ocean incineration: its role in managing hazardous waste

Ocean Incineration: Its Role in ManagingHazardous Waste

August 1986

NTIS order #PB87-100327

Library of Congress Catalog Card Number 86-600566

For sale by the Superintendent of DocumentsU.S. Government Printing Office, Washington, DC 20402

Foreword

The American approach to managing hazardous wastes is undergoing rapid change.A decade ago Congress passed the Resource Conservation and Recovery Act (RCRA),formally recognizing the costs of past, indiscriminate land disposal. The Nation now ismoving with some urgency toward development and greater utilization of methods thatdestroy, treat, recycle, or reduce the generation of hazardous wastes.

Within this context of change, one of the many distinct technologies for managinghazardous wastes—ocean incineration—has received an extraordinary degree of attention.Is ocean incineration part of the solution to, or simply a repetition of, the mistakes of thepast? By burning hazardous wastes far from land, are we reducing risks to human healthor simply shipping our problems out to sea? Is the small but real risk of a catastrophicspill worth the benefit of actually destroying most of the wastes? These and other ques-tions have been the focus of considerable public attention over the last several years, andvarious congressional committees have responded by holding half a dozen hearings since1983.

In 1984, two congressional committees—the House Committees on Merchant Ma-rine and Fisheries and on Public Works and Transportation—requested the Office of Tech-nology Assessment to undertake a broad study of wastes in marine environments, includ-ing an examination of ocean incineration. At that time, the Senate Committee onCommerce, Science, and Transportation endorsed the study. More recently, the originalrequesting committees and the House Committee on Science and Technology asked OTAto prepare a full report on ocean incineration. In response to the latter request, this assess-ment, Ocean Incineration: Its Role in Managing Hazardous Waste, provides a compre-hensive examination of ocean incineration technology. A second assessment respondingto the initial request is in preparation.

This assessment of ocean incineration includes consideration of the adequacy of reg-ulations; risks to human health and the marine environment relative to the risks of com-parable activities; existing and emerging alternatives; the capabilities and limitations ofocean incineration in managing hazardous wastes; and how its use might affect effortsto develop superior waste treatment and reduction practices. Particular attention is ad-dressed to areas of intense public concern over the use of this technology. This report isoffered to aid Congress in its deliberation of the fate and design of the ocean incinerationprogram.

Many individuals in government, industry, the public interest and environmentalcommunities, and academia contributed to the effort represented by this report. In par-ticular, OTA wishes to thank the advisory panel and the many reviewers who devotedtime and energy to this undertaking. Their involvement does not necessarily indicate en-dorsement of the report or agreement with its findings: OTA bears sole responsibility.

Director

. . .Ill

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Wastes in Marine Environments Advisory Panel

Thomas Clingan, ChairmanUniversity of Miami School of Law

Walter Barber George LutzicWaste Management, Inc. New York City Department of Environmental

ProtectionWillard BascomScripps Institute of Oceanography William J. Marrazzo(formerly with Southern California Coastal City of Philadelphia

Waters Research Project) Joseph T. McGough, Jr.Rita Colwell Parsons BrinckerhoffDepartment of Microbiology (formerly with the New York City DepartmentUniversity of Maryland of Environmental Protection)

A. Myrick Freeman III Michael G. NortonDepartment of Economics British EmbassyBowdoin College Jerry SchubelJohn Gosdin ‘Marine Sciences Research CenterGovernor’s Office State University of New York at Stony BrookState of Texas Richard F. SchwerJon Hinck DuPontGreenpeace, USA

Kenneth KamletURS-Dalton(formerly with National Wildlife Federation)

John A. KnaussGraduate School of OceanographyUniversity of Rhode Island

NOTE: OTA appreciates and is grateful for the valuable assistance and thoughtful critiques provided by the advisory panelmembers. The panel does not, however, necessarily approve, disapprove, or endorse this report. OTA assumes fullresponsibility for the report and the accuracy of its contents.

Related OTA Reports

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Wastes in Marine Environments. In preparation.Serious Reduction of Hazardous Waste for Pollution Prevention and Industrial Efficiency. In press.Transportation of Hazardous Materials. OTA-SET-304; July 1986. GPO stock #052 -O03-O1042-9;$13.00.Superfund Strategy. OTA-ITE-252; April 1985. GPO stock #052 -O03-O0994-3; $10.00.Protecting the Nation Groundwater From Contamination. OTA-O-233; October 1984. GPO stock#052 -O03-O0966-8; $7.50.Acid Rain and Transported Air Pollutants: Implications for Public Policy. OTA-O-204; June 1984.GPO stock #052 -003-00956-1 ; $9.50Technologies and Management Strategies for Hazardous Waste Control. OTA-M-196; March 1983.NTIS order #PB 83-189241.

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OTA Project Staff

John Andelin, Assistant Director, OTAScience, Information, and Natural Resources Division

Robert M. Niblock, Oceans and Environment Program Manager

Richard A. Denisen, Principal Author and Analyst

Howard Levenson, Project Director

William Barnard, Senior Analyst

Administrative Staff

Kathleen A. Beil Brenda B. Miller

Contractors

Arthur D. Little, Inc.

EG&G Washington Analytical Services Center, Inc.

Science Applications International

Resources for the Future

Anne Meadows, Editor

Corp.

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Acknowledgments

Many individuals and organizations have contributed to this report by providing valuable informa-tion, guidance, and substantive reviews of draft material. OTA wishes to extend its gratitude to the fol-

lowing for their time and energy.

Captain Ken AllanMarine Container Equipment Certification

Corporation

Michele AndersEnvironmental Protection Agency

Deyaun BoudreauxGulf Coast Coalition for Public Health

Darrell BrownEnvironmental Protection Agency

William Y. BrownWaste Management, Inc.

Lisa BuninGreenpeace, USA

Eric ButlerOffice of Technology Assessment

Ruth A. ChemerysNational Oceanic and Atmospheric

Administration

Ann G. DanielsEnvironmental Defense Fund

Tudor DaviesEnvironmental Protection Agency

John EhrenfeldAbt Associates

Lieutenant Lee EllweinU.S. Coast Guard

Dan FarrowNational Oceanic and Atmospheric

Administration

Melanie La ForceEnvironmental Protection Agency

Butch FriesInside E.P.A.

Sue Ann FrugeGulf Coast Coalition for Public Health

Jack GentileEnvironmental Protection Agency

Richard J. GimelloNew Jersey Hazardous Waste Facilities Siting

Commission

Vincent G. GreySeaBurn, Inc.

Nan HarleeOffice of the Maritime AdministratorU.S. Maritime Administration

Commander Charles HuberU.S. Coast Guard

David S. Hugg IIIDepartment of Natural Resources and

Environmental ControlState of Delaware

Lieutenant Commander Stephen V. HughesU.S. Coast Guard

Peter JohnsonOffice of Technology Assessment

Paul KerkhovenOffice of Senator RothUnited States Senate

Sally LentzOceanic Society

Jackie LockettGulf Coast Coalition for Public Health

Henry S. MarcusOcean Engineering DepartmentMassachusetts Institute of Technology

Francis MardulaU.S. Maritime Administration

Rosalie T. MatthewsMatthews Consulting and Construction, Inc.

Susan MulvaneyCongressional LiaisonEnvironmental Protection Agency

vi

George NassosWaste Management, Inc.

Judy NelsonEnvironmental Protection Agency

Donald OberacherEnvironmental Protection Agency

Timothy OppeltEnvironmental Protection Agency

Edith PageOffice of Technology Assessment

Matthew PerlEnvironmental Protection Agency

Stephanie PfirmanCommittee on Science and TechnologyU.S. House of Representatives

Marjorie A. PittsEnvironmental Protection Agency

David RedfordEnvironmental Protection Agency

Joe RetzerEnvironmental Protection Agency

Jerry A. RiehlEnvironmental Oceanic Services

Larry RosengrantEnvironmental Protection Agency

Kenneth I. RubinCongressional Budget OfficeUnited States Congress

John SandstedtAt-Sea Incineration, Inc.

Lee SantmanU.S. Maritime Administration

Richard SchwabacherOffice of Representative HughesU.S. House of Representatives

Diane B. SheridanLeague of Women Voters of Texas

Douglas ShooterArthur D. Little, Inc.

Ellen SilbergeldEnvironmental Defense Fund

William W. Stelle, Jr.Committee on Merchant Marine and FisheriesU.S. House of Representatives

Sue Stendebachformerly with the Office of the GovernorState of Texas

Sharron StewartGulf Coast Fishermen’s Environmental Defense

Fund

David SussmanEnvironmental Protection Agency

John ThomasianCongressional Budget OfficeUnited State Congress

Patrick TobinEnvironmental Protection Agency

Christopher TulouOffice of Representative CarperU.S. House of Representatives

Marc TurgeonEnvironmental Protection Agency

George Vander VeldeWaste Management, Inc.

John WaescheMarine and Energy DivisionJardine Insurance Brokers, Inc.

Richard C. WillsAt-Sea Incineration, Inc.

Terry F. YosieScience Advisory BoardEnvironmental Protection Agency

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Contents

Chapter Pagel. Findings and Policy Options . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

2. Shaping an Ocean Incineration Program: Key Policy Issues . . . . . . . . . . . . . . . . . . . . . . . 33

3. Incinerable Hazardous Waste: Characteristics and Inventory . . . . . . . . . . . . . . . . . . . . . . 55

4. Current and Emerging Management and Disposal Technologies forIncinerable Hazardous Wastes. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 81

5. Current Land-Based Incineration Technologies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 93

6. Ocean Incineration Technology. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ......107

7. Comparison of Land-Based and Ocean Incineration Technologies . .................119

8. Environmental Releases From Ocean Incineration. . . . . . . . . . . . . . . . . . . . . . ..........133

9. Comparison of Risks Posed by Land-Based and Ocean Incineration . ...............159

10. Overview of Federal Laws and Regulations Governing Incineration . ...............173

11. History of U.S. Ocean Incineration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ....179

12. The Regulation and Use of Ocean Incineration by Other Nations. . . . . . . . . . . . . . ....193

References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ........205

Acronyms and Abbreviations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .........215

Index . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .......,....219

. . .Vlll

Chapter 1

Findings and Policy Options

Contents

PageOverview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

The Role of Congress . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4Major Public Concerns . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7Evaluating Ocean Incineration in a Broad Context . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Major Findings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9The Potential Role of Land-Based and Ocean Incineration . . . . . . . . . . . . . . . . . . . . . . . . . 9Comparison of Land-Based and Ocean Incineration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11Releases of Wastes to the Marine Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15Past and Current Use of Hazardous Waste Incineration . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16Recovery, Recycling, and Reduction of Incinerable Wastes . . . . . . . . . . . . . . . . . . . . . . . . . 16The Use of Ocean Incineration by Other Nations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

Deciding the Fate of Ocean Incineration: Major Policy Options . . . . . . . . . . . . . . . . . . . . . . . 18Policy Options and Their Implications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19Determining the Scale of an Ocean Incineration Program . . . . . . . . . . . . . . . . . . . . . . . . . . 21

Shaping an Ocean Incineration Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25Regulation of Incinerator Emissions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25Transportation Risks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26Comparison of Different Ocean Incineration Technologies . . . . . . . . . . . . . . . . . . . . . . . . . . 26Equitable Regulation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26Public Involvement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27The Effect of Ocean Incineration on the Development of Better Alternatives . . . . . . . . . . 27Unresolved Questions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

Chapter 1 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

Box PageA. What Is Ocean Incineration? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Chapter 1

Findings and Policy Options

OVERVIEW

Few practices, even in the tumultuous arena ofhazardous waste management, have engendered asmuch controversy and polarization as has the con-cept of burning hazardous wastes in incineratorsmounted on ocean-going vessels. Critics have char-acterized ocean incineration vessels as ‘‘outmoded,unforgiving technology’ and ‘‘nothing more thanold-fashioned pot-bellied stoves without the smoke-stack, whereas proponents see ocean incinerationas ‘‘a way to prevent the cancer that chemicals maycause’ and ‘‘to destroy hazardous wastes beforethey destroy us. When the U.S. EnvironmentalProtection Agency (EPA) held a public hearing onocean incineration in Brownsville, Texas, in 1983,more than 6,000 people attended, which vividlydemonstrates the level of public concern over thistechnology. ’ Such concerns have temporarily haltedthe development of ocean incineration in thiscountry.

The debate over ocean incineration reflects thetenor of change taking place in the American ap-proach to managing hazardous waste. The Hazard-ous and Solid Waste Amendments of 1984,2 whichamended the Resource Conservation and RecoveryAct (RCRA), responded to the growing recogni-tion that the methods used in the past to disposeof hazardous wastes should no longer be used.Mounting evidence of groundwater contaminationand other problems associated with leakage ofwastes from the growing list of Superfund sites lenta new sense of urgency to finding new approaches.To replace the old practices, Congress has calledfor the development of environmentally soundmethods for disposing of, treating, destroying, andrecycling hazardous wastes, and for reducing theirgeneration. It is against this background of transi-tion that Congress must decide what role, if any,ocean incineration should play in managingAmerica’s hazardous wastes.

‘This public hearing was the largest in EPA’s history. At issue waswhether to grant a permit for incinerating PC B- and DDT-containingwastes at an ocean site in the Gulf of Mexico.

‘Referred to throughout this report as the 1984 RCRA Amend-ments ( 13).

Existing and developing methods for managinghazardous wastes are commonly organized into ahierarchy that accords preferred status to methodsthat reduce risk by reducing the quantity and de-gree of hazard of wastes.

The highest tier in the hierarchy includes thosemethods—collectively referred to as waste reduc-tion—that actually avoid the generation of wastes.3

Disposal practices that attempt to contain waste oractually disperse them in the environment occupythe lowest tier. Between these tiers are thosemethods—distinct from disposal practices—that re-duce risks by recovering, treating, or destroyingwastes after they are generated. For example, aproperly operating incinerator can destroy morethan 99 percent of certain hazardous wastes, greatlyreducing both their quantity and degree of hazard.4

In such a hierarchy, the technology of oceanincineration falls midway between most disposalpractices, which are generally inferior, and mostreduction, recycling, and advanced treatment tech-nologies, which are generally superior. For whathazardous wastes could ocean incineration be used?Of all hazardous wastes, only a fraction (up to 20percent) is amenable to incineration. Of these in-cineralde wastes, only those in liquid form (up toabout 8 percent of all hazardous wastes) could beincinerated at sea. For liquid wastes that are highlychlorinated, several technical factors partially con-strain the ability of available land-based alterna-tives to effectively manage such wastes. Becausethese limitations do not apply to ocean incinera-tion, it is one of only a few technologies availableto manage highly chlorinated wastes.

3Not all practices that are commonly considered waste reductionactually lead to risk reduction. For example, process modificationscan reduce the quantity of waste or alter its composition without nec-essarily reducing the degree of hazard of any resulting waste. As usedin this report, however, the term waste reduction refers only to envi -ronmentally sound practices that actually accomplish risk reduction.

‘The undestroyed fraction of the waste is released into the envi-ronment. Concerns about incineration generally focus to a greaterdegree on the magnitude and impact of these releases than on the mag-nitude and benefit of the destruction achieved.

3

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4 ● Ocean Incineration: Its Role in Managing Hazardous Waste

The fundamental choice that must be faced iswhether to develop an ocean incineration program.This decision must consider a variety of factors,both technical and nontechnical. Because no meth-ods are risk-free, the risks that ocean incinerationposes—to human health and the marine environ-ment —and the benefits that it provides—by actu-ally destroying most of the wastes—must be weighedagainst those of the land disposal practices and othertreatment methods that are currently used for liq-uid incinerable wastes.

OTA finds that ocean incineration could bean attractive, though not essential, interim op-tion for managing liquid incinerable wastes, inparticular highly chlorinated wastes. Indeed,from several perspectives, the use of ocean inciner-ation occupies a ‘‘middle ground. In a temporalsense, it is one of several options that could helpbridge the gap between the practices of the past,which are being abandoned, and the preferred prac-tices of the future (waste reduction, recovery, andrecycling), whose capacity is only now developing.Several technical and economic factors would con-fine its applicability to a relatively small portion (lessthan 10 percent) of all hazardous wastes, althoughthey are among the most toxic and concentratedof such wastes. Finally, with respect to both risksand benefits, ocean incineration falls midway be-tween past and developing practices. For these rea-sons, ocean incineration could be a useful optiontoday but is clearly not a panacea. Multiple wastemanagement options must be developed if the Na-tion’s hazardous waste problems are to be solved.

One of the major public concerns voiced overocean incineration is that a need for the technol-ogy has not been demonstrated. Although it couldplay a role in meeting the expected near-term de-mand for alternatives to land disposal, OTA findsthat an absolute need for ocean incineration can-not be analytically demonstrated for a number ofreasons. The Nation could continue to rely onmethods that are generally less tractable for suchwastes. Moreover, predicting the rate at which pre-ferred waste management practices will supplantthe need for destruction methods such as ocean in-cineration is exceedingly difficult. (A legal require-ment to demonstrate a need for ocean dumping—

including ocean incineration—is contained in do-mestic and international regulations. No consensusexists, however, as to how this requirement shouldbe interpreted and specifically applied to ocean in-cineration. )

OTA expects that ocean incineration would ingeneral have only a limited effect on incentives forimplementing preferred waste management prac-tices. Nevertheless, to ensure that the shifttoward use of preferred practices is not impeded,any program for ocean incineration should beregarded as interim. It is important to ensure that,if permitted, reliance on ocean incineration can belessened as we develop greater capacity in betterwaste management practices and reduce the gen-eration of hazardous wastes. Within this context,ocean incineration could provide an attractive op-tion for interim management of certain wastes.

The Role of Congress

Despite its major involvement in shaping haz-ardous waste management policy, Congress hasnever directly addressed the issue of what role, ifany, ocean incineration should play. As a result,the Federal Government’s regulation of ocean in-cineration has evolved without any explicit indica-tion of congressional intent. Although few hazard-ous waste management technologies have requireddirect congressional consideration, several specialfeatures of ocean incineration may necessitate thatCongress examine public policy regarding this tech-nology.

First, despite the fact that ocean incineration isused to destroy hazardous wastes, in many respectsit falls outside of the policy and regulatory frame-work that Congress created, a framework that seeksto establish ‘‘cradle-to-grave’ management of haz-ardous wastes. Because it takes place at sea ratherthan on land, ocean incineration has been placedinto a different regulatory arena—under the um-brella of ocean dumping. The factors that originallymotivated the regulation of ocean dumping, how-ever, are somewhat at odds with the technology ofocean incineration, which involves wastes that can-not be directly dumped under present policy. More-over, the intent of using this technology is to de-

Ch. 1—Findings and Policy Options . 5

stroy wastes to the extent possible, in order to avoidthe need for direct dumping (on land or at sea). a

Second, because of its nature and setting, oceanincineration entails a wide, variety of activities thatare regulated under numerous Federal statutes andagencies. These include:

● land transportation of hazardous material bytruck or rail;

. use and development of port facilities;--- . . — -..

‘To a significant degree, this intent is accomplished; however, thosewastes that are not destroyed are re!eased directly into the marine envi-ronment.

●

federally regulated activity in States’ coastalzones;marine transportation of hazardous material;transportation, storage, treatment, and dis-posal of hazardous waste;activities that can result in air or water pollu-tion; andactivities that can affect endangered species,

Third, the activities and possible consequencesof ocean incineration typically cross political bound-aries to encompass multiple State and municipaljurisdictions. The use of ocean incineration can take

6 Ocean Incineration: Its Role in Managing Hazardous Waste

Design of an Ocean Incineration

n w-u Mist,

vessel

SOURCE: At-sea Incineration, Inc.

on international dimensions as well: waste or wasteproducts released into the environment by oceanincineration may travel significant distances, andthe site in the Gulf of Mexico designated by theUnited States is near the waters of other nations.Moreover, the potential for U.S. actions to setprecedents for other nations must be considered.

Fourth, the level of controversy and significantpublic involvement in the debate over ocean in-cineration may warrant congressional attention. Al-though the initial public response often centeredon local or regional concerns, the debate has be-come national in scope. As a result, ocean inciner-ation is increasingly viewed in a broad context, asonly one component in the process of shaping a na-tional strategy for managing hazardous wastes.

These factors are not unique to ocean incinera-tion, but their sheer number and systematic in-volvement in every application of this technologyindicate a special need for an explicit policy towardocean incineration, clearly defining what role, ifany, the technology should play in managing haz-ardous wastes.

. . . . . .Congressional involvement m decisions regard-

ing ocean incineration could take any of severalforms. The fundamental decision of whether and,if so, how to proceed with ocean incineration re-quires consideration of numerous different technicaland nontechnical factors. Many of these are regu-latory in nature, but may require oversight or direc-tion from Congress. However, other aspects ofocean incineration identified throughout this reportraise questions regarding the adequacy and appro-priateness of the current statutory authority for reg-ulating ocean incineration. The inclusion of oceanincineration under the rubric of ocean dumping andthe lack of statutory authority to develop compre-hensive regulations governing ocean incinerationare two examples of such issues. If ocean incinera-tion is permitted, resolution of these questions maynecessitate clarifying legislative action on the partof Congress.

Finally, Congress could take specific action todecide the fate of the ocean incineration program.Such action would directly establish national pol-icy toward use of this technology, and could helpguide EPA and the public in determining whetherand how ocean incineration should fit into the Na-tion’s hazardous waste management strategy. In

Ch. l—Findings and Policy Options ● 7

the absence of such action on the part of Congress,the ultimate fate of ocean incineration in the UnitedStates is an open question.

Major Public Concerns

Despite the routine use of ocean incineration formore than 15 years in Europe and more than a dec-ade of trial experience in the United States, a reg-ulatory program for ocean incineration has not yetbeen implemented. g Indeed, commercial ocean in-cineration, which has occurred only sporadicallyin this country, has been delayed at least temporar-ily, pending (at a minimum) final regulations andone or more research burns. A primary reason forthe Nation’s hesitance to embrace ocean incinera-tion as a hazardous waste management technologyhas been the strong public opposition to it. The op-position reflects a broad spectrum of concerns,some specific to ocean incineration itself, and otherssymptomatic of the much larger problem of hazard-ous waste management in general. 10 These concerns,which are evaluated in greater depth throughoutthis report, include the following questions:

●

●

●

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whether EPA has fully considered both exist-ing and developing alternatives to ocean in-cineration;whether ocean incineration is needed, in lightof the available alternatives;whether the risks and consequences of spillson land or at sea resulting from transportingor handling of waste are sufficiently under-stood, and in particular, whether availablemeans of responding to a spill are adequate;whether shipboard incinerators can adequatelydestroy wastes without posing unacceptablerisks to the marine environment or to humans;whether the regulations, monitoring, and en-forcement provisions proposed by EPA aresufficient to govern all phases of ocean inciner-ation activities; and

‘EPA proposed regulations for ocean incineration in February 1985(50 FR 8222, Feb. 28, 1985). For the purposes of this report, thisOcean Incineration Regulation will be used to represent EPA’s cur-rent approach to regulating ocean incineration, although numerouschanges are expected in the final regulation.

10A thorough and thoughtful discussion of the major areas of pub-lic concern is contained in the recent Hearing Officer’s Report onthe Tentative Determination to Issue the Incineration-at-Sea ResearchPermit HQ-85-001 (20), issued by EPA on May 1, 1986, and in theSummary of Public Comments accompanying that report.

● whether Suff icient research has been conducted

to justify the use of ocean incineration, givenour level of understanding of the marine envi-ronment and the value of its resources.

In addition, the following areas of need have beenidentified in the public debate over ocean in-cineration:

●

●

●

the need to develop an overall hazardous wastemanagement strategy that would place greateremphasis on reducing wastes at their sourceand would clarify the role, if any, of ocean in-cineration in such a strategy;the need for adequate measures to ensure thatusers of ocean incineration are fully liable forenvironmental releases or damages resultingfrom ocean incineration, and, in particular,the need for measures to address the claimsof injured parties in such cases; andthe need to consider the integrity and pastrecords of applicants for ocean incinerationpermits.

In addition to these and other specific issues, anoverriding area of public concern is whether EPAcan regulate ocean incineration in an effective andobjective manner and be truly responsive to thepublic. The lack of public trust in EPA has its rootsin the somewhat thorny history of U.S. involve-ment with ocean incineration, which is perhaps bestillustrated by examining the provisional nature ofthe current regulatory program. 11

With regard to ocean incineration, the U.S. Gov-ernment has undertaken three very different activ-ities: research, regulation, and promotion. Therelationships and boundaries between these activ-ities have often been ill-defined, and EPA has notalways fully appreciated the potential for conflictsof interest, or even the appearance of conflicts ofinterest. As a result, several such conflicts havearisen, three of which are discussed below:

1. EPA has never clearly communicate; whenand in what sequence it would conduct itsocean incineration research and develop itsregulations. Consequently, questions have

I (This issue was first clearly identified in the Hearing officer’s Re-port (20) on EPA’s proposed research burn; several additional provi-sional elements bearing on ocean incineration in general are listedhere, drawn from the history of government involvement in this area.

8 . Ocean Incineration: Its Role in Managing Hazardous Waste

2.

3.

arisen as to whether the results of researchburns carried out under the research strategywould be part of the data on which regula-tions would be based or whether EPA in-tended to develop and issue regulations be-fore granting any permits (research orotherwise). Such unanswered questions havemade the entire process appear haphazard. 12

The government’s promotional role culmi-nated in the U.S. Maritime Administrationgranting a guaranteed loan to finance the con-struction of two incineration vessels by a pri-vate company.

13 Although the government’spromotion of ocean incineration may wellhave been based on a genuine belief that thetechnology was both needed and environ-mentally sound, many members of the pub-lic have questioned the wisdom of promotingthe technology before developing a regulatoryprogram. In the eyes of its critics, EPA hascompromised its ability to fairly assess themerits and risks of ocean incineration.EPA proposed to conduct its research burnin the North Atlantic Ocean at a site that hasnot been formally designated, and the Agencyhas yielded to other agencies the authority toregulate several important activities related toocean incineration. Although clearly allowedor even required under existing regulationsand statutes, such an approach makes the reg-ulatory program seem tentative and frag-mentary.

Many of the public concerns about ocean inciner-ation can be addressed through technical or regu-latory means, but the lack of credibility and pub-lic trust are, in many respects, far more difficultto overcome. If ocean incineration is to play a rolein hazardous waste management, the government

12EPA recently decided (51 FR 20344, June 4, 1986) to deny a Pro-posed permit application for a research burn that the Agency had earliersolicited to serve as one component of its Ocean Incineration ResearchStrategy (16). In the decision, EPA stated that no permits, researchor otherwise, will be granted until final regulations are promulgated.Although this statement clarifies current EPA policy, it raises ques-tions about how the regulatory development process will be affectedby the absence of information from the research burn that was in-tended to aid in that process.

IJThe company, Tacoma Boatbui]ding, Inc. , recently filed bank-ruptcy proceedings, and its subsidiary, At-Sea Incineration, Inc., wasforced to default on its loan payments, due in large part to its inabilityto obtain operating permits for the vessels.

must not only address the specific issues listedabove, but must also provide for meaningful pub-lic involvement in the decisionmaking process ina manner that restores public confidence.

Evaluating Ocean Incineration in aBroad Context

As the previous discussion suggests, developinga policy for ocean incineration will require Con-gress to reexamine its policy towards the manage-ment of hazardous wastes as a whole. Legitimateconcerns have been raised over the need for oceanincineration, the risks it poses to the environment,and the numerous unresolved questions and uncer-tainties regarding its use. These concerns are bestviewed in the context of the corresponding avail-ability, risks, and unknowns associated with alter-native methods for managing incinerable waste.This is true for at least two reasons: no methodsare free of risk and uncertainty, and a decision notto employ one method necessarily results in the useof other methods.

Thus, resolution of the debate over ocean inciner-ation will require a thorough and objective compar-ative assessment of the technology. In particular,the full range of available choices and the trade-offs they entail must be clearly communicated.

In developing the analysis presented in this re-port, OTA encountered many issues whose dimen-sions extend well beyond the confines of ocean in-cineration, and often beyond those of hazardouswaste management in general. Some of these is-sues include:

●

●

●

●

●

●

the possibility that allowing the use of exist-ing treatment and disposal methods wouldserve as a disincentive for developing andusing better methods;the risks and regulation of hazardous materi-als transportation;problems with regulatory enforcement;the government’s capacity to monitor for ad-verse environmental impacts;the complexity of the hazardous waste mar-ket and its response to changes in the regula-tory or economic climate;the adequacy of liability provisions applicableto hazardous waste management;

Ch. l—Findings and Policy Options • 9

Photo credit: Chemical Waste Management, Inc.

The Vu/canus // incinerator ship.

● the difficulties associated with the siting of haz- cineration. In particular, the report explores thoseardous waste management facilities; and aspects of each issue that are unique to ocean in-

● the need to develop appropriate means of incineration, or for which specific approaches can bevolving the public in the decisionmaking offered for their resolution. Wherever possible, con-process. cerns regarding ocean incineration are considered

This report identifies and addresses many ofin context by comparison to concerns associated

these issues within the limited context of ocean in-with related or comparable activities.

MAJOR

The Potential Role of Land-Based andOcean Incineration14

As much as 10 to 20 percent of the estimated250 million metric tons of hazardous wastes gen-erated in the United States each year could intheory be incinerated. Nearly half of all inciner-able wastes (up to about 8 percent of all hazard-

14These findings are drawn from material presented throughout thebody of the report. Wherever appropriate, chapters containing a fulldiscussion of the basis of these findings have been indicated and shouldbe consulted.

FINDINGS

ous wastes) are liquids that could be incineratedat sea. Currently, however, only about 1 per-cent of hazardous waste is actually incinerated,and all of the incineration occurs in land-basedfacilities.

A broad range of practices is used for manag-ing incinerable hazardous wastes today. Signif-icant quantities of such wastes (as much as one-third) are recovered or recycled. Even largerquantities (as much as 65 percent), however, arebeing disposed of on land (in underground in-jection wells. landfills, or surface impound-

10 ● Ocean Iincineration: Its Role in Managing Hazardous Waste

ments) or burned as fuel in boilers and fur-naces. 15

Although a number of innovative treatment tech-nologies now under development will ultimately bepreferable to incineration, today’s land-based andocean incineration technologies represent a sig-nificant improvement over land disposal of in-cinerable wastes. A properly operating incinera-tor can permanently destroy 99.99 percent or moreof such wastes, in marked contrast to land disposal,in which wastes remain hazardous for long periodsof time.

Numerous studies have examined future demandfor incineration capacity in general. Surveys con-ducted by both private and governmental organi-zations (including EPA, the Congressional BudgetOffice, numerous State and regional hazardouswaste management planning commissions, and sev-eral waste generating industries) predict that thisdemand will continue to grow into the foresee-able future. Projections indicate that increasedquantities of hazardous waste will be generated andwill be managed through incineration. For exam-ple, current regulations mandate that waste con-taining high concentrations of polychlorinatedbiphenyls be incinerated (see box B in ch. 3), Inaddition, if implemented even roughly on sched-ule, the 1984 RCRA Amendments will restrict theland-based alternatives traditionally used for dis-posing of incinerable wastes and are expected tosubstantially increase the amount of waste avail-able for incineration (see ch. 3).

Despite this expected demand, existing incin-eration capacity is significantly below whatwould be needed to burn all incinerable wastes.Moreover, this shortfall is likely to increase withtime, largely as a result of two factors: first, theincrease in demand described above; and second,the very slow development of new capacity. Indeed,efforts to increase incineration capacity have en-countered many obstacles, including public oppo-sition, limited availability of liability insurance, anddifficulties in facility siting.

Despite this shortfall, a future need for ocean in-cineration (or land-based incineration, or any otherhazardous waste management technology) may

never be demonstrated or quantified from an ana-lytic standpoint. (See ch. 2 for a discussion of thelegal requirement to demonstrate a need to inciner-ate at sea. ) The regulatory status, economic attrac-tiveness, capacity, and actual use of each technol-ogy for managing incinerable waste vary widely,change with time, and are exceedingly difficult topredict. It is the complex interaction of these fac-tors that determines the market or need for any in-dividual option. Thus, although establishing orestimating a specific need for ocean incinerationis virtually impossible, a need clearly exists forhaving available a number of technologies ca-pable of managing incinerable wastes.

For highly chlorinated wastes, ocean inciner-ation may be preferable to available alternatives,with respect to human health risks and cost-effectiveness (see section below on technologi-cal limitations).

For other wastes, certain existing technologiesmay offer economic or environmental advan-tages over both land disposal and incineration.Current competing alternatives such as industrialboilers and furnaces burn wastes with high heatcontent to recover energy; these practices, however,are currently subject to significantly less regulatorycontrol than is incineration and may, in some cases,pose significant environmental or human healthrisks. Other alternatives allow the recovery of ma-terials from the waste. Solvent distillation, oil recla-mation, chlorination processes, and hydrogen chlo-ride recovery are examples of this approach. Theuse of such technologies for managing hazardouswastes, including developing a proper regulatoryframework, should be explored further.

Certain emerging waste reduction and treat-ment options will ultimately prove to be an evengreater improvement over the incineration tech-nologies now available, although accurately esti-mating their near-term availability and capac-ity is not currently possible.l6 In any case, theneed for waste treatment and disposal options willcontinue because of the sheer quantities of wastes,the time required to implement waste reductionmeasures and to develop sufficient capacity for recy -

lbsee Ch. LI for a brief discussion of these emerging methods. AnotherOTA assessment (14) is examining the potential for reducing the gen-erat ion of industrial wastes.15See footnote 7 in box A.

Ch. 1—Findings and Policy Options ● 1 1

cling and advanced treatment, and the fact that notall wastes will lend themselves to such techniques.

For a fuller discussion of the potential role ofland-based and ocean incineration, see chapters 3and 5.

Comparison of Land-Based and OceanIncineration

If additional capacity to incinerate liquidwastes is developed, the choice between expand-ing land-based incineration or developing oceanincineration cannot currently be resolved on atechnical basis. Nor will the collection of more in-formation be likely to significantly aid in answer-ing this question. When specific technical factorsare analyzed one at a time, one technology mayseem clearly preferable to the other, but when allsuch factors are considered as a whole, the analy-sis does not lead to an unambiguous choice. Sev-eral areas of comparison between land and oceanincineration are particularly important to consider.

Regulation

In general, the proposed regulatory frame-work for ocean incineration is more stringentand explicit than the existing regulations thatgovern land-based incineration. Technical limi-tations and performance standards, as well as re-quirements for obtaining permits, monitoring, andreporting, tend to be more involved and leave lessto the judgment of those issuing permits for oceanincineration.

In part, the regulatory differences reflect the factthat the two technologies are addressed under differ-ent primary statutes. However, they also appearto reflect two other factors: heightened public con-cern over ocean incineration, and greater perceivedand actual difficulties in monitoring an activity thattakes place far from shore.

For a fuller discussion of regulation, see chap-ter 7.

Releases of Waste

Releases of waste from the actual incinerationprocess should be equivalent for land-based andocean incineration, although the nature andlocation of these releases could differ substan-tially. Because ocean incineration requires ad-

ditional transportation and handling of hazard-ous wastes, however, it is likely to result in asomewhat greater release of waste to the envi-ronment than would land-based incineration.

EPA proposes that incineration vessels not be re-quired to have air pollution control equipment,which is required on some, but not all, land-basedincinerators. 17 This factor would not alter the to-tal quantity of waste products released during theactual incineration process. The quantity of suchproducts directly released through the stack wouldbe greater for ocean incineration than for land-basedincinerators equipped with scrubbers. However,operating a scrubber generates a hazardous wastecontaining pollutants that would otherwise havebeen emitted; this waste must be disposed of andmay itself be released to the environment, with po-tential to contaminate groundwater or surfacewater.

The size of a release is only one factor that in-fluences the severity of impact. The nature and lo-cation of expected releases must also be considered.Land-based and ocean incineration differ signifi-cantly with respect to these factors. See chapter 8for a fuller discussion of waste releases from land-based and ocean incineration.

The Issue of Scrubbers

The major technological and regulatory differ-ence between land-based and ocean incineration isthe absence of scrubbers on ocean incineration ves-sels. Scrubbers are present on approximately 45percent of existing land-based incinerators (see ch.5), including all of the large commercial facilitiesthat would offer the most direct competition toocean incineration.

The debate over the need for scrubbers on in-cineration vessels has been clouded by two com-mon misperceptions regarding scrubber and in-cinerator performance. The first involves the issueof which particular waste products are actually re-moved by scrubbers. Scrubbers are generally very

1 TFO~ convenience, Such equipsnent will be referred to h generalas { ‘scrubbers. ” Land-based incinerators burning chlorinated liquidwastes or solid wastes generally possess scrubbers, as do the large land-based commercial incinerators. Other land-based incinerators that burnother types of liquid wastes often do not; use of these facilities gener-ates emissions equivalent to incinerators at sea burning the same waste.This issue is discussed at greater length in the next section on scrub-bers, and in chs. 2 and 7.


effective at removing acid gases (e. g., hydrogenchloride) and particulate emissions (which includea large portion of toxic metals), but are not effec-tive at removing residual organic material—unburned wastes or products of incomplete com-bustion (refs. 11,17; also see ch. 7).

A second misperception is that a difference ex-ists between the emissions of organic material thatare allowed for land-based and ocean incineration.The performance of ocean incinerators (as well asland-based incinerators lacking scrubbers) is tobe measured by calculating a destruction efficiency(DE). The performance of land-based incineratorsthat carry scrubbers is measured by calculating adestruction and removal efficiency (DRE), afteremissions have passed through the scrubber. TheDE standard proposed for ocean incineration isidentical to the DRE standard for land-based in-cinerators with scrubbers. Hence, emissions fromocean incinerators could not be any greater thanthose from land-based incinerators, even afteraccounting for any incidental removal of organicmaterial accomplished by the scrubber. In otherwords, even if scrubbers were effective at remov-ing organic material from stack gases, ocean in-cinerators would still be held to the same overalldestruction performance standard.18

For these reasons, an evaluation of the need forscrubbers at sea should focus on hydrogen chlorideand particulate emissions. For these pollutants,EPA’s rationale for not requiring scrubbers on in-cineration vessels is that:

hydrogen chloride gas emissions would be rap-idly neutralized because of the high naturalbuffering capacity of the marine atmosphereand seawater, andparticulate emissions would be minimal be-cause of the specific limits placed on metal con-tent of wastes to be incinerated at sea and thefact that incineration of liquid wastes gener-ates fewer particulate than does incinerationof solid or mixed wastes.

