREATMENT
AND RECYCLING CAPACITY 24
Solvent-Water Mixtures 24
Organic Liquids 29
Organic Sludges and Solids 35
Inorganic Sludges and Solids 36
Summary of Capacity Requirements 37
D ASSESSMENT OF AVAILABLE TREATMENT AND
RECYCLING CAPACITY 40
Tank Treatment Capacity 40
Solvent Recycling Capacity 41
Incineration Capacity 42
Fuel Substitution 43
E COMPARISON OF CAPACITY REQUIREMENTS WITH
AVAILABLE CAPACITY 45
F BIBLIOGRAPHY 47
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LIST OF TABLES
Table Page
B-1 VOLUME OF WASTE SOLVENTS
CURRENTLY LAND DISPOSED .......................... 6
B-2 VOLUME OF WASTE SOLVENTS AFFECTED
BY LAND DISPOSAL RESTRICTIONS .................... 9
B-3 CODES FOR PHYSICAL DESCRIPTIONS OF
WASTE STREAMS. ................ ................... 10
B-4 REPORTED PHYSICAL FORM OF WASTE SOLVENTS
AFFECTED BY LAND DISPOSAL RESTRICTIONS ........... 13
B-5 DISTRIBUTION OF UNKNOWN SOLVENT WASTES INTO
WASTE GROUPS .............. ; ...................... 14
B-6 ESTIMATED VOLUME OF SOLVENTS AFFECTED BY
LAND DISPOSAL RESTRICTIONS BY WASTE GROUP ........ 15
B-7 MEAN SOLVENT CONCENTRATIONS OF
DISTILLATION RESIDUES ............................ 18
B-8 SMALL QUANTITY GENERATOR (SQG) WASTES
PREDICTED TO REQUIRE TREATMENT AND RECYCLING
AFTER IMPLEMENTATION OF SQG REGULATIONS .......... 20
B-9 DISTRIBUTION OF SMALL QUANTITY GENERATOR
WASTE INTO WASTE GROUPS .......................... 22
B-10 TOTAL QUANTITY OF SPENT SOLVENTS REQUIRING
TREATMENT AND RECYCLING CAPACITY ................. 23
C-1 WASTE SOLVENT MANAGEMENT PRACTICES FROM THE
INDUSTRY STUDIES DATA BASE. . . .................... 26
C-2 VOLUME OF SOLVENT WASTE REQUIRING TREATMENT
AND RECYCLING CAPACITY ........................... 38
C-3 SOLVENT WASTE TREATMENT AND RECYCLING
DEMAND ........................................... 39
E-1 COMPARISON OF ALTERNATIVE TREATMENT AND
RECYCLING DEMAND WITH UNUSED CAPACITY ............ 46
ii
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LIST OF FIGURES
Figure Page
C-1 DISTRIBUTION OF Btu CONTENT BY WASTE
CODES FOR 183 INCINERATED RCRA WASTES 2?
C-2 DISTRIBUTION OF BTU CONTENT FOR 354
INCINERATED RCRA WASTES 28
C-3 DISTRIBUTION OF BTU CONTENT vs TOTAL
NON-COMBUSTIBLES FOR INCINERATED
NON-HALOGENATED SOLVENT WASTES 32
C-4 DISTRIBUTION OF BTU CONTENT vs TOTAL
NON-COMBUSTIBLES FOR INCINERATED
HALOGENATED SOLVENT WASTES 33
iii
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PART A
EXECUTIVE SUMMARY
This volume of the background document discusses the volume
of hazardous waste solvents affected by the land disposal
restrictions and identifies the unused capacity of alternative
treatment and recycling technologies for these solvents. Specif-
ically, the following items are presented:
1. The volumes and characteristics of waste solvents affected
by the land disposal restrictions,
2. An evaluation of required treatment and recycling capacity,
3. An assessment of available treatment and recycling
capacity, and
4. A comparison of capacity requirements with available
treatment and recycling capacity.
Data from the RIA (Regulatory Impact Analysis) Mail Survey
performed in 1981 were used to quantify and characterize the
solvent wastes affected by the land disposal restrictions set
forth in the 1984 Hazardous and Solid Waste Amendments (HSWAs).
From the questionnaire information, it was estimated that 214
million gallons of solvent wastes will require alternative
treatment and recycling capacity. The 1984 HSWAs also require
the proper disposal of wastes generated by what are known as
Small Quantity Generators (SQGs). Solvent wastes generated by
the SQGs will result in an additional 7.8 million gallons,
bringing the total quantity to 222 million gallons. Additional
demand for treatment capacity may also result from increased
activities under the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA). The extent to which
this will occur, however, is unknown at this time.
Respondents to the RIA Mail Survey were requested to provide
a short physical description of their waste. This information is
important because it allows the evaluation of the various treat-
ment and recycling technologies with respect to the physical and
chemical characteristics of the waste solvent. Using the survey
data, the 222 million gallons of solvent waste have been divided
into the following groups:
1. Solvent-water mixtures,
2. Organic liquids,
3. Organic sludges and solids, and
4. Inorganic sludges and solids.
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Each waste group was further divided into halogenated and non-
halogenated organic groups using the reported hazardous waste
codes (i.e., F001 through F005).
Solvent-water mixtures are characterized as predominately
water with less than one percent total organic carbon. Con-
versely, organic liquids have organic concentrations greater than
one percent. Both waste groups are also considered to have
suspended solids contents less than one percent.
The majority of the organic sludges and solids are reported
to be residues from solvent reclamation and recycling practices.
As such, this waste stream frequently contains total organic
concentrations greater than one percent. Inorganic sludges and
solids are characterized as treatment sludges and filter cakes,
which have high solids content. This latter waste group is also
assumed to include soils contaminated with solvent constituents.
Given the physical and chemical characteristics of these
groups, the appropriate alternative treatment and recycling
technologies are treatment in tanks (biological treatment, carbon
and resin adsorption, steam and air stripping, and chemical
oxidation), incineration, fuel substitution, or distillation for
solvent recovery.
The physical and chemical characteristics of the waste
groups were compared with the restrictive waste characteristics
for each of the above treatment and recycling technologies.
Based on this comparison, each of the technologies is applicable
to different waste groups, as shown below:
Appropriate Treatment and
Waste Stream Recycling Technologies
1. Solvent-water mixtures Treatment in tanks
2. Halogenated organic liquids Distillation
Incineration
3. Organic sludges and solids Incineration
4. Inorganic sludges and solids Incineration
Fuel substitution is an appropriate technology for nonhalogenated
organic liquids and nonhalogenated organic sludges and solids;
however, the Agency is unable to predict the unused available
capacity for this technology. Consequently, fuel substitution is
not included in the comparison of capacity requirements with
available treatment and recycling capacity.
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When the volume of solvent waste (million gallons per year)
is compared to the available treatment and recycling capacity,
several shortages of capacity are identified, as shown below:
Treatment or Recovery Waste Quantity Requiring Unused
Technology Alternative Capacity Capacity
Distillation 8.6 22
Incineration 29.1 <25.6
Treatment in tanks 185 <112
These data show a significant shortfall in tank treatment capac-
ity for treating the solvent-water mixtures and a shortfall of
incineration capacity for the total volume of solvent waste
requiring incineration. If incineration capacity is not required
immediately for the 6.7 million gallons of inorganic sludges and
solids, enough incineration capacity is available to treat the
remaining 22.4 million gallons of solvent wastes requiring
incineration. It could be concluded that insufficient treatment
and recycling capacity currently exist to manage solvent-water
mixtures and inorganic sludges and solids.
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PART B
VOLUME OF WASTE SOLVENTS AFFECTED BY
THE LAND DISPOSAL RESTRICTIONS
This part of the background document presents an overview of
waste solvent generation rates and management practices. The
data and information presented here are used in Part C to assess
treatment and recycling capacity needs for waste solvents
restricted from land disposal by this rulemaking.
1. SUMMARY OF DATA GATHERING METHODOLOGY
Data concerning the volume of waste solvents generated each
year and the manner in which "these wastes are currently being
managed were obtained from an industry survey. The survey and
resulting data base are officially known as the National Survey
of Hazardous Waste Generators and Treatment, Storage, and Dis-
posal Facilities Regulated under RCRA in 1981 (2). It is more
commonly referred to as the RIA (Regulatory Impact Analysis) Mail
Survey. The latter term will be used throughout the remainder of
this document.
During the survey, questionnaires were mailed to a statisti-
cally selected population of facilities regulated under RCRA in
1981. Questionnaire recipients were generators of hazardous
waste and facilities which either treated, stored, or disposed of
hazardous waste. This latter category of facilities, called TSD
facilities, are those facilities that conduct either commercial
or private treatment, storage, or disposal operations. The
questionnaire received by the TSD facilities requested data and
information on the volumes and types of wastes managed. Specific
wastes were identified by the TSD facilities using the conven-
tional EPA hazardous waste codes established in 40 CFR Part 261.