Hydrogen Chloride Gas Emissions.—A reviewof available data reveals little documentation for

lasever~ sho~cornin~ in the o~rationd definitions Of DE ~ci DREhave been identified (see ch. 2). Because the shortcomings apply equallyto land-based and ocean incineration, however, they do not aid inthe comparative evaluation.

any significant adverse environmental impacts at-tributable to hydrogen chloride gas released fromincineration vessels. Before 1979, incineration inthe North Sea took place at a site only 23 miles offthe Dutch coast. Although no causal link to oceanincineration was established, the presence of aslightly irritating acidic atmosphere along the coast-line was reported and was one factor leading to themovement of the incineration site to a new areamore than 60 miles from the nearest shore (4,21).Designated or proposed U.S. sites are 140 to 190miles from the nearest shoreline.

Acid wastes of a much higher concentration thanwould be emitted through ocean incineration aredirectly dumped at two industrial waste disposalsites in the North Atlantic Ocean (3). Although thisdirect dumping has caused some short-term andlocalized perturbations in the alkalinity of the sea-water, complete neutralization occurs within a fewhours after the dumping and no adverse effects onmarine life have been detected. In ocean incinera-tion, the much lower concentrations of acid wouldbe deposited over a larger area and over a longerperiod of time than is the case in direct dumping.Indeed, past monitoring of ocean trial burns didnot detect any change in the alkalinity of surfacewaters that came into direct contact with the in-cinerator plume (see ch. 11). The potential for dam-age to occur to organisms in the surface microlayerprior to dispersion or neutralization, however, hasnot been adequately addressed (see ch. 9).

EPA has proposed an environmental perform-ance standard that would allow only a very smallchange in the alkalinity of seawater at an incinera-tion site. EPA’s calculations indicate that this stand-ard would easily be met even under extreme cir-cumstances (see chs. 7 and 8).

According to the chairman of the committee thatprepared the Science Advisory Board report onocean incineration (19), these and other consider-ations led the SAB to conclude that using the buffer-ing capacity of the ocean to neutralize acidic emis-sions from ocean incinerators did not pose anymajor problems (5).

Particulate Emissions. —Incinerating hazard-ous waste generates particulate matter that is com-posed primarily of metals, along with other inor-ganic material originally present in the waste. The

Ch. l—Findings and Policy Options ● 1 3

chief motivation for controlling particulate emis-sions is that, in the process, a significant portionof toxic metals is also controlled.

Toxic metals are “conservative” pollutants; thatis, they are not destroyed in the environment oreven in a process such as incineration, althoughtheir chemical form and degree of hazard can bealtered. Thus, any toxic metals present in the origi-nal waste remain after incineration, either in theresidual ash left in the combustion chamber or inthe exhaust stream exiting the incinerator stack.

Two different approaches to controlling metalemissions have been applied to land-based andocean incineration. On land, stack scrubbers areutilized to trap particulate, but relatively little con-trol is exercised over the metal content of wastesto be incinerated. At sea, rather than require scrub-bers, EPA has proposed to limit the metal contentof wastes accepted for incineration. Emissions ofsome metals would be further limited by an envi-ronmental performance standard that would pro-hibit applicable marine water quality criteria to beexceeded (see ch. 7).

In addition to the amount of a metal present, itschemical form affects its behavior in the environ-ment, its potential to cause adverse impact, and insome cases the efficiency with which it is removedby a scrubber (see ch. 7). The insufficient charac-terization of incinerator emissions described pre-viously extends to determining the chemical form,as well as quantity, of particular metals. It is es-sential that such a characterization be under-taken if the absence of a requirement for scrub-bers on incineration vessels is to be justified.Further regulation of metal emissions may well bewarranted, given EPA’s finding that most of thehuman health risks associated with ocean inciner-ation are derived from metal emissions (18).

Determining the appropriate limits for metals inwastes to be incinerated at sea certainly requiresfurther scrutiny, but in general EPA’s proposed ap-proach to limiting metal emissions is a reasonablealternative to requiring scrubbers on ocean inciner-ators. Such an approach, however, must be cou-pled with rigorous environmental monitoring to de-termine if unacceptable impacts occur.

As a final consideration, available data indicatethat even under the most extreme circumstancesallowed under EPA’s proposed regulation, the to-tal amount of metals released into the marine envi-ronment from ocean incineration would be verysmall in comparison to the amount from othersources and permitted activities (see ch. 8).

Therefore, based on the available information,OTA finds that the lack of a requirement for airpollution control equipment on ocean inciner-ation vessels appears justified, so long as oper-ating conditions and the metal content of wastesincinerated at sea are appropriately regulatedand such activity is linked to a rigorous envi-ronmental monitoring program.

Two additional arguments have been offeredagainst requiring air pollution control equipmenton ocean incineration vessels. First, the costs of in-stalling, maintaining, and operating such equip-ment are substantial, and could significantly reducethe competitive status of ocean incineration rela-tive to other alternatives. Second, the installationof scrubbers on incineration vessels faces major de-sign impediments, including spatial, weight, andfresh water requirements (15). Such constraints areespecially applicable to retrofitting existing ships,which have short vertical stacks. (Other proposeddesigns would utilize seawater ‘ ‘scrubbers’ onhorizontally oriented incinerators, but the scrub-ber effluent would be discharged directly into theocean, making the term scrubber somewhat of amisnomer. )

Although further research into using true scrub-bers aboard ships is certainly warranted, their im-mediate application appears difficult if not im-possible. In their absence, EPA’s reliance on anappropriate combination of waste and emissionslimitations, incinerator performance standards, andenvironmental monitoring requirements appears tobe a reasonable alternative approach.

Health and Environmental Risks

Land-based and ocean incineration each involveseveral kinds of risks, some of which are uniqueto one technology, others common to both. Theirprimary risks differ substantially, however, thus


constraining any quantitative comparison of thesetechnologies. Consideration of these primary risksis, nevertheless, essential in determining policytoward the use of incineration.

Because land-based incineration occurs rela-tively close to human populations, its primaryrisk is the potential for adverse impact on hu-man health-resulting from exposure to routineor normal releases of waste or waste products.A full understanding of the magnitude of this riskis constrained by our lack of knowledge concern-ing the nature of incinerator emissions and thedifficulties associated with environmental monitor-ing of land-based incinerators.

In contrast, ocean incineration’s primary riskis to the marine environment. Most of this riskderives from the potential for a major acciden-tal spill. By all estimates, such an event would beextremely unlikely to occur, even less likely thana spill resulting from the transportation of nonwastehazardous materials. However, a major spill of ei-ther hazardous waste or nonwaste material couldhave catastrophic consequences; for example, if itoccurred in a sensitive estuarine area, large-scaleloss of fish and bottom-dwelling organisms couldresult. The situation would be exacerbated by theacknowledged difficulty or impossibility of cleanup.

The major risk to human health from oceanincineration is expected to arise from exposuresdue to the transport and handling of wastes onland. In this respect, land-based and ocean inciner-ation appear to be quite similar.

For further discussion of risks to human andenvironmental health posed by land-based andocean incineration, see chapter 9.

Unanswered Questions

EPA’s Science Advisory Board has identifiedmany unanswered questions, regarding perform-ance and emissions, that apply to both land andocean modes of incineration and, in some cases,to all combustion processes. 19 For example, the SABstated that no reliable characterization of emissionsor their toxicities is available for either technology,

Igsuch processes include the burning of fossil fuels in powerp]ants,the burning of gasoline in automobiles, and even the burning of woodin fireplaces.

which means that the potential for exposure andadverse impact to the environment or to humanscannot be adequately assessed. The study also chal-lenged EPA’s method of evaluating the total per-formance of both land-based and ocean incinera-tors by measuring destruction efficiency for onlya few selected compounds. The SAB recommendedthat EPA undertake a complete characterization ofemissions and products of incomplete combustionarising from both technologies. These well-foundedconcerns are addressed in more detail in chapter 2.

Technological Limitations

Because land-based and ocean incineration eachpossess inherent capabilities and limitations, froma technical perspective certain wastes are bettermanaged by one or the other technology. Twoexamples of such factors are discussed below.

First, because they cannot incinerate solidsand sludges, ocean incinerators are inherentlyless versatile than land-based rotary kiln inciner-ators, despite their greater capacity. Such a limi-tation can be especially important in local or re-gional settings, where a variety of waste types mayneed to be incinerated. In addition, applying wasterecovery and recycling technologies to incinerablewastes is expected to increase the amounts of in-cinerable solids and sludges at the expense of in-cinerable liquids (see ch. 3). For these and otherreasons, a number of States20 plan to build land-based rotary kiln facilities to meet their anticipatedneeds. It is not known how much and how soonsuch efforts might affect the shortfall between ca-pacity and demand for incineration.

Second, despite the limitation discussed above,incineration of highly chlorinated wastes at sea hascommonly been preferred over their incinerationon land. Indeed, in both Europe and the UnitedStates, ocean incineration has been employedalmost exclusively for highly chlorinated wastes.The extensive rationale for this is based on the factthat incinerating such wastes generates high con-centrations of corrosive and toxic hydrogen chlo-ride gas. For numerous reasons related to this find-ing, incineration of highly chlorinated wastes atsea may be advantageous:

● Incineration of such wastes on land requiresZtlFor eXarn#e, see refS. 2,7.


the use of scrubbers, which are costly and dif-ficult to operate and maintain.

● Scrubber operation generates additional haz-ardous waste that must be disposed of, typi-cally through neutralization and discharge intosewers or surface impoundments. These prac-tices can in turn contaminate groundwater orsurface water,

● Limitations on the chlorine content of wasteare often written into the operating permitsof land-based incinerators, for three reasons:—Certain highly chlorinated wastes can, in

fact, exceed the feasible capacity of scrub-bers for removing hydrogen chloride gas.

—The energy content of a waste decreases asthe chlorine content increases. Thus, for agiven feed rate, as chlorine content increasesa point is reached where insufficient energyis present to ensure combustion.

—Free chlorine gas, which is even more toxicto humans than hydrogen chloride gas andis not efficiently removed by scrubbers, isgenerated during the incineration of highlychlorinated wastes. As a result, an upperlimit on the chlorine content of wastes mustbe set, usually at about 30 percent (23).In light of these factors, highly chlorinated

wastes can be burned on land only if they areblended with auxiliary fuel or nonchlorinatedwastes to reduce the chlorine content and in-crease the energy content of the waste beingincinerated. The net effect is a reduction inthe effective capacity of land-based incinera-tors for chlorinated wastes.

● Ocean incineration vessels are not required tohave scrubbers, because of the capacity of sea-water to neutralize hydrogen chloride gas, andbecause the incinerators operate at a locationfar removed from human populations. (Seesection above on scrubbers and chs. 2 and 7.)

● Because they lack scrubbers, ocean incinera-tors can burn chlorinated wastes at a muchhigher rate than can land-based incinerators.Consequently, ocean incineration has a greatercapacity for chlorinated wastes. Moreover, thehigher feed rate reduces or obviates the needto use supplementary fuel or high energywastes.

Thus, from the perspectives of human healthrisks, capacity, and cost-effectiveness, inciner-ating highly chlorinated wastes at sea may bepreferable to incinerating them on land. Thesebenefits must be balanced against the potentialrisks ocean incineration poses to the marine envi-ronment.

Releases of Waste to the MarineEnvironment

Releases of waste and risks of impact from oceanincineration should properly be viewed in the con-text of releases and risks from comparable activi-ties and from other sources of marine pollution.Only in such a context can the significance of suchrisks in relation to potential benefits be fullyassessed.

Ocean incineration entails a very small incre-mental increase in risk relative to that routinelyborne by this Nation in the marine transport ofhazardous (nonwaste) materials. This is the casewith respect to the number of transits, quantitiesand types

21 of material carried, and the expectedfrequency and size of releases. However, given thepotentially catastrophic consequences of a ma-jor marine spill, the acknowledged difficulty orimpossibility of cleanup, and the intense pub-lic concern focused on this issue, extensive reg-ulatory attention would be warranted if oceanincineration were permitted. This should includeconsideration of measures beyond the already sub-stantial provisions that exist or have been proposedby EPA and the U.S. Coast Guard (see ch. 2).

In certain settings, the normal operation of in-cineration vessels may represent a small but poten-tially significant contributor of some pollutants tothe marine environment. This contribution, how-ever, is expected to be considerably smaller thanthat of other permitted activities that introducepollutants to marine waters. Furthermore, pol-lutants released during normal incineration oper-ations would result in virtually no detectable long-term increase over background levels, except in ex-treme circumstances.

ZIOne major exception is speci~ wastes, such as PC Bs, which areno longer commercially produced and are therefore not routinely trans-ported, except as waste. See box B in ch. 3.


Prior to dispersing, pollutants emitted by oceanincinerators could cause short-term adverse impactsupon contact between the incinerator plume andthe ocean surface. Although the affected region isexpected to be limited to a small area along the pathof the ship, in this region significant damage couldresult. Further study of such impacts, particularlyon the surface microlayer (see ch. 9), is warranted.

For further discussion of releases of waste fromocean incineration relative to other sources of ma-rine pollution, see chapter 8.

Past and Current Use of HazardousWaste Incineration

Currently, all U.S. incineration of hazardouswastes takes place in land-based facilities. EPA hasestimated that there are currently 240 to 275 land-based hazardous waste incinerators in the UnitedStates (6, 10). About 210 to 250 of these facilitiesare located at sites where the incinerated wastes aregenerated. These onsite facilities are generally usedsolely for incinerating wastes generated by theirowners. Approximately 30 others are commercial,offsite, facilities used to incinerate waste generatedby industrial clients. Estimates of the annual quan-tity of wastes destroyed by incineration range fromabout 1.7 million metric tons (mmt) in 1981 (22)to 2.7 mmt in 1983 (12). In 1980, about 0.4 mmtwas incinerated at commercial facilities (l).

Ocean incineration has been employed in theUnited States only on a research or interim basis,but has been used routinely in the North Sea forEuropean wastes for more than a decade. Two in-cinerator ships are currently operating in Europe;22

two have recently been built in the United States,but have yet to be employed commercially. Sev-eral other companies have expressed interest in themarket.

The technological performance and environ-mental effects of ocean incineration have been sub-jected to considerable testing (see ch. 11). Unfor-tunately, the results of this effort are hotly contested,and do not aid substantially in evaluating the safetyof ocean incineration. The test data appear to sup-port two somewhat conflicting findings:

ZZThe two Vesse]s are the Vulcan us 11 and the Vesta; the VukanusZ is operationa] but not currently active.

1. Ocean incineration can, at least under certainconditions, meet applicable regulatory andtechnical requirements and achieve very effi-cient destruction of hazardous wastes.

2. The technology’s ability to perform in sucha manner consistently has not been demon-strated for complex mixtures of wastes or thebroad range of operating and environmentalconditions likely to be encountered.

For further discussion of the use of hazardouswaste incineration at sea and on land, see chs. 3,5, and 11.

Recovery, Recycling, and Reduction ofIncinerable Wastes23

Recovery, recycling, and reduction practices aregenerally given preferred status in the hazardouswaste management hierarchy discussed previously.Many critics of ocean incineration argue that allow-ing its development would impede efforts to imple-ment these preferred practices. (In the followingdiscussion, a distinction is drawn between wasterecycling/recover y and waste reduction. )

Some wastestreams comprising incinerable wasteare very amenable to recovery and recycling proc-esses. Much of this potential, however, is already be-ing realized. For example, large quantities of wastesolvents (as much as 70 percent) and oils (about 10percent) are currently recovered (see ch. 3). Severaladvanced thermal destruction techniques can recoveror reutilize the chlorine content of chlorinated wastes.These technologies, however, have only been usedon a small scale, primarily in Europe, and are notcompetitive with other sources of the recovered ma-terial. They have not been employed commercially

in the United States and provide little or no capacityat the present time, Thus, only modest increases inrecovery and recycling of liquid organic hazard-ous wastes are expected in the near future.

Much of the anticipated increase in recovery

and recycling of hazardous wastes in the nearfuture will involve wastestreams that have lit-

Zs’rhese issues are explored in ref. 14. Based on the definition usedin that study, the term waste reduction is distinguished in this reportfrom recycling and recove~; it generally refers only to those prac-tices that reduce waste at its source. This definition excludes wasterecycling, for example, unless it occurs as an integral part of an in-dustrial process. Also see footnote 3

Ch. l—Findings and Policy Options • 17

tle or no potential for incineration, for exam-ple, metal-containing liquids and sludges. De-velopment of ocean incineration and expansion ofland-based incineration would not be expected toaffect incentives for recycling or recovery of thesenonincinerable categories of waste.

Estimating to what extent the implementationof waste reduction practices will affect the quan-tity of incinerable wastes generated is virtuallyimpossible. In large part, this uncertainty is dueto the lack of data and even appropriate meansto measure waste reduction. The visibility and ap-plication of waste reduction measures are clearlyincreasing, and their potential to reduce the gen-eration of hazardous waste is enormous. It is equallyclear, however, that major institutional, economic,and attitudinal obstacles impede its widespread ap-plication in the near future (14).

Even the most optimistic observers of ocean in-cineration project a total industry of only severalships, which together would be capable of inciner-ating a small fraction of incinerable liquid waste,and an even smaller fraction of all hazardous waste.This probable market picture—together with lim-ited or uncertain application of reduction, recov-ery, and recycling practices to incinerable wastes—argues that the development of ocean incinera-tion, as an interim option, would be expectedto have a very limited effect on overall incen-tives for using these practices (see chs. 2 and 3).There is no consensus, however, regarding this con-clusion. Indeed, some critics strongly contend thatocean incineration will have a significant adverseeffect on such incentives. OTA’s policy options (dis-cussed below) include provisions that could be usedto ensure that the shift toward use of preferred prac-tices is not impeded.

Recovery processes applied to liquid wastes gen-erally produce residuals. Thus, increasing use ofsuch processes is likely to increase the quantitiesof incinerable sludges and solids (which cannot beincinerated at sea) relative to the quantities ofocean-incinerable liquids. Many residuals fromproduct purification as well as recovery processes,however, are in liquid form and are prime candi-dates for ocean incineration.

Thus, although significant long-term poten-tial remains for further application of recoveryand other emerging technologies, in the near-

term they appear unlikely to substantially re-duce the amount of incinerable waste (liquidsas well as sludges and solids) requiring manage-ment through currently available means.

The Use of Ocean Incineration byOther Nations

Ocean incineration of hazardous wastes has beenused routinely in Europe since 1969, and two in-cineration vessels are currently operating full-timein the North Sea. Opinions and positions regard-ing the future use of ocean incineration vary greatlyamong European and other developed nations.General agreement exists that incineration at seashould be viewed as an interim method for man-aging wastes, to be used only when preferable land-based alternatives are unavailable. No consensuscurrently exists, however, regarding when it willbe possible to terminate its use.

In 1981, members of the Oslo Commission,which includes most Western European nations,adopted a rule stating that ‘ ‘the Commission willmeet before the first of January 1990 to establisha final date for the termination of incineration atsea ‘‘ in the Oslo Convention area (i. e., the NorthSea). In 1985, a survey of Member States was un-dertaken to determine the feasibility of endingocean incineration in the North Sea on or aboutthat date. The survey documented the followingtrends:

● There is a potential shortfall in the capacityof land-based incinerators and other 1and-

●

●

based treatment methods to dispose of thewastes currently being incinerated at sea.Spare capacity on land is considered far fromsufficient, and very little increase in such ca-pacity is expected in the near future.The major constraint blocking termination ofocean incineration is the lack of land-based ca-pacity for chlorinated hydrocarbon wastes.It is expected that by 1990 wastes will remainfor incineration at sea.

Certain nations, such as Denmark and Sweden,argue for termination as soon as possible; some na-tions, such as The Netherlands and the FederalRepublic of Germany, regard ocean incinerationas a necessary method for the foreseeable future be-cause land-based incineration capacity is lacking;

18 ● Ocean Incineration: Its Role In Managing Hazardous Waste

and other nations, such as the United Kingdom,view ocean incineration of certain wastes to be thebest practicable environmental option.24

Conclusion

The preceding discussions suggest the possibil-ity that ocean incineration, carried out under asufficiently rigorous and comprehensive regulatoryframework (see discussion of policy options laterin this chapter and ch. 2), could be one of severaloptions to fill an interim need in hazardous waste

Z4There are further indications of the ambiguity with which Euro-peans view ocean incineration. For example, both The Netherlandsand West Germany have reported that they anticipate significant de-creases in their reliance on ocean incineration as a result of increasesin land-based capacity. More recently, however, The Netherlands an-nounced plans to conduct a trial burn of PCBS, in anticipation of theneed for the ocean incineration option resulting from the loss of thecountry’s land-based incineration capacity for PCBS (see ch. 12).

management. Under such a scenario, ocean incin-erators would focus on highly chlorinated liquidwastes (possibly including special wastes such asPCBs) that can be advantageously burned at seabecause of the absence of a requirement for scrub-bers. Land-based incinerators might concentrateon wastes that could not be burned elsewhere—organic sludges and solids with relatively high metalcontent and relatively low energy value. Liquidswith high heat content but little or no chlorine mightcontinue to be burned in industrial boilers and fur-naces, though under stricter regulation where ap-propriate. Much of the expected application ofwaste recovery and recycling to incinerable wastesis expected to be applied to such liquids, and thuswill produce organic sludges appropriate for land-based incineration. As capacity develops in bettertechnologies, and as waste reduction practices areincreasingly implemented, the use of ocean inciner-ation should be concomitantly decreased.

DECIDING THE FATE OF OCEAN INCINERATION:MAJOR POLICY OPTIONS

Out of the controversy and polarization sur-rounding the development of ocean incineration,several disparate perspectives have emerged regard-ing whether and, if so, how to use this technology.The fundamental choice of whether to proceed can-not be resolved on a technical basis; it will requiredifficult political choices as well. Much of the de-bate has focused on the whether question in an all-or-none fashion. Certain intermediate alternatives,however, might be considered that would allowsome use or further investigation, carried out ina manner that directly addresses the areas of dis-agreement.

Because ocean incineration has the potential toplay an important but limited interim role in man-aging hazardous wastes, there is a need to considera broad range of possible approaches to its use, in-cluding certain intermediate options. This intentis reflected in four distinct policy options OTA hasidentified: :25

zsThiS discussion is limited to consideration Of policy options thataffect the fate of ocean incineration. If a decision were reached to pro-ceed with ocean incineration, numerous additional issues and options

●

●

●

Option 1: Halt the development of ocean in-cineration permanently and rely entirely onland-based options.Option 2: Halt commercial ocean incinerationtemporarily, until more research is completed.The research would probably require a fewburns at sea to collect data needed to evalu-ate incinerator performance, to characterizeemissions, and to assess environmentalimpacts.Option 3: Proceed with a commercial oceanincineration program under the regulatoryframework being developed by the Environ-mental Protection Agency. 26

related to the shaping of an actual program would need to be addressed.Resolution of some of these issues may require regulatory action onthe part of EPA or oversight on the part of Congress; others may ne-cessitate additional legislative action. Detailed discussion of these is-sues is presented in ch. 2.

zcIn this report, EpA’s developing regulatory framework iS repre-sented, for the most part, by EPA’s proposed Ocean Incineration Reg-ulation (50 FR 8222, Feb. 28, 1985). Several substantial changes areexpected during finalization of this regulation, some of which maydirectly bear on issues discussed under option 4.


● Option 4: Proceed with a modified ocean in-cineration program that would accomplish oneorA.

B.

c.

more of the following:include provisions that impart an interimstatus to the program;strengthen regulatory requirements wherenecessary to address areas of deficiency orcontinuing public concern; and/orprovide for greater direct involvement bythe government in the actual operation ofocean incineration.

For options 3 and 4, numerous factors would de-termine the scale of the program. These include in-fluences from market factors, government interven-tion, public opposition, and modification of theregulatory program in response to new informa-tion. Many of the factors could be subject to direc-tion through regulatory or economic measures, butothers would be more difficult to predict or control.

Policy Options and Their Implications

Each of these policy options has certain impli-cations when viewed in the context of overall man-agement of hazardous wastes. Moreover, eachchoice necessarily engenders additional decisionsthat must be made. Some of the possible implica-tions of each option are presented below.

Option 1:Halt the development of ocean inciner-ation permanently and rely entirely onland-based options.

Implications

1. Land-based incineration capacity for inciner-able wastes would lag even further behind demand.If three of the existing incineration vessels27 wereused, the commercial incineration capacity for liq-uid wastes would roughly double. In their absence,efforts to expand the capacity of land-based inciner-ation or other alternative technologies would needto increase.

2. The increased shortfall between incinerationcapacity and demand might cause some limited in-

crease in incentives for waste reduction, recycling,and innovative treatment of incinerable liquids.The need for currently available waste treatmentoptions would clearly continue into the foreseeablefuture, however, because of the sheer quantities ofwastes, the time required to implement waste re-duction measures and to develop sufficient recy-cling capacity, and the fact that not all wastes willlend themselves to such techniques.

3. The incentive for waste generators to man-age their incinerable liquid wastes onsite would beexpected to increase somewhat, which might meanan increase in noncommercial incineration or othertreatment capacity. Reliable estimates of the ex-tent of this increase do not exist.

4. If sufficient alternative capacity were not de-veloped, wastes would continue to be disposed ofon land, often using practices that pose demon-strated risks to the environment and human health.Under the Hazardous and Solid Waste Amend-ments of 1984, wastes to be banned from land dis-posal could be granted variances or extensions ifsufficient alternative treatment, recovery, or dis-posal capacity were not available.28

5. More incineration would take place in land-based facilities closer to human populations, therebyincreasing direct human exposure to incineratoremissions. At the same time, the risk of a spill orother adverse impact on the marine environmentwould not be increased.

6. Prices charged to generators to dispose of atleast some incinerable hazardous wastes (e. g.,PCBs) would probably rise, because of increaseddemand on available capacity. This same factormight also increase existing pressures to dispose ofhazardous waste illegally.

Option 2:Halt commercial ocean incineration tem-porarily, until more research is com-pleted. The research would probably re-quire a few burns at sea to collect dataneeded to evaluate incinerator perform-

ZTIt is assumed that three incineration vessels would operate pri-marily in the United States: the Apollos Z and 11 and the Vulcan usZZ. The remaining vessels are assumed to continue operating in Europe.

Zesec. 2(I I (h) of the amendments specifies that such variances orextensions may be granted for a maximum of 2 years. The courseof action that would ensue after 2 years if alternative capacity werestill unavailable is not clear.


ance, to characterize emissions, and toassess environmental impacts.

Implications (in addition to those forOption 1)

1. A climate of extended regulatory uncertaintyprobably would significantly impede or halt newinvestment in the ocean incineration industry. Therecent bankruptcy of the builder of the Apollo in-cineration vessels and their owner’s subsequent loandefault are widely attributed to their inability to ob-tain an operating permit. Some companies cur-rently awaiting program development might decideto abandon plans to enter the market.

2. Research would probably answer some ques-tions and narrow the overall window of uncertainty.It should be relatively easy, for example, to improveour understanding of the composition of incinera-tor emissions and at least their initial environmentalbehavior. Nevertheless, numerous questions, espe-cially those involving the risk of spills or cumula-tive adverse environmental impacts, would prob-ably only be resolved through experience on a largerscale.

3. If a decision were ultimately made to proceedwith ocean incineration, the ensuing programwould probably benefit from information gleanedthrough research. Incorporating such informationinto a regulatory program during its developmentwould probably be easier than modifying an on-going program.

4. The question of when enough research hadbeen done would have to be faced. Comparable at-tention to information gaps in other alternativeswould be necessary, including land-based inciner-ation, to provide a valid comparative risk assess-ment. After any amount of research, some level ofuncertainty would always remain, and decisionswould have to be made in the face of incompleteinformation.

5. Criteria for determining the type and num-ber of ocean research burns to conduct would needto be developed and evaluated. For example, EPA’sOcean Incineration Research Strategy (16) calls forusing PCB waste because both the toxicity charac-teristics and the detection methods for PCBs havebeen well studied. Because typical ocean incinera-

tion wastestreams would probably be composed ofcomplex mixtures of many different chemicals,however, the applicability of results from this testburn to real situations would be limited.

6. The question of who should do the researchwould also need to be faced. Widespread publicmistrust currently exists as to whether EPA or in-dustry could objectively carry out the research. Ad-dressing this credibility gap or identifying alterna-tive ways to perform the studies or to assure credibleresults would not be an easy task.

Option 3:Proceed with a commercial ocean in-cineration program under the regulatoryframework being developed by the Envi-ronmental Protection Agency.

Option 4:Proceed with a modified ocean inciner-ation program that would accomplishone or more of the following:

A.

B.

c .

include provisions that impart an in-terim status to the program;strengthen regulatory requirementswhere necessary to address areas of defi-ciency or continuing public concern;and/orprovide for greater direct involvementby the government in the actual oper-ation of ocean incineration.

In contrast to the first two options, options 3 and4 both involve a choice to employ ocean incinera-tion on a routine basis.29 Options 3 and 4 differfrom each other primarily in how much they woulddictate or influence the scale of the ocean inciner-ation program. The discussion of these options,therefore, begins below by examining factors thatmight influence the extent to which ocean inciner-ation would be used. The discussion also exploressome of the implications of proceeding with oceanincineration on various scales.

Option 4 goes beyond the status quo approachof option 3, by suggesting several approaches to ad-dressing certain of the key deficiencies or poten-

Zg”rhe actua] shaping of an ocean incineration program would in-volve numerous additional technical and policy factors that are dis-cussed in ch. 2.


tial uses of ocean incineration that OTA has iden-tified. The discussion considers several possibledepartures from EPA’s proposed program, both toaddress specific shortcomings and to illustrate thepotential for modifying the current approach tousing ocean incineration. Most importantly, thediscussion suggests certain mechanisms that mighthelp to ensure that any ocean incineration programthat developed would be instituted in an interimmanner, allowing the reliance on ocean incinera-tion to decrease as capacity in better alternativesdevelops.

Determining the Scale of an OceanIncineration Program

Influences

Although innumerable factors would influencethe scale of an ocean incineration program, manycould be directly controlled through regulatory oreconomic measures. Depending on how much con-trol the government exerted, the scope of the pro-gram could be tentative or experimental in nature,could evolve in an essentially free market setting,or could entail active government promotion or in-volvement.

Regardless of the intent and extent of the con-trols, however, predicting the actual scale of oceanincineration would be difficult. This source of un-certainty would complicate the task of estimatingresource allocation and regulatory needs, and ofpredicting how ocean incineration would affect haz-ardous waste management in general. Sufficient re-sources must be available for regulatory and mon-itoring activities to ensure safe operation and toallow the collection of reliable data on which to basefuture decisions. Moreover, the question of whoshould pay for these activities must be addressed.The availability of resources, particularly in a timeof fiscal restraint, must be seriously considered indeveloping and designing a regulatory program.

Four categories of “scaling” factors are discussedbelow:

1. Market Factors: These are factors that directlyinfluence the costs of doing business either forthose who generate wastes or for those whoown and operate incineration facilities. Thesecosts would, of course, be strongly influenced

2.

by regulations or other government actions(see below). Market factors would include howmuch waste generators would have to pay forocean incineration services compared to howmuch other alternatives cost; the availabilityand regional distribution of ocean incinera-tion sites and of port facilities for storage andtransfer of wastes; and how much new capi-tal investment would be required to developsuch facilities.

The current economic status of incinerableliquids with high fuel value (i. e., energy con-tent) exemplifies the influence of market fac-tors. Such wastes currently represent a verycompetitive market, comprised of industrialboilers and furnaces, recovery and recyclingoperations, and land-based incinerators. Thepredictable result is that wastes move in thedirection of lowest costs to generators (withinregulated bounds). The entry of ocean inciner-ation into such a market would result in ad-justments based largely on how competitivelypriced the new services were.Government Intervention: Ocean incinera-tion, if developed, would obviously be sub-ject to tremendous governmental attention,which could take both regulatory and non-regulatory forms. Regulatory requirementscould, for example, influence the market forocean incineration by affecting the quantitiesand types of waste available for ocean inciner-ation (e. g., limitations on waste composition;requirements to demonstrate a need to in-cinerate at sea) or the costs of doing business(e.g., requirements for liability and financialresponsibility; fees for monitoring and permit-ting). Nonregulatory influences might includeeconomic incentives or disincentives or directgovernment support measures (e. g., loanguarantees; taxes assessed on the quantity ofwaste generated or disposed; government own-ership or operation of incineration vessels).

Broader government regulatory actions in-fluencing hazardous waste management ingeneral could exert significant indirect influ-ence over the use of ocean incineration. Ex-amples of such factors include the extent andschedule of implementation of the 1984 RCRArestrictions on land disposal and the develop-ment of siting criteria for disposal facilities.


3.

4.

Piblic Opposition: EPA’s attempt to developa regulatory program for ocean incinerationhas encountered growing public opposition toall phases of operation: locating port facilitiesfor storing and transferring wastes; transport-ing wastes over land to port sites; designat-ing sites for ocean incineration; setting re-quirements for permits and liability; andregulating the incineration process itself. Thepublic has also been critical of the adequacyof mechanisms for ensuring meaningful publiceducation and participation.

Perhaps most important, the public hasquestioned whether EPA can objectively de-velop and administer a regulatory programfor ocean incineration, Indeed, legitimatepublic concern exists over the potential for sig-nificant conflict of interest between EPA’spromotional and regulatory roles. Clearly,additional means of addressing public con-cerns must be developed as part of any futureprogram.‘ ‘Feedback Another factor that would in-fluence the scale of an ocean incineration pro-gram would be any response taken to accountfor new information obtained through experi-ence or monitoring. As operations proceededon any scale, data would need to be gatheredand analyzed to answer unresolved questionsand to evaluate the adequacy of the regula-tory program. Such data might relate to ac-cident rates, the relative safety of differenttechnologies, the effectiveness of particularregulatory measures, the results of environ-mental monitoring, or the program’s influenceon progress toward implementing measuresto reduce waste or developing preferable treat-ment alternatives.

The regulatory program’s ability to respondto the new information would depend on nu-merous factors, such as the effectiveness of thedata-collection efforts, the ability of the reg-ulatory and political processes to accommo-date needed changes in a timely manner, andthe nature of the gathered information itself.Mechanisms would have to be developed formodifying the scale of the program if the dataindicated that adjustments were warranted.

Two examples illustrate the potential need foradjustments:

1.

2.

Further controls or incentives might be re-quired if the market outlook for ocean inciner-ation conflicted with waste management pol-icy. For example, as capacity in preferablealternatives such as recycling and recovery de-veloped, economic or regulatory measuresmight be needed to redirect wastes from oceanincineration to these options. Such measurescould be particularly important to ensure theinterim status of the ocean incinerationprogram.New scientific information or regulatory re-quirements might arise. For example; thecumulative effects of large-scale incinerationat a single site could become significant andrequire attention.

Specific Approaches

The proposed regulatory framework for oceanincineration contains few provisions that woulddirectly limit the scale of the program. As currentlyformulated, it could be expected to result in a rela-tively open-ended (although highly regulated) sys-tem, whose size would largely depend on privateinitiative and investment and on the operation ofthe market. This approach would be consistent withthe current regulatory approach to land-based in-cineration and certain other hazardous waste tech-nologies.

Recent statutory and regulatory attempts to shifthazardous waste management away from sometraditional land-based disposal options and towardbetter treatment technologies provide examples ofthe government’s intervention into the market forthe purpose of achieving a desired waste manage-ment goal. Congress and EPA might wish to con-sider analogous measures for controlling the use ofocean incineration, particularly if interim statuswere the desired goal. OTA has identified severalpossible approaches.

Permit Ocean Incineration Only for Wastesfor Which a Need To Incinerate At Sea Can BeDemonstrated.— Whether there is a need for oceanincineration is the subject of both public and legal


concern. The issue of need is closely related to thequestion of how ocean incineration would affect theuse of better waste management or waste reduc-tion alternatives. (See ch. 2 for a fuller discussionof both of these issues. ) OTA expects that devel-oping ocean incineration would probably not sig-nificantly impede the development and implemen-tation of preferable alternatives. Certain regulatorymeasures could be applied to users of ocean inciner-ation, however, to ensure that the best availableoptions are used to manage or reduce the genera-tion of incinerable wastes.

Such measures, which could be implementedthrough the permitting process, might require awaste generator to demonstrate that ocean inciner-ation would be better than (or at least not inferiorto) the other available options. Alternatively, themeasures could require the waste generator to dem-onstrate that no feasible land-based alternativeswere available for a particular waste. A third ap-proach would be to use the permitting process tolink use of ocean incineration to compliance witha schedule for achieving particular levels of wastereduction, recovery, or recycling.

For these sorts of measures to succeed, severalimplementation problems would have to be resolved(see ch. 2). Nonetheless, mechanisms of this sortcould provide concrete means to ensure that oceanincineration was indeed employed in an interimmanner.

Direct Certain Wastes Toward or Away FromOcean Incineration. —OTA’s finding that highlychlorinated wastes might be more beneficially in-cinerated at sea than on land suggests the possibil-ity of encouraging or even requiring the use ofocean incineration for such wastes (assuming theymeet other applicable criteria).

EPA has proposed limiting the metal contentof wastes to be incinerated at sea. The adequacyof the proposed limits, however, is at issue (see ch.2), and will likely require further scrutiny and pos-sible revision of the proposal. If the final regula-tion maintains the lack of a requirement for scrub-bers on incineration vessels, adequate control overmetals will be an essential regulatory element.Limiting the metals would, in turn, affect the typesof incinerable wastes that could qualify as candi-dates for ocean incineration.

The energy content of wastes might also be afactor in determining which wastes would be in-cinerated at sea. High-energy wastes are currentlymanaged using several different technologies orpractices, as described previously. Land-based in-cineration companies compete for such wastes touse as fuel in order to reduce the need for sup-plementary raw fuel to burn low-energy wastes(e.g., various organic solids and sludges; see ch.2). Industrial boilers and furnaces can also burnhigh-energy wastes in order to recover their energycontent, again as an alternative to burning raw fuel.If the government were to decide that public ben-efit (as opposed to private economic benefit30) wassufficient to justify such uses, then a restrictionmight be placed on the burning of high-energywastes at sea.

Finally, considerable attention has focused onusing ocean incineration to burn special wastes,such as PCBs and DDT. Proponents of ocean in-cineration cite the properties that render such chem-icals so troublesome (environmental persistence,toxicity, ability to bioaccumulate, and resistanceto burning) as reasons why these special wastesshould be burned at sea, whereas opponents ofocean incineration cite the same properties as rea-sons why such wastes should not be burned at sea.The dichotomy in this debate reflects whether one’smain concern is with direct exposure and impactto humans or the marine environment. The poten-tial use of ocean incineration for such wastes wouldneed further evaluation. Such an evaluation wouldbe particularly important in light of current regu-lations requiring incineration of PCBs (see box Bin ch. 3).

Both regulatory and economic approaches todirecting particular wastes toward or away fromocean incineration might be warranted if Congressor EPA decided to encourage or restrict the use ofocean incineration for any of the wastes describedabove. Obviously, because they could significantlyaffect the overall market for either included or ex-

?OObviou~]y the private firms involved would experience a savings

in fuel costs. This argument has been used by land-based incinera-tion companies in their opposition to ocean incineration (see ref. 9,for example). Proponents of ocean incineration claim that the land-based companies are simply wary of more competition, and that themarket should decide where such wastes go (see ch. 2).


eluded wastes, such measures would therefore needto be assessed from a broad perspective.

Geographically Restrict the Transportation ofWastes To Be Incinerated At Sea. —Transportingand importing wastes generated in one area toanother area for storage and loading onto an in-cineration vessel has engendered a significantamount of public concern. These issues have raisedquestions of equity with respect to who should bearthe risks and enjoy the benefits of using ocean in-cineration. Such questions are by no means uniqueto the issue of ocean incineration.

Implementation of geographic limitations on thetransportation of wastes for the purpose of inciner-ation at sea might help to address some of the publicconcern. These limitations might take any of sev-eral forms, including specifying a maximum dis-tance for land transport, directing wastes to portsmost suitable for handling them, or requiring theuse of particular burn sites for particular wastes.In conjunction with designating multiple sites forocean incineration and with developing port selec-tion criteria (see ch. 2), geographic limitations couldhelp to address the equity issue by requiring wastesto be managed near their points of origin.

Because most incinerable wastes are generatedin coastal States (see ch. 3), geographic restrictionsprobably would not significantly reduce the poten-tial market for ocean incineration. The restrictionscould pose difficulties, however, if several compa-nies wished to operate out of the same port. It couldalso place unprecedented restrictions on one set ofcommercial activities—ocean incineration—withoutaffecting comparable activities such as land-basedincineration 31 or marine commerce in hazardous

materials.

Restrict the Number of Operating Permits.—If the Nation were to proceed with a provisionalor experimental program of ocean incineration,Congress or EPA might want to specifically limitthe size of the fleet or the number of vessels in oper-ation at any given time. This could be accomplishedby granting permits only to existing vessels or tosome predetermined number of vessels, based on

J 1 The Scarcity of commercj~ land-based incinerators in some re-gions of the country commonly results in wastes being transportedconsiderable distances to reach existing facilities—in some cases, fur-ther than would be required to reach port facilities.

particular criteria such as the expected market size,the desired frequency of operation of incinerationvessels at existing sites, or the level at which mon-itoring could be feasibly performed.

The public has repeatedly raised the question ofthe credibility of private companies and their abil-ity to comply with all regulatory requirements.Some observers have called for the development ofcriteria to allow consideration of a company’s com-pliance record as an integral part of the permittingprocess. In addition, demonstrating financial re-sponsibility would be a minimum requirement forreceiving a permit, although the level and the na-ture of liability to be required for ocean incinera-tion have yet to be determined (see ch. 2).

Using criteria such as these to restrict the num-ber of permits granted would limit the scale of theprogram and would specifically address key pub-lic concerns. However, this approach might severelycurtail new investment into ocean incineration and,therefore, could limit expansion of the fleet thatmight be desired at a later date or hamper researchand development aimed at improving existingocean incineration technology.

Restrict the Period for Which Permits AreGranted. —EPA’s proposed Ocean IncinerationRegulation would grant individual ocean inciner-ation operating permits for 10 years, subject torenewal after 5 years (or more frequently at the re-quest of the Assistant Administrator). Critics haveraised legitimate questions over whether a 10-yearpermit length would be appropriate in a new pro-gram. To attract private investment, of course,some degree of business certainty and sufficient op-portunity for making profits would be necessary.

In any event, determining the appropriate lengthof’ permits provides an additional opportunity forcontrolling the scale of an ocean incineration pro-gram, and should be a consideration in resolvingthe ongoing debate on this issue. See chapter 2 forfurther discussion of this issue.

Implement One or More of the Above Con-ditions During a “Trial Period. ’’—Regardlessof the nature and number of research burns un-dertaken, numerous questions will remain unan-swered until an actual ocean incineration programis operating. Even if an open-ended program werethe eventual goal, however, gaining some opera-


tional experience on a limited scale in the begin-ning would be useful, if not essential. Thus, evenif the approaches discussed above were deemed toorestrictive or unworkable in the long run, invok-ing them at the start of the program might still bewarranted.

The appropriate length for such a trial periodwould be difficult to determine in advance. Pre-dicting when enough experience has been gainedto make a final decision—to proceed with a largerprogram, to maintain a limited program, or to ter-minate the activity entirely—would be difficult be-cause some uncertainties and risks would remainafter any period.

Provide for the Government To Own or Oper-ate Incineration Vessels. —This option is argua-bly the most extreme of those considered, becauseof its radical departure from the traditional andwidespread private approach to hazardous wastemanagement in this country, and the potential con-flicts of interest associated with direct entry of thegovernment into such a controversial enterprise.

This approach, however, would provide a verydirect mechanism for controlling the scale of anocean incineration program, in that the government

could determine the quantities and types of wastesit would burn in its own ships .32 Moreover, becausegovernment-sponsored ocean incineration could po-tentially occur in a nonprofit-driven setting, thegovernment could more easily reduce or terminatethe program, if and when that were deemed desira-ble. This approach could very directly and relativelyeasily ensure that ocean incineration would beviewed and conducted as an interim program.

Serious obstacles to government ownership,however, are equally apparent. Perhaps the mosttroublesome is that it would juxtapose regulatoryand promotional roles that many members of thepublic regard as too close already. Indeed, the po-tential for significant conflict of interest wouldgreatly increase and would need to be specificallyaddressed. Given the already low degree of publicconfidence that EPA could objectively develop andadminister a regulatory program for private oceanincineration, the concept of public ownership maysimply be too precarious to be seriously entertained.

32Thi~ option is not entire]v academic: the go\’ernment ma}’, in fact,now own two incineration vessels, because of the recent bankru ptc)’of Tacoma Boatbuilding, Inc. , and the subsequent loan default of itssubsidiar~’, At-Sea Incineration. Inc.

SHAPING AN OCEAN INCINERATION PROGRAM

The fundamental policy issue concerning oceanincineration is whether to proceed with develop-ment of a regulatory program. Although this deci-sion will require difficult political judgments,analyzing particular issues from a technical perspec-tive can help clarify the implications of various alter-natives and help design ensuing programs if oceanincineration is allowed. To this end, OTA has iden-tified and analyzed a large number of technical fac-tors that bear directly on such a decision. Severalkey policy issues have emerged from this analysis,and are briefly introduced below. Chapter 2 dis-cusses each of these issues in greater depth, and ana-lyzes various regulatory and policy options thatmight be implemented to resolve these issues.

Regulation of Incinerator Emissions

One important policy issue is whether pro-posed regulations governing incinerator emis-sions are adequate. In regulating emissions fromocean incineration, EPA has proposed to extendthe approach it originally developed for regulatingland-based incineration, which is based primarilyon measures of incinerator performance .33 This ap-proach emphasizes the attainment of a particularlevel of destruction of wastes, as opposed to estab-lishing numeric limitations on each of the many

NEpA has also proposed certain en~’ironmcn[al performance stand-ards that would indirectly apply to emissions.

26 Ž Ocean Incineration: Its Role in Managing Hazardous Waste

components of the emissions. The basis for this ap-proach lies in the extreme complexity both of thewastes and of the emissions that are generated whenhazardous wastes are incinerated. This complex-ity precludes routine measurement of all com-ponents.

To make the tasks of monitoring and regulatingincineration manageable, EPA limits the numberof compounds to be analyzed to a small set of com-pounds that is chosen to be as representative of theentire waste as possible. Incinerator performanceis then gauged by measuring the destruction effi-ciency (DE) for these preselected compounds .34EPA’s proposed reliance on the DE performancestandard has been criticized on several bases.

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EPA’s definition of DE does not provide anadequate measure of destruction for all com-ponents of the waste or for all possible sets ofoperating conditions.Methodologies for sampling emissions andmonitoring incinerator performance are notwell developed or have not been verifiedthrough actual experience.Incinerator emissions have been insufficientlycharacterized and quantified to permit a validevaluation of the need for specific emissionstandards, particularly for metals.The toxicity of incinerator emissions, particu-larly with respect to possible long-term im-pacts, has not been sufficiently examined.The identity, origin, and toxicity of productsof incomplete combustion (PICs) have beeninsufficiently studied, precluding an assess-ment of their significance and of the possibleneed for regulation.

Transportation Risks

second key policy issue concerns the extentnature of land and marine transportation

risks associated with ocean incineration. Thetransportation of hazardous waste is regulated un-

stFor land-based incinerators equipped with air pollution cOntrO]devices (i. e., scrubbers), the destruction performance standard is ac-tually a destruction and removal efficiency (DRE). DRE is measuredafter the operation of scrubbers. In practice, however, EPA has foundthat DE and DRE are functionally equivalent, because scrubbers arevery inefficient at removing the organic substances that are measuredin calculating DE or DRE.

der many authorities at the Federal, State, and lo-cal levels. For the purpose of regulating ocean in-cineration, EPA is proposing few specific controlsbeyond those already generally applicable to in-cineration vessels and associated waste transpor-tation and transfer activities. The adequacy of suchan approach has been questioned and several areasneeding additional attention have been identified:

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Applicable regulations under other agenciesneed to be referenced and applied specificallyto ocean incineration.Explicit mechanisms are needed to ensure ade-quate interagency coordination and delegationof authority for enforcement and monitoring.Criteria are needed for selecting and design-ing ports to be used for ocean incineration.Contingency plans and emergency responsecapabilities need to be developed and co-ordinated.

Comparison of Different OceanIncineration Technologies

third key policy issue concerns the need fora comparative evaluation of different technol-ogies for ocean incineration. Several different de-signs exist or have been proposed for incineratorvessels and associated facilities. These designs coulddiffer significantly with respect to safety and per-formance. A thorough comparative assessment ofdifferent designs may be necessary to ensure theuse of the best available technology for ocean in-cineration. In addition, mechanisms for incorporat-ing newly developed alternative or superior designfeatures into the regulatory program must be de-veloped.

Equitable Regulation

A fourth key policy issue involves equity inthe regulation of land-based and ocean inciner-ation. Because land-based and ocean incinerationare regulated under different statutes, numerousdifferences exist in regulatory requirements and ex-pectations. Many provisions that apply only to oneof the technologies, or are more stringent for oneor the other, have stirred considerable debate.Often, such provisions are necessary or desirableto account for differences between the technologies


in, for example, the kinds of risks they pose orwhere they are used.

Given such differences, simply adopting identi-cal sets of regulatory requirements is not likely toaccomplish equitable regulation of land-based andocean incineration. The technical and nontechni-cal bases for any differential regulations, however,should be subjected to thorough scrutiny and madeas explicit and open to review as possible.

Public Involvement

A fifth key policy issue is whether public in-volvement in decisions regarding ocean inciner-ation is adequate. Public opposition to ocean in-cineration has arguably been the major impedimentto development of a regulatory program. At thesame time, public involvement has played a sub-stantial role in broadening the scope of the debateover ocean incineration to include consideration ofthe need to develop a national strategy for manag-ing hazardous wastes.

The nature and extent of public opposition toocean incineration suggests that available mecha-nisms for involving the public in the decisionmak-ing process are woefully inadequate. Although thisproblem is by no means confined to the subject ofocean incineration, additional mechanisms aimedat ensuring and encouraging meaningful publicparticipation and education are essential to any fu-ture regulatory program for ocean incineration. Inaddition, if any ocean incineration program is togo forward, specific steps must be taken to addressand resolve outstanding public concerns surround-ing ocean incineration.

The Effect of Ocean Incineration on theDevelopment of Better Alternatives

A sixth key policy issue is how an ocean in-cineration program would affect the develop-ment and implementation of environmentally

preferable waste treatment, recovery, and reduc-tion practices. A major point of contention hasbeen whether ocean incineration would undermineexisting incentives for using and developing bet-ter practices and technologies for hazardous wastemanagement. Although OTA’s analysis suggeststhat such an effect is likely to be limited, prudencemay dictate taking steps to ensure that waste re-duction is implemented wherever possible and thatthe remaining incinerable wastes are, in fact,directed toward the best available managementpractices. To this end, certain policy directives orregulatory requirements, specifically applying tousers of ocean incineration, might be desirable. Par-ticularly deserving of serious attention are meas-ures that would ensure and increase the accounta-

bility of waste generators that choose to utilize oceanincineration. Other regulatory and economic meansof affecting the role that ocean incineration playsin hazardous waste management may warrant con-gressional action.

Unresolved Questions

A seventh key policy issue concerns the seri-ousness of unresolved questions about the oper-ation and impacts of ocean incineration. Signif-icant debate centers on whether enough informationis currently available to allow an informed decisionon whether and, if so, how to proceed with a pro-gram for ocean incineration. Although most ob-servers acknowledge that many unresolved ques-tions remain, consensus is lacking on whichquestions, if any, need to be answered before oceanincineration can be permitted and on what meansshould be used to answer such questions.

Many of the unresolved questions about oceanincineration apply equally to already permittedactivities, such as land-based incineration. Conse-quently, questions arise regarding whether, howmuch, and when research should be done on thesealternatives, and how such research should relateto that required for ocean incineration.


CHAPTER 1 REFERENCES

1. Booz-Allen & Hamilton, Inc., “Review of Activi-ties of Major Firms in the Commercial HazardousWaste Management Industry: 1982 Update, ” pre-pared for the U.S. Environmental ProtectionAgency, Office of Policy Analysis (Bethesda, MD:Aug. 15, 1983).

2. Environmental Resources Management, Inc., NewJersey Hazardous Waste Facilities Plan, preparedfor New Jersey Waste Facilities Siting Commission(Trenton, NJ: March 1985).

3. Fay, R. R., and Wastler, T. A., “Ocean Incinera-tion: Contaminant Loading and Monitoring, inWastes in the Ocean, vol. 5, D.R. Kester, et al.(eds.) (New York: John Wiley & Sons, 1985), pp.73-90.

4. GESAMP (Joint Group of Experts on the ScientificAspects of Marine Pollution), “Scientific Criteriafor the Selection of Waste Disposal Sites At Sea, ”No. 16, in Reports and Studies of the Inter-Gov-ernmental Maritime Consultative Organization(London: 1982), p. 31.

5. Hartung, R., “Uncertainties Associated WithOcean Incineration Programs, ” MTS Journal20(1):48-51, March 1986.

6. Keitz, E., Vogel, G., Holberger, R., et al., A Pro-file of Existing Hazardous Waste Incineration Fa-cilities and Manufacturers in the United States,EPA No. 600/2-84-052, prepared for the U.S. Envi-ronmental Protection Agency, Office of Researchand Development (Washington, DC: 1984).

7. Office of Appropriate Technology, “Alternatives tothe Land Disposal of Hazardous Wastes, An Assess-ment for California, Toxic Waste AssessmentGroup, Governor’s Office of Appropriate Technol-ogy (Sacramento, CA: 1981).

8. Oppelt, E. T., “Hazardous Waste Destruction, ”Environ. Sci. Technol. 20(4):312-318, 1986.

9. Philipbar, W., Testimony Before the Subcommit-tee on Natural Resources, Agricultural Researchand Environment, House Committee on Scienceand Technology, Hearing on ‘ ‘Ocean Incinerationof Hazardous Waste, “ June 13 and 25, 1985, No.61 (Washington, DC: 1985).

10. Stephan, D. G., letter of transmittal to Office ofTechnology Assessment dated May 22, 1985, ac-companying Keitz, et al., 1984.

11. Trenholm, A., German, P., and Jungclaus, G.,Performance Evaluation of Full-Scale HazardousWaste Incinerators, EPA/600/S2-84, contract reportprepared for the U.S. Environmental ProtectionAgency (Washington, DC: May, 1984).

12. U.S. Congress, Congressional Budget Office, Haz-

ardous Waste Management: Recent Changes andPolicy Alternatives (Washington, DC: U.S. Gov-ernment Printing Office, 1985), p. 24.

13. U.S. Congress, House of Representatives, Hazard-ous and Solid Waste Amendments of 1984, H. Re-port 98-1133 to accompany H.R. 2867, 98th Cong.,2d sess. (Washington, DC: U.S. Government Print-ing Office, 1984).

14. U.S. Congress, Office of Technology Assessment,“Serious Reduction of Hazardous Waste for Pol-lution Prevention and Industrial Efficiency, ” inpress (Washington, DC: 1986).

15. U.S. Environmental Protection Agency, U.S. De-partment of Commerce Maritime Administration,U.S. Department of Transportation Coast Guard,and U.S. Department of Commerce National Bu-reau of Standards, Report to the Interagency AdHoc Work Group for the Chemical Waste Inciner-ator Ship Program, NTIS No. PB-81-112849(Springfield, VA: National Technical InformationService, September 1980), app. B.

16. U.S. Environmental Protection Agency, Office ofWater, Incineration-At-Sea Research Strategy(Washington, DC: Feb. 19, 1985).

17. U.S. Environmental Protection Agency, Office ofPolicy, Planning and Evaluation, “Background Re-port I: Description of Incineration Technology, ”Assessment of Incineration as a Treatment Methodfor Liquid Organic Hazardous Wastes (Washing-ton, DC: March 1985), p. 30.

18. U.S. Environmental Protection Agency, Office ofPolicy, Planning and Evaluation, “Background Re-port IV and Appendices: Comparison of RisksFrom Land-Based and Ocean-Based Incineration, ”Assessment of Incineration as a Treatment Methodfor Liquid Organic Hazardous Wastes (Washing-ton, DC: March 1985), ch. 8.

19. U.S. Environmental Protection Agency, ScienceAdvisory Board, Report on the Incineration of Liq-uid Hazardous Wastes by the Environmental Ef-fects, Transport and Fate Committee (Washington,DC: April 1985).

20. U.S. Environmental Protection Agency, “HearingOfficer’s Report on the Tentative Determination toIssue the Incineration-At-Sea Research Permit HQ-85-001” (Washington, DC: May 1, 1986).

21. Weitkamp, C., “Methods To Determine Hydro-gen Chloride in Incineration Ship Plumes, ” inWastes in the Ocean, vol. 5, D.R. Kester, et al.(eds.) (New York: John Wiley & Sons, 1985), pp.91-114.

22. Westat, Inc., National Survey of Hazardous Waste

Ch. l—Findings and Policy Options . 29

Generators and Treatment, Storage and Disposal 23.Facilities Regulated Under RCRA in 1981, contractreport prepared by S. Dietz, M. Emmet, R.DiGaetano, et al., for the U.S. Environmental Pro-tection Agency, Office of Solid Waste (Rockville,MD: Apr. 20, 1984), p. 190.

White, R. E., Busman, T., Cudahy, J.J., et al.,New Jersey Industrial Waste Study, EPA/600/6 -85/003, prepared for the U.S. Environmental Pro-tection Agency, Office of Research and Develop-ment (Washington, DC: May 1985), p. 53.

Chapter 2

Shaping an Ocean IncinerationProgram: Key Policy Issues

Contents

PageTechnical Issues and Options. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33

Controlling Stack Emissions From Incinerator Ships . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33Reducing Transportation Risks Associated With Ocean Incineration . . . . . . . . . . . . . . . . . 37Incorporating Technological Improvements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

Nontechnical Issues and Options. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40Regulating Land-Based and Ocean Incineration Equitably . . . . . . . . . . . . . . . . . . . . . . . . . . 40Involving the Public in Decisions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..,. 41

Viewing Ocean Incineration in a Broad Context . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43The Effect of Ocean Incineration on the Development of Better Alternatives . . . . . . . . . . 43Understanding the Impacts of Ocean Incineration Relative to

Those of Other Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~ . . . . . 44

Other Issues and Public Concerns . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Demonstrating a Need for Ocean Incineration . . . . . . . . . . . . . . . . . . .Setting Liability Requirements. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Evaluating the Effect of Ocean Incineration on Land-Based Incinerat

. . . . . . . . . . . . . . . . 45

. . . . . . . . . . . . . . . . 45

. . . . . . . . . . . . . . . . 46on. . . . . . . . . . . . . . 48

Designating Sites for Ocean Incineration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~ . . . . . . . . . . . 49Considering Applicants’ Compliance Records . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49Determining Appropriate Operating Permit Length and Renewal Provisions . . . . . . . . . . 50

Chapter 2 References. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51

Chapter 2

Shaping an Ocean Incineration Program:Key Policy Issues

If Congress decides to allow the development ofan ocean incineration program, several key regu-latory and policy issues will need to be resolved toprovide an equitable, efficient, and environmentallysound approach to managing the activity. Despitedebate over the significance or means of resolvingthe outstanding issues, general agreement exists asto what the issues are. This chapter examines someof the issues that are key to the design of an oceanincineration program. The discussion provides arange of policy or regulatory options that might beused to resolve these issues.

ditional or more extensive controls and approachesthat are oriented toward the same general end.

The chapter discusses technical issues, which pri-marily concern the incineration technology; non-technical issues, which concern institutional orsocial structures that affect regulation of ocean in-cineration; and issues, both technical and nontech-nical, that influence how ocean incineration fits intoan overall waste management strategy. The chap-ter also discusses several additional issues that havegenerated significant public concern.

For each issue, the discussion describes currentcontrols or approaches, 1 followed by a range of ad-

1 Discussions of EPAs approach generally refer to the approach setout in EPA’s proposed Ocean Incineration Regulation (50 FR 8222,Feb. 28, 1985), Many of the provisions discussed in this report areexpected to change in the process of finalizing the regulation, but thechanges cannot yet be identified and, therefore, cannot serve as a ba-sis for discussion.

TECHNICAL ISSUES AND OPTIONS

Controlling Stack Emissions FromIncinerator Ships

Current Controls

EPA’s proposed regulation would approach thisissue indirectly, controlling waste composition andincinerator performance, rather than limiting theemissions themselves. The regulation would limitthe quantities of metals allowed in wastes to be in-cinerated, as a means of controlling particulate andmetal emissions. Two methods of monitoring in-cinerator performance would be used to controlemissions of unburned or partially burned waste.First, trial burns would determine operating con-ditions that would achieve the required destructionefficiency (DE) (see ch. 7), and all subsequent burnswould have to utilize these conditions. Second, in-cinerator operators would be required to monitor

combustion efficiency (CE) continuously and main-tain a minimum level, which would serve as a par-tial surrogate for the DE requirement.

Under the proposed regulation, no limitationsor standards would be specified for particular com-ponents of the emissions themselves. Instead, theregulations would require compliance with twoenvironmental performance standards. First, acid-forming emissions (primarily hydrogen chloridegas) would be limited to amounts that would notchange the alkalinity of the water by more than 10percent. Second, emissions would be limited toamounts that would not ‘ ‘unreasonably degrade orendanger human health, welfare, or amenities, orthe marine environment, ecological systems or eco-nomic potentialities or recreational or commercialshipping or boating or recreational use of beachesor shorelines. Such amounts would generally be

33


determined by referring to appropriate marinewater quality criteria, where they exist.

Additional Controls

Numerous more stringent controls on ocean in-cinerator emissions have been proposed. The fol-lowing discussion focuses on two types of additionalcontrols: those that are not currently imposed oneither land-based or ocean incinerators but that arerelevant to both; and those that are currently im-posed on land-based incinerators but would not beimposed on ocean incinerators under EPA’s pro-posed regulation.

Proposals Applicable to Incineration Both onLand and At Sea. —Five proposals for additionalcontrols would be relevant to both land-based andocean incineration.

1) Redefine Destruction Efficiency To Providea Measure of Complete Destruction of All the WasteConstituents That Are Present.—EPA would re-quire demonstration of the ability to attain a min-imum destruction efficiency for a preselected setof parent compounds known as Principal OrganicHazardous Constituents (POHCs). The com-pounds chosen as POHCs would be present in highconcentrations in the waste and/or difficult to de-stroy completely by burning. The definition of DEwould be based on two major assumptions: 1) thatif a compound disappeared, it must have been com-pletely destroyed; and 2) that if the preselected com-pounds were abundant and were more difficult todestroy than were all other components, the restof the waste would be destroyed with equal orgreater efficiency. The validity of both assumptions,however, has been questioned by several observers,including EPA’s Science Advisory Board:

As long as the definition of DE addresses onlythe disappearance of the parent POHC and doesnot take into account products of partial decom-position or products newly synthesized in the in-cineration process, the definition is limited in itsability to aid in the assessment of total emissionsand subsequent assessments of environmental ex-posures (12).

Several alternative approaches to determiningDE have been proposed (12, 15). Some have beenused in actual testing of incinerator vessels, andEPA is currently conducting research to evaluate

their validity and potential use (5). The alterna-tive definitions are based on a total destruction effi-ciency, or TDE, derived by measuring the totalquantity of organic material released in emissions.Several variants of this approach have been used,including measuring emissions of organically boundchlorine or of difficult-to-incinerate tracer com-pounds added to the waste prior to incineration.

The DE standard measures performance byfocusing on what incineration destroys and removesfrom wastes. The standard does not regulate whatactually comes out of the incinerator. It providesno measure of the absolute quantity of organic ma-terial released into the environment, EPA has con-sidered adopting two other standards that wouldmeasure actual emissions (14). One is a mass emis-sion rate standard, which would regulate the quan-tity of organic emissions released per unit of time;the other is a mass emission concentration stand-ard, which would limit the quantity of emissionsper unit of volume. Although these standards pro-vide measures that could be used directly to assessexposure and risk, the only bases for setting thestandards would be technology or risk. Technol-ogy is already used as a basis for the DE standard;risk would have to be derived on a facility-by-facilitybasis, which would impose tremendous data, mon-itoring, and administrative burdens.

For these reasons, EPA opted for the uniformperformance-based DE standard. Particularlyharmful constituents, however, might warrant ac-tion to regulate emissions further by limiting therate at which wastes can be burned or by requir-ing a higher DE. Permits for incineration of wastescontaining polychlorinated biphenyls (PCBs), infact, have limits on PCB content or the rate at whichthe wastes can be fed into the incinerator (48 FR48986, Oct. 21, 1983).

2) Require Complete Analysis of the ChemicalCharacteristics of the Emissions That Would AriseUnder a Variety of Operating Conditions. Basedon Such a Characterization, Emissions Standardsfor Particular Components May Be Needed. —TheScience Advisory Board (SAB) found that “inciner-ators can be built and run under a set of optimalconditions so that the DE for the selected POHCscan meet specified criteria of 99.99 percent (for mostwastes) to 99.9999 percent (for PCBs). ” Because

Ch. 2—Shaping an Ocean Incineration Program: Key Policy Issues “ 35

DE would not be measured on a continuous or evenperiodic basis, however, the SAB found that itwould not adequately account for variability in in-cinerator performance, particularly for incineratorupsets, which might be brief but could significantlyreduce the time-averaged DE.

Calculating DE during deliberately created up-set conditions or monitoring DE continuously dur-ing operational burns, as well as trial burns, hasbeen proposed. Unfortunately, current analyticalmethodologies are not rapid enough for DE to serveas a means of monitoring incinerator performance.EPA proposed relying on combustion efficiency asthe best available substitute for DE, although astrong correlation between CE and DE has not beenestablished. The SAB called on EPA to develop arevised DE that adequately accounts for the wellestablished variability in how incinerators perform.

The SAB also recommended that a completecharacterization of incinerator emissions be per-formed, analyzing the chemical composition of theemissions produced under a variety of operatingconditions. Many observers have called for thecharacterization and regulation of metal emissions,based on anticipated environmental effects. Thisproposal may be particularly important because,under EPA’s proposed regulation, waste limitationswould control the amount of individual metals al-lowed in the waste, but would not control thewaste’s aggregate metal concentration (see proposal5 below).

Both land-based and ocean incinerators could besignificant sources of nitrogen and sulfur oxides andof other hazardous air pollutants. The EPA regu-lation, however, would not require control over oreven consistent monitoring for such components instack emissions. Both the Resource Conservationand Recovery Act (RCRA) and the Clean Air Actregulate land-based incinerators, but emissionsstandards apply only to total particulate and acidgases. For ocean incineration, acid-forming emis-sions are regulated through an environmental per-formance standard for seawater, but this standarddoes not regulate any substances as hazardous air

pollutants.

3) Require Tests of the Short-Term and Long-Term Toxicity of Emissions. —The SAB called onEPA to determine the toxicity of representative in-

cinerator emissions in a manner that would addressboth short- and long-term effects. The tests shouldbe performed on a representative number andrange of species and life stages. The tests shouldalso account for environmental mechanisms thatare capable of concentrating emission products(e.g., by trapping organic constituents in the oceansurface microlayer; see ch. 9).

4) Limit Emissions of Products of IncompleteCombustion (PICS). —Data on the generation andtoxicity of PICS are scarce, although such highlytoxic compounds as dioxins and dibenzofurans havebeen identified among the PICS created in hazard-ous waste incinerators. EPA’s proposed regulationwould not regulate PICS, partly because of the lackof data on how operating conditions are correlatedwith the formation of PICS. EPA has, however,offered two possible approaches to controlling PICSunder future regulations (50 FR 8247, Feb. 28,1985).

First, emissions limits could be established on aPIC-by-PIC basis, reflecting the applicable waterquality criteria or marine aquatic life no-effectlevels. Water quality criteria, however, currentlydo not exist for most PICS and would have to bedeveloped. Moreover, monitoring for PICS couldnot be carried out during routine operations be-cause of the complexity of analysis required.

A second approach would be to limit the totalquantity of unburned hydrocarbons allowed inemissions. In effect, this approach would set an up-per limit on PIC emissions, but individual PICSwould not be identified or limited.

5) Limit Metal Emissions. —The proposedOcean Incineration Regulation would specificallylimit the amount of each of 14 metals that couldbe present in waste to be incinerated at sea (50 FR8244, Feb. 28, 1985). Two types of limitations wereproposed, one on the wastes that are initially ac-cepted for incineration and one on the final blendedwaste fed to the incinerator.

Concentrations of each of the metals in wastes

accepted for incineration at sea would be limitedto 500 parts per million (ppm) per metal. The ag-gregate concentration of all metals in the waste,however, would not be limited. Thus, a waste con-taining metals far exceeding 500 ppm could be le-


gaily accepted for incineration. Critics also pointout that no scientific basis exists for setting the metallimitations at 500 ppm, and that the limitationsshould be metal-specific and risk-based. In prac-tice, the actual concentrations of metals in wastesthat have been incinerated at sea have generallybeen far below the 500 ppm level (see ch. 8), solowering this standard—at least for the more toxicmetals—might not significantly affect the range ofwastes that could be accepted for ocean incineration.

Because incinerator ships do not have scrubbers,all metals in the waste are presumed to exit throughthe stack directly into the environment. In light ofthis, EPA proposed a second limitation, in this caseon the concentrations of metals in the final blendedwaste that is fed to the incinerator. These concen-trations would be limited to amounts such that theresulting emissions would not exceed marine waterquality criteria, after accounting for initial atmos-pheric and oceanic dispersion.2 This limitation isscientifically based, since marine water quality cri-teria are developed on the basis of metal-specifictoxicity data. Of the metals listed above, EPA hasdetermined that mercury, silver, and copper mustbe limited below the 500 ppm level to meet ma-rine water quality criteria (50 FR 51362, Dec. 16,1985).

The proposed regulation would appear to pro-vide special treatment for mercury and cadmiumbecause of their special treatment in international(London Dumping Convention, or LDC) and do-mestic ocean dumping regulations. Emissions ofthese two metals, however, actually would be sub-ject to the same standards as would other metals;that is, they would be limited “to that amountwhich if directly dumped would not exceed theirapplicable water quality criteria’ (emphasis added).Thus, despite language apparently singling outthese two metals, the proposed regulation wouldlimit all 14 metals in the same manner.

Finally, in addition to the absolute amount, thechemical form of a metal plays an important rolein determining the metal’s environmental fate andeffects (see ch. 7). The chemical forms, as well as

‘Marine water quality criteria have been developed for all 14 ofthe metals specified by EPA.

quantities, of particular metals in incinerator emis-sions have not been fully determined. Undertak-ing such a characterization of the emissionswould be essential for justifying the lack of a re-quirement for scrubbers on incineration vessels.Further regulation of metal emissions might wellbe warranted, given EPA’s finding that most of thehuman health risks associated with ocean inciner-ation would be derived from metal emissions (1 1).

The potential need for stricter regulation of metalemissions also applies to land-based incinerators,where total particulate are regulated, but no mon-itoring or regulation of individual metals is re-quired.

Proposals Extending Current Land-Based In-cineration Requirements to Ocean Incinera-tion. —Two proposals would extend to ocean in-cineration some requirements that currently applyonly to land-based incineration.

1) Require Air Pollution Control Equipment onIncinerator Ships. —This is a major focus of the de-bate over ocean incineration, and reflects the ma-jor technical and regulatory difference betweenland-based and ocean incineration. See chapter 1for OTA’S analysis of this issue.

2) Require Secondary Chambers and/or LongerResidence Times on Incinerator Ships. —EPA’s ini-tial proposal for regulating land-based incineratorsunder RCRA specified minimum operating con-ditions for residence time (how long the wastes mustreside in the incinerator) and temperature. Inpromulgating its final regulations, however, EPAopted for what it considered a ‘ ‘more flexible’ sys-tem based on performance standards. An excep-tion to this approach is made for land-based inciner-ation of PCBs regulated under the Toxic SubstancesControl Act (TSCA), which specifies minimumtemperature and residence times.

EPA proposed an intermediate approach for reg-ulating ocean incineration, to comply with inter-national requirements under the LDC. Minimumtemperatures would be required for the wall andflame of the incinerator, unless the trial burn estab-lished that DE and CE requirements could be metat lower temperatures. A minimum residence time(lower than that required under TSCA for land-based incineration of PCBs) would also be specified.

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Ch. 2—Shaping an Ocean Incineration Program: Key Policy Issues • 37

Critics of EPA’s proposed ocean incineration reg-ulation have argued that, relative to land-based in-cineration, ocean incineration technology is less safebecause it employs a shorter residence time. Al-though not specifically required to do so, land-basedrotary kiln incinerators are generally designed toinclude secondary chambers or afterburners, whichexpose volatilized waste to a second flame to en-sure complete combustion. This design keeps wastesin the combustion zone longer, which is considerednecessary for incinerating solids and sludges.

Liquid wastes, however, are often injecteddirectly into the afterburner section of a rotary kiln,which means their residence time is relatively short.In addition, land-based liquid injection incinera-tors (like ocean-based incinerators) typically haveno afterburner section. On land, therefore, liquidwastes generally are subject to shorter residencetimes than are solid or sludge wastes. Given therelative ease with which liquids are incinerated,short residence times may be sufficient for de-struction.

Finally, as noted by the SAB (12), liquid injec-tion incinerators on land and at sea generally em-ploy higher temperatures than do rotary kilns. Gen-erally, an inverse relationship exists between theresidence time and the temperature required to at-tain a particular DE; that is, the higher the tem-perature, the shorter the time required to com-pletely destroy the waste.

Thus, the important distinctions are not betweenland-based and ocean incineration, but rather be-tween liquid wastes and solid and sludge wastes,and between liquid injection and rotary kiln tech-nologies. A shorter residence time alone is not suffi-cient evidence of inadequate destruction of wastes.

Because residence time is primarily determinedby the design of the combustion chamber or cham-bers, only limited increases in residence time arepossible once a facility has been constructed. There-fore, the residence time of existing ocean inciner-ators could not be substantially lengthened.

Although considerable controversy over this is-sue has arisen in the debate over ocean incinera-tion, EPA has maintained that relying on perform-ance standards rather than design criteria ensuressufficient waste destruction, while providing flexi-bility and accommodating a variety of designs.

Based on available information, this conclusionseems warranted.

Reducing Transportation RisksAssociated With Ocean Incineration

Regulations governing hazardous waste trans-portation are scattered among numerous Federalagencies, and additional requirements often existat the State and local levels. Although examiningin detail the adequacy of the regulatory frameworkor coordination among various authorities exceedsthe scope of this study, certain issues specificallyrelated to ocean incineration can be identified andaddressed. 3

Current Controls

Transporting hazardous waste over land for thepurpose of incineration at sea could involve the useof both highway and rail vehicles and would be sub-ject to regulation primarily by the Department ofTransportation (DOT). EPA’s proposed ocean in-cineration regulation would not address land trans-portation activities. Instead, EPA argues, “controlsimposed by programs specially designed and ex-perienced in the area of land transportation are bestable to provide protection against environmentalrisks during that phase of ocean incineration activ-ities” (50 FR 8225, Feb. 28, 1985).

Waste transfer activities at port facilities wouldbe subject to U.S. Coast Guard (USCG) regula-tions. EPA generally would defer to the USCG’Sspecial expertise and would not incorporate allUSCG requirements into the permitting process forocean incineration, although the USCG would haveauthority to recommend such permit requirements.EPA proposed that applicants for permits be re-quired to prepare contingency plans detailing theprocedures to be followed if spills occurred; theUSCG would have review authority over the plans.

USCG regulations would also govern a ship’stransit from the port facility to the incineration site.The USCG has authority to invoke several meas-ures to ensure safe transit, including:

● providing a USCG escort and shiprider,

3Another OTA assessment examines this issue in the context of trans-portation of hazardous materials in general (8).

3$ . Ocean /incineration: Its Role in Managing Hazardous Waste

●

●

●

restricting transit to daylight hours or particu-lar weather conditions,establishing a moving safety zone around thevessel, andrequiring the vessel to broadcast a Notice toMariners to avoid its route.

Imposing such measures falls under the jurisdic-tion of the Captain of the Port (COTP) and typi-cally occurs as part of the permitting process, basedon the COTP’s evaluation of the particular condi-tions of each port. For the recently denied researchburn in the North Atlantic, the COTP of Phila-delphia incorporated all four measures into the re-search permit, which would have governed transitfrom the harbor to the open ocean.

The USCG is currently developing a set of in-structions specifically for ocean incineration, des-ignating a full range of measures (including thoselisted above) for COTPs to consider when deter-mining what particular permits should require.4

Additional Controls

Two general approaches might address the prob-lem of multiagency jurisdiction over ocean inciner-ation activities.

Comprehensive Regulations. -Comprehensiveregulations covering all aspects of ocean incinera-tion could be developed under one agency (presum-ably EPA). The proposed Ocean IncinerationRegulation obviously would not accomplish this bu-reaucratic feat, and EPA lacks the statutory author-ity to propose regulations that would. If the devel-opment of such regulations is desired, Congresswould need to provide the necessary authority un-der the Marine Protection, Research, and Sanc-tuaries Act (MPRSA) or another statute.

Improved Regulatory Coordination.—A sec-ond, alternative approach would leave jurisdictionsover distinct activities divided among various agen-cies, capitalizing on the USCG’s particular exper-tise and experience, but would improve interagencycoordination and would tailor regulations to theunique features of ocean incineration. Several stepsin addition to those proposed by EPA would be nec-essary to accomplish this end.