Approximately 11,000 questionnaires were mailed; the
response rate was 94 percent. All responses received were
screened prior to inclusion in the data base to ensure that
reported wastes were hazardous under the RCRA definition, and
that they were treated, stored, or disposed in processes regu-
lated under RCRA.
Valuable data concerning types of wastes generated as well
as land disposal practices were obtained from the survey. The
resulting RIA Mail Survey data base has previously undergone
extensive evaluation (1,2). This data base provides the basis
for the information and data presented in this section concerning
waste volumes and current land disposal practices.
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2. LAND DISPOSAL PRACTICES
Land disposal is defined under RCRA as any placement of
hazardous waste into or on the land. Therefore, storage and
treatment of hazardous waste in or on the land is also considered
land disposal. Land disposal methods can be divided into numer-
ous categories. Four of these methods are addressed in detail in
this document: storage and disposal in landfills; disposal in
waste piles; treatment and disposal by land treatment; and
treatment, storage, and disposal in surface impoundments.
Utilization of salt dome formations, salt bed formations, and
underground mines and caves are additional methods of land
disposal that are affected by this rulemaking. Currently there
is insufficient information to document the volumes of waste
solvents disposed by these three methods; therefore, they are not
addressed in the analysis of volumes and alternative treatment
capacity. Underground injection, another form of land disposal,
will be covered under a separate rulemaking; thus it is not
considered further in this analysis.
The quantities of waste solvents managed by each of the four
land disposal methods affected by this rulemaking were estimated
using RIA Mail Survey data. The survey requested treatment,
storage, and disposal facilities to provide information on the
type and quantity of each hazardous waste managed at that facil-
ity, as well as the method of management. The solvent waste
codes include the waste codes F001, F002, F003, F004, F005; and
wastes coded by individual constituent codes (i.e., U and P
codes). These individual constituent codes are listed in Volume
I of this background document. The data obtained on wastes
reflecting these waste codes were tabulated and assigned statis-
tical weights. They were then used to project national estimates
of waste volumes (2).
Table B-1 presents the volumes of waste solvents currently
land disposed by each of the four methods: landfill, land treat-
ment, waste pile, and surface impoundment. Surface impoundments
are further divided into four management techniques. These
present a special case, which is discussed separately below. The
estimates in Table B-1 differ slightly from those developed
previously for EPA (1) for the following reasons:
1.. Disposal through deep well injection is no longer
included,
2. Treatment, storage, and disposal using surface impound-
ments is now included, and
3. Disposal in waste piles is now included.
Table B-1 also presents estimates of the volume of waste
solvents currently treated, stored, or disposed of in surface
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TABLE B-1
VOLUME OF WASTE SOLVENTS
CURRENTLY LAND DISPOSED
(Million gallons per year)
Waste Disposition
Landfill
Land treatment
Waste pile
Treatment only in
surface impoundments
Storage only in
surface impoundments
Disposal in surface
impoundments
Treatment and storage
in surface
impoundments
TOTAL
Volume
32.1
0.001
0.743
389
318
8.79
452
1,200
Percent of Total
2.7
32
27
-3A
100
Source: RIA Mail Survey
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impoundments. Four scenarios were considered when evaluating the
quantity of waste solvents that are managed in surface impound-
ments:
1. Storage in surface impoundments,
2. Treatment in surface impoundments,
3. Concurrent storage and treatment in surface
impoundments, and
4. Disposal in surface impoundments.
Data from the RIA Mail Survey were used to estimate the
volume of waste solvents currently being managed by each of these
methods, as well as the volume of those waste solvents that will
require alternate treatment or recycling capacity. The use of
questionnaire data concerning each of these methods is discussed
below.
About 8.79 million gallons of waste solvents are disposed in
surface impoundments each year. Disposal in surface impoundments
is considered land disposal, which is restricted by this rule-
making. Consequently, all of this waste will require alternate
treatment, recycling, or disposal by alternative methods to land
disposal as a result of this rulemaking.
A number of respondents reported that they were storing
waste solvents in surface impoundments. Storage implies a
temporary placement of wastes in the surface impoundment, while
disposal implies a permanent containment. Waste solvents stored
in surface impoundments are eventually treated or recycled, or
they are routed to permanent disposal in other surface impound-
ments or by other means. Thus, the volumes of waste solvents
reported as being stored in surface impoundments were not
included in the estimates of volumes requiring alternate dis-
posal. This was done to avoid counting them twice: once when
they are stored and again when they are finally disposed.
In addition to the waste solvents stored in surface impound-
ments, 841 million gallons of waste solvents per year are esti-
mated to be treated, or treated and stored concurrently, in
surface impoundments. Under RCRA, surface impoundments may
continue to receive hazardous wastes if the surface impoundments
are used for treatment. These surface impoundments, however,
must meet certain design and operating criteria (see RCRA Section
3005 (j)(11)(A) and (B)). According to RCRA, any surface
impoundment that continues to receive banned solvent waste must
be equipped with double liners, leachate collection systems, and
ground water monitoring systems. Because of these stipulations,
it is anticipated that a portion of the impoundments not meeting
these design criteria will no longer receive hazardous waste
because of the expense of achieving these criteria. It is
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estimated that as a result of the land disposal restrictions,
20.5 percent of the volume of solvents currently treated in
surface impoundments will no longer be placed in surface impound-
ments and will require management by alternate treatment or
recycling methods. This assumption is consistent with the
findings of the Regulatory Impact Analysis supporting this
rulemaking (3).
Based on the analysis given above, the total volume of waste
solvent that will compete for alternative treatment and recycling
capacity is presented in Table B-2.
3. IDENTIFICATION OF WASTE SOLVENT PHYSICAL
AND CHEMICAL CHARACTERISTICS
In order to assess the treatment capacity requirements that
will result from the land disposal restrictions, it is necessary
to identify the physical and chemical form of the 214 million
gallons of waste solvents land disposed annually. Without this
information, it is not possible to identify which treatment
technologies are applicable to a given waste stream. For exam-
ple, solids contaminated with solvents are not amenable to
reclamation by distillation; the high solids level would plug or
foul the system.
Data contained in the RIA Mail Survey were used to accom-
plish this task. The questionnaires provided a space for each
respondent to provide a written description of each waste, in
addition to its RCRA waste code. This information has been
included in the data base, and it forms the basis for identifying
the quantities of solvent wastes generated and managed by physi-
cal and chemical form. The descriptions of the wastes were
analyzed and condensed into the physical and chemical codes shown
in Table B-3. All codes were further identified as either
inorganic solids, inorganic sludges, inorganic fluids (solvent-
water mixtures), organic fluids, organic sludges and solids, or
miscellaneous.
The hazardous waste codes reported by the respondents can be
used to identify the quantity of waste that is halogenated (i.e.,
containing bromine, chlorine, fluorine, or iodine). This infor-
mation is important because halogen content influences the
treatability of the waste and could preclude the use of a given
treatment technology. Waste solvents reported as F001 and F002
(as well as the corresponding P and U waste codes) are halogen-
ated wastes because the constituents for which they are listed
are halogenated (see 40 CFR Part 461, Appendix VII). Similarly,
waste solvents reported as F003, F004, and F005 (or as the
related P and U wastes) are nonhalogenated wastes. Given this
information, the total volume of solvent waste affected by the
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TABLE B-2
VOLUME OF WASTE SOLVENTS AFFECTED
BY LAND DISPOSAL RESTRICTIONS
(Million gallons per year)
Waste Disposition Volume
Landfill 32.1
Land treatment 0.001
Waste pile 0.743
Treatment only in surface impoundments 79.8
Storage only in surface impoundments 0
Disposal in surface impoundments 8.79
Treatment and storage in surface
impoundments 92.8
214
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TABLE B-3
CODES FOR PHYSICAL DESCRIPTIONS OF WASTE STREAMS
INORGANIC SOLIDS
INORGANIC SLUDGES
SOLVENT-WATER MIXTURES
101. Contaminated Dirt
102. Fly Ash
193. Baghouse or APCD Dust
104. Bottom Ash or Slag
105. Spent Carbon
106. Spent Adsorbents (NOS)
107. Spent Filter Aids
108. Polymerized Solids
109. Spent Catalysts
110. Off-Specification Solid Chemicals
111. Waste NaOH or KOH
112. Metal Fines
113. Asbestos
200. Inorganic Sludge (NOS)
201. Metal Hydroxide Sludge
202. Wastewater Treatment Sludge
203. Biotreatment Sludge
204. Cooling Tower Sludge
205. Lagoon/Pond Sludge
206. Filter Cakes
207. APCD Sludge
208. Sludge from Electroplating
300. Aqueous Solution (NOS)
301. Wastewater (NOS)
302. Process Water
303. Wash/Rinse Water
304. Cooling Tower Slowdown
305. Lagoon/Pond Water
306. Incinerator Scrubber Waters
307. Caustic Scrubber/Petroleum Refinery
308. Waste Acid
309. Waste Caustic Solutions
310. Concentrated Chemical Solutions
311. Waste Acidic Solution
312. Acid and Base
313. Chromic Acid Waste
NOS = Not Otherwise Specified
10
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TABLE B-3 (Continued)
CODES FOR PHYSICAL DESCRIPTIONS OF WASTE STREAMS
ORGANIC FLUIDS
ORGANIC SLUDGES/SOLIDS
MISCELLANEOUS
400. Organic Liquid (NOS)
401. Spent Solvents
402. Light Ends
403. Hydraulic Oils
404. Cutting Oils
405. Transformer Oils
406. Waste Oils (NOS)
407. Oil/Water Emulsion
408. Waste Paint
409. Paint Thinner
410. Off-Specification Liquids/Solvents
411. Coatings (laquer, varnish, epoxy)
500. Organic Sludge (NOS)
501. Heavy Ends
502. Still Bottoms/Residues
503. Tars
504. Oily Sludge
505. Paint Sludge
506. Tank Bottoms
510. Solid Organic Chemicals
000. Unknown/Undescribed
601. Lab Packs
602. Lab Wastes
603. Liquids (NOS)
604. Resins (form unspecified)
605. Paint Stripper
606. Sludge (NOS)
610. Empty Containers
611. Gas
612. Organic Waste (NOS)
NOS = Not Otherwise Specified
11
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land disposal restrictions as presented in Table B-2 can be
divided into waste groups. This distribution is shown in Table
B-4.
In order to properly evaluate the capacity requirements for
alternative treatment and recycling, it is necessary to distrib-
ute into waste groups the wastes that are reported in the survey,
but that are not identified by physical form, the so called
miscellaneous or unidentified waste. The following methodology
and assumptions were used to assign the unidentified waste to
waste groups:
1. Unidentified waste was assumed to be divided into waste
groups in the same proportions as the characterized
waste.
2. The unidentified waste distributed into waste groups
(inorganic sludges and solids, organic liquids, and
organic sludges and solids) was then divided into
halogenated and nonhalogenated wastes. The division was
performed by assuming that the unidentified wastes
follow the same ratio of halogenated to nonhalogenated
wastes given for other wastes in Table B-4.
Approximately 37 percent (5.54/14.8) of the unidentified
wastes were reported to be halogenated; thus for each
waste group in Table B-5, 37 percent of the total amount
was assumed to be halogenated and 63 percent was assumed
to be nonhalogenated.
Given these assumptions, the waste that appeared as unidentified
in Table B-4 can be divided into waste groups, as shown in Table
B-5.
Table B-6 then presents the total estimated volumes of spent
solvents that are affected by the land disposal restrictions by
waste group. The characteristics of these waste groups are
discussed in greater detail below.
a. Solvent-Water Mixtures
From the survey data it is apparent that three facilities
with large-volume aqueous waste streams account for 94 percent of
the total volume of solvent-water mixtures subject to this
analysis. It is assumed that these three waste streams ade-
quately represent all F001 through F005 solvent-water mixtures
that are currently land disposed. The RIA Mail Survey character-
izes these three waste streams as 99 percent water. The sum of
the other constituents (including solids) in these waste streams
must therefore be less than one percent. According to the RIA
Mail Survey, 98 percent of the solvent-water mixtures (and 85
12
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TABLE B-4
REPORTED PHYSICAL FORM OF WASTE SOLVENTS AFFECTED
BY LAND DISPOSAL RESTRICTIONS
(Million gallons per year)
Waste Form
Unknown
Inorganic Sludges
Solvent-Water Mixtures
Organic Liquids
Organic Sludges/Solids
Total
ilogenated
5.54
6.14
0
7.39
4.8Q
Nonhalogenated
9.3
0.103
173
6.28
1.QO
Total
14.8
6.25
173
13.7
6.78
24.0
190
214
Source: RIA Mail Survey
13
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TABLE B-5
DISTRIBUTION OF UNIDENTIFIED SOLVENT WASTES
INTO WASTE GROUPS
(Million gallons per year)
Waste Form Halogenated Nonhalogenated Total
Inorganic Sludges/Solids 0.19 0.32 0.5
Solvent-Water Mixtures 0 12.8 12.8
Organic Liquids 0.37 0.63 1.0
Organic Sludges/Solids 0.19 0.32 0.5
Total 0.75 14.07 14.8
14
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TABLE B-6
ESTIMATED VOLUME OF SOLVENTS AFFECTED BY LAND
DISPOSAL RESTRICTIONS BY WASTE GROUP
(Million gallons per year)
Waste Form
Inorganic Sludges and
Solids
Solvent-Water Mixtures
Organic Liquids
Organic Sludges/Solids
Total
Halogenated Nonhalogenated Total
6.33 0.423 6.75
0
7.76
5.08
19.2
186
6.91
2.22
196
186
14.7
7.28
215
15
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percent of all solvent wastes) land disposed annually are managed
in surface impoundments. Additional data from the Industry
Studies Data Base (ISDB) characterize all waste streams contain-
ing the constituents of F001 through F005 wastes that are placed
in surface impoundments as averaging 0.3 percent (3|000 mg/1)
total solvent (4). Based on these data it is assumed that all
solvent-water mixtures contain less than one percent (10,000
mg/1) total organic constituents and less than one percent total
suspended solids.
b. Organic Liquids
Because solvent-water mixtures contain less than one percent
total organic constituents, organic liquids are assumed to have
greater than one percent total organics. It also appears to be a
reasonable assumption that organic liquids are low in
suspended solids (less than one percent). If this were not the
case, they would have been reported in the RIA Mail Survey as
organic sludges.
According to the survey, over 80 percent of the 14.7 million
gallons of organic liquids that are land disposed annually are
described as "spent solvents." By definition, all wastes listed
in 40 CFR Part 261.31 as F001, F002, F003, F004, and F005 are
"spent solvents." However, it is EPA's judgement that solvent
wastes identified as "spent solvents" in the survey are actually
used, highly concentrated waste solvents resulting from certain
industrial applications.
For example, metal degreasing is a common means of generat-
ing a concentrated spent solvent. Industrial grade metal
degreasing solvents such as 1,1,1-trichloroethane contain less
than 100 mg/1 water and less than 10 mg/1 non-volatile residue.
As metal degreasing operations proceed, solvent vapors are
contained within the system by contacting the vapors with cooling
coils so that the vapor is condensed and returned to the system.
At the same time, atmospheric moisture also condenses on the
cooling coils. Quite frequently, water that may accumulate in
the solvent during degreasing is removed by gravity separation in
a quiescent tank. If the water concentration is allowed to
increase in the solvent during degreasing, the chlorinated
hydrocarbons begin to hydrolyze and form hydrochloric acid. As
this occurs, the effectiveness of the solvent is reduced and a
corrosive mixture is produced. Hydrolysis is prevented by
incorporating chemical additives into the solvent that react with
the water (13).
Consequently, spent solvents from modern degreasing opera-
tions contain a high percentage of solvent contaminated with oil
16
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and grease removed from the metal parts. The water accumulation
in the spent solvent from modern units is negligible.
In older units that do not remove water, water will accumu-
late in the system and can reach concentrations as great as 80
percent (1). Even so, the solvent content is still reported to
be above 10 percent, in addition to 5 percent oil.
c. Organic Sludges and Solids
The majority of this waste is reported to be heavy ends,
still bottoms, or residues from distillation units used to
reclaim spent solvents, all of which are high in solids content.
Data from the ISDB show that these wastes contain significant
quantities of solvents (4). As shown in Table B-7, the solvent
concentration is generally reported to be above one percent. For
many of the solvent constituents, the mean concentration is above
10 percent and ranges up to 50 percent. Based on this informa-
tion, all organic sludges and solids are assumed to have solids
and total organic contents greater than one percent.
d. Inorganic Sludges and Solids
Inorganic sludges and solids reported in the survey include
those wastes listed in Table B-3 as numbers 100 through 208. The
majority of these wastes are treatment sludges and filter cakes,
which have high solids contents. Based on these descriptors, all
of the inorganic sludges and solids are assumed to have a solids
content greater than one percent and total organic content less
than one percent.
The inorganic sludges and solids waste group also includes
soils contaminated with solvents. According to RCRA, any con-
taminated soil resulting from the spill of a listed hazardous
waste (e.g., F001 through F005) must also be managed as a listed
hazardous waste. Contaminated soils may contain greater than one
percent organics; however, it was assumed that the respondents to
the RIA Mail Survey reported any soil contaminated with solvents
as an inorganic solid.