‘Commander C. Huber, U.S. Coast Guard, personal communi-cation, June 1986.

1) Cross-Reference Regulations. —At a mini-mum, EPA regulations should specifically cite thoseregulations that, although promulgated and en-forced by other agencies, would apply to ocean in-cineration.

2) Clarify Regulatory Requirements and Juris-dictions. — Regulatory requirements and agencyjurisdictions would have to be clarified, perhaps byan Interagency Memorandum of Understanding,which some observers have recommended. Othersbelieve, however, that because no actual conflictsexist between agency authorities or regulations,what would really be needed would be a clear guid-ance manual for agencies and the public. The man-ual would define agencies’ authorities and respon-sibilities, cross-reference all applicable regulations,and state how the regulations applied to ocean in-cineration. 5

3) Develop Criteria for Selecting Ports.—Togovern or guide the selection of ports for ocean in-cineration activities, EPA should develop criteriaanalogous to those specified under the proposed reg-ulation for selecting ocean incineration sites. Thesecriteria should address the full range of factors thatbear on using or developing a port facility, includ-ing such diverse issues as marine, highway, andrail traffic patterns; the nature and safety of accessroutes and their surroundings; the resources, ca-pabilities, and emergency preparedness of local au-thorities; and the environmental sensitivity and eco-nomic value of areas that might be affected, Becauseso many topics would need to be considered, andbecause the potential exists for conflict with localgovernments that have authority over port devel-opment, the process of developing the criteriashould involve all relevant Federal, State, local, andpublic interests.

Additional Regulatory Initiatives.—Both EPAand USCG are developing regulatory programsgoverning ocean incineration. Several specificaspects of these programs relating to transporta-tion risks might require or warrant further atten-tion to effectively address major public concerns.

1) Designate Several Sites and Ports. —Designa-ting several ocean sites and port facilities for oceanincineration would help to reduce the distances

‘EPA is currently developing such a manual (13).

Ch. 2—Shaping an Ocean Incineration Program: Key Policy issues • 39

wastes would have to be transported, thereby re-

ducing importation of wastes from other regions.The existence of several sites could at least theo-retically increase public acceptance of ocean inciner-ation, by lessening the risk any single communityor region would have to bear, and by allowingwastes to be disposed of close to where they are gen-erated. The major public opposition to using thePort of Philadelphia for a research burn in theNorth Atlantic as an alternative to the previouslyused Gulf Coast port and site, however, suggeststhat designating several sites might actually increaseopposition by creating multiple ‘‘backyards.

2) Tailor Waste Handling and TransportationRegulations Specifically to Ocean Incineration. —The USCG is currently promulgating constructionand design standards that would be specific for in-cineration vessels. Other USCG regulations, in-cluding requirements for certifying and operatingwaterfront facilities and for safely transferring bulkliquid cargoes other than oil, are more general innature and may not be applicable to, or sufficientlyaccount for, special problems associated with oceanincineration vessels and operations. G

Several technical or design features of the vari-ous existing and proposed ocean incineration tech-nologies bear directly on transportation safety.These include containerization versus bulk storageand transfer, and self-propelled versus barge ves-sels (see ch. 6).

Incorporating TechnologicalImprovements

Current Approach

In adopting a performance-based approach toregulating both ocean and land-based incineration,EPA established performance standards that reflectthe capabilities of current incineration technologiesto destroy waste and the detection limits of currentsampling technologies. As EPA stated in its ration-ale for requiring a 99.99 percent destruction effi-ciency (a standard more stringent than that requiredunder international law), ‘‘there is extensive data

6The USCG is currently developing regulations that govern the han-dling and transfer of chemical substances; the regulations would beanalogous to those that already apply to oil (Commander C. Huber,U.S. Coast Guard, personal communication, June 1986).

indicating that such destruction efficiencies are at-tainable and can be routinely measured in inciner-ators burning a wide range of organic wastes’ (50FR 8245, Feb. 28, 1985). Moreover, EPA arguedthat such an approach could both accommodate abroad spectrum of incinerator designs and main-tain a high uniform level of performance.

The various existing and proposed technologiesfor ocean incineration differ in ways that could sig-nificantly affect the performance and safety of theincineration process itself, and of associated activ-ities. Chapter 6 describes and compares these tech-nologies in more detail.

The existence of alternative technologies createsa tension between two opposing approaches to reg-ulatory policy. On the one hand, the regulatoryframework must strive to incorporate superior de-sign features that would allow performance stand-ards to be upgraded, ensuring that such standardswould not simply become the lowest commondenominator. On the other hand, specifying par-ticular design features in regulations might dis-courage the development of better designs andcould render obsolete existing facilities that weredesigned to comply with standards regarded assufficient at an earlier time. The latter phenome-non is typically addressed through ‘ ‘grandfather-ing’ or by applying standards to new sources only.

Many observers have argued that existing in-cinerator ships represent ‘ ‘first generation’ tech-nology and should not be accorded the status of bestavailable technology. Other observers disagree, ar-guing that, in addition to meeting all regulatoryrequirements, existing designs are ‘‘proven’ tech-nologies, in contrast to newer designs, which areeither untested or lack sufficient operational ex-perience.

Additional Approaches

EPA’s proposed Ocean Incineration Regulationwould not address the issue of how to incorporatebetter design features or to upgrade the perform-ance standards for incineration vessels. Althoughmany aspects of the problem extend well beyondthis single regulation, certain steps could be takento address its application to ocean incineration.7

‘Because none of these steps is required under RCRA, the}” wouldrepresent a departure from the approach used for regulation of land-based incineration.


Comparing Technologies. -Congress could re-quire EPA to conduct a detailed comparison of thevarious existing, proposed, and emerging ocean in-cineration technologies, with respect to such fac-tors as performance, cost, and availability. Thisevaluation should be ongoing or subject to periodicupdating, in order to identify promising new re-search and development efforts.

Reviewing Permits. —The periodic review ofpermits for ocean incineration provides a naturalpoint at which to consider whether additional reg-ulatory requirements should be introduced or

whether operating conditions or design featuresshould be changed. EPA could institute such anevaluation as part of the permit review process.

Developing New Regulatory Approaches.—Congress could require EPA to examine the pos-sibility of developing best available technology ornew source performance standard approaches forregulating ocean incineration. Such approachesmight provide means to increase the stringency ofperformance standards as technology capable ofachieving them became available.

NONTECHNICAL ISSUES AND OPTIONS

Regulating Land-Based and OceanIncineration Equitably

Current Approach

Land-based incineration facilities are regulatedunder RCRA (although incineration of PCBS iscovered under TSCA), whereas ocean incinerationvessels are regulated under the primary authorityof MPRSA. Existing or proposed regulatory re-quirements for these two types of facilities differin several ways, some of which are the subject ofconsiderable controversy (see below).

The desirability of having different requirementsfor land-based and ocean incineration depends onnumerous nontechnical factors, and therefore tech-nical analysis alone generally cannot justify main-taining or eliminating the differences. For exam-ple, the shiprider requirement applicable only toocean incineration may, in part, reflect the fact thatpublic surveillance of incinerators would be muchmore difficult at sea than on land. This require-ment therefore might be necessary to address the‘‘out-of-sight, out-of-mind’ concerns of the pub-lic and the regulator.

Clearly, equitable regulation of land-based andocean incineration does not mean simply adoptingidentical sets of regulatory requirements. The tech-nical and nontechnical bases for any differential reg-ulations, however, should be thoroughly scrutinizedand made as explicit and open to review as possible.

The issue of equitability raises larger questionsconcerning the adequacy of current legislative au-thority to regulate ocean incineration. Because itfalls under MPRSA, ocean incineration is regulatedas a form of ocean dumping. Although certainaspects of this activity (i. e., release of emissionsdirectly into the marine environment) do consti-tute a form of ocean dumping, the fundamentalpurpose of the activity—waste destruction-mightnot be adequately addressed through MPRSA’Slegislative authority.

Regulatory Differences.—Listed below are re-quirements that apply exclusively to or are morestringent for one of the two technologies, Many ofthese requirements are discussed in detail in othersections of this report and are mentioned here onlyfor the sake of comparison. Extensive rationalessupport many of the differences, so the more de-tailed discussions should be consulted for a full un-derstanding of the issue.

Requirements That Apply Exclusively to or Are MoreStringent for Land-Based Incineration. —At least threerequirements apply only to land-based incinerationor apply to it more stringently than to ocean in-cineration.

1. Emissions standards are specified for partic-ulates and hydrogen chloride gas for land-based incinerators; no emission standards arespecified for ocean incinerators, although envi-ronmental performance standards and mon-

Ch. 2—Shaping an Ocean Incineration Program: Key Policy Issues ● 41

2.

3.

itoring requirements that are not required ofland-based incineration would be required forocean incineration.Air pollution control or particulate equipmentis required for land-based incinerators if theemissions standards would otherwise be ex-ceeded. Under TSCA, such equipment mustbe present if PCBs are burned.For land-based incineration of PCBs, TSCArequires a minimum temperature of 1,2000 C+ 1000 C for a 2 .O-second residence time, or1,600° C + 100° C for a 1.5-second residencetime, with the temperature to be measured atthe wall or flame of the incinerator. No oper-ating conditions are specified for non-PCBwastes. For ocean incineration of all wastes,EPA proposes to require a minimum l-secondresidence time and a minimum temperature of1,250° C measured at the flame and 1, 100° Cmeasured at the incinerator wall.

Requiwnwnts That Apply Only to Ocean Incineration. —Several requirements apply to ocean incinerationbut not to land-based incineration:

●

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●

Waste analysis and operational monitoringdata for each ocean burn would have to be sub-mitted to EPA. Monitoring data would haveto be recorded using an automatic tamper-resistant or tamper-detectable device.A limitation on metals content of wastes wouldbe specified for ocean incineration but not forland-based incineration.Environmental monitoring would have to beconducted periodically during and followingocean incineration burns but not land-basedincineration.EPA would have to review and approve thequalifications of ocean incineration companypersonnel involved in monitoring and analyz-ing waste.A full-time EPA shiprider, and possibly aUSCG shiprider as well,8 would be requiredto be on board for each ocean burn.Government inspection of ocean incineration

8This decision falls under the authority of the Captain of the Port,as discussed previously. At least for the initial burns, the USCG fullyanticipates requiring a shiprider to accompany the vessel during har-bor and bay transit.

●

●

●

vessels and port facilities (yearly by USCG,on demand by EPA) would be required.Transfer of wastes to the vessel at docksidewould have to be supervised by the USCG.Each applicant for an ocean incineration per-mit would have to assess and report to EPAthe potential effects of the applicant’s loadingand transportation activities on endangeredspecies. EPA would have to prepare a formalendangered species assessment as part of thesite designation process.As specified under MPRSA, each permit ap-plicant would be required to demonstrate aneed to incinerate wastes at sea.

Involving the Public in Decisions

Perhaps the major obstacle to developing a pro-gram of ocean incineration is the high degree oforganized public opposition. 9 A full analysis of thehistorical and current basis for the opposition goesbeyond the scope of this study; indeed, many ofthe issues raised in the public debate have broadapplication extending well beyond the confines ofocean incineration or even hazardous waste man-agement. The importance of such issues in deter-mining policy for ocean incineration, however, can-not be overstated.

Current Approach

Although EPA’s fulfillment of the public hear-ing requirements set forth under MPRSA has pro-vided for ample expression of public opinion, it hasnot succeeded in abating opposition or assuring thepublic of EPA’s ability to develop an environ-mentally sound program. Moreover, although pub-lic opposition to incineration was a major factor inhalting ocean incineration until regulations werepromulgated, it is questionable whether the meansthat are available to EPA for ensuring public par-ticipation are capable of truly responding to pub-lic concerns.

. - - —‘For an excellent discussion of the major areas of public concern

and approaches to addressing them, see the recent EPA HearingOfficer’s Report (13) and the accompanying Summary of PublicComments.


Photo credit: Valley Morning Star, Har/lngen, Texas

Over 6,000 people attended a U.S, EnvironmentalProtection Agency public hearing held in Brownsville,Texas, in 1983. The hearing, which concerned whethera permit should be granted for Incineration of PCB- andDDT-containing wastes in the Gulf of Mexico, was thelargest public hearing in EPA history and reflected

intense public concern about the technology.


measures for resolving specific issues of publicconcern.

Increasing Public Participation.—Several ap-proaches would increase public involvement in deci-sionmaking, which could decrease opposition toocean incineration:

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●

provide for public participation, through citi-zen advisory panels, in the permitting proc-ess and in selecting ports and incineration sites;develop national criteria or guidance for se-lecting ports in a manner that addresses pub-lic concerns and involves the public and localinterests;develop a more explicit approach to involvingState and local concerns in the decisionmak-ing process; anddevelop a broad waste management strategyand educate the public as to how incinerationfits into it.

Resolving Specific Concerns.—Several ap-proaches for resolving specific concerns warrant fur-ther

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attention:

provide for adequate liability and public pro-tection in the event of accidental spills ordarnages arising from incineration operations;in particular, provide adequate mechanismsfor injured parties to recover damages;designate several ports and incineration sitesto more equitably distribute the risks and bur-dens of ocean incineration;reopen the designation process for the GulfCoast incineration site;carry out more research before proceedingwith operational ocean incineration; andconsider an applicant’s compliance history indeciding whether to grant a permit.

Two general approaches have been suggested foraddressing the issue of public opposition: first, mech-anisms providing for greater or more meaningfulpublic participation in decisionmaking; and second,


VIEWING OCEAN INCINERATION IN A BROAD CONTEXT

The Effect of Ocean Incineration on theDevelopment of Better Alternatives

Current Approach

Many critics of ocean incineration have arguedthat because ocean incineration would conceivablyprovide a cheap management option for liquid or-ganic wastes, companies would choose ocean in-cineration instead of investing in waste reductionand recovery or better treatment technologies. 10

Proponents counter that ocean incineration wouldfill a niche by providing the best treatment optionfor wastes that do not, for economic or technicalreasons, offer great potential for recovery or re-duction.

OTA’S analysis indicates that, for several rea-sons, ocean incineration would have a very limitedeffect on overall incentives for developing superiorhazardous waste management practices:

● As the findings described in chapter 1 indicate,in the near future, only modest increases areexpected in the use of recovery, recycling, andnew treatment technologies for liquid organichazardous wastes. These practices are expectedto be applied mostly to nonincinerable wastesand would not be affected by the availabilityof ocean incineration as an option (see ch. 3).

● Only a small fraction (less than 10 percent) ofall hazardous waste is suitable for ocean in-cineration, and the amount actually availablefor burning at sea would probably be signifi-cantly smaller, because of geographic, regu-latory, and economic constraints. Realisticprojections of the size of the market for oceanincineration indicate a small fleet of ships han-dling a very small fraction of all hazardouswastes.

● Predicting how future waste reduction activ-ity would affect the ocean incineration mar-ket, and vice versa, is difficult because the nec-essary data are lacking and no meaningful wayexists to measure waste reduction. Enormouspotential obviously exists for such activity tosignificantly decrease the quantities of wastes

IOThe inadequacy of liabi]ity provisions for waste generators thatchoose ocean incineration also discourages better waste management,according to the critics. This issue is examined later in this chapter.

●

●

requiring management; at least in the shortterm, however, major institutional, economic,and attitudinal obstacles to waste reduction re-main. ”Ocean incineration costs waste generators con-siderably more than do the other forms ofmanagement and disposal used for most in-cinerable wastes today. This cost differentialmight actually increase incentives for capitalinvestment in recovery and reduction options,particularly when an economic return (evena relatively long-term return) on the invest-ment could be anticipated.A portion of the ocean incineration market ac-tually consists of wastes generated during thepurification or recovery of chemicals (e. g., dis-tillation wastes). These wastes, which can re-sult from preferred management practices suchas waste recovery, still require disposal ortreatment, and are prime candidates for in-cineration.


Although ocean incineration would be unlikelyto impede the development of better waste man-agement practices in the current climate, Congressand EPA might want to ensure, for example, thatincinerable wastes that were (or became) recover-able would be directed toward the best availablemanagement practices. Several policy directives orregulatory requirements that would specifically ap-ply to users of ocean incineration might be consid-ered that would make waste generators more ac-countable for properly managing their wastes.

Providing Accountability .—Precedent and apotential model for instituting accountability mightalready exist. The Ocean Dumping Regulations (40CFR 227.14-227. 16) explicitly require that each ap-plicant for a permit to dump waste in the oceanmust provide information on what processes gen-erated the wastes, how it was previously disposedof, what other alternatives have been explored, andwhy the waste now needs to be dumped in theocean.

1 IAnother OTA assessment, to be released in fall of 1986, exploresthese issues in detail (9).


Section 224 of the 1984 RCRA Amendmentsprovides a step in the same direction for hazard-ous waste generators that dispose of wastes by meth-ods regulated under RCRA. Although the effec-tiveness of regulations implementing Section 224remains to be seen, the section is intended: 1) torequire generators to develop waste reduction ordetoxification programs on a waste-specific basis,and to report periodically on the progress of theseprograms; and 2) to certify on manifests that thetreatment or disposal option to be used is ‘ ‘thatpracticable method currently available to the gener-ator which minimizes the present and future threatto human health and the environment.

Applying such an approach to ocean incinera-tion might be complicated by the fact that the per-mit applicants do not generate the waste but onlytransport and dispose of wastes that generally wouldcome from numerous sources. Thus, evaluatingand justifying the need to incinerate the wastesmight be beyond the applicants’ capabilities. Thiscomplication is one of the reasons that EPA’s pro-posed Ocean Incineration Regulation would not re-quire permit applicants to adhere to this require-ment of the Ocean Dumping Regulations.

Nevertheless, operators of ocean incineration ves-sels could be required to gather waste-specific in-formation from generators and submit it as partof their applications for permits. Such a require-ment might, however, place the permit applicantin the difficult position of having to obtain data frompotential clients and then wait for a determinationfrom EPA before accepting or refusing the clients’wastes. Alternatively, waste generators seeking touse ocean incineration could be required, throughregulatory provisions developed to address thisaspect of the 1984 RCRA Amendments, to justifytheir need to use ocean incineration. Where appro-priate, approval could be made contingent on com-pliance with a waste reduction schedule.

Directing Wastes to Better Alternatives. -Ad-ditional measures could include regulatory restric-tions on the ocean incineration of wastes for whichrecovery or recycling capacity existed or could bedeveloped. Economic approaches, such as impos-ing a tax on waste incinerated at sea, provideanother possible avenue for ensuring that inciner-

able wastes would be directed toward preferredpractices. 12

Other less direct options might include measuresto encourage the development and introduction ofsuperior technologies for incinerable wastes. Forexample, Congress might consider providing directincentives for research and development efforts andestablishing a formal institutional structure for dem-onstrating new technologies. Such an approachmight be especially useful for managing particu-larly troublesome wastes, such as PCBs.

Understanding the Impacts ofOcean Incineration Relative to

Those of Other Alternatives

Many observers maintain that ocean incinera-tion’s possibilities and limitations in managing haz-ardous wastes have been inadequately defined andinsufficiently exposed to public scrutiny and debate.This situation is one symptom of a much larger defi-ciency: the lack of a comprehensive national haz-ardous waste management strategy.

One of the major obstacles to developing sucha strategy is the scarcity of comparative data on thepotential effects and applications of available andemerging technologies. In the course of this study,OTA encountered major gaps in information aboutbasic aspects of the waste management problem thatgreatly impede the development of sound policy.Congressional attention to several general problemareas might significantly strengthen our under-standing of what a technology like ocean incinera-tion can and cannot accomplish. Congress mightwant to:

● provide for more comparative research intowaste management technologies by the Fed-eral Government (e. g., by EPA and the Na-tional Oceanic and Atmospheric Administra-tion), by industry (accomplished throughincentives), and by universities (supported byFederal grants);

Izunless it were app]ied to all waste management practices, or atleast to those considered less environmentally sound than ocean in-cineration, such a tax might divert wastes to the less sound options.

Ch. 2—Shaping an Ocean /incineration Program: Key Policy Issues ● 45

● mandate and provide sufficient resources forestablishing and maintaining more compre-hensive and accessible databases on waste gen-eration and disposal, number and status ofmanagement facilities, andbasic areas; and

OTHER

numerous other

ISSUES AND

In addition to the key policy issues discussedabove, several other policy issues have become ma-jor public concerns in the debate over ocean inciner-ation. This section describes and analyzes each ofthese issues and, wherever possible, highlights po-tential approaches to resolving them.

Demonstrating a Need forOcean Incineration

Current Approach

Under provisions of both the London DumpingConvention and the Marine Protection, Research,and Sanctuaries Act, before a permit can be grantedfor the dumping of any waste at sea, the need forsuch dumping must be established. Because it fallsunder the definitions of ocean dumping used byboth the LDC and MPRSA, ocean incinerationwould be subject to the requirement for a needsassessment. 13 The Eighth Consultative Meeting ofContracting Parties held in 1984 (cited in thepreamble to the proposed Ocean Incineration Reg-ulation; 50 FR 8247, Feb. 28, 1985) interpretedthe need provision of the LDC to mean that:

. . . other means of disposal should be consideredin the light of a comparative assessment of humanrisks; environmental costs; hazards (including ac-cidents) associated with treatment, packaging,transport, and disposal; economics (includingenergy costs); and exclusion of future uses of dis-posal areas, for both sea disposal and the alterna-tives. If the foregoing analysis shows the land alter-natives to be more practical, a license for seadisposal should not be given.

IJThe requirement to establish a need for ocean incineration is aunique feature of the Marine Protection, Research, and SanctuariesAct. Establishment of need is not required for land-based incinera-tion or any other land-based waste disposal technology.

● ensure that current data-collection and mon-itoring efforts are designed, managed, and co-ordinated in a manner- that generates usefuland accessible information for use in decision-making.

PUBLIC CONCERNS

The requirement to establish need has been in-corporated into the proposed Ocean IncinerationRegulation (Section 234.50) in a manner that EPAclaims to be generally consistent with the LDCinterpretation. Under the proposed regulation, needwould not be defined solely in terms of capacity,so that even if sufficient land-based capacity existed,need for the ocean alternative could still be dem-onstrated: ‘ ‘Need will be presumptively demon-strated if ocean incineration poses less or no greaterrisks than practicable land-based alternatives’ (50FR 8247, ‘Feb. 28, 1985).

EPA’s proposed approach to demonstrating needis to prepare a generic needs assessment for oceanincineration on a national scale, rather than on acase-by-case basis. 14 The generic needs analys is

would provide a rebuttable presumption of needfor individual permit applications, placing on thosewho challenged permit applications the burden ofproving that no need existed. EPA presented tworationales for such an approach:

1. The issue of ocean incineration is onlv a part

2

of a larger problem of hazardous waste man-agement, which requires solutions and man-agement technologies to be looked at from abroad perspective far beyond the capabilitiesof the permit applicants.The permit applicants do not generate thewaste but only transport and dispose of wastethat generally comes from numerous sources.Because applicants would lack the necessaryinformation, evaluating and justifying theneed to incinerate the wastes would be beyondtheir capabilities.

l+EpA is apparently reconsidering its proposed generic needs ap-proach in preparing its final Ocean Incineration Regulation, optingfor the permit-by-permit approach embodied in the Ocean DumpingRegulations.



EPA’s approach to defining need is emerging asa major point of contention in the ocean incinera-tion debate. Critics of the technology argue: 1) thatthe burden of proof should lie with EPA to provethat ocean incineration is as safe as, or safer than,other available alternatives; 2) that need should beevaluated on a permit-by-permit basis; and 3) thatthe EPA’s presumptive definition would be incon-sistent with the intent of the MPRSA and LDC.

The controversy over the need for ocean inciner-ation is in many respects related to the general is-sue of accountability. Public concern has been wide-spread that ocean incineration would largely freewaste generators of accountability for wastes in-cinerated at sea. Accountability in this contextwould have two components: first, accountabilityfor reducing wastes as much as possible (as initi-ated under the 1984 RCRA Amendments); andsecond, accountability with respect to legal liabil-ity for releases of waste. Implementing a mecha-nism for ensuring that generators would be heldaccountable would help to resolve the objectionsthat ocean incineration would: 1) undermine in-centives for waste reduction; and 2) allow genera-tors to dispose of their waste with little or no lia-bility, because of the difficulty of tracing waste backto its source or assigning liability to individualgenerators.

Setting Liability Requirements

Current Approaches

Many of the problems concerning liability thatapply to ocean incineration reflect the much broadercrisis in environmental liability generally. Thegrowing difficulty in obtaining affordable commer-cial pollution liability insurance threatens all han-dlers of waste, hazardous and otherwise. Except asit directly relates to land-based and ocean inciner-ation facilities, however, an analysis of liability isbeyond the scope of this study.

At the outset, liability limits must be distin-guished from financial responsibility requirements.Liability limits, which are commonly set by stat-utes, represent specified maximum amounts ofmoney that parties can be legally required to payfor damages. Financial responsibility requirements,

which can be set by statutes or regulations, are de-signed to assure that parties undertaking certainactivities have sufficient financial resources to meetliabilities the parties might incur. Therefore, theliability limit and the required level of financialresponsibility are commonly the same.

The MPRSA establishes no liability limits forany of the activities it covers, including ocean in-cineration; nor does the Act explicitly authorizeEPA to impose a financial responsibility require-ment through regulation. In the proposed OceanIncineration Regulation, however, EPA indicatedthe clear need to impose such a requirement andsolicited comments on an appropriate level of fi-nancial responsibility to be required of companiesthat seek to incinerate hazardous wastes at sea. EPAsuggested a range of $50 million to $500 million(50 FR 8233, Feb. 28, 1985).

EPA’s authority to impose any such requirementthrough its Ocean Incineration Regulation has beenquestioned (7), particularly because certain otherstatutes and regulations already apply to incinera-tion vessels.

For purposes of comparison, the following dis-cussion summarizes existing liability and financialresponsibility requirements that apply to land-basedand ocean incineration.

Land-Based Incineration.—Two Federal stat-utes invoke liability and financial responsibility re-quirements that apply to land-based hazardouswaste treatment, storage, and disposal facilities, in-cluding land-based incinerators. RCRA sets ‘ ‘sud-den and accidental” liability limits and financialresponsibility requirements at $1 million per acci-dent or $2 million annually. Limits for damagesand third-party claims due to ‘‘gradual pollution’are higher: $3 million per incident or $6 millionannually. The latter limits, however, currently ap-ply only to landfills, surface impoundments, andland treatment facilities, not to incinerators. Fur-ther liability and financial responsibility require-ments might be imposed on incinerators underregulations developed in response to RCRA’s pro-visions for closure and corrective action, althoughthese requirements would probably be determinedon a facility-by-facility basis.

Superfund (formally known as the ComprehensiveEnvironmental Response, Compensation, and Lia-


bility Act, or CERCLA) specifies a much higherliability limit of $50 million plus the costs of cleanupfor some land-based hazardous waste treatment,storage, and disposal facilities, including land-basedincinerators. (Corresponding regulations specify-ing levels of financial responsibility have not yetbeen developed under CERCLA, however, so land-based incinerators do not have to demonstrate theirfinancial ability to meet the required level of lia-bility. Given this, the applicable financial responsi-bility requirements are those specified under RCRA.)

Ocean Incineration.— EPA’s proposed regula-tion was noncommittal on the issue of financialresponsibility and solicited public comment on aproposed range of $50 million to $500 million forocean incineration permitters.

Several existing statutory limitations, however,apply to incineration vessels (7). The oldest is basedon maritime law, dating back to 1851, limiting thelegal liability of vessel owners to the value of thevessel plus its cargo after the accident.

Congress has enacted two additional statutes thataddress liability as it applies to ocean incinerationvessels.

Section 311 of the Clean Water Act. —This pro-vision limits legal liability for pollution damages to$150 per gross ton, which amounts to $300,000 to$600,000 for existing incineration vessels. Anidentical financial responsibility requirement isspecified.

Section 107 of the Current CERCLA.—ThisSuperfund provision specifies a liability limit of $5million to cover both damages to natural resourcesand the costs of responding to the release of a haz-ardous substance. The statute also imposes an iden-tical financial responsibility requirement.

Thus, CERCLA’S $5 million liability limit andfinancial responsibility requirement appear to rep-resent the current limits applicable to ocean inciner-ation vessels.


Recent amendments to CERCLA offered in bothHouses of Congress (and agreed on in conference)would bring the liability limit for incineration ves-sels up to the level required of land-based inciner-

ators, which is $50 million plus the cost of respond-ing to the accident. In addition, the $50 millionlimit would apply to damages resulting from faultyincineration or other releases of waste, and wouldextend liability to the generators and transportersof the waste in addition to the vessel owners.

The amendments would also extend current fi-nancial responsibility requirements for land-basedincinerators to ocean incineration vessels, but theexact amount of financial responsibility is not speci-fied. Instead, the amendments provide EPA withthe discretion to set financial responsibility require-ments, with the explicit expectation that these re-quirements should be commensurate with those forother activities that have similar levels of risk.

If adopted, these amendments to CERCLA ap-parently would resolve the issue of whether EPAhas the statutory jurisdiction to require liability in-surance in excess of the limitations established un-der statutory law, or to invoke strict liability re-quirements for ocean incineration vessels.

Remaining Questions

Marine insurance policies are also subject to sev-eral legal defenses. For example, such policies typi-cally do not cover damages resulting from acts ofGod. Most policies provide no coverage unlessnegligence by the vessel’s owner or operator canbe proved. Nor does coverage generally extend todamages resulting from the actual incinerationprocess itself. In other words, coverage applies todamage arising from sudden and accidental events,such as spills, but not to damages from gradual pol-lution, such as incinerator emissions. 15 How suchdefenses and limitations would apply to releasesfrom an ocean incineration vessel is currently anopen question.

Another major remaining question concerns lia-bility for damages to third parties. Critics have ar-gued that existing law does not adequately providefor private parties to recover damages they havesustained from spills of hazardous substances. Pro-

l~Damages arising from federally permitted releases are excludedfrom coverage under CERCLA. This immediately raises the ques-tion of how to distinguish damage caused by permitted releases fromdamage caused by nonpermitted releases.


posed amendments to MPRSA would remove bar-riers to third-party suits, but they do not addressthe acknowledged difficulty third parties encoun-ter in collecting damages. 16 Prospects for collect-ing damages are particularly slim when no evidenceof direct physical damage can be offered, eventhough indirect or reputational damage may havebeen substantial. This issue is complicated by theextreme uncertainty entailed in estimating damagesfrom hazardous waste spills.

Availability and Costs of Liability Insurance

A major factor influencing the insurance mar-ket for incineration vessels is their lack of operat-ing experience in this country. In addition, insur-ance is much more difficult to obtain and moreexpensive when coverage is desired for damages re-sulting from both the incineration function and thetransportation function the vessels serve.

A recent study prepared for EPA assessed themarket availability and potential costs of obtain-ing liability insurance for incineration vessels (l).Based on interviews with insurance industry rep-resentatives, the study estimated that coverage of$50 million would require a premium of about $5million annually, or 10 percent of the liability limit.In contrast, a policy that meets the CERCLA-mandated $5 million liability limit would carry anannual premium of $20,000. The higher premiumfor incineration vessels could increase per-ton ratesby as much as 63 percent, according to the study,and would make insurance costs the chief operat-ing expense for ocean incineration. 17

Evaluating the Effect of OceanIncineration on Land-Based Incineration 18

The Land-Based Perspective

Land-based incineration companies havestrongly argued that ocean incineration is notneeded, because the market for incineration of or-.—

lbTheSe amendments, to Section 106 of MPRSA, Were adopted onJune 26, 1986, by the House-Senate conference on H.R. 2005, whichwould reauthorize CERCLA (W. Stelle, House Committee on Mer-chant Marine and Fisheries, personal communication, July 10, 1986).

I TThese results have been disputed by some ocean incineration in-dustry representatives. Based on their experience, these representa-tives argue that the costs and difficulty of obtaining liability insur-ance for ocean incineration are overstated.

1 Bsee Ch. 3 for further analysis of the arguments presented here.

ganic liquid wastes will not significantly increase(e.g., see refs. 2,6). They also argue that sufficientliquid waste incineration capacity already exists onland.

Moreover, these companies believe that sludgeand solid wastes are best incinerated by using high-energy organic liquid wastes to provide the neededfuel, and they have suggested that the market forland-based incineration of sludges and solids, butnot liquids, will increase. The companies have ex-pressed concern that ocean incineration might drawoff much of the available high-energy liquid waste,because of the economies of scale that the large at-sea incinerators would provide. If this occurred, theland-based incinerator companies would have topurchase raw fuel to burn sludges and solids, whichthey argue would be less cost-effective and less envi-ronmentally sound.

Land-based incineration companies base theirviews of future needs on the following analysis: Be-cause liquid wastes are highly amenable to recov-ery or other treatment, the quantities of liquidsavailable for incineration will decline, with a con-comitant increase in quantities of sludges and highlyviscous liquids which would result from the treat-ment and which could only be incinerated on land.These companies do not believe that the 1984RCRA land disposal restrictions will greatly in-crease liquid waste volumes available for incinera-tion, because most of the organic wastes currentlylandfilled are sludges and solids.19

The Ocean Perspective

On the other side of the issue, proponents ofocean incineration predict that the gap between ca-pacity and demand for liquid waste incinerationwould continue growing if ocean incineration werenot permitted. The proponents cite EPA’s marketanalysis (10), which suggests this gap may be ashigh as sevenfold. This study is highly controver-sial, however, because of the myriad assumptionson which it is based (see ch. 3).

19This view appears t. Over]ook liquids that are disposed in surface

impoundments and deep wells. Some of these liquids could be inciner-ated. The use of these options also will be restricted under the 1984RCRA Amendments, although at a slower pace than for landfills.


Ocean incineration companies believe that land-based incinerators are simply wary of the compe-tition. High-energy liquid wastes form a very com-petitive market, in which land-based incinerationcompanies already compete with industrial boilersand furnaces (e. g., cement kilns) as well as wasterecyclers. Proponents of ocean incineration arguethat land-based incinerators who want to continueto use liquid wastes as fuel for co-incinerating solidsand sludges would only be able to obtain the liq-uid wastes by charging generators lower rates thanthose charged by their competitors. If land-basedincinerators lost this market and had to resort tobuying raw fuel, the costs could and would bepassed on to the sludge and solid waste generatorsin the form of higher incineration charges.

Finally, proponents of ocean incineration arguethat, in its absence, greater quantities of hazard-ous waste would be disposed of using land alter-natives known to be unsafe, including illegal dump-ing, which would be far less acceptable than thepotential risks posed by ocean incineration.

Designating Sites for Ocean Incineration

The proposed Ocean Incineration Regulationlists the Gulf of Mexico Incineration Site as the onlycurrently designated site for ocean incineration andstates that the site may be used for up to 10 years.Many members of the public and several electedofficials, including the governors of two Gulf States,have argued that the designation process for theGulf site should be reopened because conditionshave substantially changed since its initial desig-nation in 1976.20 The changes include the discoveryof valuable new fisheries in the area and increasedship traffic and navigational hazards, Questionshave also arisen about the adequacy of opportuni-ties for public participation in the initial decisionand about whether EPA has complied with the Agen-cy’s own proposed criteria for site designation.

Finally, the 10-year designation has been chal-lenged as too long a period to account for chang-ing conditions and to accommodate any findingsderived from environmental monitoring; an alter-native proposal for 3-year designation with annualreview has been proposed (for example, see ref. 16).

‘“A petition callin~ for the withdrawal of designation of the Gulfsite has been submitted to EPA by Texas Rural Legal Aid (3).

EPA has countered that the site still meets its ini-tial selection criteria, and that it would also haveto satisfy the new requirements for site designation(carrying capacity and a monitoring plan) beforeit could be used for operational burns.

The same issue has surfaced with respect to theproposed North Atlantic Incineration Site. An envi-ronmental impact statement (EIS) was prepared onthe site in 1981, but changed conditions (includ-ing use of the adjacent 106-mile deepwater dump-site for the dumping of sewage sludge) have led torequests that the 1981 EIS be updated (13). Up-dating the EIS for the Gulf site would also be war-ranted, given that it was initially designated in 1976(see ch. 11).

Considering Applicants’ ComplianceRecords

Current Approaches

Many concerned citizens and elected officialshave suggested that an applicant’s prior compliancerecord with Federal, State, or local environmentallaws be included as a criterion in EPA’s evalua-tion of applications for ocean incineration permits .21Texas has included such a provision in the State’snew (and as yet untested) hazardous waste man-agement act (16). EPA has rejected such proposalson the grounds that equitable criteria for such anevaluation are impossible to develop. As an alter-native, EPA has proposed a permit-by-permit de-termination of an applicant’s ability to meet allpermit requirements and the development of an en-forcement strategy to guide the response to a vio-lation of a permit.


This issue is especially troublesome, because ofits close link to the larger issue of public confidencein EPA and ocean incineration companies to carryout this program in the safest possible manner. Ata minimum, EPA should evaluate whether theavailable means are adequate: 1 ) to ensure that ap-plicants can (and do) meet all permit requirements,2) to hold permitters fully liable for any damagesthat might result, 3) to enforce all provisions of the

z 1 For a de[aj]ed dlSCuSS](ln of [his position and thc~ precedents forits adoption, see ref. 4.

50I . Ocean Incineration: Its Role in Managing Hazardous Waste

regulations, and 4) to provide for sufficient penal-ties for violations. It is also essential that the re-sults of such a review be communicated to the pub-lic in an open manner.

In addition, further attention should be given todeveloping appropriate means of considering theintegrity and environmental compliance records ofapplicants for ocean incineration permits (13). Al-though a workable solution to this problem wouldbe difficult to formulate, permit proceedings shouldat least provide full disclosure of applicants’ records,including opportunities for applicants to explainrelevant mitigating or changed circumstances. If,in preparing its final regulations, EPA ultimatelydecides to reject direct consideration of past com-pliance in evaluating permit applications, the ration-ale for the decision deserves more than the sort ofpassing mention provided in the proposed OceanIncineration Regulation (50 FR 8248, Feb. 28,1985).

Determining Appropriate OperatingPermit Length and Renewal Provisions

Current Approach

EPA’s proposed Ocean Incineration Regulationwould grant operating permits for ocean incinera-tion for 10 years, subject to renewal after 5 years(or more frequently at the request of the AssistantAdminstrator). Renewals would require approvalof a new application and satisfactory completionof a new trial burn. EPA argues that shorter per-mit terms would not provide sufficient economicincentive for companies to enter the market or al-low them to make sufficiently long-term commit-ments to waste generators (50 FR 8232, Feb. 28,1985).


Although such concerns are legitimate, a permitlength of 10 years at the initiation of a new pro-gram appears excessive. The length of the term is

especially troublesome in light of the existing per-m it terms under other environmental regulations:

● aa 3-year term for ocean-dumping permits un-der MPRSA;

● a 5-year term for discharge permits under theClean Water Act;

. a requirement under the London DumpingConvention for a survey (including a trialburn) to be conducted every 2 years; and

● a 10-year term, with review every 5 years, for

the well established land-based incinerationprogram under RCRA.

Two provisions of the proposed regulationsaffecting permit renewal are also problematic. First,the review process appears to be limited to success-ful completion of a trial burn, and would not pro-vide for reconsideration of the many factors thatmight have changed since initial granting of the per-mit: for example, the need for ocean incinerationof the particular wastes to be burned; the environ-mental characteristics of the incineration site withrespect to factors such as data obtained from mon-itoring, the presence of endangered species, or otheror increased use of the site; and needed or desiredchanges in operating conditions, monitoring, orsampling protocols. Nor would the review appearto allow an opportunity to make more substantialchanges as needed to reflect advances in ocean in-cineration technology or the scientific understand-ing of incinerator emissions, environmental im-pacts, and so forth. Particularly if a 10-year permitlength were to be considered, a substantive reviewwould be essential.

Second, as currently formulated, the proposedregulation would provide for continued operationbeyond the end of the permit term in the event ofa delay on the part of EPA in processing a permitreapplication. This provision is difficult to justify,given: 1) the small number of permits (and there-fore, the relatively small administrative burden)likely to be involved; and 2) the real need for thecriteria listed above to be reexamined prior to con-tinued operation.


1.

2.

3.

4.

5.

6.

7.

8.

9.

10.

CHAPTER 2Clark, L. H., and Oppenheimer, R. H., Environ-mental Insurance Coverage for Ocean IncinerationVessels, prepared for the U.S. Environmental Pro-tection Agency, Office of Policy, Planning, andEvaluation (Washington, DC: Aug. 10, 1985).ICF Inc., “Survey of Selected Firms in the Com-mercial Hazardous Waste Management Industry:1984 Update, ” final report prepared for the U.S.Environmental Protection Agency, Office of PolicyAnalysis (Washington, DC: Sept. 30, 1985), p. 2-5.Inside EPA, “Environmentalists Fear EPA May Fi-nesse Approval of Mexico Sea Incineration Site,Inside EPA 6(2):2, July 12, 1985.Oceanic Society, Joint Comments of Environmentaland Other Citizen Organizations in Response to theU.S. Environmental Protection Agency’s DraftRegulations on Ocean Incineration (Washington,DC: June 28, 1985).Oppelt, E. T., “Hazardous Waste Destruction, ’Environ. Sci. Technol. 20(4):312-318, 1986.Philipbar, W., Testimony Before the Subcommit-tee on Natural Resources, Agricultural Researchand Environment, House Committee on Scienceand Technology, Hearing on ‘ ‘Ocean Incinerationof Hazardous Waste, ” June 13 and 25, 1985, No.61 (Washington, DC: 1985).U.S. Congress, Library of Congress, CongressionalResearch Service, “Authority of EPA To ImposeFinancial Responsibility Requirement as Conditionfor Ocean Incineration Permits” (Washington, DC:Aug. 8, 1985).U.S. Congress, Office of Technology Assessment,Transportation of Hazardous Materials, OTA-SET-304 (Washington, DC: U.S. GovernmentPrinting Office, July 1986).U.S. Congress, Office of Technology Assessment,“Serious Reduction of Hazardous Waste for Pol-lution Prevention and Industrial Efficiency, ” inpress (Washington, DC: 1986).U.S. Environmental Protection Agency, Office ofPolicy, Planning and Evaluation, “Background Re-

REFERENCES

11

12.

13.

14.

15.

16

port III: Assessment of the Commercial HazardousWaste Incineration Market, ” Assessment of In-cineration as a Treatment Method for Liquid Or-ganic Hazardous Wastes (Washington, DC: March1985).U.S. Environmental Protection Agency, Office ofPolicy, Planning and Evaluation, ‘ ‘Background Re-port IV and Appendices: Comparison of RisksFrom Land-Based and Ocean-Based Incineration, ’Assessment of Incineration as a Treatment Methodfor Liquid Organic Hazardous Wastes (Washing-ton, DC: March 1985), ch. 8.U.S. Environmental Protection Agency, ScienceAdvisory Board, Report on the Incineration of Liq-uid Hazardous Wastes by the Environmental Ef-fects, Transport and Fate Committee (Washington,DC: April 1985), pp. 16, 18, 20.U.S. Environmental Protection Agency, “HearingOfficer’s Report on the Tentative Determination ToIssue the Incineration-At-Sea Research Permit HQ-85-001” (Washington, DC: May 1, 1986),U.S. Environmental Protection Agency, Office ofSolid Waste and Emergency Response, “Support-ing Documentation for the RCRA Incinerator Reg-ulations, 40 CFR 264, Subpart O—Incinerators,prepared by PEER Consultants, October 1984,NTIS No. PB-86-110293 (Springfield, VA: Na-tional Technical Information Service, August 1985),p. 7-19,U.S. Environmental Protection Agency, Incinera-tion-At-Sea Regulation Development Task Force,Office of Water Regulations, Criteria and Stand-ards Division, “Summary of Public Comments onthe Proposed Ocean Incineration Regulation(Washington, DC: September 1985).White, M., Governor of Texas, Testimony Beforethe U.S. Senate Subcommittee on EnvironmentalPollution, Committee on Environment and PublicWorks, Hearing on “Ocean Incineration of Haz-ardous Waste, ” June 19, 1985 (Washington, DC:1985).

Chapter 3

Incinerable Hazardous Waste:Characteristics and Inventory

Contents

PageCharacterizing Incinerable Waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 55

Waste Properties.. . ., . $ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 55Types of Ocean-Incinerable Wastes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58

Quantifying Incinerable Waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59Waste Inventory . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59Projections of Future Waste Generation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66Onsite Versus Offsite Management of Hazardous Wastes . . . . . . . . . . . . . . . . . . . . . . . . . . . 72Capacity of and Demand for Offsite Treatment Facilities . . . . . . . . . . . . . . . . . . . . . . . . . . . 73Future Use of and Demand for Incineration Capacity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 74Other Factors Affecting Future Waste Generation and Management . . . . . . . . . . . . . . . . . 76

Chapter3 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 77

BoxPage

B. PCBS: A Unique Hazardous Waste Problem . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60

Tables

Table No. Page1. Most Common and Most Abundant Chemical Constituents Found in

Incinerated Hazardous Wastestreams . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 572. Major Categories of Ocean-Incinerable Hazardous Waste . . . . . . . . . . . . . . . . . . . . . . . . . . 593. Quantities of Incinerable Wastes Generated in the United States, 1983 . . . . . . . . . . . . . . . 654. Generation of Ocean-Incinerable and Total Hazardous Wastes,

by EPA Region, 1983 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 685. Top 10 States for Generation of Ocean-Incincrable Hazardous Waste, 1983 . . . . . . . . . . 686. Hazardous Waste Generation in 1983 and 1990: Effect of Recycling and Recovery

on Waste Quantities Requiring Treatment or Disposal, Summary of Comparison . . . . . 707. Hazardous Waste Generation in 1983 and 1990: Effect of Recycling and Recovery

on Waste Quantities Requiring Treatment or Disposal,Comparison by Individual Waste Type . . . . . . . . + . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 71

8. Two State Estimates of Future Hazardous Waste Generation andExtent of Waste Reduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72

Figures

Figure No. Page1. Major Industries Generating Wastes Suitable for Ocean Incineration . . . . . . . . . . . . . . . . 672. Percent of Total Ocean-Incinerable Hazardous Wastes Generated by State, 1983 . . . . . . 69

Chapter 3

Incinerable Hazardous Waste:Characteristics and Inventory

CHARACTERIZING INCINERABLE WASTE

Waste Properties

Any discussion of the quantities of hazardouswaste that could be incinerated on land or at seamust start by considering characteristics of both thewaste and the technologies for incineration. Thissection identifies and discusses the most importantcharacteristics of incinerable wastes, relating themto the requirements or restrictions of available in-cineration technologies.

Generally, only organic wastes or other wasteswith significant organic content are consideredappropriate for incineration, which excludes all in-organic materials. 1 Other important attributes ofwaste include energy content, physical form, thepresence of hazardous constituents or properties,and chlorine and metal content.

Energy Content

An important characteristic that influences awaste’s suitability for incineration is energy con-tent (usually expressed in British thermal units, orBtu). Efficient thermal destruction of the organicportion of a waste requires that the entire mixturebeing incinerated have some minimum energy con-tent. Therefore, many incinerable wastes must beblended with, or burned in the presence of, aux-iliary fuel or high-energy waste to ensure completedestruction. Other incinerable organic wastes havesufficient energy content to maintain their owncombustion, enhancing both the efficiency and cost-effectiveness of incineration.

Many common wastes represent mixtures of or-ganic and inorganic materials. The organic frac-tion of such wastes, no matter how small, is at leasttechnically incinerable. For example, the Environ-

mental Protection Agency (EPA) recently used amobile incinerator to destroy dioxin-tainted soil inTimes Beach, Missouri. Four pounds of dioxin con-tained in 40 tons of soil were successfully destroyedby using auxiliary fuel to heat the soil to a suffi-cient temperature (20). However, for more routineoperations, and particularly for commercial inciner-ation, the cost of incinerating wastes with extremelylow organic content would probably be prohibitive.

Physical Form

Different incineration technologies have devel-oped for handling the various physical forms (solid,sludge, liquid, and gas) of hazardous organic wastes(see ch. 5).

Incinerable wastes that are candidates for oceanincineration generally fall into the category of liq-uid organic wastes. Only wastes in liquid form aresuitable for the liquid injection technology used byall incineration vessels built or planned to date. Liq-uid injection technology has the advantage of largecapacity but can only handle wastes that can bepumped and be introduced into the incinerator inthe form of small droplets.2

A significantly broader range of waste forms isconsidered incinerable on land than at sea, becauseland-based facilities can employ a broader rangeof incineration technologies. Most commercial land-based incineration facilities use rotary kiln tech-nology, which can incinerate organic solids andsludges, as well as liquids (25). Some existing ro-tary kilns can even incinerate solid waste containedin 55-gallon steel drums (l).

The presence of water in wastes can be eitheran advantage or a disadvantage with respect to theirincinerability. Generally, aqueous (water-contain-

‘The term organic refers to chemical substances that possess amolecular skeleton made of carbon and hydrogen and that generallycontain only a few other elements, such as nitrogen, oxygen, or chlo-rine. Inorganic materials are generally composed of or contain metals.

‘Certain solid or sludge wastes that can be suspended in liquid wasteto render them pumpable could also be incinerated at sea.

55


Photo cradt: Air Pollution Control Association/EPA

A mobile incinerator, used by the U.S. Environmental Protection Agency to destroy wastes contaminated with dioxin,A mobile system can be transported to hazardous waste sites, thereby eliminating the need to transport wastes.

ing) wastes are not considered particularly amen-able to incineration, because more energy is neededto heat and evaporate the water. If an aqueouswaste also contains organic material with a veryhigh energy content, however, the presence of watercan actually prevent overheating and increase therate at which wastes can be incinerated.

Hazardous Constituents or Properties

The vast majority of incinerable liquid wastes aresubject to regulation as hazardous waste under theResource Conservation and Recovery Act (RCRA)or certain State statutes. This designation may bebased either on the presence of particular toxic com-

ponents or on a generic characteristic of the waste(e.g., ignitability). In addition to incinerable wastesclassified as hazardous, a few nonhazardous liquidwastestreams are amenable to incineration. For ex-ample, alcohol-based portions of some pharmaceu-tical and pesticide wastes are incinerable but notclassified as hazardous (l).

Liquid organic wastes are derived from a widevariety of industrial processes and sources and,therefore, can contain an enormous number ofchemical constituents. One profile undertaken byEPA identified over 400 distinct hazardous waste-streams being incinerated in land-based facilities(12). These wastes contained 237 different constit-

Ch. 3—lncinerable Hazardous Waste: Characteristics and Inventory ● 57

uents, 140 of which were listed as hazardous un-der RCRA. Table 1 summarizes those constituentsthat were most commonly found and those thatwere incinerated in the greatest amounts.

A second EPA profile of existing hazardous wasteincinerators used RCRA hazardous waste codes (40CFR 261, Subpart D) to classify wastes currentlybeing incinerated in land-based facilities. This study(10) found that the most frequently reported wasteswere nonlisted ignitable (RCRA Code DOO1) withhigh energy content and high concentrations ofhazardous constituents. The waste category repre-senting the largest annual quantity of incineratedwaste, however, was spent nonhalogenated solvents(F003). The next most common categories con-tained sufficient water to be considered aqueouswastes. These included the following:

●

●

●

●

●

aqueous corrosives (DO02),aqueous reactives (DO03),aqueous ignitable (DOO1) with low energycontent and low concentrations of hazardousconstituents,wastewater from acrylonitrile production(KO11), andhydrocyanic acid (P063).

Most of these aqueous wastes are consideredpoorly suited for recycling and recovery and aregenerated in quantities too large to be economicallyshipped for offsite disposal. Therefore, the wastesare generally managed—by using underground in-jection or, where possible, incineration—at the fa-cilities where they were generated. Such wasteswould be unlikely candidates for ocean incineration.

Table 1 .—Most Common and Most AbundantChemical Constituents Found in

Incinerated Hazardous Wastestreams

Five constituentsFive most commonly incinerated in theidentified constituents greatest amounts1. Toluene 1. Methanol2. Methanol 2. Acetonitrile3. Acetone 3. Toluene4. Xylene 4. Ethanol5. Methyl ethyl ketone 5. Amyl acetate

SOURCE: Mitre Corp., CornposWon of Hazardous Waste Streams Current/yIncinerated, contract report prepared for the US. EnvironmentalProtection Agency, Office of Solid Waste (Washington, DC: April 1983),

Chlorine Content

Many liquid wastes considered especially amena-ble to ocean incineration contain relatively highamounts of organically bound chlorine.

Energy content is inversely related to chlorinecontent, which means that the heat value of wastesdecreases as chlorine content increases.

Thermal destruction of chlorinated wastes by in-cineration generates highly corrosive and toxichydrogen chloride gas. Land-based facilities are re-quired to have air pollution control equipment (i. e.,scrubbers) capable of removing and neutralizingacid gases, if wastes with significant chlorine con-tent are to be incinerated (47 FR 27520, June 24,1982). The proposed Ocean Incineration Regula-tion (50 FR 8222, Feb. 28, 1985) does not requirethe use of scrubbers on ocean incinerator vessels,because of seawater’s natural capacity to neutral-ize hydrogen chloride gas, and because the vesselsoperate far away from human populations. 3

Several factors act to place a practical limit onthe chlorine content of wastes that can be inciner-ated in land-based facilities, as discussed in chap-ter 1. These factors include:

●

●

●

limitations on the practical size and capacityof scrubbers for removing hydrogen chloridegas;the increase in the quantity and corrosivity ofhydrogen chloride emissions as the chlorinecontent of wastes increases, which can dam-age the incinerator or scrubber system; andthe generation of chlorine gas (1 3,28), whichis not efficiently removed by stack scrubbersand could pose risks from direct inhalation bynearby human populations.

For these and other reasons, the chlorine con-tent of hazardous wastes can strongly influence therange of available management options. Wastes ofintermediate chlorine content can in some cases beburned in cement kilns and other industrial fur-naces, where corrosive gases are directly used inthe production process. Although there appears tobe an enormous available capacity for burning suchwastes in these facilities, the reluctance of many fur-

~For a number of reasons, incineration of highly chlorinated wastesat sea may be advantageous (see ch. 1).

58 . Ocean /incineration: Its Role in Managing Hazardous Waste

nace operators to use the wastes as fuel, the rela-tive lack of regulation and rigorous environmentaltesting of the practice, and practical limits onacceptable chlorine content, are obstacles to itsgreater application (2,5,17). See chapter 4 for adetailed discussion of the burning of hazardouswastes in industrial boilers and furnaces.

Metal Content

In contrast to the organic component of hazard-ous wastes, metals are not destroyed by incinera-tion. Metals present in waste fed to an incineratorare either deposited in the ash residue left behindin the chamber or emitted in stack gases. Mostmetals that leave the incinerator stack are in theform of particulate matter and can be captured bystack scrubbers,4 Particulate and associated metalsare deposited in the sludge generated by the oper-ation of the scrubber. Ash and sludge residues fromhazardous waste incineration are generally classi-(fied as hazardous waste and must be handled ac-cordingly.

Although metals are not destroyed by incinera-tion, high temperatures can alter the physical andchemical forms of metals, thereby affecting theirsubsequent fate and behavior, For example, cer-tain toxic metals (e. g., arsenic and selenium) arevolatilized (i. e., changed into gas form) during in-cineration and pass through particulate collectiondevices (28). For this reason, wastes that containsignificant amounts of these toxic metals or thathave high overall metal content are not consideredappropriate for incineration.

Types of Ocean-Incinerable Wastes

Liquid organic wastes are derived from a widevariety of industrial processes and sources. Theseinclude activities or uses that: 1) contaminate ma-terials so that they are no longer usable in the proc-ess (e. g., spent solvents); 2) produce wastes throughpurification or recovery of desired products (e. g.,distillation wastes resulting from solvent recoveryor chemical synthesis); 3) produce wastes through

‘Particulate matter may be composed of metals adsorbed onto dustor soot particles, or actual small metallic fragments. Particulate mat-ter can vary significantly in size, and small particles are captured muchless efficiently by air pollution control equipment than are large par-ticles (l).

treatment or handling of other wastes (e. g., PCBcontamination of solvents used to clean electricaltransformers); or 4) result in products that do notmeet specifications and therefore must be discarded,

Four major categories of liquid hazardous wastesare generally identified as primary candidates forocean incineration. These categories, their RCRAclassification designations, their primary uses, andtheir industrial sources are listed in table 2. Specialmaterials or wastes, such as liquid PCBs, are alsocandidates for ocean incineration. These wastes,which are unique in many respects, are discussedin box B. The four major liquid incinerable wastecategories are briefly described below (l).

Waste Oils

These result from the use of lubricants, greases,and other petroleum specialty products. Waste oilsare used in a variety of ways because of their highheat content and relative ease of reclamation. Wasteoil can be: 1) burned as fuel in boilers and furnaces;2) used as auxiliary fuel for incineration; 3) re-refined for reuse in its original purpose; or 4) usedfor dust suppression on roads (a declining practicebecause of environmental concerns).

A well established and growing market for thereuse of waste oils exists, along with a network forthe collection of waste industrial and commercialtransportation oils. Collection and reuse of wasteautomotive oils from individuals is not yet an estab-lished practice but is on the rise. As indicated intable 2 and discussed further in chapter 4, wasteoils are coming under RCRA regulation as haz-ardous waste. These regulations have the poten-tial to affect the quantities of such wastes availablefor incineration.

Nonhalogenated Solvents

Waste solvents are commonly generated as mix-tures of solvents, including aromatic hydrocarbons,ketones, alcohols, and esters. Many waste solventscontain large amounts ( 10 to 50 percent) of water,as well, although this is increasingly avoidedthrough process modifications. The wastes also typi-cally contain significant amounts of suspendedsolids, including organic and inorganic pigmentsand heavy metals (lead, chromium, barium, cop-per, nickel).

Ch. 3—/ncinerable Hazardous Waste: Characteristics and Inventory ● 59

Table 2.—Major Categories of Ocean-lncinerable Hazardous Waste

RCRAType of waste classification Primary uses Major sourceswaste oils . . . . . . . . . . . . . . . . . a Industrial lubricants Metal and service industries

Transportation oilsNonhalogenated solvents . . . . DOO1, FO03-005 Painting, coating, cleaning operations ManufacturingHalogenated solvents . . . . . . . FO01-O02 Cleaning and decreasing agents Manufacturing

Dry cleaningOther organic liquids . . . . . . . . “K wastes” Generated in chemical production Organic chemicals manufacturing

FR 49528,29 November 1965), and has finalized regulations for burning of waste fuel and used oil fuel in nonindustrial boilers and furnaces (50 FR 49164,29 November1965). Burning of waste fuel and used oil fuel in Industrial boilers and furnaces is currently exempted from regulation, although EPA plans to regulate this practiceunder permit standards to be proposed in 1966.

SOURCE: Office of Technology Assessment

Nonhalogenated waste solvents are generally indemand as fuel because of their high heat content(greater than 10,000 Btu/lb). In addition, largequantities of waste solvents are currently cleanedthrough distillation for recycling or reuse.

Halogenated Solvents

Most halogenated5 solvents consist of chlorine-containing compounds, with bromine- and fluorine-containing compounds much less common. Wastehalogenated solvents are produced in the cleaningand decreasing of metals, machinery, and gar-ments, and hence commonly contain oils, greases,dirt, and other solids. The dry cleaning industrygenerates substantial quantities of waste perchloro-ethylene.

Halogenated solvents have a high initial eco-nomic value due to the expense of their produc-tion and, therefore, are commonly recoveredthrough distillation for reuse. Most halogenated sol-vents are not in demand as fuel, because they haverelatively low heat value (less than 5,000 Btu/lb).In fact, their incineration often requires the use ofauxiliary fuel.

5 Halogens are a group of related chemical elements, which arepresent in many organic chemical compounds. The group includesfluorine, chlorine, bromine, and iodine.

Other Organic Liquids

A broad range of wastestreams with significantorganic content is generated by various industrialprocesses used to manufacture or purify organicchemicals. Typically each of the wastestreams ishomogeneous but may have a unique composition.Many or most wastestreams created in chemicalproduction or purification are specifically listed ashazardous wastes under RCRA, and are referredto as “K” wastes. The wastestreams can containa very broad spectrum of hazardous constituents.Organic, water, and halogen content, and thus heatvalue, can also vary significantly.

Several techniques are available or being devel-oped for separating the organic and aqueous frac-tions of these wastestreams, potentially allowinggreater or more economical use of incineration fordestroying the organic portion. Although organicwastes mixed with water can be incinerated, theenergy requirements (and hence costs) of doing sooften increase dramatically as water content in-creases. However, for a waste whose organic por-tion has a very high energy content, the presenceof water can actually be used to advantage by re-ducing total heat output to avoid overheating of theincinerator.

QUANTIFYING INCINERABLE WASTE

Waste Inventoryample, many industrial wastewaters are composed

The absolute quantities of incinerable waste may of extremely dilute aqueous solutions of hazardousnot adequately reflect the degree of toxicity or haz- chemicals. In contrast, many incinerable wastes areard associated with a particular waste type. For ex- among the most concentrated and toxic of all haz-

60 . Ocean Incineration: Its Role in Managing Hazardous Maste

Ch. 3—lncinerab/e Hazardous Waste: Characteristics and Inventory ● 61

Ch. 3—Incinerab/e Hazardous Waste: Characteristics and Inventory ● 63

ardous wastes and, therefore, represent a muchlarger fraction of the total toxicity attributable tohazardous wastes than their absolute quantity in-dicates.

Total Hazardous Waste

Given that virtually all ocean-incinerable wastesare classified as hazardous, the starting point forestimating the quantity of such wastes is to exam-ine the various inventories for hazardous waste gen-eration. Unfortunately, no statistically reliable data-base exists to allow an accurate estimation of thetotal generation of hazardous wastes. Studies varytremendously both in the definition of what con-stitutes hazardous waste and in methodologies fordata collection and analysis. In addition, all thestudies rely to some extent on sets of simplifyingassumptions and models. Although using such as-sumptions is probably essential for generating acomplete national profile, they represent anothermajor and inherent source of variability and un-certainty.

The most prominent (and most often cited) ofsuch studies is the so-called Westat mail survey,which was completed for EPA’s Office of SolidWaste in April 1984 (27). The Westat study esti-mated that 264 million metric tons (equivalent to71 billion gallons) of hazardous waste were gener-ated in the base year of 1981. This quantity is manytimes larger than all previous estimates and is gen-erally regarded to be far closer to the actualquantity.

The Westat figure closely agrees with estimatesmade by the Congressional Budget Office (21) forthe base year of 1983, using industrial outputmodels (see below), and by the Office of Technol-ogy Assessment (23) for the base year of 1981, usingdata obtained from a survey of the States. Thisagreement is somewhat surprising, in view of thefact that the Westat survey was primarily designedto determine numbers of waste generators andtreatment, storage, and disposal facilities, ratherthan waste quantities.

Incinerable Hazardous Waste

Virtually all of the available national data on haz-ardous waste generation are aggregated by broadindustrial categories, rather than by specific waste

types. Consequently, the data are not useful in esti-mating the portion of hazardous waste that is in-cinerable. Moreover, even the basis for defininga material as a waste is often far from clear. Forexample, solvents are not always classified as wasteif they have the potential to be recovered. Andmany States do not consider used oils as waste andtherefore do not require them to be recorded onmanifests, which means estimates of incinerablequantities must be extrapolated from available dataon oil use and recovery (1).

Finally, many ill-defined technical, economic,and regulatory limitations bound the universe ofincinerable wastes. These and other constraintsgreatly hinder an accurate measure of how muchincinerable hazardous waste is generated annually.

This section discusses two studies that allow anestimation of waste generation by waste type andtherefore help to bound estimates of the quantityof incinerable waste. With respect to wastes suit-able for ocean incineration, these studies suggestthat between 10 million and 21 million metric tons(mmt) of liquid incinerable wastes are generatedon an annual basis in the United States.

A recent study by the Congressional Budget Of-fice (CBO) (21) can be used to provide an upperestimate of incinerable waste quantities. This studyestimates national generation of hazardous wastein a manner that allows aggregation of the data un-der any of four classifications: 1) by Standard In-dustrial Classification (SIC) codes representing ma-jor industrial categories (e. g., chemicals and alliedproducts); 2) by waste type (e. g., halogenated liq-uids); 3) by method of treatment or disposal (e. g.,deep-well injection); or 4) by State. Data derivedfrom EPA survey estimates (27) for a base year of1983 are used to make projections for the year 1990.

The hazardous waste universe as defined byCBO is significantly larger than that currentlyregulated under RCRA. In particular, the CBOdefinition includes waste oils, which are only nowbeing brought under RCRA regulation; PCBs,which are regulated under the Toxic SubstancesControl Act (TSCA); and industrial scrubber sludges,air pollution control dusts, and certain other liq-uid hazardous wastestreams, which EPA is cur-rently studying for possible future regulation un-der RCRA.

64 • Ocean Incineration: Its Role in Managing Hazardous Waste

Several additional features of the CBO studywarrant discussion, as they introduce some uncer-tainty into the resulting estimates of waste genera-tion. Because comprehensive and statistically relia-ble raw data on which to base waste generationestimates were generally lacking, CBO developeda computer-based model of hazardous waste gen-eration derived from data on industrial output for70 industrial categories. 1 2 T h i S a p p r o a c h a s s u m e d

that specific industries generated particular typesof waste at measurable rates. These generation rateswere assumed to result from three factors: indus-trial output (measured by employment directly re-lated to production, on an industry-by-industry ba-sis), process technology, and production efficiency.Estimates of future waste generation were then de-rived from projections of growth in industrialemployment. CBO found that statistics on employ-ment growth were the only comprehensive and con-sistent set of industry-specific projections available.Because such statistics only indirectly reflect wastegeneration, however, a degree of uncertainty wasintroduced into the resulting estimates (21).

In addition to attempting to account for changesin waste generation resulting from changes in in-dustrial output, CBO also estimated changes dueto the application of waste reduction, recycling, andrecovery practices. CBO’s projected estimates ofthe levels of recycling and recovery that could beexpected by 1990 were based on information ob-tained directly through surveys of industrial wastegenerators and the waste recovery industry. Theseestimates were then applied to the waste genera-tion estimates, which were derived using the CBOmodel.

Estimating the future extent of waste reductionis extremely difficult, given the current lack of dataand the absence of an accepted and appropriatemeans of measuring waste reduction (24). For thisreason, CBO’s analysis did not consider the fullrange of approaches that might be used to reducewaste. CBO’s estimates, therefore, probably un-derstate the potential for reduction. However, al-though an enormous amount of waste reduction ispossible, many obstacles remain (24).

IZThese 70 industries accounted for about 95 percent of all hazard-ous waste generated in 1981, according to the Westat survey (27).

Despite these potential shortcomings, the CBOeffort represents the only available source of com-prehensive waste generation data that is aggregatedon the basis of specific waste types, which is essen-tial for estimating quantities of incinerable wastes.

Given its limitations, the CBO data maybe bestused to derive an upper estimate of incinerablewaste generation. Waste generation data are firstaggregated by waste type to allow estimation of thequantities of waste generated in those categories thatcould be managed through incineration. These dataare then adjusted downward to account for thelevels of recycling, reuse, and recovery that cur-rently take place in each waste category, as esti-mated by CBO. Finally, separate aggregation ofdata for liquids versus solids and sludges providesan estimate of quantities of waste that are ocean-incinerable (liquids) and waste that could only beincinerated on land (solids and sludges). Table 3presents the estimates derived using such a pro-cedure.

The numbers presented in table 3 should betaken as an upper bound for the following reasons:

●

●

●

●

●

It is unlikely that all of the wastes in each cat-egory are physically or economically suitablefor incineration.Current market factors dictate the use of lessexpensive disposal practices (e. g., under-ground injection) even for clearly incinerablewastes.Other competing fuel uses, particularly forwastes with high energy content, reduce quan-tities available for incineration.Many incinerable wastes are extensively re-covered, reused, or recycled (see column 2 intable 3), and the application of such practicesis growing due to clear economic incentives.Application of other treatment methods (e.g.,chemical detoxification of PCBs) and waste re-duction practices to some incinerable wastesis likely to increase in the near future.

Even with these limitations, the CBO data indi-cate that large quantities of the hazardous wastegenerated annually could be incinerated, either onland or at sea. This upper estimate indicates thatas much as 47 mmt per year, or about one-fifth ofall hazardous wastes not currently recovered orrecycled, could be incinerated. As much as 21 mmt

Ch. 3–lncinerab/e Hazardous Waste: Characteristics and Inventory • 65

Table 3.–Quantities of Incinerable Wastes Generated in the United States, 1983

Quantity generated Current percent Quantity afterType of waste (mmt) RECYC/RECOV a RECYC/RECOV a (mmt)Liquids:Waste oils . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14.25 1 1 % 12.68Halogenated solvents. . . . . . . . . . . . . . . . . . . . . . . . 3,48 70 1.04Nonhalogenated solvents . . . . . . . . . . . . . . . . . . . . 12.13 70 3.64Other organic liquids . . . . . . . . . . . . . . . . . . . . . . . . 3.44 2 3.37Pesticides/herbicides . . . . . . . . . . . . . . . . . . . . . . . . 0.026 55 0.012PUBS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 0.001 0 0.001

Total liquids . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Sludges and solids:Halogenated sludges . . . . . . . . . . . . . . . . . . . . . . . .Nonhalogenated sludges . . . . . . . . . . . . . . . . . . . . .Dye and paint sludges . . . . . . . . . . . . . . . . . . . . . . .Oily sludges.,.. . . . . . . . . . . . . . . . . . . . . . . . . . . . .Halogenated solids . . . . . . . . . . . . . . . . . . . . . . . . . .Nonhalogenated solids . . . . . . . . . . . . . . . . . . . . . .Resins, latex, monomer . . . . . . . . . . . . . . . . . . . . . .

33.33

0.722.244.243.739.784.584.02

380/o

o00500

65

20.74

0.722.244.243.549.784.581.41

Total sludges/solids . . . . . . . . . . . . . . . . . . . . . . . 29.31 10% 26.51Total incinerable wastes . . . . . . . . . . . . . . . . . . . 62.64 25% 47.25

Total hazardous wastes . . . . . . . . . . . . . . . . . . . . . . 265.60 6% 249.28All quantities are millions of metric tons (mmt)aRECYC/REC@/ refer~to w=terecyciing and re~ove~ Practices thataffectthequantityof Wasteneedingtreatment ordisposal. These estimates are derived byCBO

from information obtained directly through surveys of industrial waste generators and the waste recovery industry.NOTE:AU other categories listed by CBOare inorganic liquids, sludges, and mixed or solid wastes, with Iowor no potential for incineration,

SOURCE: Office of Technology Assessment, baaed on U.S. Congress, Congressional Budget Office, Hazardous Waste Marragemerrt: Recent Changes and Po/icy Alternatives(Washington, DC: U.S. Government Printing Office, 19S5); and unpublished data.

per year are liquids that could be incinerated onland or at sea. In contrast, only an estimated 2.7mmt—slightly more than 1 percent of all hazard-ous waste generated in the United States and lessthan 6 percent of all wastes that could have beenincinerated —were incinerated in 1983 (21).

Table 3 indicates that very different quantitiesof the four major categories of ocean-incinerablewaste were generated. CBO estimated that wasteoils and nonhalogenated solvents were generated inamounts about four times higher than were hal-ogenated solvents and other organic liquids. Afteraccounting for current levels of recycling, how-ever, waste oils were predominant, and waste hal-ogenated solvents represented the smallest category.

A second study, conducted under contract toOTA, provides a lower bound on the quantities ofincinerable hazardous wastes generated nationallyon an annual basis. Arthur D. Little, Inc. (1) hasdeveloped estimates of liquid organic hazardouswastes based primarily on data derived from bien-nial State hazardous waste reports to EPA for theyear 1983. These data were aggregated by RCRA

hazardous waste codes (40 CFR Part 261, SubpartD) but also include additional wastes consideredhazardous under State regulations.

The ADL estimates provide a lower bound onthe quantities of incinerable hazardous waste, forthe following reasons:

●

●

The ADL inventory included only thoseRCRA categories designating wastes that wereessentially 100 percent incinerable, including—DOO1 (ignitable wastes),—FOO1-FO02 (halogenated solvents), and—FO03-FO05 (nonhalogenated solvents).

The inventory excluded several other catego-ries that contain potentially significant quan-tities of incinerable wastes, because the inciner-able fraction could not be estimated. Excludingthese categories undoubtedly means a signifi-cant underestimation of total incinerable wastequantities. The categories include:—DO02 (corrosive wastes),—DO03 (reactive wastes),—K wastes (wastes from specific sources),


—P wastes (wastes containing acutely hazard-ous compounds), and

—U wastes (wastes containing toxic com-pounds).

● Certain wastes that were managed onsite werespecifically excluded from the State reports.These include wastes burned as fuel in indus-trial boilers and wastes recycled at the facil-ities where they were generated. Many suchwastes are not required to be reported as wasteunder existing regulations.

● Data that could be used to determine quanti-ties of incinerable liquid wastes generated in1983 were not available for six States.13

ADL’s lower bound estimate for the quantity ofincinerable liquid wastes in these categories (whichexclude waste oils) is 5.8 mmt annually. This canbe compared to the somewhat higher CBO estimateof 8.1 mmt (see table 3).

The ADL analysis also included an examinationof the use and disposition of waste oils. Of the esti-mated 2.1 billion gallons annually used in theUnited States, ADL estimated that about 1 billiongallons are consumed in use, leaving 1.1 billion gal-lons currently divided between disposal and vari-ous forms of reuse (burning as fuel, reclamation,asphalt conditioning, and dust control). This quan-tity is equivalent to about 4.2 mmt of waste oil an-nually, which is significantly lower than the 12.7mmt of waste oil estimated by CBO. The reasonsfor this large discrepancy are unclear. Both studies,however, estimated that waste oils constitute justover 40 percent of all liquid wastes generated.

In sum, ADL conservatively estimated that aminimum of about 10 mmt of incinerable liquidwaste suitable for ocean incineration is generatedannually in the United States.

Industries Generating Incinerable Waste

Most incinerable waste is generated by a few ma-jor industries. CBO has estimated the amounts ofvarious waste types contributed by industries ineach of 12 SIC codes representing major industrialclassifications (U.S. Congress, Congressional Bud-

lsThe six States were Arizona, Colorado, Kansas, Ouahoma, Utah,and Wyoming. None of the six are coastal States, and all but two(Kansas and Oklahoma) are expected to be very minor producers ofincinerable wastes.

get Office, unpublished data). For each of the fourmajor categories of incinerable liquids, figure 1shows the industries that together contribute over90 percent of the wastes. With respect to total haz-ardous waste generation, the list includes industriesthat are major (chemicals and petroleum/coal) andminor (wood preserving and motor freight trans-portation) contributors (21).

Geographical Distribution ofWaste Generation

For both total and ocean-incinerable hazardouswastes, CBO’s data allows an estimation of gener-ation rates for 1983 on a State-by-State basis. Aregional distribution profile for hazardous wastegeneration can be developed by adding the esti-mates for the States comprising each EPA Region.Table 4 presents such a regional profile, and table5 lists the 10 States in which the most ocean-incin-erable hazardous waste is generated. Figure 2 showsthe proportion of ocean-incinerable wastes gener-ated by each State in the Nation.

As is apparent from figure 1, the great majorityof ocean-incinerable hazardous wastes is generatedby the petroleum and chemical industries. Figure2 indicates, not surprisingly, that at least half is gen-erated along either the Gulf Coast (primarily frompetroleum refining) or the Middle Atlantic Coast(primarily from chemical industries) .14 These con-clusions are consistent with a comparable analysisperformed for OTA using data submitted by theStates to EPA in their biennial reports (l).

Thus, a large portion of ocean-incinerable wastewould not have to be transported great distancesto reach potential ocean incineration port facilities.Moreover, this geographical distribution is consist-ent with EPA’s designation of an ocean incinera-tion site in the Gulf of Mexico, and its proposalfor a site located off the Middle Atlantic Coast.

Projections of Future Waste Generation

Projections of future generation of hazardouswaste and of liquid organic hazardous waste requirethe use of assumptions that can drastically affectthe resulting estimates. One common approach to

i +According t. the CBO data, Texas done produces nearly one-

quarter of all such liquid wastes (see table 5).

Ch. 3—lncinerable Hazardous Waste: Characteristics and inventory . 67

Figure 1.— Major Industries Generating WastesSuitable for Ocean Incineration

WASTE OILS

Chemicals

Other (1 O/.)

( 8 8 ” / 0 )

SOURCE: Office of Technology Assessment, based on U.S. Congress, Congres-sional Budget Office, Hazz?~ous Waste Marragernent: Recenr Changesand Po/icy A/kwratives (Washington, DC: U.S. Government PrintingOffice, 1985); and unpublished data.

formulating such projections, therefore, is to de-sign a number of scenarios based on various rea-sonable sets of assumptions, in the hope of at leastbounding the problem. However, estimates derivedby such an approach carry a degree of uncertaintythat render their use in a policy setting problematic.Given existing deficiencies in the data on which pro-jections must be based, uncertainty is an inherentproblem that must be borne in mind when consid-ering any projection of waste generation.