4. OTHER CAPACITY REQUIREMENTS
a. Small Quantity Generators
The discussions above present estimates of the quantities of
solvent wastes that will be affected by the land disposal
restrictions proposed by this rulemaking. To fully evaluate
treatment and recycling capacity requirements, other wastes that
will compete for alternative -capacity with solvent waste
restricted from land disposal must be identified and included in
17
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TABLE B-7
MEAN SOLVENT CONCENTRATIONS
OF DISTILLATION RESIDUES
(Percent)
Heavy Ends Distillation Residues
Number of Mean Number of Mean
Constituent Reported Values Concentration Reported Values Concentration
carbon disulfide 4 53 -
methyl isobutyl ketone 2 30 1 30
toluene 32 2? 23 30
acetone 9 25 6 23
n-butyl alcohol 12 23 8 22
isobutanol 5 22 4 20
ethyl acetate 4 18 3 22
xylene 7 13 5 10
ethylbenzene(s) 14 11 6 15
chlorobenzene 17 11 14 10
methanol 14 11 8 3
tetrachloroethylene 26 8 12 4
methylene chloride 14 6 9 0.2
carbon tetrachloride 19 6 85
trichloroethylene 22 4 14 4
1,2-dichlorobenzene 82 63
cyclohexanone 6 1 4 3
1,1,1-trichloroethane 12 0.3
trichlorofluoromethane 2 2 -
Source: Science Applications International Corporation. Industry Studies Data Base.
Prepared for the U.S. EPA, Office of Solid Waste. 1985.
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the analysis. This will include those wastes, for which new
requirements are proposed, generated by what are known as Small
Quantity Generators (SQGs) (see generally 5£ FR 31278). Prior to
the Hazardous and Solid Waste Amendments (HSWAs) of 1984, wastes
generated by SQGs were not subject to most RCRA requirements.
The amendments, however, now require that certain SQGs manage
their wastes as hazardous where appropriate. The final
regulations pertaining to these SQGs will result in an additional
demand for alternative capacity that must be accounted for here.
As shown in Table B-8, approximately 7.8 million gallons per year
of spent solvent waste are attributable to SQGs.
The volume of waste generated by SQGs predicted to require
treatment and recycling as a result of the HSWAs was derived from
the National Small Quantity Generators Survey, conducted for the
U.S. EPA (5). Of the waste types reported to be generated by the
respondents to the survey, three were determined to be solvent
wastes that will require treatment and recycling capacity: spent
solvent wastes, solvent still bottoms, and dry cleaning filtra-
tion residues. The volume of each of these waste types generated
by SQGs is presented in Table B-8. The majority of the waste (75
percent) was reported to be spent solvent wastes. Twenty percent
is dry cleaning filtration residues, and the remaining 5 percent
was reported to be still bottoms. The amount of spent solvent
wastes predicted to require treatment and recycling capacity was
derived by adding the volumes of each of these three waste types
to obtain 7.8 million gallons per year.
As indicated previously, the physical and chemical charac-
teristics of a waste stream determine the appropriate treatment
and recycling technologies applicable to that waste stream.
Thus, it is necessary to segregate the SQG waste into the physi-
cal groupings described previously for the waste solvents so that
capacity limitations can be fully evaluated. The SQG waste has
been segregated into waste groups using the following methodology
and assumptions:
1. The SQG spent solvent waste is assumed to be an organic
liquid (i.e., the total organic content is greater than
one percent).
2. The solvent still bottoms and dry cleaning filtration
residues are assumed to be organic sludges and solids.
3. The ratio of halogenated to nonhalogenated spent solvent
from the SQGs is assumed to be the same as the ratio for
the 13.7 million gallons of organic liquid currently
land disposed annually, as presented in Table B-4.
19
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TABLE B-8
SMALL QUANTITY GENERATOR (SQG) WASTES PREDICTED TO REQUIRE
TREATMENT AND RECYCLING AFTER IMPLEMENTATION
OF PROPOSED SQG REGULATIONS
(Million gallons per year)
Waste Group
SQG Spent Solvent Wastes
SQG Solvent Still Bottoms
SQG Dry Cleaning Filtration Residues
Total SQG Wastes
Quantity
Requiring
Treatment
and Recycling
5.9
0.3
7.8
Source: ABT Associates. National Small Quantity Generators Survey,
Prepared for the EPA, Office of Solid Waste. 1985.
20
-------
Thus, 54 percent (7.39/13.7) of the 5.9 million gallons
is assumed to be halogenated organic liquids.
4. The ratio of halogenated to nonhalogenated sludges for
the SQGs is assumed to be the same as for the 6.8
million gallons of organic sludges currently land
disposed annually, as presented in Table B-4. Using
this assumption, 72 (4.9/6.8) percent of the 1.87
million gallons are halogenated organic sludges.
With the above methodology and assumptions, the volume of waste
attributable to SQGs by waste group is presented in Table B-9.
These data can then be aggregated with the data in Table B-6 to
determine the total volume of waste that will compete for alter-
native capacity. A summation of these data is presented in Table
B-10. Treatment and recycling requirements for SQG wastes is
discussed in Part C. This volume of waste is evaluated against
existing alternative capacity in Part E of this volume.
b. CERCLA Waste
It is also possible that wastes resulting from the Compre-
hensive Environmental Response, Compensation, and Liability Act
(CERCLA) could result in additional competition with waste
solvents and other RCRA wastes for alternative capacity. There
are insufficient data, however, to accurately estimate the
treatment and recycling methods appropriate to either past or
future CERCLA waste. Further, the Agency at this time does not
have the information necessary to determine to what extent future
CERCLA activities will increase the current demand for treatment
and recycling capacity. As a result, it is assumed for the
purpose of this proposal that the alternative capacity (e.g.,
incineration capacity) required by CERCLA wastes will remain
constant. If the necessary information becomes available prior to
final promulgation, the additional capacity needs of CERCLA
wastes will be considered in this analysis.
21
-------
TABLE B-9
DISTRIBUTION OF SMALL QUANTITY GENERATOR
WASTE INTO WASTE GROUPS
(Million gallons per year)
Waste Form Halogenated Nonhalogenated Total
Organic Liquids 3.1 2.8 5.9
Organic Sludges 1.3 0.6 1.Q
Total 4.4 3.4 7.8
22
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TABLE B-10
TOTAL QUANTITY OF SPENT SOLVENTS REQUIRING
TREATMENT AND RECYCLING CAPACITY
(Million gallons per year)3
Waste Form Halogenated Nonhalogenated Total
Solvent-Water Mixtures 0 186 186
Organic Liquids 10.9 9.7 20.6
Organic Sludges 6.4 2.8 9.2
Inorganic Sludges 6.3 0.4 6.7
Total 23.6 199 223
aThe volumes presented here are a summation of the volume of
solvent waste currently land disposed (Table B-6) and the
volume of waste attributable to small quantity generators
(Table B-9).
23
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PART C
EVALUATION OF REQUIRED
TREATMENT AND RECYCLING CAPACITY
The waste groups affected by this rulemaking were identified
and characterized in detail in Part B. The appropriate alterna-
tive treatment or recycling technologies (BOAT) for each waste
group were presented in Volume II of this document. This section
presents an analysis of the alternative treatment and recycling
capacity that will be required by the solvent waste groups banned
from land disposal by this rulemaking.
Given a particular waste type, there are several treatment
and recycling options available to a hazardous waste generator
that can be used as an alternative to land disposal. Therefore,
it is impossible to predict precisely what treatment technologies
any of the numerous generators will -choose as an alternative to
land disposal. The factors that will influence which treatment
or recycling technology is selected are both technical and
economic. The cost of applying a specific technology to a waste
are facility-specific, depending on the characteristics and
volume of the waste generated, and the proximity of commercial
treatment and recycling facilities. As a result, the analysis
given here will consider economics only implicitly, in that the
capacity of technologies currently available to treat hazardous
wastes is influenced by the relative economic feasibility. This
evaluation will primarily consider the technical feasibility of
applying available technologies to specific waste groups.
In the discussions that follow, the waste groups have been
assigned to a given treatment or recycling technology based on
the information presented in Part B of this volume, and in Volume
II of this document. Information obtained from the ISDB is also
used to select appropriate treatment technologies for the waste
groups.
1. SOLVENT-WATER MIXTURES
As discussed in Part B, solvent-water mixtures are aqueous
mixtures containing less than one percent total organic content
by weight. An estimated 186 million gallons of solvent-water
mixtures land disposed each year will be affected by the land
disposal restrictions and will require alternative management.
Based on the characteristics described in Part B, solvent-
water mixtures are amenable to one or more of the following
wastewater treatment technologies described in Volume II of this
document: biological treatment, carbon and resin adsorption,
24
-------
steam and air stripping, chemical oxidation, or some combination
of these methods. In addition, incineration is a treatment
option for solvent-water mixtures. As discussed in Volume II,
each of these technologies can achieve BDAT levels for some waste
streams.