Such projections must also reflect recent changesin the regulatory environment surrounding hazard-ous waste management. As a result, many addi-tional data gaps and sources of uncertainty are in-troduced. For example, in adjusting estimates toaccount for the effect of the land disposal restric-tions contained in the 1984 RCRA Amendments(22), assumptions are required about the scheduleand extent of their implementation and the antici-pated responses of generators and handlers of af-fected wastes.

The Congressional Budget Office (21 ) has esti-mated the quantity of hazardous waste that will begenerated and that will require disposal or treat-ment in 1990. These projections, which are ag-gregated by waste type, can be compared with thequantities generated in 1983. The projections as-sume that EPA will meet the land disposal dead-lines specified in the 1984 RCRA Amendments,which are scheduled to be largely implemented bythat time. 15

CBO’s projection model takes into account twoadditional variables that could significantly influ-ence the quantities of wastes requiring disposal ortreatment in 1990:

1. the extent and effect of waste recovery andrecycling activities undertaken by industry; 16

and

15CB0 indicates that this assumption is perhaps over]y optimisticbut that any other assumption would be arbitrary. To the extent thatthe implementation schedule is delayed, use of undesirable land prac-tices will continue, Moreover, many of the specified deadlines are con-tingent on availability of capacity in alternative treatment technologies.

IeAS indicated previously, CBO has not attempted to account for

the full extent of waste reduction, because of information cm whichto base such an analysis is unavailable.


Table 4.–Generation of Ocean-Incinerable and Total Hazardous Wastes, by EPA Region, 1983

EPA Total Percent Ocean-i ncinerable Percentregion States hazardous wastes of total hazardous wastes of total

I CT, MA, ME, NH, Rl, VT . . . . . . . . . . . 11.51 mmt 4.3% 0.78 mmt 2.3%II NJ, NY. . . . . . . . . . . . . . . . . . . . . . . . . . 22.83 8.6 2.45

Ill DE, MD, PA, VA, WV. . . . . . . . . . . . . . 31.82 12.0 2.76 8.3Iv Al, FL, GA, KY, MS, NC, SC, TN . . . . 39.11 14.7 3.16 9.5v IL, IN, Ml, MN, OH, WI . . . . . . . . . . . . 62.60 23.6 5.54 16.7

AR, LA, NM, OK, TX . . . . . . . . . . . . . . 55.69 21.0 11.75 35.4VII IA, KA, MO, NK . . . . . . . . . . . . . . . . . . 11.12 4.2 1.39 4.2

Vlll CO, MT, ND, SD, UT, WY . . . . . . . . . . 4.70 1.8 1.18 3.6lx AZ, CA, Hl, NV. . . . . . . . . . . . . . . . . . . 18.51 7.0 3.41 10.3x AK, ID, OR, WA . . . . . . . . . . . . . . . . . . 7.71 2.9 0.79 2.4

Totals. . . . . . . . . . . . . . . . . . . . . . . . . 265.60 mmt 33.22 mmtSOURCE: Office of Technology Assessment, baaed on U.S. Congress, Congressional Budget Office, Hazardous Waste Management: Recent Changes arrd Po/icyA/ternat/ves

(Washington, DC: U.S. Government Printing Office, 19S5); and unpublished data.

Table 5.—Top 10 States for Generation ofOcean-Incinerable Hazardous Waste, 1983

Percent of allQuantitv ocean-i ncinerable

State (mt/yr)- hazardous wasteTexas . . . . . . . . . . . . . . . .California. . . . . . . . . . . . .Louisiana. . . . . . . . . . . . .

1 Pennsylvania. . . . . . . . . .Illinois . . . . . . . . . . . . . . .New Jersey . . . . . . . . . . .Ohio . . . . . . . . . . . . . . . . .Oklahoma . . . . . . . . . . . .Indiana. . . . . . . . . . . . . . .Michigan . . . . . . . . . . . . .

7,723,1753,199,1662,468,3571,846,6521,782,1971,674,3521,304,5031,051,550

977,969805,882

23.20/o9.67.45.65.45.03.93.22.92.4

68.6%SOURCE: Office of Technolow Assessment, baaed on U.S. Coww% cOuveS-

sional Budget Offlce~ Hazardou s Waste A4arqpment.’ Recent Changesand Po/lcy A/tematkea (Washington, DC: U.S. Government PrintingOffice, 19S5); and unpublished data.

2. changes in baseline waste generation due toexpected increases or decreases in the produc-tion activities of particular industries, in re-sponse to both general and industry-specificeconomic factors.

Thus, for a given waste category, each of theabove factors contributes to any changes predictedto occur between 1983 and 1990.

Expected changes in total hazardous waste gen-eration and in individual waste categories are pre-sented in tables 6 and 7. The summary in table 6presents CBO’s data for the broad categories of in-cinerable wastes (liquids versus solids and sludges)and nonincinerable wastes, and indicates how bothwaste recycling/recovery and changes in waste out-put affect the projected net change in waste quan-

tities. Table 7 presents a more detailed examina-tion of CBO’s data aggregated by individual wastetype.

Two major trends are apparent from these data.First, CBO predicts that waste recovery and recy-cling activities will only modestly decrease the quan-tities of potentially incinerable wastes. As shownin column 8 of table 6, the greatest effect of wasterecovery and recycling will be on nonincinerablewastes. These data predict that the decrease inamounts of nonincinerable wastes due to increasesin waste recovery and recycling activities will bealmost 15 times greater than the decrease in inciner-able liquids (44 mmt versus 3 mmt). A few par-ticular waste types, such as metal-containing liq-uids, will account for a large portion of the decreasein nonincinerable wastes (see table 7).

This trend becomes even more apparent whenthe actual quantities of wastes expected to be re-covered or recycled in 1990 are compared with thefigures for 1983 (table 6). For nonincinerablewastes, almost 45 mmt is projected to be recoveredor recycled in 1990, whereas less than 1 mmt is esti-mated to have been recovered or recycled in 1983.However, the projection for incinerable wastes isabout 20 mmt for 1990, only a modest increase overthe 15 mmt recovered or recycled in 1983.17

A second trend indicated by these data is thatthe two factors discussed above—changes in wastegeneration and the limited application of waste re-

I TT-hese figures are c~cu]ated from the data in table 6 as follows:for 1990, subtract column 5 from column 4; for 1983, subtract column2 from column 1.

Ch. 3—lncinerable Hazardous Waste: Characteristics and Inventory Ž 69

Figure 2.—Percent of Total Ocean.lncinerable Hazardous Wastes Generated by State, 1983

0.3 (DE)0.5 (MD)

SOURCE: Office of Technology Assessment; based on U.S. Congress, Congressional Budget Office, Hazardous Waste Management: Recent Changes and Po/icy A/ter-natlves (Washlrtgton, DC: U.S. Government Printing Office 19S5), and unpublished data.

covery and recycling to incinerable wastes—willboth slightly alter the relative amounts of liquidsversus solids and sludges generated in 1990. TheCBO data (table 6, column 9) predict that the quan-tities of incinerable solids and sludges will slightlyincrease between 1983 and 1990 (by about 1 mmt),whereas the quantity of incinerable liquids willslightly decrease in quantity (by about 3 mmt). De-spite these changes, CBO projects that waste in bothcategories will continue to be generated in quanti-ties that greatly exceed our current incineration ca-pacity for them.

Several other sources, including evaluations offuture hazardous waste management needs under-taken by a number of States, support the conclu-sions drawn from this analysis of the CBO data.

Two of the sources will be discussed here to lendfurther support to these conclusions.

The Minnesota Waste Management Board (11)projected that, because of economic growth, Min-nesota’s generation of wastes in 14 representativecategories would increase substantially by the year2000, even under the State’s “high waste reduc-tion alternative. This scenario assumed thatwastes would be reduced as much as possible andrecycled whenever they had resource recovery po-tential. Estimates of the extent of waste reduction18

expected in each category by the year 2000 were

J81~ the Minnesota study, the term waste reduction is broadly ap-plied to include recovery and recycling activities as well as source re-duction.

Table 6.-Hazardous Waste Generation in 1983 and 1990: Effect of Recycling and Recovery onWaste Quantities Requiring Treatment or Disposal, Summary of Comparison

Ch. 3—lncinerab/e Hazardous Waste: Characteristics and Inventory ● 71

Table 7.—Hazardous Waste Generation in 1983 and 1990: Effect of Recycling and Recovery onWaste Quantities Requiring Treatment or Disposal, Comparison by individual Waste Type8

1983 1990 Percent changeQuantity after Quantity after in quantity after

Percent waste RECYC/RECOV Percent waste RECYC/RECOV RECYC/RECOVType of waste RECYC/RECOV (mmt) RECYC/RECOV (mmt) 1983-1990Incinerable wastes:Liquids:Waste oils . . . . . . . . . . . . . . . . . . . . . . . . 11 ”/0 12.68 15 ”/0 11.84 –6.60/0Halogenated solvents . . . . . . . . . . . . . . 70 1.04 80 0.76 –26.9Nonhalogenated solvents . . . . . . . . . . . 70 3.64 80 2.37 –34.9Other organic liquids. . . . . . . . . . . . . . . 2 3.37 25 2.82 – 16.3Pesticides/herbicides . . . . . . . . . . . . . . 55 0.012 70 0.008 –33.3PCBs . . . . . . . . . . . . . . . . . . . . . . . . . . . . 0 0.001 0 0.001 0.0

Total incinerable liquids . . . . . . . . . .

Sludges and solids:Halogenated sludges. . . . . . . . . . . . . . .Nonhalogenated sludges . . . . . . . . . . .Dye and paint sludges . . . . . . . . . . . . .Oily sludges . . . . . . . . . . . . . . . . . . . . . .Halogenated solids . . . . . . . . . . . . . . . .Nonhalogenated solids . . . . . . . . . . . . .Resins, latex, monomer . . . . . . . . . . . .

Total incinerable sludges/solids . . .

Total incinerabie wastes . . . . . . . .Nonhcinerable wastes:Metal liquids . . . . . . . . . . . . . . . . . . . . . .Cyanide/metal liquids . . . . . . . . . . . . . .Nonmetallic liquids . . . . . . . . . . . . . . . .Metal sludge . . . . . . . . . . . . . . . . . . . . . .Cyanide/metal sludge . . . . . . . . . . . . . .Nonmetallic sludge . . . . . . . . . . . . . . . .Contaminated soils . . . . . . . . . . . . . . . .Metal dusts/shavings. . . . . . . . . . . . . . .Nonmetallic dusts . . . . . . . . . . . . . . . . .Explosives . . . . . . . . . . . . . . . . . . . . . . . .Miscellaneous wastes . . . . . . . . . . . . . .

Total nonincinerable wastes . . . .

All hazardous wastes . . . . . . . . . . . . . .

38 20.74 47 17.80 – 14.2

0 0.72 0 0.68 –5.6o 2.24 0 2.48 + 10.70 4.24 25 3.08 –27.45 3.54 10 3.20 –9.6o 9.78 0 11.56 + 18.20 4.58 0 5.23 + 14.2

65 1.41 70 1.38 –2.110 26.51 14 27.61 +4.2

25 47.25 31

22000005000

19.367.24

82.2614.500.56

28.065.467.34

21.120.72

15.41

7075201015

50

1510

55

<1 202.03 216 249.28 23

45.41

5.991.82

71.9313.630.50

26.775.756.90

19.990.78

15.92169.98215.39

–3.9

–69.1–75.0– 12.6–6.0

– 10.7–4.6+5.3–6.0–5.4+8.3+3.3

– 15.9

– 13.7asee footnotes to table 6 for explanation of table.

SOURCE: Office of Technology Assessment, baaed on U.S. Congress, Congressional Budget Office, Hazardous Waste Management: Recent Changes and Poficy Alternatives@Washington, DC: U.S. Government Printing Office, 1966); and unpublished data.

used to predict the annual quantity of waste that . substantial quantities of both organic solids/would require treatment or disposal. Table 8 pro- sludges and liquids will require treatment intovides these projections for several categories. the foreseeable future.

The data from the Minnesota analysis supportthe conclusions drawn by the CBO study:

● a net increase will occur in future quantitiesof incinerable wastes, including liquids, evenafter accounting for waste reduction;

● the application of waste reduction, recycling,and recovery practices will be greater for non-incinerable wastes than for incinerable wastes;and

The New Jersey Hazardous Waste FacilitiesSiting Plan (5) estimated the effect of waste reduc-tion on the quantities of various types of hazard-ous wastes that are sent offsite for treatment or dis-posal. Baseline quantities were projected for 1988,and then adjusted to account for the anticipated ex-tent of waste reduction. Table 8 shows the data forseveral major categories of incinerable and non-incinerable hazardous waste.


Table 8.—Two State Estimates of Future Hazardous Waste Generation and Extentof Waste Reduction (all quantities in thousands of metric tons)

MinnesotaBaseline Downward Net change

projection adjustment for in quantityfor 2000 waste reduction over 1982

lncinerable:Solvents/organic liquids . . . . . 33 +7Oils and greases . . . . . . . . . . . 75 –22 –3Organic sludges/bottoms. . . . 8 0 +2

Nonincinerable:Inorganic liquids/sludges . . . . 42 –28 –17

All hazardous wastes . . . . . . . . . . . . . 212 –66 –13

New JerseyBaseline Downward Net change over

projection adjustment for average quantityfor 1988 waste reduction for 1981 to 1983

incinerable:Organic liquids . . . . . . . . . . . . 95 0 +35Solvents . . . . . . . . . . . . . . . . . . 34 –4 +2Oils . . . . . . . . . . . . . . . . . . . . . . 69 –3 +5

Nonincinerable:Inorganic liquids . . . . . . . . . . . 122 -21 –6

All offsite waste . . . . . . . . . . . . . . . . . 418 –30 +41SOURCES: Minnesota Waste Management Board, 19S4; and Environmental Resources Mangement, Inc., New Jersey Hazardous

Waste Facl/Wes Pkr, prepared for New Jersey Waste Facilltles Siting Commission (Trenton, NJ: March 1985).

This analysis of data for New Jersey wastes sentoffsite also supports the same general conclusionsas the CBO study: most waste reduction will be ap-plied to nonincinerable wastes, and even after ac-counting for such activity, large and increasingquantities of incinerable (as well as nonincinera-ble) waste will require treatment.

Onsite Versus Offsite Management ofHazardous Wastes

Another important distinction to be made in dis-cussing quantities of waste likely to require treat-ment or disposal is whether waste managementactivities occur within the facility at which wasteswere generated (onsite), or at a separate, typicallycommercial, facility (offsite). Each of these wastemanagement strategies poses its own special advan-tages, requirements, and risks. For example, off-site management introduces the added burdens oftransportation and recordkeeping, although inspec-tion and enforcement are generally accomplishedmore easily at offsite facilities.

Whether a waste generator decides to manageits wastes onsite or offsite largely depends on the

size of the generator. Some generators can realizeeconomies of scale sufficient to make investmentin onsite facilities attractive, and others generatewastes in quantities too large to make offsite trans-port practicable; small generators typically find itmore cost-effective to ship wastes to commercial fa-cilities for treatment or disposal. The onsite versusoffsite distinction is especially relevant to oceanincineration, which is by definition offsite.

The majority of all hazardous waste is disposedor treated onsite, although available estimates varyover a considerable range. The Westat survey (27)and the CBO study (21) estimated that less than5 percent of all hazardous waste was managed ordisposed of offsite. Interestingly, a number of Stateor regional analyses found that a somewhat largerproportion was managed offsite. For example, Min-nesota’s data indicated that at least 15 percent ofits hazardous waste was managed offsite (1 1). TwoNew Jersey studies reached disparate estimates:One study (5) suggested that only a small percent-age of all waste was sent offsite; lg the other (28) in-

lgrf Wastewater Were excluded from this calculation, an estimated25 percent would be sent offsite.

Ch. 3—lncinerable Hazardous Waste: Characteristics and Inventory • 73

dicated that 26 percent of New Jersey’s hazardouswaste was sent for offsite disposal or treatment. Arecent study of hazardous waste management inNew England found that the region’s waste wasdivided almost evenly between onsite and offsitemanagement (14).

Unfortunately, none of these data concerningon/offsite distribution was aggregated by wastetype, which precludes a separate evaluation forthose wastes with potential for incineration at sea.However, other data suggest that most liquid or-ganic hazardous wastes are managed onsite. TheWestat survey (27) found that about 0.9 mmt ofliquid organic hazardous wastes was incinerated inland-based facilities in 1981, and that 98 percentof this activity took place onsite. And the EPA mar-ket analysis (26) found that at least 90 percent ofcurrent incineration of liquid wastes took place inprivate onsite facilities.

Current land-based incineration of all forms ofhazardous waste follows a similar distribution: In1983, 210 to 250 onsite hazardous waste incinera-tors managed an estimated 2.4 mmt, and about 30offsite incinerators managed about 0.4 mmt (2, 10,19,21).

Considerable uncertainty surrounds projectionsof onsite versus offsite waste management and,more specifically, incineration. It is not knownwhether, and to what extent, waste generators fac-ing restrictions on land disposal options will choose(or will be able) to develop additional onsite capacityor will instead send more waste to commercial fa-cilities. Clearly, the future market for ocean inciner-ation will be influenced to a large degree by suchdecisions.

Several studies have estimated potential shifts inonsite versus offsite treatment and disposal. CBO(21) projected that the quantity of all hazardouswaste sent offsite will roughly double from 1983 to1990. The magnitude of this shift depends onwhether the 1984 RCRA restrictions on land dis-posal are implemented according to schedule; if de-lays occur, the increase in offsite treatment wouldbe more gradual. CBO indicated that the trendtoward offsite treatment would be particularlystrong for wastes that can be incinerated or chem-ically treated, and that existing capacity in thesetechnologies could be surpassed easily.

A considerably less dramatic shift is forecast bythe majority of respondents to an EPA survey ofselected commercial hazardous waste managementfirms (8). According to these respondents, changesin the level of offsite treatment and disposal wouldbe limited at most to a ‘ ‘small (perhaps 4 to 6 per-cent), short-term pulse, ‘‘ primarily because of fa-cility closures under new RCRA restrictions .20 Fur-thermore, they expect that offsite shipment ofwastes will eventually decline as waste reductionpractices are implemented. A minority of respond-ents to the survey, however, predicted a larger in-crease of 10 percent or more in response to RCRArestrictions and also argued that ‘‘generators havealready exhausted most of their options to reducewaste volumes.

Capacity of and Demand for OffsiteTreatment Facilities

The shifting of waste from onsite to offsite treat-ment is only one of several factors that contributeto the overall demand for commercial treatment fa-cilities. Other factors include:

●

●

●

●

an increase in actual waste generation, becauseof economic growth;changes that result from new regulatory con-trols, such as more stringent regulations thatgovern the burning of hazardous waste inboilers, restrictions on the use of land disposalpractices, or increased implementation and en-forcement of effluent guidelines;closure of existing facilities that are unable tocomply with new regulations or unwilling toincur the additional costs of compliance; andcleanup of uncontrolled hazardous waste dis-posal Sites.

Several countervailing factors also may affectoverall demand:

. an increase in the capacity of existing facilities,whether they are private or commercial;

ZOSOme obSeNerS have questioned the reliability of information ob-tained from existing commercial hazardous waste firms, arguing thatthese firms have a strong self-interest in downplaying any future needfor additional facilities. Aside from this issue, whether such a surveyis representative of the industry is questionable; indeed, EPA cau-tions readers that ‘ ‘no statements can be made about the entire com-

mercial hazardous waste management industry from this small sam-ple” (8).


increasing waste or volume reduction bygenerators that are seeking to minimize theamounts of waste requiring offsite treatment;andincreasing use of mobile treatment facilitiesthat are designed to treat wastes at the site ofgeneration.

Each of these factors is very difficult or impossi-ble to assess in any quantitative manner. Never-theless, several States attempted to account for thesefactors in studies of future demand for offsite treat-ment capacity. 21 Virtually all of these studies pro-jected a substantial growth in the demand for off-site capacity into the foreseeable future, althoughestimates of the magnitude of growth varied con-siderably.

The studies also support the corollary that ashortfall between offsite treatment capacity and de-mand is expected if substantial growth in existingcapacity does not occur. 22 Given this, capacity couldbe increased by: 1) developing new facilities, or2) expanding capacity at existing facilities. Althoughboth of these avenues are being pursued, progresshas been very slow:

● The firms surveyed in the EPA study (8) havegenerally abandoned plans to develop new fa-cilities, because of local public opposition andbecause operating permits cannot be obtainedwithout a minimum delay of several years.

● Some of these firms indicated plans to expandtheir incineration and other treatment capacityat existing facilities; however, they again citedsignificant delays in obtaining permits as a ma-jor obstacle, and argued that “stretching outexisting capacity can only go so far. Eventu-ally, new sites must be brought on-line. ”

● CBO (21) indicated that—at the current rateof permitting for hazardous waste treatment,

zl~e= in~ude efforts undertaken in Missouri, New Jersey (5), NewYork, North Carolina, and Pennsylvania. References and moredetailed analyses of these studies are presented in ref. 24.

22 For examp]e, the Minnesota Waste Management Board (11) con-

cluded that ‘‘there is not sufficient capacity at the present time to treatall of the hazardous wastes amenable to treatment in the United States.As increasing emphasis is put on treatment as an alternative to dis-posal of hazardous wastes, there may be an overall shortage in treat-ment capacity. Another observer indicated that ‘‘little growth of avail-able commercial incineration capacity may be expected over the shortterm. A three- to five-year delay is possible before significant new ca-pacity could be available” (17).

●

storage, and diposal facilities—7 to 10 yearswould be needed to issue the final permits thatthese facilities must have to continue operat-ing. 23In a survey of private (onsite) treatment fa-cilities in New Jersey, facility owners expressedvery little interest in expanding capacity and/orcommercializing their operations to help meetthe projected shortfall in treatment capacity(5).

This discussion illustrates that the magnitude ofthe expected shortfall in offsite hazardous wastetreatment capacity is exceedingly difficult, if notimpossible, to estimate. Despite this, the demandfor such capacity clearly will increase. The next sec-tion addresses these same issues with a focus on pro-jecting the use of and demand for incineration ca-pacity.

Future Use of and Demand forIncineration Capacity

Numerous studies have indicated that the actualuse of and demand for incineration technologies tomanage hazardous waste will increase significantly(1 ,5,8,16,17,21 ,28). This trend is a reflection of theability of these technologies to destroy the organicportion of wastes and significantly reduce wastevolume:

Thermal destruction systems have become rec-ognized over the past decade as an increasinglydesirable alternative to the more traditional meth-ods of disposing of hazardous wastes in landfills,lagoons, and injection wells (17).

As one example of these studies, CBO (21) pro-jected that incineration of hazardous wastes wouldtriple or quadruple (from 2.7 mmt in 1983 to 8.2to 11.6 mmt in 1990). The higher estimate assumedthat no waste recycling and recovery beyond cur-rent levels would be undertaken; the lower estimateassumed that waste recycling and recovery effortswould achieve the level reflected in tables 6 and 7.CBO also indicated that the increased use of in-cineration would be the single largest change in theuse of all hazardous waste management technol-

Z’)section z 1s of the 1984 RGRA Amendments requires that d] in-cineration facilities receive final permits within 5 years of enactment,and all other treatment facilities within 8 years.

Ch. 3—Incinerab/e Hazardous Waste: Characteristics and Inventory • 75

ogies, and that incineration would increasingly beused to manage organic liquid, sludge, and solidwastes.

The EPA survey of commercial hazardous wastemanagement firms (8) also revealed that increasedquantities of waste were being directed toward in-cineration, a phenomenon clearly attributed by therespondents to the first effects of the new RCRArestrictions on land disposal. At least for the por-tion of the commercial market represented by thissurvey, waste quantities received for incinerationwere increasing at a faster rate than incinerationcapacity .24

The survey respondents argued that future in-creases in demand for incineration capacity wouldbe primarily for organic solids and sludges, and thatliquid capacity was sufficient and would probablyremain so. Unfortunately, no data were presentedthat indicated the relative quantities of the differ-ent physical forms of incinerable waste that werereceived .25

Attempts To Project the Future Market forOcean Incineration

As part of EPA’s ‘‘Assessment of Incinerationas a Treatment Method for Liquid Organic Haz-ardous Waste, Booz-Allen & Hamilton, Inc., con-ducted an analysis of the near-future commercialmarket for incinerable liquid wastes. The study (26)was intended to directly quantify the potential sizeof the ocean incineration market. The analysis,however, was complicated by a set of constraintsbeyond those confronting the studies cited above.Because the study focused on the commercial sec-tor of the incineration industry, assumptions hadto be made regarding, for example, the relativeproportion of incinerable wastes to be managed on-site versus offsite, and the contribution of commer-cial land-based incineration and other facilities tothe overall market picture for incinerable liquidwastes,

Z4TheSe firms repo~ed that the amount of wastes received for in-cineration increased by 48 percent from 1983 to 1984, while their in-cineration capacity increased by only 18 percent.

zsAs discussed Previously, incinerable liquids are often in demand

because of their fuel value, Receiving these wastes from generatorsis clearly attractive to commercial incineration firms, because burn-ing them reduces the need to use auxiliary fuel when burning solidsand sludges that have a lower energy content. Thus, separate discus-sions of liquid capacity and solids and sludge capacity do not appearto be particularly meaningful.

The result was a study that has been criticizedas being statistically unreliable and as failing to ac-count sufficiently for the use of technologies otherthan incineration. EPA indicated that the study didnot (and was not intended to) fulfill the require-ment for EPA to conduct a formal needs assessmentfor ocean incineration, as specified under the Ma-rine Protection, Research, and Sanctuaries Act.Rather, the study was intended to serve as a gen-eral indicator of the size of the potential shortfallin commercial liquid incineration capacity, in sup-port of EPA’s contention that there maybe a needfor ocean incineration. (For a fuller discussion ofuncertainties inherent in the market study, see refs.4,15,26,29).

Despite its flaws, EPA’s incineration marketassessment was generally consistent with virtuallyall other available studies. The major finding pre-dicted a significant and growing shortfall in inciner-ation capacity as a result of: 1 ) increases in thequantities of wastes generated and available for in-cineration, and 2) very slow development of capac-ity in incineration and other technologies for man-aging such wastes.

EPA’s market analysis (26) projected the poten-tial demand for ocean incineration based on a quan-tification of the shortfall in future commercial in-cineration capacity for liquid wastes. 2G A range ofprojections was derived under scenarios involvingimplementation of one or more of the land disposalrestrictions embodied in the 1984 RCRA Amend-ments. Assuming full implementation of all of theRCRA restrictions, a range was estimated for thequantity of excess liquid waste that would be shiftedaway from land disposal. Managing the quantityof wastes at the midpoint of that range would re-quire 33 incinerator ships with a capacity of 50,000mt per ship per year (or 82 additional land-basedincinerators at 20,000 mt per year).

This midpoint projection would represent an in-creased demand for commercial liquid waste in-cineration capacity of 1.65 mmt annually. 27 Aswould be expected, CBO’s estimate of the increase

ZGThis finding has been contested by land-based incineration com-panies (see ch. 2).

27The range in projected increased demand was considerable, from

0.75 to 2.55 mmt annually. This corresponded to a range of 15 to51 incinerator vessels, or 38 to 128 land-based incinerators. The ex-tent of this range is one indicator of the degree of uncertainty accom-panying such projections.


in total use of incineration (i. e., both commercialand private facilities burning liquids, sludges, andsolids) was higher, by a factor of 3 to 5.28 Thus,despite major differences in methodology and some-what different estimates, these two studies wereroughly consistent; both supported the conclusionthat, in the near future, there will be increased de-mand for capacity to manage liquid incinerablewastes.

EPA’s market analysis cast its results in termsof a specific demand for liquid incineration capac-ity. A more neutral statement of the result, how-ever, is that the capacity to manage incinerablewastes is expected to fall short of demand. Thisshortfall could (and likely will) be addressed in anumber of ways. For example, development ofocean incineration capacity or expansion of land-based incineration capacity or both could help tomeet this demand. Alternatively, it could be par-tially met by other means now used for a portionof these wastes—including chemical treatment,recycling and recovery, and use as fuel in indus-trial boilers and furnaces. Finally, the quantitiesof waste requiring treatment could be decreasedthrough increased application of waste reductionpractices. Accurately estimating the future use ofany of these technologies is highly complex, if notimpossible.

Thus, a future need for ocean incineration (orland-based incineration, or any other hazardouswaste management technology) may never be un-equivocally demonstrated or quantified from ananalytical standpoint. Nevertheless, given the gen-erally acknowledged shortfall in our present andfuture capacity to manage incinerable wastes, thedevelopment of several options will likely be nec-essary.

Other Factors Affecting Future WasteGeneration and Management

The two most important variables with respectto hazardous waste generation and management inthe near future appear to be: 1) the extent and

ZfICBO>S range Was 8.2 m 11.6 mmt annually. After accounting forcurrent use of incineration at 2.7 mmt annually, this would repre-sent an increase of 5.5 to 8.9 mmt annually. Thus, compared to theEPA value of 1.65 mmt, CBO’S values were three to five times higher.

schedule of implementation of the new (1984)RCRA authority (which bans certain wastes fromland disposal) as well as future changes in theRCRA definition and classification of hazardouswastes (e. g., for waste oils); and 2) the extent ofapplication of new and emerging waste reduction,reuse, and recovery technologies and strategies.

In addition to banning some wastes from landdisposal, two other changes in RCRA resultingfrom the 1984 amendments will increase the quan-tities of hazardous waste by bringing heretofore un-regulated wastestreams or generators under RCRAauthority:

1,

2.

Exemptions for hazardous wastes or used oilsburned as fuel are being removed, and newregulations governing their blending, burn-ing, and recycling for reuse are mandated.CBO (21) estimated that, in 1983, signifi-cantly more hazardous waste was burned inRCRA-exempt industrial boilers and furnacesthan was incinerated (9.5 mmt versus 2.7mmt). EPA estimated that 3.4 to 5.4 mmt ofhazardous waste and used oils are burned an-nually in industrial boilers (50 FR 1684, Jan.11, 1985). See chapter 4 for a detailed discus-sion of this topic.The waste level below which generators areexempted from regulation has been reducedfrom 1,000 to 100 kilograms per month, there-by greatly increasing the number of regulatedsmall generators; EPA (50 FR 31285, Aug.1, 1985) estimated that the number of RCRA-regulated generators would increase from thecurrent 14,000 to a total of 175,000, but thatthese small generators account for only about760,000 metric tons per year of hazardouswaste (much less than 1 percent of the nationaltotal).

Conversely, new RCRA requirements for im-plementing waste reduction and detoxification pro-grams and increasing industrial efforts aimedtoward waste reduction, recycling, and recoverywould be likely to moderate or reduce future haz-ardous waste generation. The full impact of suchmeasures depends on a variety of regulatory, in-stitutional, and economic variables and is thereforeexceedingly difficult to predict.

Ch. 3—lncinerable Hazardous Waste: Characteristics and Inventory • 77

1.

2.

3.

4.

5.

6.

7.

8.

9.

10.


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pared for New Jersey Waste Facilities Siting Com-

m i s s i o n ( T r e n t o n , NJ : March 1985 ) , p . 170 .E P R I J o u r n a l , ‘ ‘Handling PCBS, ” EPRI Jour-nal 10(8):26-27, October 1985.Gossett, R. W., Brown, D. A., and Young, D. R.,“Predicting the Bioaccumulation and Toxicity ofOrganic Compounds, Coastal Water ResearchProject Biennial Report for the Years 1981-1982( L o n g B e a c h , C A : S o u t h e r n C a l i f o r n i a C o a s t a lWater Research Project, 1982).

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mercial Hazardous Waste Management Industry:

1984 Update, ” final report prepared for the U.S.

Environmental Protection Agency, Off ice of Pol-

icy Analysis (Washington, DC: Sept. 30, 1985).

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11.

12.

13.

14.

15.

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17.

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21.

22.

23.

Minnesota Waste Management Board, “RevisedDraft Hazardous Waste Management Plan’(Crystal, MN: February 1984).Mitre Corp., Composition of Hazardous WasteStreams Currently Incinerated, contract report

prepared for the U.S. Environmental Protection

Agency, Office of Solid Waste (Washington, DC:

April 1983).

N a u k e , M . K . , “ D e v e l o p m e n t o f I n t e r n a t i o n a l

Controls for Incineration At Sea, ” in Wastes inthe Ocean, vol. 5, D.R. Kester, et al. (eds. ) (NewYork: John Wiley & Sons, 1985), pp. 33-52.New England Congressional Institute, HazardousWaste Generation and Management in New Eng-land (Washington, DC: February 1986).Oceanic Society, Joint Comments of Environ-mental and Other Citizen Organizations in Re-sponse to the U.S. Environmental ProtectionAgency’s Draft Regulations on Ocean Incinera-tion (Washington, DC: June 28, 1985).Office of Appropriate Technology, “Alternativesto the Land Disposal of Hazardous Wastes, AnAssessment for California, Toxic Waste Assess-ment Group, Governor’s Office of AppropriateTechnology (Sacramento, CA: 1981).Oppelt, E. T., ‘ ‘Hazardous Waste Destruction,Environ. Sci. Technol. 20(4):312-318, 1986.SEAMOcean, Inc., ‘ ‘Preliminary Assessment ofthe Cost Implications of Multimedia Waste Man-agement Decisions That Include an Ocean Op-tion, final report prepared for National Oceanicand Atmospheric Administration, Office ofOceanic and Atmospheric Research (Wheaton,MD: February, 1986).Stephan, D. G., letter of transmittal to Office ofTechnology Assessment dated May 22, 1985, ac-companying Keitz, et al., 1984.Tejada, Susan, “The Blue Goose Flies!” EPA

Journal, October 1985.U.S. Congress, Congressional Budget Office,Hazardous Waste Management: Recent Changesand Policy Alternatives (Washington, DC: U.S.Government Printing Office, 1985).U.S. Congress, House of Representatives, Haz-ardous and Solid Waste Amendments of 1984,H. Report 98-1133 to accompany H.R. 2867,98th Cong., 2d sess. (Washington, DC: U.S.Government Printing Office, 1984).U.S. Congress, Office of Technology Assessment,Technologies and Management Strategies for


24.

25.

26.

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Hazardous Waste Control, OTA-M-196 (Wash-ington, DC: U.S. Government Printing Office,March 1983). 27.U.S. Congress, Office of Technology Assessment,‘ ‘Serious Reduction of Hazardous Waste for Pol-lution Prevention and Industrial Efficiency, ” inpress (Washington, DC: 1986).U.S. Environmental Protection Agency, Office ofPolicy, Planning and Evaluation, “BackgroundReport I: Description of Incineration Technol- 28.ogy, Assessment of Incineration as a TreatmentMethod for Liquid Organic Hazardous Wastes(Washington, DC: March 1985).U.S. Environmental Protection Agency, Office ofPolicy, Planning and Evaluation, “BackgroundReport 111: Assessment of the Commercial Haz- 29.ardous Waste Incineration Market, Assessmentof Incineration as a Treatment Method for Liq -

uid Organic Hazardous Wastes (Washington,DC: March 1985).Westat, Inc., National Survey of HazardousWaste Generators and Treatment, Storage andDisposal Facilities Regulated Under RCRA in1981, contract report prepared by S. Dietz, M.Emmet, R. DiGaetano, et al., for the U.S. Envi-ronmental Protection Agency, Office of SolidWaste (Rockville, MD: Apr. 20, 1984).White, R. E., Busman, T., Cudahy, J.J., et al.,New Jersey Industrial Waste Study, EPA/600/6-85/003, prepared for the U.S. EnvironmentalProtection Agency, Office of Research and De-velopment (Washington, DC: May 1985), pp. 52,53, 87,Zurer, P. S., ‘ ‘Incineration of Hazardous WastesAt Sea—Going Nowhere Fast, ” Chem. Engr.News, Dec. 9, 1985, pp. 24-42.

Chapter 4

Current and Emerging Managementand Disposal Technologies forIncinerable Hazardous Wastes

Contents

PageIncinerable Waste Quantities Currently Managed by Various

Treatment and Disposal Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 81

Current Use of Particular Technologies for Managing Incinerable Wastes . . . . . . . . . . . . . 82Land Disposal., . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 82Use of Incinerable Waste as Fuel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 84Biological and Physical/Chemical Treatment .,.... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 85Waste Recovery and Recycling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 85Waste Reduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 86

New and Emerging Technologies for Incinerable Wastes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 87Recovery Processes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 87Thermal Detoxification Processes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 88Chemical Detoxification Processes .....+ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 88

Chapter4 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 89

Chapter 4

Current and Emerging Managementand Disposal Technologies forIncinerable Hazardous Wastes

Incinerable wastes are currently managed by abroad array of methods; how extensively eachmethod is used depends on innumerable economic,regulatory, and geographic factors. In addition, awide range of new technologies for managing haz-ardous wastes is being developed, and many ap-ply directly to incinerable wastes. This chapter firstsummarizes available data on the quantities of in-cinerable waste currently managed by particularmethods and examines each method in more detailwith respect to its potential for influencing the useof ocean incineration. Then the chapter briefly de-scribes several new technologies with respect to theiravailability, capacity, and degree of applicabilityto incinerable wastes.

The discussion specifically excludes the largequantities of hazardous waste present in waste-waters that are directly and indirectly dischargedinto surface waters. Such disposal practices are reg-ulated under the Clean Water Act and are specifi-cally exempted from Resource Conservation andRecovery Act (RCRA) regulations applicable tohazardous waste. Moreover, only a small portionof incinerable liquid wastes is discharged into sur-face waters. Another OTA report (21) will exam-ine these practices in detail.

INCINERABLE WASTE QUANTITIES CURRENTLY MANAGED BYVARIOUS TREATMENT AND DISPOSAL METHODS

Several studies have estimated the quantities ofhazardous waste managed through treatment, dis-posal, and recycling or recovery (6,18,24). How-ever, only one study—by the Congressional Bud-get Office— was aggregated by waste type; thisallowed separate estimates to be developed for thevarious categories of incinerable hazardous waste,which include waste oils, halogenated and non-halogenated solvents, and other organic liquids (ref.18, and unpublished data).

The CBO estimates for the overall dispositionof hazardous waste differed significantly in somecases from those of the Environmental ProtectionAgency (24). 1 The sources of data for both studiescontain uncertainties and systematic errors whichlikely contribute to such differences. In addition,the universe of hazardous wastes considered in the

‘C BO acknowledged this discrepancy and discussed differences inthe methodologies of the two studies in a paper (19) which accompa-nied its 1985 report (18).

two studies differs significantly: CBO adopted a def-inition that is much broader than the RCRA defi-nition used by EPA. Finally, CBO assumed fullcompliance with RCRA and Clean Water Act re-quirements in generating its estimates. Given thesesources of uncertainty, the following discussion willprovide a range of estimates, wherever possible, toprovide a qualitative picture of current manage-ment of hazardous waste that could be incinerated.