Because of the low total organic content, solvent-water
mixtures are not amenable to fuel substitution or reclamation.
Data obtained from the ISDB, presented in Table C-1, demonstrate
that mean solvent concentrations for reclamation are approxi-
mately 40 percent (4). Similarly, the low organic content
indicates that the heat value of this waste is inadequate for
fuel substitution. This is also demonstrated in Table C-1 which
shows that the mean solvent concentration of wastes used as fuel
substitutes is 37 percent. The most viable treatment options for
solvent-water mixtures are incineration and wastewater treatment
in tanks ; these are discussed below in greater detail.
a. Incineration
Data from the ISDB, shown in Table C-1, demonstrate that
even waste streams of very low heat value can be destroyed using
incineration technology. Additional data from the Regulatory
Impact Analysis for the Incinerator Regulations show that wastes
containing 0.1 to 80 percent solvent have been destroyed using
incineration technology (6). A summary of these data is pre-
sented in Figures C-1 and C-2. These figures present graphically
the heat value, in Btus per pound, of incinerated RCRA wastes.
In Figure C-1, the data are presented by waste code. Waste codes
F001, F003, F005, D001, and mixed codes are represented. The
data points available for waste codes F002 and F004 were too few
in number to be considered statistically significant. The
figures indicate that wastes of widely varying heat content are
incinerated. Ignitable wastes (coded D001) in particular have a
mean heat value of only 6,900 Btu/lb.
b. Wastewater Treatment
As stated previously, the solvent-water waste group identi-
fied in the RIA questionnaire information is predominantly water
(over 99 percent). As discussed in Volume II, the most viable
option for managing solvent-water mixtures is some form of
wastewater treatment.
All wastewater treatment methods are defined generically as tank
treatment.
25
-------
TABLE C-1
WASTE SOLVENT MANAGEMENT PRACTICES FROM THE
INDUSTRY STUDIES DATA BASE3
N)
Waste Management Technique
Fuel Substitution for
Industrial Boilers
Discharge to Surface Waters
Discharge to POTW
Treated at a Commercial
Facility (TSDF)
Incineration
Landfill
Stored or Treated in
On-Site Tanks
Reclamation
Surface Impoundments
Injection Well
Number
of Reported
Waste Streams
Mean
Quantity of Wastes Total Solvent
(Million gallons Concentration
per year) (Percent)
61
108
93
16
157
91
120
136
101
61
61.2
2,580
341
165
36.0
39.8
1,590
413
2,130
442
37
0.
1.
26
28
7.
0.
40
0.
5.
31
2
4
71
30
6
Compilation of data for wastes containing the solvent constituents of F001, F002,
.F003, F004, and F005 waste codes.
All concentrations are prior to any treatment.
May include some double counting of waste streams discharged to surface waters.
-------
Code: P001
Type: haloqenated
solvents
mean: 4,800 BTU/lb.
N: 11 wastes
Code: P003
Type: non halogen a ted
solvents
mean: 14,700 BTU/lb.
N: 30 wastes
Code: POOS
Type: nonhalogenated
solvents
mean: 14,000 BTU/lb.
N: 27 wastes
Code: D001
Type: igni table
wastes
mean: 6,900 BTU/lb.
N: 87 wastes
Code: Mixed Codes
Type: igni tables and
solvents
mean: 10,800 BTU/lb.
Nr 28 wastes
( 0 - Bean value)
1 1 1 1
•v:
©
i i i i
• «..;•:.•'.
o
©
1 1 1 1
- : . .s .:. . .
©
i i i i
Ms- . : • : : :::.:: •
*••••• * 5 • • • •*••*••
••• • . .
©
i i i i
•
• •• * •• ••• **• •• •
•
'©
iiii
5,000 10,000 15.000 20,000
BTU/lb.
Source: Supporting Documentation for the RCRA Incineration
Regulations . PB-86-110293. 1984.
FIGURE C-l
DISTRIBUTION OF Btu CONTENT BY WASTE CODES
FOR 183 INCINERATED RCRA WASTES
27
-------
40 -
28
u
NJ
00
e o
•rl *•
e 3
»-• M
•H
^W M
04)
M
• J3
JS
SO -
20 -
10 -
5.000
10,000
BTU/lb.
15,000
20,000
Source: Supporting Documentation for the RCRA Incineration Regulations,
FIGURE C-2
DISTRIBUTION OF Btu -CONTENT FOR 354 INCINERATED RCRA WASTES
-------
This is also supported by ISDB information which shows that
solvent waste streams discharged as wastewaters (i.e., to surface
waters and POTWs) have mean solvent concentrations of approxi-
mately one percent or less. A summary of these data is presented
in Table C-1.
The demonstrated wastewater treatment technologies for
solvent water mixtures are biological treatment, steam and air
stripping, and carbon adsorption. As discussed in Volume II,
biological treatment, steam and air stripping, and carbon adsorp-
tion are demonstrated technologies for many solvent wastes. Other
technologies such as chemical oxidation and resin adsorption, are
not widely demonstrated, but are capable of achieving BDAT
treatment performance levels for some solvent wastes.
Solvent-water mixtures may be treated by many different
combinations of wastewater treatment technologies sequenced in
various process trains taking place in tanks. The choice of
treatments will depend on specific waste characteristics and
economic factors. There are currently insufficient data to
determine precisely the volumes of wastes that would require any
of these specific wastewater treatment technologies. Because
these data are currently unavailable, it is impossible to deter-
mine the future capacity needs for these specific wastewater
treatment technologies. For the purpose of determining capacity
needs in this document, the solvent-water mixtures of less than
one percent total organics are grouped into one treatability
group of wastes, all of which require some form of wastewater
treatment occurring in tanks.
2. ORGANIC LIQUIDS
As discussed above, organic liquids (as opposed to solvent-
water mixtures) are defined in this analysis as those liquids
having a total organic concentration greater than one percent.
From the RIA questionnaire information, over 80 percent of the
13-7 million gallons identified as organic liquids are described
as spent solvents. Such waste streams are amenable to various
management practices such as distillation for solvent recovery
and reuse, destruction through incineration, and destruction
through fuel substitution. Furthermore, it is demonstrated that
these treatment technologies have been utilized to manage spent
solvents. Each technology is discussed in greater detail below.
a. Distillation
Distillation is a suitable method of separation for volatile
liquid organics and for aqueous solutions containing volatile
liquid organics. The boiling points of the components of the
mixture must be separated by 20 C to 30 C. Substances with low
29
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boiling points are more economical to distill because less heat
is required. In addition, mixtures of substances with vastly
different volatilities are easier to separate by distillation
than are mixtures of substances with similar volatilities.
Within these constraints, the primary reason more of the
13.7 million gallons of spent solvents classified as organic
liquids are not recovered through distillation appears to be
economics. Given the past options for managing spent solvents,
land disposal in most situations is less costly than recovering
solvents through distillation. The economic cut-off centers on
the concentration and mixtures of solvents in the waste liquid.
As noted above, because of the heat input required for distilla-
tion, waste streams currently reclaimed by distillation generally
contain solvent concentrations sufficient to offset the recovery
cost. From the ISDB, it appears the mean concentration of
solvent wastes reclaimed through distillation is 40 percent.
Further evaluation of the data shows a range of 0.4 percent to 98
percent. At the lower concentration range, it is likely that the
waste stream is being reclaimed to recover other constituents
that are present at much higher concentrations. Nonetheless,
current and future regulatory and economic incentives will make
distillation a more attractive alternative for the management of
organic liquids.
A second reason that distillation is not currently more
widely used is the practice of commingling different solvents.
In cases where there is no economic incentive to distill and
recover waste solvents, generators often commingle several
different solvents. When solvents are commingled, their recovery
becomes much more difficult. Commingled solvents preclude the
use of the relatively simple and inexpensive binary distillation
units. The single equilibrium stage provided by these units does
not allow for the separation and recovery of more than two
compounds, normally water and one solvent. More complicated and
expensive fractional distillation columns are required to accom-
plish the separation and recovery of multiple solvents from a
single waste stream.
Greater volumes of solvent waste may be recovered by distil-
lation if the waste management practices of generators are
altered to prevent commingling. For example, if waste solvents
1,1,1-trichloroethane and trichloroethylene are mixed together in
a waste stream, pot distillation, commonly used to reclaim a
single solvent constituent, cannot be used to recover the indi-
vidual solvents. Furthermore, although recovered 1,1,1-trichlor-
oethane or trichloroethylene alone may be sold for over $2.00 per
gallon, a recovered mixture of these solvents has little or no
resale value.
30
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b. Fuel Substitution
A second alternative to land disposal for organic liquids is
fuel substitution. For a waste stream to be useful as a fuel
substitute, it must meet certain criteria for two important waste
characteristics: heating value and halogen content. In order
for a facility to utilize a waste solvent as an alternative fuel,
it must contain sufficient heating value to offset the consump-
tion of primary fuel. An EPA survey of industrial boilers,
cement kilns, and aggregate kilns found that most facilities
specify that wastes burned as fuel are acceptable when the
heating value is between 10,000 and 18,000 Btu/lb (7). Analysis
of data from the RIA for the Incinerator Regulations demonstrates
that if the heating value of solvent waste incinerated was above
10,000 Btu/lb, the sum of the noncombustibles totalled less than
30 percent (Figures C-3 and C-4). Much of the 20.6 million gal-
lons of organic liquid is characterized as used, highly concen-
trated spent solvent. It is anticipated that a significant
portion of this waste stream will contain greater than 70 percent
organics and meet the heating value criterion.
Examination of the ISDB reveals that the mean solvent
concentration in wastes used as auxiliary fuels in industrial
boilers is 37 percent. Solvent concentrations in the individual
wastes range from 0.4 percent to 80.5 percent. At the lower end
of this range, the waste stream is typically blended with other
fuels so that the overall heat value is acceptable. This prac-
tice is more common when the waste solvent is used as a fuel
substitute by the generator.
Not only will chlorine affect the heating value of a waste,
but it may also contaminate the product (e.g., cement kilns) (8),
reduce the particulate matter control efficiency of electrostatic
precipitators (9), or it may present a corrosion problem for
industrial boilers (12). As a result, the chlorine content of
wastes used as fuel in these devices is often quite limited. For
industrial boilers this limit is about three percent; for cement
kilns it is five percent (7). Given these constraints, the
nonhalogenated organic liquids are the preferred choice for fuel
substitution. This is further evidenced by the fact that only
two of the 61 waste streams reported in ISDB as being used as
fuel in boilers were halogenated. Of the 20.6 million gallons of
organic liquid wastes, 47 percent are reported to be nonhalogen-
ated.
The remaining halogenated wastes could be used for fuel
substitution provided the chlorine content is below three to five
percent. However, because most organic liquids contain high
concentrations of solvents, it is unlikely the chlorine content
of the halogenated organic liquid wastes will meet this
31
-------
:o,ooo
18,000- • •
16,000-
14,000-
12,000-
10,000
8,000-
6,000-
4,000-
2,000-
10% 20t 30t 40* SOt 60t 70t
I I
SOt 901 100?
Total Non-Combustibles
(sum of percent water, chlorine and ash content)
Source : Supporting Documentation for the RCRA Incineration
Regulations , PB-86-110293 .
FIGURE C-3
DISTRIBUTION OF Btu CONTENT vs. TOTAL NON-COMBUSTIBLES FOR
INCINERATED NONHALOGENATED SOLVENT WASTES
32
-------
3
JJ
03
4,000-
2,000-
lOt 20t SOt 40t SOt
ill
70t SOt 90t
100*
Total Non-Combustibles
(sum of percent water, chlorine and ash content)
Source: Supporting Documentation for the RCRA Incineration
Regulations. PB-86-110Z93. T3&T.
FIGURE C-4
DISTRIBUTION OF Btu CONTENT vs. TOTAL NON-COMBUSTIBLES FOR
INCINERATED HALOGENATED SOLVENT WASTES
33
-------
criterion. Therefore, it is assumed that none of the waste
streams containing halogenated constituents will be used as fuel
substitutes.
c. Incineration
As shown in Figures C-1 and C-2, the heat and noncombustible
content of a given waste is not as restrictive a characteristic
for incineration technology as it is for fuel substitution. In
fact, approximately 31 facilities in the Incineration RIA report
(6) destroyed wastes with a heat content less than 1,000 Btu/lb.
Figure C-2 clearly illustrates that even low Btu, halogenated
organic solvents are incinerated.
As compared to solvent-water mixtures, organic liquids are
more amenable to destruction through incineration because of
their higher organic content. In many cases, their heat value is
high enough so that little auxiliary fuel is required to maintain
sufficient temperatures for complete destruction. The require-
ment for auxiliary fuel, of course, depends largely on such
factors as the ash, chlorine, and water content of the waste as
discussed above. In addition, because they are pumpable, organic
liquids can be injected into an incinerator under highly turbu-
lent conditions, promoting more complete combustion and destruc-
tion.
d. Summary of Capacity Requirements for Organic Liquids
In conclusion, the data indicate that organic liquid waste
containing halogenated solvents are more likely to be distilled
or incinerated than to be used as a fuel substitute. Therefore,
in order to estimate the total quantity of organic liquid waste
that is amenable to each alternative technology, EPA assumes that
approximately half (when considering rounding of decimals) of all
halogenated organic liquids will be incinerated and about half
will be distilled. This yields 5.4 million gallons per year
routed to distillation and 5.5 million gallons per year routed to
incineration.
In the preceding discussion, it was shown that organic
liquids containing nonhalogenated solvents are amenable to
incineration and distillation treatment, or use as fuel substi-
tutes. However, the available fuel substitution capacity is
unknown, as explained in Part D. EPA is assuming that 6.5
million gallons of nonhalogenated organic liquids will be incin-
erated each year, and 3.2 million gallons will be distilled. The
lower volume routed to distillation reflects the fact that
nonhalogenated solvents have a lower purchase cost than
34
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halogenated solvents. As such, it is more economical to recycle
halogenated solvents.
3. ORGANIC SLUDGES AND SOLIDS
As discussed in Part B, an estimated 7.3 million gallons of
solvent contaminated organic sludges and solids are generated per
year. These sludges and solids contain greater than one percent
total organics and greater than one percent total solids. In
addition, 1.9 million gallons of wastes generated by small
quantity generators are organic sludges and will compete for
alternative capacity with currently land disposed organic
sludges. Also, 1.2 million gallons of still bottoms will be
generated by distillation of the organic liquids discussed above.
This generation rate for still bottoms is based upon data gath-
ered through a survey of the Small Quantity Generators. These
data indicate that approximately 14 percent of the input to
distillation leaves as a residue (5).
Therefore, a total of 10.4 million gallons of organic
sludges and solids require alternative capacity. Of this quan-
tity, 7.2 million gallons are halogenated organics and 3.2
million gallons contain nonhalogenated constituents.
Data from the ISDB characterizing these wastes indicate that
they are most amenable to incineration and fuel substitution.
Both of these technologies are discussed below with respect to
organic sludges and solids.
a. Fuel Substitution
The preceding discussion identified the critical waste
characteristics that will limit the use of organic liquids as
fuel substitutes. These same characteristics, as well as viscos-
ity and solids content, will affect the applicability of organic
sludges and solids to fuel substitution. The fuel handling
systems for boilers and industrial kilns are capable of handling
liquids (fuel oil) and/or granulated solids (coal). High viscos-
ity sludges (greater than 23 stokes) are not pumpable and there-
fore not compatible with the liquid injection units used to feed
fuel oil.
Viscosity, solids content, and heat content information is
not available for the 10.4 million gallons of organic sludges and
solids; therefore, it is not possible to predict the quantity of
this material that will be used for fuel substitution. Using
these waste materials for fuel substitution is nevertheless
demonstrated. In a telephone survey performed for the Agency, 29
facilities operating solvent recovery operations were identified
as using the residuals for fuel substitution (1). Further
35
-------
examination of these data show that the residuals containing
nonhalogenated solvents are more likely to be used as fuel
substitutes than the residuals containing halogenated solvents.
As discussed above under organic liquids, it is assumed that
halogenated solvent wastes will not be used for fuel substitu-
tion.
b. Incineration
Commercial incinerators are capable of destroying highly
viscous, halogenated wastes. Furthermore, the fact that these
wastes are used as auxiliary fuels indicates they have sufficient
heat content to be incinerated with a minimum of auxiliary fuel.
Rotary kiln, fixed hearth, multiple hearth, and fluidized
bed incinerators are capable of destroying viscous wastes that
are not compatible with liquid injection units. In addition,
commercial incinerators are refractory-lined to minimize corro-
sion due to halogens. Finally, commercial incinerators are not
subject to product quality constraints as is the case with
industrial furnaces and kilns.
For the purpose of determining treatment capacity, it is
assumed that all of the 9.2 million gallons of organic sludges
and solids will be incinerated. This is due to the fact that
there are several factors limiting the use of organic sludges and
solids as fuel substitutes. It is not possible to precisely
predict how much of this quantity would be acceptable as a fuel
substitute. Secondly, as explained in Part D, the available
unused fuel substitution capacity is unknown.