Available data indicate that large quantities ofwaste that could be incinerated are currently be-ing disposed of on land—in landfills, surface im-poundments, or injection wells. Of liquids thatcould be incinerated at sea, CBO estimates thatalmost a third of oils and solvents and more than80 percent of other organic liquids are disposed ofon land. For incinerable sludges and solids, reli-ance on land disposal is even higher: CBO estimatesthat more than 80 percent of these wastes are land-disposed.

81


The CBO data also indicate that most waste oils(about 60 percent) and significant quantities ofwaste solvents (5 to 10 percent) are burned inRCRA-exempt industrial boilers, currently underlittle or no regulation. These data are generally con-sistent with those from other sources (refs. 4 and13; 50 FR 1684, Jan. 11, 1985).

The 1984 RCRA Amendments were designedto significantly restrict the use of these options formanaging hazardous wastes, because of concernsabout adverse impacts to human health and theenvironment. If the restrictions are implementedaccording to schedule, they are likely to significantly

increase the quantities of waste. available for ordirected to incineration.

CBO’S data and other data indicate that signifi-cant quantities of incinerable wastes, particularlyliquids, are currently being recovered, reused, orrecycled. These practices are likely to be increas-ingly used in the future. As shown in table 6 (seech. 3), however, despite the anticipated levels ofrecovery, reuse, and recyling, it is likely that mostincinerable hazardous wastes generated by 1990 willcontinue to require some form of treatment ordisposal.

CURRENT USE OF PARTICULAR TECHNOLOGIESFOR MANAGING INCINERABLE WASTES

Hazardous waste management technologies canbe organized into a generally accepted hierarchyof methods ranging from least to most environ-mentally desirable or sound. This hierarchy canbest be represented by a hazardous waste manage-ment “pyramid,” with the following tiers:

dispersion in the environment;isolation or containment;stabilization of waste through physical orchemical means;destruction or treatment of wastes to reducetoxicity;recovery of waste for recycling or reuse of ma-terials or energy; andreduced generation of waste, with respect toboth volume and toxicity.

A particular technology may actually contain ele-ments from more than one tier in the hierarchy.For example, ocean incineration entails destructionof most of the waste, dispersion of a small amountof unburned wastes into the environment, and con-tainment of any residuals by disposing of them inlandfills. This section briefly discusses technologies(other than incineration) in light of the above hier-archy and indicates which technologies contain ele-ments of more than one tier. Currently availableincineration technologies are discussed in chapter 5.

Land Disposal

Large quantities of incinerable hazardous wastesare now disposed of on land. Land disposal includesthree primary methods: underground injection,landfilling, and surface impoundment. Althoughthey are meant to isolate and contain wastes, allthree methods have often resulted in dispersion ofwastes, through leakage and migration of wastesfrom the disposal site. In some cases, wastes arestabilized prior to disposal in order to lessen therisk or degree of dispersion.

If implemented according to schedule and con-gressional intent, the 1984 RCRA Amendments’restrictions on land disposal would shift large quan-tities of hazardous waste, particularly incinerableliquids, away from land disposal. Almost all of theRCRA prohibitions, however, are contingent onthe availability of alternative capacity for manag-ing banned wastes. If alternatives are unavailable,temporary variances can be granted.

Underground Injection

The injection of hazardous wastes into deep wellsis the disposal technology used most often for suchwastes. In 1983, an estimated 44 million metric tons(mmt) to 67 mmt, or one-sixth to one-quarter of

all hazardous wastes generated, were disposed ofby underground injection (ref. 18; EPA, cited inref. 19). The 1984 RCRA amendments impose newrequirements on this practice, although they are lessstringent than those applicable to landfilling andsurface impoundment. The schedule for banningthe underground injection of hazardous waste ismore gradual and the burden of proof of adverseimpact may be somewhat more stringent.

Landfilling

CBO(18) estimated that over one-fifth of all haz-ardous wastes generated in 1983 was disposed ofin landfills. Increasingly stringent RCRA require-ments are raising costs, however, and are expectedto lead to decreased usage. Minimum technology

standards embodied in the 1984 RCRA Amend-ments require the use of double liners, leachate col-

lection systems, and groundwater monitoring ca-pability. Landfilling of bulk liquid hazardous wasteis already prohibited, and prohibitions on landfill-ing of other hazardous wastes are being decided ona legislatively mandated schedule.

Surface Impoundment

Surface impoundments, which include ponds,pits, and lagoons, are used to store and treat, aswell as dispose of, many hazardous wastes. CBO(18) estimated that almost one-fifth (50 mmt) of allhazardous wastes generated in 1983 was placed insurface impoundments. Treatment processes usedin surface impoundments include volatilization,evaporation, aerobic or anaerobic digestion, andcoagulation and precipitation. Under the 1984RCRA Amendments, the same minimum technol-


I

i

I

II

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ogy standards applicable to landfills now apply tosurface impoundments, although the immediateban on bulk liquid hazardous waste does not apply.

Use of Incinerable Waste as Fuel

A variety of technologies use incinerable wasteas a fuel source. These technologies embody ele-ments of the treatment/destruction and recoverytiers in the waste management hierarchy. In addi-tion, disposal of residuals from such processes mayinvolve isolation/containment or dispersion of wastes,as well.

Technologies employing incinerable waste as fuelcompete directly with both land-based and oceanincineration. A regulatory distinction exists, how-ever, between thermal technologies whose primarypurpose is to use and capture the energy contentof raw fuel or hazardous waste, and typical inciner-ation technologies, which are designed primarilyfor the purpose of destroying wastes (46 FR 7666,Jan. 23, 1981).2

Various types of boilers and furnaces, both in-dustrial and nonindustrial, employ incinerablewaste as fuel to some extent. Nonindustrial boilersare used largely for space heating in apartments,office buildings, schools, and hospitals. Industrialboilers are used for space heating and steam pro-duction by utilities or other industrial facilities.

Industrial furnaces include cement and limekilns, asphalt plants, and steel blast furnaces. Someof these technologies use the chlorine as well as theenergy from hazardous wastes. For example, ce-ment kilns use the acid gas formed from burningchlorinated wastes to reduce the alkalinity of thecement slag; the kiln itself acts essentially as a scrub-ber, and the quality of the cement product is actu-ally improved in the process.

Profile of Existing Facilities UsingIncinerable Waste as Fuel

This section provides a profile of the number ofthese facilities and the extent of their use in burn-ing hazardous wastes as fuel.

A very large number of industrial boilers and fur-naces are used in the United States. EPA estimates

‘Incineration technologies are discussed in ch. 5.

that about 43,000 industrial boilers and 600 indus-trial furnaces are currently in operation (4, 13). Ofthese, about 1,300 boilers and 10 to 20 furnacesburned some waste oil or hazardous waste-derivedfuel in 1983 (25). EPA estimated that 3.4 to 5.4mmt of hazardous waste and used oils are burnedannually in industrial boilers (50 FR 1684, Jan. 11,1985) and that about 0.35 mmt are burned annu-ally in industrial furnaces (24). CBO (18) reporteda much higher estimate of 9.5 mmt for industrialboilers and furnaces. In any case, significantly morehazardous waste is burned in industrial boilers andfurnaces than is incinerated: 1.7 to 2.7 mmt(18,24).

While industrial furnaces and boilers appear tohave enormous capacity for hazardous wastes, sev-eral factors limit their use. First, although thesepractices were exempted from RCRA regulations,the 1984 RCRA Amendments call for their regu-lation as hazardous waste facilities (see below). Sec-ond, these facilities have tended to burn only haz-ardous wastes that are relatively clean and have ahigh energy content. Attempts to significantly ex-pand their use would involve wastes that are lessattractive to facility operators, because they con-tain higher amounts of ash, water, or solids (13).Indeed, the reluctance of many operators to usesuch wastes for fuel is reflected in the small propor-tion of existing facilities that actually burn hazard-ous wastes (as indicated above).

A third factor limiting the use of these facilitiesfor hazardous wastes is the relative lack of rigor-ous environmental testing or appropriate pollutioncontrol equipment. Very few industrial boilers areequipped with scrubbers (12, 13), so that wastes withsignificant chlorine or ash content could not beburned; moreover, the corrosivity of the resultingexhaust gases would damage the boilers.

A fourth factor limiting such use is the chlorinecontent of wastes. Wastes of intermediate chlorinecontent can be burned in cement kilns and otherindustrial furnaces, where corrosive gases aredirectly used in the production process. Burningof chlorinated wastes in kilns, however, tends toincrease the release of particulate, necessitatingthat facilities be upgraded prior to such use (12).These and other factors limit the chlorine contentof wastes that can be burned in such facilities.

Ch. 4—Current and Emerging Management and Disposal Technologies for Incinerable Hazardous Wastes ● 85

In some States, industrial furnaces have experi-enced regulatory problems when burning hazard-ous wastes and have been forced to stop acceptingcertain or all such wastes. This has led to increas-ing quantities of waste being sent to commercialincinerators (2).

Regulation

Some regulation of hazardous waste burning inboilers and furnaces has already occurred, and moreis likely in the near future. Burning of hazardouswaste in nonindustrial (particularly residential) de-vices is now strictly regulated and for the most partprohibited (50 FR 49164, Nov. 29, 1985). The 1984RCRA Amendments prohibit burning of hazard-ous waste in cement kilns located in cities with pop-ulations exceeding 500,000 unless the facility com-plies with RCRA incineration standards (Section204(b)(2)(c)).

For facilities producing fuels containing hazard-ous waste, notification and labeling requirementsand product standards were also mandated and arecurrently being developed. In addition, exemptionsfor hazardous wastes or used oils burned as fuel arebeing removed, and new regulations governingtheir blending and burning are mandated. Finally,in 1986 EPA expects to issue permit standards thatwould extend the current performance standardsand requirements applicable to land-based inciner-ators to all industrial boilers and furnaces (50 FR49164, Nov. 29, 1985).

Biological and Physical/ChemicalTreatment 3

Many technologies for treating hazardous wastesare applicable to incinerable wastes. Biologicalmethods include traditional aerobic and anaerobicdigestion, in which naturally occurring bacteria areused to metabolize the organic constituents of thewaste. Aerobic processes generally can be used onlywith relatively dilute wastestreams (liquids that con-tain low levels of solids), because high concentra-tions of waste components or metabolic productsare often toxic to bacteria. Anaerobic procedures

3Although incineration and other thermal processes are often clas-sified as treatment technologies, this discussion is limited to nonther-mal processes.

are less sensitive, and have been used to digestsludges that contain significant amounts of solids.

Biologists have isolated naturally occurring bac-teria that can degrade particular toxic or persist-ent chemical compounds (5,23). Particularly forspecialized and highly problematic wastes such asPCBS, these and other emerging biological ap-proaches may prove extremely useful and cost-effective.

Traditional physical/chemical treatment entailsremoving organic or metallic compounds fromaqueous wastes—by using coagulant, absorbentssuch as activated carbon, or chemical reactions—and then destroying or disposing of the contami-nated residues. Newer methods applicable to in-cinerable waste include several related technologiesfor dechlorination. Such processes chemically stripoff chlorine atoms from highly chlorinated organiccompounds, thereby greatly decreasing or elimi-nating their toxicity and persistence. Mobile unitshave been developed specifically to detoxify PC B-contaminated transformer fluids and PCB- or di-oxin-contaminated soils.

Waste Recovery and Recycling

Current methods for recovering waste have beenapplied primarily to waste solvents and oils. Sol-vent recovery is a well established industry, whichhandles most of the waste solvents that are gener-ated (18). Solvents are often sent offsite to be pu-rified and returned to the generator for a fee. Inother cases, the recoverer resells solvents to newcustomers.

Solvent recovery consists of several independentprocesses, which result in sequentially cleaner mate-rial. Some loss of quality relative to virgin materialsaccompanies all of these processes. Although thiscan lower the demand for recovered solvents, mar-kets currently exist for both partially and fully re-covered solvents. The intended use determines theextent of treatment; for example, use as fuel re-quires only minimal treatment, whereas reuse assolvent may require substantial treatment andexpense.

The initial step in solvent recovery usually is toremove suspended impurities by filtration and cen-trifugation. Separation and removal of water, or


separation of different solvents present in a mix-ture, is accomplished through various forms of dis-tillation. Each of these processes generates a resid-ual, which must be disposed of or destroyed. Forexample, distillation generates various still wastes,which are candidates for incineration (on land orat sea).

Waste oil recovery, which is used to a muchsmaller extent than is solvent recovery, also entailsseveral processes that produce sequentially cleanermaterial. Specifications based on intended reusehave been established, and they largely dictatethe extent and nature of treatment. Reclaimingwaste oil entails removing suspended solids, water,and degraded oil compounds. Reclaimed oils areblended or reformulated, resulting in products thatcan be resold for uses that do not require oil meet-ing the specifications for virgin material. Rerefin-ing of reclaimed oil is accomplished through frac-tional distillation to generate a final product thatapproaches original specifications.

In addition to the new RCRA requirements thatapply to the blending and burning of fuels contain-ing hazardous waste, EPA has proposed listing usedoil as a hazardous waste under RCRA (50 FR49258, Nov. 29, 1985) and has proposed regula-tions governing recycled oil (50 FR 49212, Nov.29, 1985). The regulations would ban the use ofrecycled oil for oiling roads and would extend torecycled oil those regulations that govern otherrecycled hazardous wastes.

A third method of waste recovery applicable tomany types of waste is liquid extraction. This tech-nique is especially useful for recovering a dissolvedwaste component that has economic value in itspure form. For example, phenol can be recoveredin this manner from refinery and coke oven wastes.

A number of newer technologies, which have notbeen widely employed in the United States, can di-rectly recover or use the chlorine released whenchlorinated wastes are thermally destroyed. These

processes are discussed in the section on new andemerging technologies.

Waste Reduction

Although the term waste reduction has a verybroad meaning in common usage, in its most pre-cise connotation it refers to technologies and proc-esses that reduce the actual generation of waste(measured in terms of volume, or in terms of thetoxicity or degree of hazard per unit volume). Atechnology like incineration reduces the toxicity andvolume of waste, but a true waste reduction tech-nology or process is used before the wastes are ac-tually generated (i. e., in order to prevent their gen-eration). The term, therefore, also excludes wasterecovery technologies that reduce the quantity ofwaste requiring treatment or disposal but that actafter the waste is generated.

Waste reduction technologies generally fall intotwo categories. First, process modifications reducewaste generation by, for example, internal recy-cling or more efficient use of feedstocks. Thesemeasures are ‘typically process-specific, and themodifications are often driven by direct economicincentive. Even modifications that are not tied tothe process itself have often been used to reducewaste (e. g., computer-based scheduling and inven-tory control in paint manufacturing) (l).

A second category of waste reduction technol-ogies includes product or ingredient substitution,in which toxic or polluting materials are replacedby safer components. For example, water-basedinks or adhesives can sometimes be substituted forthose containing or made with organic solvents.

A full discussion of waste reduction far exceedsthe scope of this study. For additional information,see references 3,9,14,15,16.4

4Another ongoing OTA assessment (20) examines in detail the po-tential for industrial waste reduction.

Ch. 4—Current and Emerging Management and Disposal Technologies for /ncinerab/e Hazardous Wastes . 87

NEW AND EMERGING TECHNOLOGIESFOR INCINERABLE WASTES

A wide range of new technologies is being de-veloped for the management of hazardous wastes.Many of these technologies, including methods forthe recovery as well as detoxification (through treat-ment or destruction) of wastes, apply directly to in-cinerable wastes. A full analysis of the new tech-nologies would exceed the scope of this assessment,but the topic has been examined in detail by others(7,8,1 1,22). This section briefly describes a fewpromising technologies and, where data are avail-able, discusses their status, capacity, and degreeof applicability to incinerable wastes.

Recovery Processes

Solvent Recovery—Thin Film Evaporation

This technology, in which waste solvent is frac-tionated by evaporation from a thin film appliedto a heated surface, provides an alternative to con-ventional solvent distillation. The technology’s pri-mary advantages over conventional distillation area higher efficiency of recovery (greater than 95 per-cent), a smaller amount of residual material requir-ing disposal or destruction, and the ability to re-cover even highly viscous liquids.

A few commercial solvent recovery firms haverecently installed thin film evaporators (l), but dataon current or near-future capacity are not available.

Advanced Oil Recovery Processes

Application of advanced petroleum technologyto waste oil has resulted in a number of new meth-ods for removing contaminants and fractionatingoil, thereby producing material that closely approx-imates original specifications. Several of these meth-ods have recently been put into operation. The ex-tent to which they would be applied to incinerablewastes would partly depend on oil prices and therelative cost of existing alternatives, including in-cineration.

Chlorine Recovery Processes

Several emerging technologies can use the chlo-rine that is released during the incineration of highly

chlorinated organic wastes (17). These technologiesfall into two major classes. First, certain processescan recover chlorine liberated during incinerationin the form of concentrated hydrochloric acid.These processes are generally applicable to a broadrange of chlorinated organic wastes, but they haveonly been used on a small scale to date, probablyin part because they are not competitive with otherindustrial sources of hydrochloric acid (10). Sec-ond, a group of related chlorination processes di-rectly use liberated chlorine in additional chemi-cal chlorination reactions. These technologies canbe applied, for example, to the production of chlo-rinated hydrocarbons such as trichloroethylene, butthe waste used in the process must be quite pureand homogeneous. To date, only wastes generatedin the production of vinyl chloride and propyleneoxide have been used successfully in chlorinationrecovery processes.

Both types of processes are limited by the mar-ket’s capacity to absorb their products. In addition,the technologies have been used primarily in Eur-ope and have not found significant application inthe United States. Current costs are several timeshigher than those for ocean incineration of the samewastes, although the return on recovered materi-als can sometimes alter the ratio. From an envi-ronmental perspective, these recovery processes of-fer the advantage of occurring in relatively closedsystems, thus greatly reducing the emissions asso-ciated with conventional incineration.

Supercritical Fluid Extraction

This process is an advanced form of liquid ex-traction, employing elevated temperature and pres-sure to extract particular organic compounds fromwaste mixtures. The process entails higher capitalinvestment but lower operating costs than conven-tional distillation or solvent extraction. As with liq-uid extraction, supercritical fluid extraction is likelyto be most useful for treating aqueous wastes con-taining valuable or highly toxic components. It mayalso be able to concentrate the organic portions ofwastes in order to render their subsequent inciner-ation more economical.

88 ● Ocean /incineration: Its Role in Managing Hazardous Waste

I

Thermal Detoxification Processes5

High-Temperature Electric Reactor

This technology is an advanced pyrolytic tech-nique in which wastes are rapidly heated to ex-tremely high temperatures (about 4,000° F) anddestroyed. Its developer claims that the destructionefficiencies the reactor achieves are much higherthan those required of, or achieved by, conventionalincinerators. The reactor was initially developedto destroy organic contaminants in soils or carbonabsorbents, but it has recently been used for liq-uid wastes, as well.

The reactor’s throughput for solids is estimatedto be as high or higher than that of conventionalincineration, although for liquids the converse maybe true. Commercialization is underway.

Molten Salt

This technology destroys organic wastes and re-moves inorganic residuals from combustion gasesin a single step. Wastes are injected into a poolor bath of molten sodium carbonate or calciumcarbonate maintained at a temperature of about1,6500 F; the inorganic byproducts of combustion(containing phosphorus, sulfur, halogens, or me-tals) react with the carbonate component of the bathand are retained as inorganic salts. These products,as well as ash, must be periodically removed fromthe bath.

Molten salt baths are suitable for both liquid andsolid wastes (including highly halogenated waste-streams) with low ash content. Throughput of apilot-scale facility was estimated to be about 100lbs/hr. No commercial units are currently em-ployed, although they are available for purchase.

Molten Glass

A similar technology employing a molten glassbath maintained at about 2,200° F has also been de-veloped. Inorganic components other than halogensare trapped and removed in a classified, and there-fore highly stabilized, form. Scrubbers are neces-sary when this technology is used with halogenatedwastes.

5This discussion is drawn primarily from refs. 1 and 8.

Fluid Wall Reactor

In this process, wastes pass through a porous car-bon cylinder heated to about 2,200° F. A mobileunit has been developed for destroying dioxin-con-taminated liquids and soils. Projected costs are com-parable to those of offsite incineration.

Plasma Arc

Wastes are destroyed in this process by injectioninto an electrically superheated ionized gas(plasma). Temperatures employed are claimed tobe extremely high: 10,000° F or more. An after-burner is usually attached to ensure complete de-struction. The method has been used on PCBs andother highly chlorinated liquid wastes, and has dem-onstrated very high destruction efficiencies (higherthan 99.9999 percent). A unit currently being dem-onstrated has a waste throughput of 600 lbs/hr. Acommercial unit is expected to be available withina few years. The costs, which are projected to be5 to 10 times higher than conventional incinera-tion, would probably limit the technology’s use tohighly toxic liquids.

Supercritical Water Reactor

In this process, elevated temperature and pres-sure enhance the rate and efficiency of thermal ox-idation of aqueous wastes. Inorganic constituentsare either neutralized or precipitated, eliminatingthe need for scrubbers on systems fed with chlori-nated wastes. Destruction efficiencies of demonstra-tion units have been somewhat lower than thoserequired of incinerators.

A reactor system now being developed wouldtreat liquids and sludges containing high levels ofinorganic and toxic constituents. The unit wouldbe equipped with heat recovery capability as well.Throughput is expected to be between 1,000 and2,000 gallons per day (300 to 600 lbs/hr). Com-mercialization is expected to occur within severalyears.

Chemical Detoxification Processes

As a general rule, incinerable wastes are not goodcandidates for chemical treatment. Particular wastessuch as PCBs and dioxins, which have been the fo-cus of considerable public attention, may be excep-

Ch. 4—Current and Emerging Management and Disposal Technologies for Incinerab/e Hazardous Wastes • 89

tions to this generalization. For more informationabout chemical detoxification processes, see ref. 1.

Oxidative Ultraviolet Light Treatment

This process couples the oxidative capacity ofozone or hydrogen peroxide with the ability of high-energy ultraviolet light to break chemical bonds.Several techniques are being developed, but theyare likely to be quite expensive, especially for wastewith significant organic content, thus limiting theirability to compete with incineration. The techniquesmay, however, be useful for hard-to-treat wastessuch as PC B- and dioxin-containing solids.

Catalytic Dehalogenation6

Two dehalogenation processes are being devel-oped. One would be applicable to liquids with low

‘Most halogenated chemicals contain chlorine rather than other halo-gens; the processes discussed below are, therefore, often referred toby the term dechlorination.

organic halogen content, the other to pure haloge-nated compounds or liquids with highly concen-trated halogenated compounds. The first processwould replace halogen (usually chlorine) atoms withhydrogen, detoxifying the original compound orrendering it less stable. The halogen gas generatedin the process would have to be treated in a scrub-ber device. In the second process, the original com-pound would be oxidized to carbon dioxide andwater, and the halogen would take the form of thepure element (e. g., chlorine gas), which could berecovered.

The feasibility of both processes has been estab-lished in pilot-scale units, but neither has yet beenemployed commercially. Both systems are expectedto be suitable for use in mobile units, which couldbe employed at cleanup sites, but would probablybe too small for major commercial operations.


1.

2.

3.

4.

5

Arthur D. Little, Inc., Overview of Ocean Incin-eration, prepared by J. R. Ehrenfeld, D. Shooter,F. Ianazzi, and A. Glazer, for the U.S. Congress,Office of Technology Assessment (Cambridge,MA: May 1986).Booz-Allen & Hamilton, Inc., ‘‘ Review of Activ-ities of Major Firms in the Commercial Hazard-ous Waste Management Industry: 1982 Update,prepared for the U.S. Environmental ProtectionAgency, Office of Policy Analysis (Bethesda, MD:Aug. 15, 1983), p. 8.Campbell, M., and Glenn, W., Profit From Pol-lution Prevention (Toronto, Ontario: PollutionProbe Foundation, 1982).Castaldini, C., Willard, H. K., Wolbach, C. D.,et al., A Technical Overview of the Concept ofDisposing of Hazardous Wastes in Industrial Boil-ers, EPA No. EPA-600/2-84-197, prepared for theU.S. Environmental Protection Agency, Office ofResearch and Development, Industrial Environ-mental Research Laboratory (Washington, DC:December 1984).Chemical and Engineering News, ‘‘New Findingson PCBs, Other Pollutant Group, Chemical &Engineering News 63(18): 10, May 6, 1985.

6.

7.

8.

9.

10.

11.

12

Chemical Manufacturers Association, Results ofthe 1984 CMA Hazardous Waste Survey (Aus-tin, TX: Engineering-Science, Inc., January1986).Dombrowski, C. H., “Land Ban Encourages Tech-nological Advancements, World Wastes, March1986, pp. 25-28.Freeman, H., Innovative Thermal HazardousWaste Treatment Processes, EPA/600/2-85/049,prepared for the U.S. Environmental ProtectionAgency (Washington, DC: April 1985).Huisingh, D., and Bailey, V. (eds. ), Making Pol-lution Prevention Pay (New York: PergamonPress, 1982).Nauke, M. K., “Development of InternationalControls for Incineration At Sea, ” in Wastes inthe Ocean, vol. 5, D.R. Kester, et al. (eds. ) (NewYork: John Wiley & Sons, 1985), pp. 33-52.Nell, K. E., Haas, C. N., Schmidt, C., et al., Re-covery, Recycle and Reuse of Industrial Wastes,James W. Patterson Industrial Waste Manage-ment Series (Chelsea, MI: Lewis Publishers, Inc.,1985).Office of Appropriate Technology, “Alternativesto the Land Disposal of Hazardous Wastes, An


13.

14.

15.

16.

17.

18.

19.

20.

Assessment for California, Toxic Waste Assess-ment Group, Governor’s Office of AppropriateTechnology (Sacramento, CA: 1981), p. 225.Oppelt, E. T., ‘‘Hazardous Waste Destruction,Environ. Sci. Technol. 20(4):312-318, 1986.Piasecki, B. (cd.), Beyond Dumping—New Strat-egies for Controlling Toxic Contamination (West-port, CT: Quorum Books, 1984).Royston, M. G., Pollution Prevention Pays (Ox-ford: Pergamon Press, 1979).Sorokin, D.J., et al., Cutting Chemical Wastes(New York: INFORM, 1985).Sutter, H., “Trends in the Incineration of Chlo-rinated Hydrocarbons At Sea, Mull and Abfall(Garbage and Waste), April 1984, pp. 89-93.U.S. Congress, Congressional Budget Office,Hazardous Waste Management: Recent Changesand Policy Alternatives (Washington, DC: U.S.Government Printing Office, 1985).U.S. Congress, Congressional Budget Office,“Empirical Analysis of U.S. Hazardous WasteGeneration, Management, and Regulatory Costs, ”draft staff working paper (Washington, DC: Oc-tober 1985).U.S. Congress, Office of Technology Assessment,‘‘Serious Reduction of Hazardous Waste for Pol-lution Prevention and Industrial Efficiency, ” inpress (Washington, DC: 1986).

21.

22.

23.

24.

25.

U.S. Congress, Office of Technology Assessment,“Wastes in Marine Environments, ” draft report(Washington, DC: 1986).U.S. Environmental Protection Agency, Office ofPolicy, Planning and Evaluation, “BackgroundReport II: Assessment of Emerging AlternativeTechnologies, Assessment of Incineration as aTreatment Method for Liquid Organic Hazard-ous Wastes (Washington, DC: March 1985).Walton, G. C., and Dobbs, D., “Biodegradationof Hazardous Materials in Spill Situations, Con-trol of Hazardous Material Spills (Nashville, TN:Vanderbilt University, 1980), pp. 23-45.Westat, Inc., National Survey of HazardousWaste Generators and Treatment, Storage andDisposal Facilities Regulated Under RCRA in1981, contract report prepared by S. Dietz, M.Emmet, R. DiGaetano, et al., for the U.S. Envi-ronmental Protection Agency, Office of SolidWaste (Rockville, MD: April 20, 1984).Westat, Inc., Used or Waste Oil and Waste De-rived Fuel Material Burner Questionnaire for1983, prepared for the U.S. Environmental Pro-tection Agency (Rockville, MD: 1984).

Chapter 5

Current Land-Based IncinerationTechnologies

Contents

PageTraditional Incineration Technologies. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 93

Liquid Injection Incineration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 93Rotary Kiln Incineration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 93Hearth Incineration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 96Fluidized Bed Incineration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 97

Other Incineration-Like Technologies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 98Pyrolysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 98Wet Air Oxidation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 98

Use of Air Pollution Control and Heat Recovery Equipment. . . . . . . . . . . . . . . . . . . . . . . . . . 98Air Pollution Control Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 98Energy Recovery Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 99

Profile of Existing Hazardous Waste Incinerators. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..100Number of Incineration Facilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ................100Location of Incineration Facilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ................101Incinerator Capacities and Operating Characteristics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .101

Chapter5 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .......................104

Tables

Table No. Page9. Two Estimates of the Number of Land-Based Incineration Units Operating

in the United States . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10010. Commercial Status of Land-Based Incineration Facilities, by EPA Region . ..........103

Figures

Figure No. Page3. Liquid Injection Incineration Technology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 954. Rotary Kiln Incineration Technology. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 955. Fluidized Bed Incineration Technology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 976. Wet Air Oxidation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 997. A Regional Profile of Land-Based Hazardous Waste Incineration Facilities:

Number of Facilities Located in Each State and EPA Region . . . . . ..................1028. A Profile of the Capacity of Land-Based Incinerators for Liquid Wastes . . . . . . . . . . ....103

Chapter 5

Current Land-Based IncinerationTechnologies

A variety of technologies are used to thermallydestroy hazardous wastes. In its strictest sense, in-cineration means the high-temperature destructionof wastes carried out in the presence of oxygen. Forpractical purposes, however, certain other thermaldestruction technologies that destroy wastes usinglittle or no oxygen (i.e., pyrolysis and starved airincineration) can be be grouped with incinerationtechnologies. 1 This section briefly describes the dis-

‘The destruction of hazardous wastes in boilers and furnaces (seech. 4) is a common practice that is only beginning to come under reg-ulation; however, under current regulations (46 FR 7666, Jan. 23,1981 ), these practices are distinguished from incineration becausewastes are burned in boilers and furnaces for the primary purposeof recovering their energy content, not for the purpose of destroyingthe wastes. EPA estimated that, in 1981, almost twice as much haz-ardous waste was burned in boilers and furnaces than was burnedin incinerators (4).

tinctive features of the various processes that ther-mally destroy hazardous wastes.

All waste incinerators have several common com-ponents: a waste feed system, a combustion air oroxygen system, a combustion chamber, combus-tion monitoring systems, and (where required) anair pollution control and ash removal system. Theactual applications of the various components varysomewhat in different designs. The following briefdescription of available incineration technologiesdiscusses each of these features.

T R A D I T I O N A L I N C I N E R A T I O N T E C H N O L O G I E S

Liquid Injection Incineration

Liquid injection incineration is, by far, the mostcommon incineration technology used on land (pri-marily onsite), and is the only technology beingused or considered for ocean incineration, As thename implies, liquid injection incineration can ac-commodate only freely flowing (pumpable) liquidor slurry wastes. When coupled with other typesof incinerator designs, this technology serves as asecondary chamber (afterburner) for volatilizedconstituents produced by the primary incinerator.

Liquid injection incinerators are designed withalmost no moving parts and are almost exclusivelysingle-chamber units. (Figure 3 depicts in schematicform a typical liquid injection incinerator. ) Wastesare typically injected into the combustion cham-ber after being atomized (i.e., broken up into veryfine droplets) by passage through a nozzle or rotat-ing cup located in or near the burner. A forced airdraft system supplies the oxygen required for com-bustion and also provides turbulence to aid in mix-

ing. The combustion chamber itself is typically arefractory-lined (heat-resistant) cylinder, which canbe mounted either vertically or horizontally.

Combustion gases are vented directly to theatmosphere, if they comply with air pollution reg-ulations for incinerators. If halogenated wastes areburned, scrubbers capable of removing acid gasesmay be required. Incineration of liquids usually re-sults only in very low particulate emissions and,therefore, does not usually require particulateremoval equipment.

Rotary Kiln Incineration

Rotary kiln incineration is the technology mostcommonly used by major commercial land-basedfacilities and is the third most common incinera-tor design in the United States. Rotary kilns canaccommodate a wide range of solid and sludgewastes, including dry flowable granular wastes, con-tainerized wastes, nonpumpable slurries, and semi-solids. Rotary kilns are generally equipped with sec-

93


Photo credit: E.T. Oppelt, Hazardous Waste Engineering Laboratory, US. Environmental Protection Agency

Liquid injection incineration, the most common incineration technology in the United States, is typically used bywaste generators to destroy their own liquid wastes onsite. It is the only technology being used or considered

at this time for ocean incineration.

ondary combustion chambers (afterburners) to of rotary kiln technology are significantly higherincrease the length of time during which wastes are than those of liquid injection systems.subjected to the high temperatures necessary to en-

The combustion chamber of a rotary kiln inciner-sure complete destruction.ator consists of a slowly rotating, refractory-lined

The major commercial facilities operate large ro- cylinder mounted at a slight incline to aid gravitytary kilns, coupled with liquid injection units to ac- feed of wastes. (Figure 4 is a schematic represen-commodate liquid wastes. Rotary kiln technology tation of a typical rotary kiln incinerator. ) Solid andis not currently applicable to at-sea operation, nor sludge wastes enter at its high end, and liquidis it likely to be in the foreseeable future, because wastes or auxiliary fuel are introduced as neededof design and spatial constraints. The capital costs through nozzles. Ash moves to the low end of the

Ch. 5—Current Land-Based Incineration Technologies Ž 95

Water -

treatment

for the Office of Technology Assessment (Cambridge, MA: May 1986).

Figure 4.-Rotary Kiln Incineration Technology

Drummed hazardous wasteSOURCE: Arthur D. Little, Inc., Overview of Ocean Incineration, prepared by J.R. Ehrenfeld, D. Shooter, F. Ianazzi, and A. Glazer for the Office of Technology Assessment

(Cambridge, MA: May 1986).

% • Ocean Incineration: Its Role in Managing Hazardous Waste

I

Photo credit: E.T. Oppelt, Hazardous Waste Engineering Laboratory, EPA

Rotary kiln incineration can destroy a wide range ofhazardous wastes—solids, sludges, and liquids—and

is the technology most frequently usedat commercial facilities.

kiln, where it can be removed for disposal. Afterbeing volatilized and partially destroyed in the pri-mary chamber, gases are directed to the second-ary chamber to complete the destruction process.

Incinerating solid wastes creates appreciable ashresidues and particulate, so rotary kilns are typi-cally equipped with stack scrubbers to clean fluegases.

Hearth Incineration

Hearth incineration, which is the second mostcommon design in the United States, is employedprimarily to burn wastes onsite. Hearth incinera-tors are designed to burn waste in solid and sludge

Photo credit: Trade Waste Incineration/Air Pollution Control Association

Fixed hearth incinerators are commonly used to burnsolids and sludges at the site of generation. Thisparticular facility has been equipped with liquid

injection equipment to allow the incinerationof liquid hazardous wastes as well.

form, but they can also be equipped with liquid in-jection capability.

Wastes are introduced onto a platform (hearth)in the bottom of the combustion chamber. Bothfixed- and multiple-hearth designs are in use.Multiple-hearth designs, in which wastes are con-veyed from chamber to chamber, are especially use-ful for burning complex wastes that need to be ex-posed to high temperatures for long periods.Incineration in fixed hearth units can occur underconditions of excess air or starved air (pyrolytic)conditions. Pyrolytic systems are generally accom-panied by excess-air afterburners.

Although air flow over the waste mass can becontrolled to limit the amount of particulate mat-ter in the exhaust gases, scrubbers are often nec-essary to comply with air pollution regulations.

Ch. 5—Current Land-Based Incineration Technologies ● 97

Fluidized Bed Incineration

Fluidized bed incineration uses a layer of smallparticles (e. g., sand) suspended in an upward flow-ing stream of air. (Figure 5 schematically illustratesa fluidized bed incinerator. ) The particles behavemuch like a fluid (hence, the name). Wastes (andauxiliary fuel, if needed) are mixed into the sus-pended bed and combusted. Fluidized bed inciner-ators were developed primarily to accommodatehighly viscous liquids and sludges not easily burnedin more conventional types of incinerators.

Combustion gases from this type of incinerationtypically contain high levels of particulate and,therefore, must be scrubbed before release to theatmosphere.

Photo credit: GA Technologies, Inc.

Fluidized bed incinerators can destroy liquids andsludges that are not easily handled by more

conventional incinerator technologies,

Figure 5.— Fluidized Bed Incineration Technology

/

ParticulateS o l i d f e e d removal

Waste feed pump\

recycle Trampmaterial

Recycled bed material return

Bed material

Bedmakeup

Stack

Fan

SOURCE: Arthur D. Little, Inc., Overview of Ocean /nc/nerat/on, prepared by J.R. Ehrenfeld, D. Shooter, F. Ianazzi, and A. Glazer for the Office of Tech.nology Assessment (Cambridge, MA: May 19S6).

98 . Ocean /incineration: Its Role in Managing Hazardous Waste

Several other incinerator designs are currently ing ammunition and explosives, drum burners, andin operation. These include fume incinerators (typi- combination systems (e. g., a hearth connected tocally with liquid waste incineration capability) for a liquid injection unit).burning gaseous wastes, incinerators for destroy-

O T H E R I N C I N E R A T I O N - L I K E T E C H N O L O G I E S

In addition to the traditional incineration tech-nologies, two incineration-like technologies for de-stroying wastes are currently in use.

Pyrolysis

Pyrolysis refers to technologies that accomplishthermal destruction in an oxygen-deficient atmos-phere. Pyrolysis equipment is similar to conven-tional incineration technologies, with the obviousexception that it lacks a system for introducing airinto the combustion chamber. Organic waste com-pounds are volatilized and partially decomposed bythermal reactions alone. Gases from the pyrolyticchamber then pass into a conventional chamberwhere they are combusted in the presence of ex-cess air. One advantage of pyrolytic technologiesis that emissions of particulate tend to be lowerthan do those from more traditional incinerators(8).

Three pyrolysisthe United States,(l).

units are currently operating inand several others are planned

Wet Air Oxidation

Wet air oxidation is a thermal destruction tech-nology that oxidizes organic contaminants in water.The water modifies oxidation reactions so that theycan occur at relatively low temperatures (3500 to650° F). Air is bubbled through the liquid phase,and the reactor vessel is maintained at a pressurehigh enough to prevent excessive evaporation (8).