4. INORGANIC SLUDGES AND SOLIDS
Part B explained that an estimated 6.7 million gallons of
inorganic sludges and solids are currently land disposed. These
wastes consist of soils contaminated with solvents and sludges
and solids containing less than one percent total organics.
These wastes are further characterized as having greater than one
percent total solids. Although soils contain up to several
percent organics, it is assumed the RIA Mail Survey respondents
reported these soils as inorganic solids.
These inorganic sludges and solids contain concentrations of
solvents too low and solid contents too high to allow these
wastes to be distilled or reused as fuel. Consequently the only
treatment option for the 6.7 million gallons of inorganic sludges
and solids contaminated with solvents is destruction by incinera-
tion. As discussed previously, commercial incineration technol-
ogy is capable of destroying highly viscous wastes containing
halogenated, as well as nonhalogenated, constituents.
36
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Furthermore, auxiliary fuels such as natural gas or other high
heat content wastes can be used as a supplemental fuel source
during incineration. Because this waste group has a low organic
content, auxiliary fuels will be needed. Figures C-1 and C-2
demonstrate that low heat content wastes can be treated using
incineration technology.
5. SUMMARY OF CAPACITY REQUIREMENTS
Waste solvents are comprised of four waste groups that will
require alternate treatment or recycling capacity if banned from
land disposal: solvent-water mixtures, organic liquids, organic
sludges and solids, and inorganic sludges and solids. For each
of these waste groups, the volume of solvent waste requiring
treatment or recycle capacity for each of the following technolo-
gies was estimated: distillation, commercial incineration, fuel
substitution, and wastewater treatment. The total volume of
solvents wastes requiring treatment and recycling capacity is
summarized in Table C-2; these quantities are distributed by
treatment or recycle technology in Table C-3.
37
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TABLE C-2
VOLUME OF SOLVENT WASTE REQUIRING TREATMENT
AND RECYCLING CAPACITY
(Millions gallons per year)
Halogenated Nonhalogenated
Physiqal Form Solvents Solvents Total
Solvent-Water Mixtures 0 186 186
Organic Liquids 10.9 9.7 20.6
Organic Sludges 6.4 2.8 9.2
Inorganic Sludges 6.3 0.4 6.7
23.6 199 223
38
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TABLE C-3
SOLVENT WASTE TREATMENT AND
RECYCLING DEMAND
(Million gallons per year)
Waste
Treatment Quantity Requiring
or Recovery Technology Alternative Capacity
Distillation
Halogenated Organic Liquids 5.4
Nonhalogenated Organic Liquids 3.2
Total Solvent Wastes 8.6
Incineration
Halogenated Organic Liquids 5.5
Nonhalogenated Organic Liquids 6.5
Halogenated Organic Sludges 6.4
Nonhalogenated Organic Sludges 2.8
and Solids
Halogenated Still Bottoms 0.8 (a)
Nonhalogenated Still Bottoms 0.4 (a)
Inorganic Sludges and Solids 6.7
Total Solvent Wastes 29.1
Wastewater Treatment
Solvent-Water Mixtures 186
Total 223
(a) Still bottoms will be generated through distillation of the
5.4 million gallons of halogenated organic liquid and 3.2
million gallons of nonhalogenated organic liquid. Based on
data collected in the SQG survey, 14 percent of the
distillation input is removed as still bottoms (5).
This factor is used to account for still bottoms that will
be generated when the organic liquids are recycled.
39
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PART D
ASSESSMENT OF AVAILABLE TREATMENT
AND RECYCLING CAPACITY
Four basic management practices were identified as the best
demonstrated available technologies for waste solvents. Each of
these technologies is considered a viable option to land disposal
of waste solvents:
1. Treatment in tanks,
2. Distillation for solvent recovery,
3. Incineration, or
4. Fuel substitution.
Treatment in tanks refers to biological treatment, carbon
and resin adsorption, steam and air stripping, and chemical
oxidation. The analysis of the unused capacity available for
each of these methods is presented below.
The evaluation of available treatment and recycling capacity
will not include private solvent treatment and recycling facili-
ties. Data are not available to determine to what extent private
facilities will manage additional solvent waste in the future.
It is not known how many owner/operators of private treatment and
recycling facilities also land disposed solvent waste that will
be banned, nor is there information on the quantity of such land
disposed waste. Thus, the analysis presented below includes only
the capacity of commercial facilities.
Information was also unavailable concerning any treatment or
recycling facilities that are in various stages of development
(e.g., permitting, design, construction). Only existing,
on-line facilities were included in this analysis.
1. TANK TREATMENT CAPACITY
Several sources of national tank treatment capacity were
considered: (1) the RIA Mail Survey, (2) the RCRA Biennial
Reports Data Base, and (3) the Hazardous Waste Data Management
System (HWDMS). The Biennial Reports Data Base gives the total
number of RCRA-regulated treatment facilities, but this data base
does not identify the type of treatment, the waste treated, or
the treatment capacity.
HWDMS contains information from Part A and Part B of the
RCRA treatment, storage, and disposal facility permit applica-
tions submitted to the EPA. Although the Part A applications
list all of the waste codes managed, the capacities reported
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include all of the capacity that the interim status facility
planned to have at an unspecified time in the future. This
capacity is not an accurate indication of either actual design
capacity or of unused capacity. Part B applications give actual
design capacity; however, many currently regulated tank treatment
facilities are operating under interim status and have not yet
submitted Part B applications to EPA.
The RIA Mail Survey is the only source that provides design
capacity, percent utilization, and waste codes for treated wastes
at individual commercial facilities. In the case of tank treat-
ment, however, the questionnaire was not designed to report the
capacity available to treat waste by specific treatment methods.
Consequently, all of the treatment capacity at tank treatment
facilities must be grouped together. From these data, an esti-
mated 112 million gallons per year of excess tank treatment
capacity exist for solvent wastes. This excess capacity was
derived from a reported planned design capacity of 170 million
gallons per year and a reported capacity utilization of 34 per-
cent.
Some of the facilities that treat solvents also treat other
types of wastes, such as those containing metals. The total
capacity given above includes the capacity available to treat
these other wastes. Consequently, the RIA Mail Survey data
provides a maximum unused capacity for treating solvent wastes.
The actual unused capacity available to treat solvents is less
than 112 million gallons because some of the calculated capacity
is part of treatment systems designed to treat other types of
wastes.
2. SOLVENT RECYCLING CAPACITY
An estimate of the commercial recycling capacity was ob-
tained through a telephone survey of the members of the National
Association of Solvent Recyclers (NASR) (1). According to NASR,
their members represent 70 percent of the commercial recycling
capacity available in the United States. Data and information on
recycling capabilities were obtained from 31 of the 43 member
facilities.
The telephone survey effort involved contacting each recy-
cler and asking a series of questions concerning their opera-
tions. The following information requested during the survey was
used here to determine recycling capacity:
1. The volumes and types of solvent managed by "F" hazard-
ous waste designation,
2. The type of recycling process, and
3. The process capacity.
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The data and information obtained from the 31 facilities
were compiled by EPA region. Subsequently, the data were extrap-
olated proportionally to cover the remaining NASR firms and the
remaining 30 percent of the nationwide recycling capacity.
The principal method of solvent recycling reported is
distillation. From the telephone survey it is estimated that
approximately 374 million gallons per year of commercial distil-
lation capacity exist in the United States. It is also estimated
that each year, approximately 150 million gallons of spent
solvents undergo reclamation by commercial distillation. Thus,
there exist about 224 million gallons per year of unused commer-
cial distillation capacity.
An additional 278 million gallons of spent solvents are
recycled by distillation in privately operated units. The
majority of this amount is believed to be halogenated solvents,
which, in general, have a higher resale value than nonhalogen-
ated solvents.
3. INCINERATION CAPACITY
EPA calculated estimates of the total and unused commercial
incineration capacity based on data and information from several
sources. A summary of this information is presented below.
A telephone survey of commercial hazardous waste treatment
facilities was performed in 1984 (10). This survey included five
major firms operating nine commercial incinerators. Because the
survey information is confidential, only summary information can
be provided here. Based on answers from the five incinerator
owner/operators, the total quantity of hazardous waste burned in
1984 was 239,000 metric tons. The reported total design capacity
was 301,000 metric tons with a current capacity utilization of 80
percent. Assuming the waste had a weight similar to water, these
estimates yield an unused capacity of 18.7 million gallons per
year.
The telephone survey also allowed industry representatives
to provide direct input regarding the interpretation of the data
they provided. For example, incineration capacity is frequently
discussed in terms of thermal input. In many cases, it was
necessary to convert thermal input into a volume by assuming an
average waste heat content.
A second, more complete estimate of incinerator capacity was
determined using data obtained from several sources. This
information was obtained from telephone contacts with commercial
incinerators, site visit reports, the RIA Mail Survey, permit
data, and the HWDMS. Most of this information is confidential.
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Non-confidential information is provided in the Administrative
Record supporting this rulemaking. As of November 1985, it was
determined that there are 17 commercial incineration units in the
United States operated by 11 firms. There have been more commer-
cial incineration facilities in the United States, but they have
ceased accepting hazardous waste or are no longer in operation.
The volume of waste incinerated and the thermal capacity of
these facilities was uniformly converted using the following
assumptions:
1. The average heat content for the incinerable waste is
8,000 Btu/lb (1),
2. The capacity utilization is 80 percent (1,10),
3. The average available operating time is 83 percent
(7,270 hours/yr) (14), and
4. The average weight of the incinerable waste is that of
water, 8.34 pounds per gallon (10).
Using the above conversion factors, the available capacity
at these 17 facilities is estimated to be a maximum of 25.6
million gallons per year. This estimate is slightly higher than
that calculated from Reference 10 because all operating incinera-
tors are included.
Further data available in Reference 1 indicates that in 1984
the thermal capacity of the commercial incinerators was 986
million Btu per hour. Using the conversion factors listed above,
986 million Btu per hour converts to an unused commercial incin-
eration capacity is 21.5 million gallons per year.
These three estimates of unused commercial incineration
capacity, obtained from independent sources, appear consistent.
For the purposes of evaluating capacity availability, the most
current and complete estimate of 25.6 million gallons per year
will be used.
4. FUEL SUBSTITUTION
From the RIA Mail Survey, it has been determined that at
least 231 million gallons of hazardous waste are burned annually
as fuel substitutes (7). In addition, approximately 159 million
gallons of that quantity contain solvent constituents found in
F001, F002, F003, F004, and F005 wastes (1). The majority of
this 159 million gallons is reported to be ignitable waste (77
percent). Less than one percent is halogenated, and the remain-
ing 23 percent is reported to be nonhalogenated. As discussed
previously, halogenated wastes are not used extensively as fuel
substitutes.
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Because of the numerous high temperature industrial process-
es operated in the United States, there is a substantial poten-
tial for available capacity to destroy organic wastes by using
these wastes as auxiliary fuel. For example, it is estimated
that of the over 400,000 industrial boilers, approximately 5,500
are capable of destroying organic wastes (11).
An EPA survey of handlers and burners of used or waste oil
and waste-derived fuel material identified 1400 boilers that use
organic wastes as auxiliary fuels (7). These data indicate that
there is substantial thermal capacity available for fuel substi-
tution in industrial boilers. It is likely that the same situa-
tion exists for high temperature industrial kilns and furnaces.
Nevertheless, the Agency is unable to predict the willingness of
these facilities to accept hazardous wastes to offset fuel costs.
Further, it should be noted that EPA is considering regula-
tions that could curtail fuel substitution practices. These
regulations may require that industrial operations using hazard-
ous wastes to co-fire boilers, furnaces, and kilns demonstrate
and achieve destruction and removal efficiencies of 99.99 percent
or greater. As discussed in Volume II of this document, various
industrial boilers, industrial kilns, and industrial furnaces
have demonstrated that this degree of destruction is achievable.
EPA is also considering additional limitations for particu-
late matter and hydrochloric acid emissions. These emission
limits would be achievable through proper air pollution control
or by reducing the mass feed of waste material into the opera-
tion. Because of these limitations, and because industrial
facilities may not be willing to accept hazardous wastes, it is
not possible to estimate the quantity of unused fuel substitution
capacity.
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PART E
COMPARISON OF CAPACITY REQUIREMENTS
WITH AVAILABLE CAPACITY
In the previous sections, volume estimates of solvent waste
that will be directed to specific types of alternative treatment
and recycling technologies were presented. Estimates were also
presented for the unused commercial capacity of these alternative
treatment and recycling technologies. In this subpart, the
required capacity is compared to the unused capacity in order to
determine where capacity shortfalls exist. A summary of EPA's
estimates of quantities of solvent wastes requiring treatment and
recycling and the unused commercial capacity per technology is
presented in Table E-1. It should be remembered that this
analysis does not include any solvent wastes that may be cur-
rently disposed in salt-dome formations, salt bed formations, and
underground mines and caves.
The Agency has concluded that based on the analysis of the
data in Table E-1, sufficient unused commercial recycling capac-
ity exists for all solvent wastes that will be distilled. This
volume represents less than a four percent increase over the 159
million gallons of solvent waste currently reclaimed through
distillation.
Table E-1 also demonstrates there is insufficient commercial
incineration capacity. When capacity is insufficient to treat
all of the waste groups requiring the same technology, EPA is
proposing to utilize all of the available capacity by banning
from land disposal the more toxic or concentrated waste first.
In this case, inorganic sludges and solids may be considered the
least toxic or concentrated waste among those requiring incinera-
tion. When the 6.7 million gallons of inorganic sludges and
solids are subtracted from the estimates of required incineration
capacity, the estimated available incineration capacity is
adequate to handle the wastes containing the greater concentra-
tions of solvents and total organics. These wastes are organic
liquids, organic sludges, and still bottoms. Therefore, the
Agency concludes that a shortfall in incinerator capacity exists
for inorganic sludges and solids.
Current estimates of commercial wastewater treatment capac-
ity also show a significant shortfall for treating the estimated
185 million gallons of solvent-water mixtures containing less
than one percent (10,000 ppm) total solvent that are currently
land disposed each year.
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TABLE E-1
COMPARISON OF ALTERNATIVE TREATMENT AND
RECYCLING DEMAND WITH UNUSED CAPACITY
(Million gallons per year)
Treatment or Recovery Waste Quantity Requiring Unused
Technology Alternative Capacity Capacity
Distillation 8.6 224
Incineration8 29.1 25.6
Wastewater Treatment 185 <112
aWhen the inorganic sludges and solids are subtracted, the waste
quantity requiring incineration is 22.4 million gallons.
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PART F
BIBLIOGRAPHY
1. Engineering-Science. 1984. Supplemental Report on the Technical
Assessment of Treatment Alternatives for Waste Solvents.
Washington, D.C.: U.S. Environmental Protection Agency.
2. U.S. Environmental Protection Agency. 1984. National Survey of
Hazardous Waste Generators and Treatment, Storagef and Disposal
Facilities Regulated Under RCRA in 1Q81. EPA/530-SW-005, GPO Pub.
05/N055-000-00239-8.
3. U.S. Environmental Protection Agency. 1985. Regulatory Analysis
of Proposed Restriction on Land Disposal of Certain Solvent
Wastes. Office of Solid Waste, Washington D.C.
4. Science Applications International Corporation. 1985. Industry
Studies Data Base. Prepared for the U.S. EPA, Office of Solid
Waste, Waste Identification Branch.
LL I, ^ 5. ABT Associates. 1985. National Small Quantity Generator Survey.
H^ Washington, D.C.: U.S. Environmental Protection Agency.
6. Supporting Documentation for the RCRA Incineration Regulations.
1984. PB-86-110293. U.S. EPA, Office of Solid Waste.
7. Westat. 1985. Data Base for the Survey of Handlers and Burners
of Used or Waste Oil and Waste - Derived Fuel Material. Prepared
for the U.S. EPA, Office of Solid Waste, Economics and Policy
Analysis Branch.
— 8. Oppelt, E. 1981. Thermal Destruction Options for Controlling
Hazardous Waste. Civil Engineering - American Society for Civil
Engineers.
9. Peters, J.A., Day, D.R., and Mournighan, R.E. 1984. Effects of
Disposal of Hazardous Wastes in Cement Kilns. Incineration and
Treatment of Hazardous Waste, Proceedings of the Tenth Annual
Research Symposium, U.S. Environmental Protection Agency.
10. ICF, Inc. 1985. Survey of Selected Firms in the Commercial
Hazardous Waste Management Industry: 1Q84 Update. Final Report.
Washington D.C.: U.S. Environmental Protection Agency.
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11. Olexsey, Robert A. 1984. Incineration of Hazardous Waste in
Power Boilers: Emissions Performance Study Rationale and Test
Site Matrix. Incineration and Treatment of Hazardous Waste,
Proceedings of the Tenth Annual Research Symposium, U.S.
Environmental Protection Agency.
12. Fred C. Hart Associates, Inc. 1982. Impact of Burning of
Hazardous Waste in Boilers. Prepared for SCA Chemical Services.
13. Johnson, J. C. The Dow Chemical Company, Midland, MI. 1985.
Vapor Degreasing. Metal Finishing Guidebook Directory.
14. U.S. Environmental Protection Agency. 1985. Assessment of
Incineration as a Treatment Method for Liquid Organic Hazardous
Wastes. Background Report III! Assessment of the Commercial
Hazardous Waste Incineration Market. Prepared by Booze, Allen
and Hamilton Inc. for the U.S. EPA Office of Policy Analysis.
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