Wet air oxidation is primarily applicable to aque-ous waste contaminated with dissolved or sus-pended organic material. The organic content ofwastes suitable for wet air oxidation is generally toolow to make traditional incineration economical,but sufficiently high to sustain the reaction tem-peratures needed for oxidation. The technology hasbeen used successfully to treat a variety of aque-ous wastes contaminated with nonhalogenated or-ganic compounds, but it has been much less suc-cessful with halogenated compounds. Moreover, asecondary process is typically needed, because de-toxification is incomplete (40 to 95 percent).

Figure 6 depicts a typical wet air oxidation sys-tem. Several units are currently operating in theUnited States.

U S E O F A I R P O L L U T I O N C O N T R O L A N D

H E A T R E C O V E R Y E Q U I P M E N T

Equipment serving either of two additional func-tions can be (or is required to be) added to the basicsystems described above. Such equipment includesdevices to control the emission of air pollutants anddevices to recover and use a portion of the energyreleased through incineration. 2

‘This discussion is drawn primarily from refs. 1 and 3; these sourcesshould be consulted for additional information,

Air Pollution Control EquipmentAir pollution control equipment is often required

for land-based incinerators, particularly if wasteswith significant ash or halogen content are to beincinerated. Such equipment consists of two com-ponents. The first is a quench chamber or heat ex-changer to cool the gases leaving the combustionchamber. The cooling is necessary for efficient oper-ation of air pollution controls located downstream.

Ch. 5—Current Land-Based /incineration Technologies • 99

Figure 6.— Wet Air Oxidation

Feed tank 1

Heat exchanger

LOW pressure High pressurefeed feed pump

ICompressed

air

Heat exchanger2

Reactor

* Off-gas

~ Oxidized& 1 a liquor

Cooler PressureCooling

Separatorcontrol

water release

SOURCE: Arthur D. Little, Inc., Ovendew of Ocean /nc/neration, prepared by JR, Ehrenfeld, D. Shooter, F. Ianazzi, and A. Glazer for the Office ofTechnology Assessment (Cambridge, MA: May 1986).

The second component includes one or morescrubbers for actually cleaning the gases. Majorcommercial incineration facilities typically removeparticulate by using wet or dry electrostatic precipi-tators, venturi scrubbers, or, less commonly, fab-ric filters. Removal of gaseous pollutants, includ-ing corrosive acid gases, usually requires a wetscrubber, which neutralizes gases through contactwith an alkaline liquid reagent. Operation of a wetscrubber requires installation of a mist eliminatordownstream, to separate the flue gases from waterdroplets containing contaminants. (For a fuller dis-cussion of scrubbers, see app. B in ref. 6.)

Both particulate and gaseous pollutant removalsystems generate waste sludges that, along with ashresidues, are typically handled as hazardous wastesand disposed of in hazardous waste landfills.

Energy Recovery Equipment

Energy recovery equipment is not required un-der current regulations but is sometimes installed

on hazardous waste incinerators if it is deemed eco-nomically feasible and advantageous. Such equip-ment generally can only be installed upstream fromair pollution control equipment, that is, prior toremoval of corrosive gases or particulate. Inciner-ation of wastes generating these products may dam-age or interfere with the operation of energy re-covery equipment and, therefore, often precludesits use. Certain modifications have recently beenintroduced to partially alleviate these design re-strictions.

Energy is generally recovered through the pro-duction of steam, which can be used to generateelectricity, to drive machinery, or to provide heat.Alternatively, energy can be used to heat the airfed to the incinerator, thereby increasing combus-tion efficiency and reducing the need for auxiliaryfuel.

Typical energy recovery equipment consists ofwatertube or firetube boilers capable of recovering60 to 80 percent of the heat content of combustiongases.


P R O F I L E O F E X I S T I N G H A Z A R D O U S W A S T E I N C I N E R A T O R S

This section, which is drawn largely from EPAdocuments, summarizes available information onthe number, capacity, and characteristics of exist-ing land-based hazardous waste incinerators. OTAhas found that these data are incomplete and onlyprovide rough estimates, even of seemingly straight-forward statistics, such as the number of permittedhazardous waste incineration facilities currentlyoperating in the United States. No reliable nationaldatabase containing such information currently ex-ists. Moreover, the number and permit status ofincineration facilities is constantly changing, as per-mits are processed or facilities open or shut downin response to various regulatory or economic,

factors.

Despite these deficiencies, data derived from sev-eral sources can be used to develop a profile of ex-isting facilities.

Number of Incineration Facilities

EPA has estimated that about 240 to 275 oper-ating hazardous waste incineration facilities existin the United States.3 This estimate emerged fromseveral independent studies, including those basedI

‘This estimate excludes industrial boilers and furnaces, which arenot considered incinerators under current regulations. These facilities,are numerous in the United States, and they currently account forthe destmction of substantially more hazardous waste than do inciner-ators (see ch. 4).

on the Westat national survey (10), interviews withincineration manufacturers, a survey of RCRAPart A permit applicants listed in the EPA Haz-ardous Waste Data Management System, and datafrom EPA Regional Office permit files.

As of July 1982, EPA had identified 271 hazard-ous waste incineration facilities using 352 opera-tional incineration units (3). Based on 1985 per-mit data, however, this estimate was reviseddownward, to about 240 facilities using about 310incineration units (5). The reduction in partreflected the fact that some facilities ceased opera-tions instead of securing final Part B RCRApermits.4

Table 9 presents two estimates of the number ofincinerators of each design that were in use in 1981(3). One estimate (shown in column A) was derivedfrom interviews with incinerator manufacturers re-garding the number and type of units sold in theUnited States. The other (column B) was extrapo-lated from partial data obtained from applicationsfor RCRA Part A permits. These estimates gener-ally agree regarding liquid injection and hearth in-

*Complicating matters further, OTA recently obtained a computerprintout from the Hazardous Waste Data Management System of in-cinerator facilities that had submitted permit applications as of May1986. This source listed a total of 274 incineration facilities with pend-ing applications, but it did not provide any information concerningincinerator design or commercial status. In this discussion, the datafrom this source will be used as the most current available data.

Table 9.—Two Estimates of the Number of Land-Based incineration UnitsOperating in the United States

Estimate Aa Estimate Bb

Number Percent Number Percentof units of total of units of total

Liquid injection . . . . . . . . . . . . . . . . . . . . . 219 650/o 213 61 ‘/0

Hearth (total) . . . . . . . . . . . . . . . . . . . . . . . 70 21 75 21Hearth (with liquid capacity). . . . . . . . — — (44) –Hearth (solids only) . . . . . . . . . . . . . . . – — (31) –

Rotary kiln (total) . . . . . . . . . . . . . . . . . . . 37 11 17Rotary kiln (with liquid capacity) . . . . – — (15) 5Rotary kiln (solids only) . . . . . . . . . . . . — (2) –

Fluidized bed. . . . . . . . . . . . . . . . . . . . . . . 9 3 5 1Other or unspecified . . . . . . . . . . . . . . . . — — 42 12

Total . . . . . . . . . . . . . . . . . . . . . . . . . . . . 335 352%etlmate A is derived from interviews with incinerator manufacturers regarding the number and type of units sold in the United!3atea.

bE9timate B ia b~&j on extrapolation from partial data obtained from RCRA part A Permit applicant.

SOURCE: E. Keitz, G. Vogel, R. Holberger, et al., A Profile of Ex/st/ng Hazardous Waste Inchreratlorr FacH/ties and h4anufac-turera in the Un/ted States, EPA No. S00/2-84452, prepared for the U.S. Environmental Protection Agency, Officeof Research and Development (VWahington, DC: 19S4).

Ch 5—Current Land-Based Incineration Technologies • 101

cinerators but differ significantly regarding rotarykilns. (Note that these estimates were derived from1981 data; the total number of units has changedsince 1981, but revised data for the distributionamong different designs are not available. )

The data from Estimate B in table 9 indicate thatalmost 80 percent of hazardous waste incineratorshave some capacity for burning liquid wastes.

Data on the use and nature of air pollution con-trol equipment on land-based incinerators arescant. Based on data obtained from applicants forRCRA Part A permits, EPA (3) estimated thatabout 45 percent of existing incinerators have someform of air pollution control equipment. About 37percent of existing units use some type of scrub-ber. Large incinerators and those employing highertemperatures and longer residence times were morelikely to have air pollution control equipment.

EPA (3) also found that only about 22 percentof existing incinerators used energy recoveryequipment. Energy recovery equipment is morecommonly found on incinerators burning liquids,on larger incinerators, and on incinerators oper-ating on a continuous basis.

Only six incineration facilities are currently per-mitted to incinerate PCBs, as provided under theToxic Substances Control Act. See box B in chap-ter 3 for a more detailed discussion of PCB in-cineration.

Location of Incineration Facilities

This section considers both the regional distri-bution and the commercial status (i.e., onsite versusoffsite) of existing incineration facilities. For the 274facilities for which data were available, figure 7 in-dicates the number of facilities located in each Stateand EPA Region. Table 10 presents the commer-cial status of the 227 facilities whose status was in-dicated in reference 3.

Several conclusions can be drawn from these dataon regional distribution. First, as was true for in-cinerable waste generation, the distribution of haz-ardous waste incinerators is concentrated in par-ticular States and regions. (For example, as shownin figure 7, EPA Regions V and VI each containabout one-fifth of all facilities. Texas alone accountsfor almost one-eighth of all facilities. ) Second, the

Northwestern United States, in general, containsfew incineration facilities, and EPA Region VIIIcontains no commercial facilities. Finally, the greatmajority (80 percent) of existing hazardous wasteincinerators are private facilities located onsite. Nocorrelation is apparent between onsite or offsite in-cineration and regional distribution.

EPA also examined the sources of waste burnedby the incinerators covered in its survey. Of therespondents, 77 percent identified waste they in-cinerated as having been generated onsite. Of the23 percent that reported handling waste generatedoffsite, 90 percent were commercial incinerators (3).

Incinerator Capacities and OperatingCharacteristics

Existing incinerators have been further charac-terized with respect to their capacity for liquid andsolid wastes and the temperatures and residencetimes attained under typical operating conditions.

Capacity

For 180 of the incinerators surveyed by EPA (3),capacity for liquid wastes was specified. Figure 8shows the range of capacities.

According to these data, the capacities of two-thirds of existing incinerators for liquid wastes arebelow 300 gal/hr (2,500 lbs/hr). The median ca-pacity for liquid wastes is 150 gal/hr (1 ,250 lbs/hr).Similar data for incinerators burning solid wastesrevealed a median capacity of less than 80 gal/hr(650 lbs/hr), or about half of the median for liq-uids. Assuming that the facilities were operated atan average of 55 percent capacity, as estimated byEPA (9), the median capacities would translate intoannual throughputs of about 1,400 metric tons forsolid wastes and 3,000 metric tons for liquids.

These data can be compared to the burning ratefor liquid wastes incinerated at sea. Each of the in-cinerators on the Vulcanus ships has a capacity ofabout 1,650 gal/hr, or about 11 times the medianfor land-based incinerators. The Apollo ships aredesigned to have an even greater capacity, about2,750 gal/hr per incinerator (7). Only 2 percent ofall land-based incinerators have a reported capac-ity greater than 2,000 gal/hr, and about 4 percenthave capacity greater than 1,000 gal/hr.


Figure 7.—A Regional Profile of Land-Based Hazardous WasteLocated in Each State and EPA Region

Incineration Facilities:(Total of 274 facilities)

Number of Facilities

2 ( D E )

10 (MD)

ISOURCE: Data based on a commter rxlntout from the Hazardous Waate Data Management System of incinerator facilities that had submitted Dermit atmlications aa. ..

of May 19S6.

The large commercial rotary kiln incinerators inuse today have annual throughputs of about 20,000to 35,000 metric tons of mixed wastes,5 whereasexisting ocean incineration vessels could each burn50,000 to 100,000 metric tons of liquid wastes an-nually (refs. 2,9; and data from incineration ves-sel owners).

Combustion Zone Temperature andResidence Time

According to EPA (3), the average combustionzone temperature in those incinerators for which

5If these incinerators were to burn only liquid wastes, the capacitywould be considerably higher.

data were available was 1,820 + 2250 F (993 +1070 C). For liquid injection incinerators, the aver-age was slightly higher, 1,857 + 224° F (1 ,014 +1070 C). In both cases, the median temperaturewas about 1,8000 F. Liquid injection incineratorsgenerally operate at higher temperatures than dorotary kilns, because the former do not require asmuch excess air to atomize and combust liquidwastes.

With respect to residence time, EPA data indi-cate that about half of the incinerators for whichdata were provided had residence times of 2 secondsor longer, and only about 15 percent had residencetimes under 1 second, Liquid injection incinera-tors had a similar distribution.

Chapter 6Ocean Incineration Technology

Contents

PageExisting and Planned Vessels . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... , ..107

Wastestream Characteristics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .........................109

Infrastructure and Logistical Support Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .......109No-Infrastructure System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .......................109Existing Infrastructure System . . . . . . . . . . . . . . . . . . . . . ., . . . . . . . . . . . . . . . . . . . ........109Integrated System. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..........................,..109

Technical Comparison of Designs for Ocean Incineration. . . . .....................,.,.110Containerization Versus Bulk Storage and Transfer . . . . . . ..........................110Self-Propelled Versus Barge Vessels . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..............113Seawater Scrubbers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ............................114Combustion Chambers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..................,......115Burner Types . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..., .. ....115

Chapter6 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .......................116

Table

Table No. Page11. Characteristics of Existing and Proposed Incineration Ships . ......................108

Chapter 6

Ocean Incineration Technology

E X I S T I N G A N D P L A N N E D V E S S E L S

Ocean incineration technology has been used on cinerate only liquid organic wastestreams. Tablea much smaller scale than has land-based inciner- 11 summarizes relevant data for all existing, under-ation or any other major technology for managing construction, and planned incineration vessels. Ofhazardous wastes. Two incineration vessels are cur- these, the only foreign-owned vessel is the Germanrently operating, primarily in Europe; 1 two moreare fully or partially built but not yet employed;and plans for constructing others have been offeredby several companies. The combined waste han-dling capacity of all of these vessels could accom-modate only a small portion of the hazardous wastegenerated in the United States.

Vesta, which operates in the North Sea.

Although all of these vessels share features in-tended to respond to the unique needs and con-straints of ocean incineration, they differ in sev-eral important respects. This chapter examinesocean incineration technology and wastestreams,as well as associated aspects of operations, such as

Generally speaking, a single technology has been requirements for port facilities. The chapter alsoused or proposed for ocean incineration. All exist- compares and contrasts the various existing anding or planned ocean incineration vessels use liq- proposed technologies for ocean incineration. Foruid injection technology, and are intended to in- a comparison of land-based and ocean incineration

‘The two vessels are the Vulcan us 11 and the Vesta; the Vulcan ustechnologies, see chapter 7.

1 is operational but not currently active.

Photo credjt: At6ea Incineration, Inc.

The Ape//o / incinerator ship, launched in 1985 but never used for incineration of hazardous wastes.

107

Table Il.-Characteristics of Existing and Proposed incineration Ships

Cargo mode . . . . . . . . . . . . . . . . . . . . .. ..8 tanks below 8 tanks belowdeck deck

Completed

Incinerator shiptype II

2

Vertical

Air nozzle

12 tanks belowdeck

1,3005,5009.9—

Oceangoing barge Small supply shipand tug type I type II

4 1

Horizontal Horizontal

Operating inEurope

Rotary cup

9 tanks belowdeck

Required infrastructure. . . . . . . . . . . . . . . Existing Existing Integrated Integrated None None Existing~acoma Boat is currently reorganizing under Federal Bankruptcy Laws; At-Sea Incineration, Inc., defaulted on payment of guaranteed loans initially granted and recently paid off by the U.S. Maritime Administration.bType 11 ~hemical tankers must have d~uble hulls and double bottoms, and must store wastes in several different compartments to reduce cargo IOSS in the event Of an accident. Design standards fOr type

I vessels include these and additional requirements. The oroDosed Ocean Incineration Regulation (50 FR 8225, Feb. 28, 1985) and U.S. Coast Guard regulations (46 CFR 172) reouire that incineration vesselsbe at a minimum type Il.

. . . .

SOURCE: U.S. Environmental Protection Agency, Office of Policy, Planning and Evaluation, “Background Report 1: Description of Incineration Technology,” Assessment of /incineration as a Treatment for LiquidOrgan/c Hazardous Wastes (Washington, DC: 1985); and W. Lankes, “lncineratlon At Sea: Experience Gained With the M/T Vesta,” in Wastes in the Ocean, vol. 5, D,R. Kester, et al, (eds.) (New York:John Wiley &. Sons, 1985), pp. 115-124,

Ch. 6—Ocean Incineration Technologies. 109

W A S T E S T R E A M C H A R A C T E R I S T I C S

Typical liquid hazardous wastestreams are com-plex mixtures of many chemical compounds. Forocean incineration in particular, most shiploads areexpected to consist of heterogeneous mixtures de-rived from several or many sources and processes.Wastestreams are usually characterized with respectto a number of parameters. The viscosity of thewaste must be sufficiently low to allow it to bepumped and introduced into the incinerator insmall droplets. The heating value (i. e., energy con-tent) of the waste feed must be sufficiently high toheat incoming waste to its ignition temperature, to

provide the energy needed for oxidation, and tomaintain combustion. The heating value of a wastegenerally decreases as water content increases andas the proportion (percent by weight) of chlorinepresent in organic compounds increases. Therefore,liquid wastes are usually blended to produce opti-mum values for energy content, chlorine and watercontent, and viscosity. Virtually all wastes, evenrelatively homogeneous ones, require some blend-ing before incineration to ensure proper consistencyand flow.

I N F R A S T R U C T U R E A N D L O G I S T I C A L S U P P O R T S Y S T E M S

The various ocean incineration vessels differ inhow much they rely on waste preparation, storage,handling, and transfer facilities on shore. Threegeneral categories of logistical systems have beenidentified (7,8).

No-Infrastructure System

Under this system, waste handlers make mini-mal use of fixed facilities. Wastes accumulate wherethey are generated or handled, stored in truck orrail tanks or in portable containers. When full, thetanks or containers are transported to existing porttransfer facilities not dedicated solely to ocean incin-eration operations. Wastes are pumped or are liftedin containers onto the vessel. Any blending ofwastes from different sources occurs only on board,as they are fed to the incinerator. Wastes fromdifferent storage tanks are fed sequentially or simul-taneously, to provide the best burning mixture.

SeaBurn, Inc., and Environmental OceanicServices Corp. plan to use a variant of this design.They would use the sealed 5,000-gallon stainlesssteel intermodal containers (see discussion of con-tainerization below) to transport wastes from theirsources to the the vessel, avoiding the need for anydockside handling of uncontainerized wastes.

Existing Infrastructure System

Under this system, waste handlers use port fa-cilities not dedicated solely to ocean incineration.Blending, preparation, and storage functions arecarried out at existing, centralized facilities that areentirely separate from the port facility.

Waste Management, Inc., plans to employ sucha system (or to develop an integrated system; seebelow) to support Vulcanus operations in the Gulf.Under the existing system, liquid wastes would betransported from generators to its testing, blend-ing, and storage facility at Emelle, Alabama.Blended wastes would be loaded onto trucks fortransport to dockside, and then pumped directlyfrom the trucks to the vessel.

Integrated System

Under this system, waste handlers use special-ized port facilities designed primarily for ocean in-cineration. The facility receives wastes directly fromgenerators and maintains onsite testing, blending,and storage capability for both containerized andtanked wastes.

At-Sea Incineration, Inc., proposed using suchan integrated port facility to support operation ofits Apollo vessels. Waste Management, Inc., is con-sidering developing such a facility, in lieu of or inaddition to its existing facility at Emelle, Alabama.


T E C H N I C A L C O M P A R I S O N O F D E S I G N S F O R

O C E A N I N C I N E R A T I O N

One major theme of the debate over ocean in-cineration is whether a best-available-technology

(BAT) approach is needed or desirable and, if so,whether existing vessels represent BAT (see ch. 2).The various designs for ocean incineration vesselsdiffer in several respects that directly bear on thenature and potential safety of their operations. TheEnvironmental Protection Agency has not yet thor-oughly evaluated the various designs; such anevaluation must be undertaken if the BAT ques-tion is to be resolved.

Given its limited mandate in this study, OTAhas not attempted to develop a comprehensive com-parative evaluation. Rather, the following discus-

i sion identifies particular design and performancefeatures that would probably be central issues insuch a comparison. By reference to table 11, thespecific vessels to which this discussion applies canbe identified.

Containerization Versus Bulk Storageand Transfer

The most obvious difference between existingI and proposed designs for ocean incineration sys-

tems is how cargo is handled and transferred. Twocompanies have proposed systems based on a con-tainership concept that would employ 5,000-gallonstainless steel intermodal tank containers. Inter-modal (IM) containers are increasingly used for alltypes of cargo throughout the world. An estimated20,000 IM tank containers designed specifically tocarry liquid commodities are in use worldwide (3).As the name implies, IM containers can be trans-ported via rail, truck, barge, and ship. Standard-ized twistlock mechanisms on containers and on ve-hicle chassis are designed to ensure that containersare adequately secured during transport.

In specifically applying the containership con-cept to ocean incineration, waste generators or han-dlers would fill and seal tank containers and wouldtransport them by truck or rail to port facilities forloading onto barges or ships. No blending or otherhandling of waste would occur at the ports. IM tankcontainers would be mounted on or above deck andtheir wastes individually pumped to a feed tank

directly connected to the incinerator. Followingcleaning, tank containers would be returned togenerators for further use.

The containership concept differs from existingocean incineration systems, which use more con-ventional tank trucks and tank farms for land trans-portation and storage, and large bulk tanks (about100,000 gallons each) to hold waste onboard thevessels. As described above, waste blending andtransfer facilities on land are an essential link insuch systems.

The relative advantages and disadvantages ofthese two approaches need to be evaluated for allphases of incineration operations, beginning withwaste generators and ending with handling duringand after shipboard incineration. Advantages anddisadvantages of IM containers are discussed be-low, for each of several phases of incinerator oper-ation: land transportation, handling, and transfer;marine transportation; and waste incineration.First, however, the reader must recognize severalassumptions that apply to this analysis.

In the following discussion of advantages and dis-advantages, the intermodal approach is implicitlycompared with the more conventional bulk han-dling system used by all existing incineration ves-sels. It is important to recognize that particular fea-tures of an individual company’s operation maygreatly affect the extent to which these advantagesor disadvantages are applicable. The discussion istherefore oriented towards a ‘ ‘generic’ operation,and wherever possible, relevant information spe-cific to a particular operation is also presented.

In addition, both the bulk and intermodal tankapproaches to handling hazardous cargoes are al-ready widely used. The U.S. Coast Guard believesthat both approaches can be, and are being, car-ried out safely under appropriate regulation. TheCoast Guard has further indicated that solutionsare available to the problems that are identified be-low, and can be addressed through proper regula-tion, thereby rendering both approaches fully via-ble.2

The intent of the discussion, therefore, will‘These comments were received through the review of a draft of

this report by the U.S. Coast Guard.

Ch. 6—Ocean Incineration Technologies ● 111

Photo credit: SeaBurn, Inc.

Stainless steel intermodal tank containers, which typically carry about 5,000 gallons, can be transported via rail, truck,barge, or ship. The supporting framework reduces the risk of breaching the tank in the event of an accident and provides

for securing of the tank to specially designed chassis during transport.

be to point out features of each approach that areadvantageous or that may require additional reg-ulation in order to ensure safe operation.

Land Transportation, Handling, and Transfer

Advantages:

● Tank containers are sealed at the site of gen-eration and before any transportation, so thatwastes do not need to be transferred later onland or at the port.

● The intermodal nature provides for flexibil-ity in transport, because IM tank containerscan travel to port facilities by truck, rail, orbarge. -

● No special facilities are required at the port,and individual IM tank containers can bestored still attached to their chassis while await-ing the arrival of the incineration vessel,facilitating their movement in the event of anemergency.

●

●

●

The IM tank container is encased in a rigidmetal protective frame that substantially re-duces the risk of breaching the tank in theevent of a rail, highway, or terminal accident.A large and growing international network forhandling and transporting IM containers isavailable.Wastes from different generators are notmixed or blended before they are incinerated,allowing the identity and source of a waste tobe traced in the event of a spill.

Disadvantages. —Although there appear to beseveral clear advantages with respect to the IM tankcontainer itself, transport of these containers, par-ticularly by truck, poses several problems. 3 Theseproblems are related primarily to the fact that thereis an insufficient number of chassis designed to—.-. -— —..-

3Another OTA assessment (9) examines hazardous materials trans-portation in detail and evaluates the relative safety, performance, andregulation of intermodal and other bulk liquid containers. Much ofthe discussion of land transportation using IM tank containers pre-sented here is drawn from that analysis.


transport IM tank containers in a manner that max-imizes over-the-road stability and complies withbridge laws that limit the vehicle weight per axleand

●

●

●

per wheelbase.

The chassis most commonly used today thatis designed specifically to carry IM containersis 20 feet in length and equipped with cornertwistlocks; however, for most liquids, a fullyloaded IM tank container mounted on sucha chassis violates bridge laws in most States.The option of partially filling the tank is notviable, since it can lead to sloshing of the liq-uid contents and instability on the road. Useof a 40-foot chassis with the IM tank containercentrally mounted using twistlocks solves theseproblems; however, the number of such chassis(estimated to be only about 400 in the entireUnited States) is far less than the number ofIM tank containers currently in use.The size, shape, and height of IM tank con-tainers are such that, even when mounted le-gally on the standard 20- or 40-foot chassis,they can be inherently unstable: the high cen-ter of gravity greatly increases the potential forroll-over. A specially designed IM chassiscalled a “low boy’ addresses this concern, andis widely used in Europe, but fewer than 100of these chassis (40-foot, center-mount, andlow boy) are in use in the United States.Although the number of standard 20-foot chas-sis possessing twistlock mechanisms is suffi-cient to accommodate the IM tank containerscurrently in use in the United States, their useon the highway violates bridge laws in manyStates. This situation commonly results in thetransport of IM tank containers on flatbedtrucks, ‘‘secured’ by wrapping with chains.This practice is entirely legal under currentDepartment of Transportation regulations,even though it has been denounced by sometrucking industry representatives and has re-sulted in a number of accidents involving haz-ardous materials (for example, see ref. 2).

These problems appear to have a straightforwardtechnical solution: required use of 40-foot low boychassis for over-the-road transport of loaded IMtank containers. Indeed, SeaBurn, Inc., has indi-cated that it plans to use the 40-foot low boy chas-sis. SeaBurn intends to have a sufficient number

of these chassis manufactured to support its oper-ation, and to dedicate these chassis exclusively tosuch use in order to preclude unauthorized meth-ods of handling its IM tank containers.

Marine Transportation

The containership concept appears to offer sev-eral advantages over bulk transport in the marinetransportation phase of ocean incineration. The ad-vantages include the following:

●

●

●

The relatively small volume of waste in eachcontainer should limit the size of a spill in theevent of an accident. Many individual tankcontainers would have to rupture to approachthe size of a release that could be expected fromthe rupture of one large bulk cargo tank.Because individual IM tank containers couldbe relatively easily salvaged, they would fa-cilitate the retrieval of waste lost overboard.IM tank containers would be stowed abovedeck, and hence above water line. In addition,an on-deck spill collection system will be uti-lized, These features would facilitate inspec-tion and leak detection and would reduce thelikelihood that leaks would contaminate bilgewater or the marine environment. The greaterventilation above deck would reduce the pos-sibility of explosions caused by buildup of reac-tive gases.

Waste Incineration

In contrast to the advantages of using IM tankcontainers with respect to marine transportation,their use may pose significant disadvantages rela-tive to bulk storage when considering the inciner-ation operation itself. These disadvantages are allrelated to the large number of individual tanks in-volved:

● Because wastes are not blended before beingloaded onto the vessel, a potentially enormousburden of waste analysis maybe involved. Un-der the proposed Ocean Incineration Regu-lation, separate sampling and analysis will berequired for each of the many individual tanks,before they are accepted by the permittee andagain before they are incinerated. Verificationby EPA that only permissible wastes are ac-cepted for ocean incineration will becomeequally burdensome.

Ch. 6—Ocean /incineration Technologies ● 113

● The potential exists for incompatible wastesto come into contact when tank containers areswitched. Accurate information regarding thecontents of each container and constant con-trol over the sequence in which tank containersare connected for pumping to the incineratorwill be essential, to a much greater degree thanwould be required of the bulk storage ap-proach.

● The reduction in the need for waste handlingon land offered by the IM mode is reversedduring the incineration operation itself. Fre-quent container switching (on the order ofevery few hours) will be required, increasingthe potential for spills or exposure of the crewto waste materials.

● Whether and how the frequent switching ofcontainers would affect incinerator perform-ance or necessitate greater surveillance has notbeen adequately investigated. For example,ensuring consistency in waste destruction effi-ciency when switching from a high-energywaste to a low-energy waste would probablyrequire adjustments in waste feed rate, use ofauxiliary fuel, air flow, and other parameters.

Despite the clear differences between the bulkand containerized modes with regard to handlingand incineration, the proposed Ocean IncinerationRegulation contains no provisions specifically ad-dressing containerized wastes. Provisions govern-ing tank containers have been developed interna-tionally and are incorporated into the LondonDumping Convention’s Technical Guidelines forOcean Incineration.

Again, it is important to acknowledge that tech-nical and regulatory solutions exist, or can bedeveloped, to address the potential problems asso-ciated with both the bulk and containerized ap-proaches, and to provide for their use to full advan-tage. The above discussion is intended to highlightareas where further attention may well be needed,rather than to detract from the merits of either ap-proach. Based on OTA’s limited analysis of thecontainership concept in relation to bulk transport,further study will be necessary to determine whethereither approach provides a clearly superior tech-nology for waste handling.

Self-Propelled Versus Barge Vessels

One company has proposed using an ocean-going barge-tug combination for ocean incinera-tion. A total of one hundred and forty-four 5,000 -gallon IM tank containers and up to four inciner-ators would be mounted on the barge. Such a ves-sel would have a shallow draft, which would allowit access to virtually any port facility.

Concerns have been raised about the relativesafety and maneuverability of a barge system. Un-fortunately, data that can be used to evaluate thesafety of the type of ocean-going barge proposedfor use in ocean incineration are largely unavail-able. The U.S. Coast Guard maintains a databasethat records all reported hazardous materials spillsto U.S. waters (10). Data for 1982 and 1983 indi-cate an accident rate for tank barges double thatfor tank ships. These data include barges of all typesused to carry oil or hazardous substances, however,including those operating on rivers or other inlandwaters. Indeed, with respect to both the numberof accidents and the quantities of material released,the vast majority involved oil released to inlandwaters. For spills involving hazardous substancesrather than oil, the number of releases was two-fold higher for tank barges, but the quantities re-leased were actually slightly higher for tank ships.

Several features of the ocean incineration bargeproposed by SeaBurn, Inc., should greatly reducethe risk of a release of waste in the event of an ac-cident, and are not reflected in the above statistics.First, the barge would be a Type I chemical tanker,which exceeds the Type II cargo containment re-quirements applicable to ocean incineration ves-sels.4 According to SeaBurn, Inc., no other suchbarges currently exist in the world’s fleet. Second,the proposed barge is ocean-going and has a ship’sbow, unlike the barges involved in the vast majorityof reported accidents. Given these and other fea-tures, SeaBurn, Inc., argues that its barge will bein a safety class all its own. 5

‘Coast Guard regulations for chemical carriers specify three levelsof cargo containment systems, Type I affording the highest degreeof containment. See 46 CFR 172 for a description of these construc-tion requirements.

‘V. G. Grey, President, SeaBurn, Inc. , personal communication,May 16, 1986.


As proposed, the SeaBurn barge would be towedbehind an ocean-going tug, a feature which some-what reduces its maneuverability relative to exist-ing ocean incineration vessels possessing bowthrusters. However, the U.S. Coast Guard indi-cates that a barge-tug system can be operated safely,even in confined areas, particularly when accom-panied by the other navigational controls (e. g., amoving safety zone) that are to be applied to oceanincineration vessels. G

Despite the factors discussed above, regulationsgoverning construction, inspection, and otheraspects of an ocean incineration system employinga towed barge should be carefully examined to en-sure that the requirements are adequate and com-mensurate with those applicable to self-propelledsystems.

Seawater Scrubbers

Existing ocean incineration systems are designedto vent combustion gases directly upwards into theatmosphere, which raises concerns about the po-tential for subsequent adverse impacts on the ma-rine environment and at least the nearest shorelines.As an alternative, two companies have proposeda system in which combustion gases would passthrough a scrubber-like device prior to discharge.A deluge of seawater would physically wash the ex-haust stream. In contrast to a true scrubber, how-ever, the seawater scrubber would immediately dis-charge the untreated scrubbing effluent into theocean. Thus, the scrubber would alter the locationand nature, but not the quantity, of the dischargeto the marine environment.

A seawater scrubber would alter incineratoremissions in two major respects, by affecting boththe partitioning and the temperature of emissions.Each of these differences offers potential advantagesand disadvantages (see below).

Although a seawater scrubber would greatly af-fect the nature of incinerator emissions, data arecurrently insufficient for determining whether theaddition of seawater scrubbers to ocean incinera-tion vessels would provide any improvement overthe technology presently employed. Further study

sThese comments were received through the review of a draft ofthis report by the U.S. Coast Guard.

may provide a basis for such a determination inthe future.

Partitioning of Emissions

A seawater scrubber would divide emission com-ponents into two parts: those discharged in thescrubbing effluent; and those not removed throughscrubbing and therefore emitted to the atmosphere.Acidic gases (typically hydrogen chloride) wouldbe expected to be mostly neutralized during thewash, because of the natural buffering capacity ofseawater. Any residual acid would be rapidly neu-tralized after the effluent was discharged to theocean. In addition, during the scrubbing, some ofthe particulate and organic components of the emis-sions would become dissolved or become suspendedin the effluent.

A seawater scrubber would significantly reducethe quantity of contaminants emitted to the atmos-phere, but would discharge contaminants into theocean at much higher concentrations than those re-sulting from contact of an unscrubbed plume withthe ocean surface (12).

Plans call for the scrubbing effluent to be dis-charged directly into the wake of the vessel to max-imize mixing and dispersion of trace contaminants.Being warmer than ambient seawater, however, thescrubbing effluent would tend to remain at, or riseto, the surface (12). The potential for these con-centrated and heated discharges to affect surface-dwelling organisms (including the so-called micro-layer; see ch. 9) has not been examined.

In contrast, emissions from vessels not employ-ing seawater scrubbers would disperse and settleout over the ocean surface, affecting a larger area,but introducing contaminants at lower concen-trations.

Temperature of Emissions

Seawater scrubbers would also quench (i.e., cool)exhaust gases, reducing their exit temperature fromabout 2,5000 F to below 3000 F. This would havetwo practical effects on incinerator emissions. First,the plume would be less buoyant and would, there-fore, not rise as far above the ocean surface. Thiseffect would tend to decrease the time required forthe plume to settle on the ocean surface, therebydecreasing the size of the affected area, but also in-

Ch. 6—Ocean Incineration Technologies ● 115

creasing concentrations at the surface. As indicatedpreviously, this increase in the concentration of in-cineration products would be expected to exert rela-tively greater effects on surface organisms residingin the smaller affected area.

Second, because sampling of stack gases is com-plicated by the high exit temperatures as well asby the corrosivity typical of ocean incineration emis-sions, a scrubber might help to simplify emissionsmonitoring and reduce damage to sampling de-vices. On the other hand, sampling of emissionsfor particulate (see ch. 7) could become more dif-ficult or impossible, because particulate might bewashed out of the plume before they could be sam-pled. Significant quantities of unburned wastes orproducts of incomplete combustion (PICs) can bebound to such particulate after exhaust gases hav’ecooled or condensed ( 1). In the absence of correc-tive measures, this effect could significantly com-promise the reliability of sampling for the purposesof calculating a destruction efficiency.

Clearly, further research into the advantages anddisadvantages of seawater scrubbers will be neces-sary to determine whether they represent best avail-able technology. As discussed in chapter 1, basedon available information, there appears to be littleneed for scrubbers on ocean incineration vessels ifproper controls are placed over waste content andoperating conditions.

Combustion Chambers

Existing and proposed technologies also differwith respect to the design and orientation of thecombustion chamber itself. Existing vessels carryvertically mounted single-chamber incinerators,whereas two proposed designs would use horizon-tally mounted two-chamber units.

Proponents of the horizontal orientation arguethat it is the only design that could accommodatea seawater scrubber and two combustion chambers,and that the design would also help to reduce plumealtitude. Passage of wastes through two combus-tion chambers should at least theoretically increaseresidence time and enhance destruction efficiency.However, confirmation of these claims must awaitthe development and testing of such an incinera-tion vessel. Moreover, because two chambers arenot considered necessary to achieve high destruc-tion efficiencies of liquid wastes in land-based in-

cinerators (see ch. 2), requiring their use in oceanincineration appears premature. Although EPA’sreliance on performance rather than design stand-ards does not negate the need for further investi-gation into combustion chamber design, it repre-sents a reasonable regulatory approach at thepresent time.

Burner Types

Incinerator burners serve several important func-tions, including atomization (i. e., fine droplet for-mation) of wastes. The degree of atomization canbe an important determinant of overall destructionefficiency because it affects the mixing rate of wasteand air in the combustion zone. The ocean inciner-ation vessels that are currently operating employa traditional European-designed burner thatatomizes incoming waste using a mechanical de-vice (rotary CUP or vortex). Those vessels recentlybuilt or planned for construction in the UnitedStates would use a U.S.-designed spray nozzle in-jection system for atomization. According to EPA,most land-based incinerators in the United Statesalso employ the spray nozzle design (11 ).

Although the mechanical design for atomizingwastes is allowed by EPA, considerable controtersyexists over the adequacy of its performance. Criticsargue that the use of rotary cup burners is beingdiscontinued or even prohibited because of’ insuffi-cient atomization and excessive .sensitivity to oper-ating conditions like waste feed rate and vibration(see refs. 4 and 5, and other references therein).Proponents argue that studies specifically designedto assess the performance and degree of atomizationof mechanical burners have found them comparableto other designs ( 1), and that the very short flamelength generated by mechanical burners yields highcombustion efficiencies (6).

According to EPA, insufficient data exist tocorrelate burner design with incinerator perform-ance. Because burner design is only one of manyfactors (e. g., operating conditions, combustionchamber geometry) that affect incinerator perform-ance, EPA has chosen to rely on performance ratherthan design standards in formulating both land-based and ocean incineration regulations (1 1).Thus, although further study of this issue is war-ranted, no consensus currently exists as to the bestavailable technology for atomizing waste.

116 Ž Ocean Incineration: Its Role in Managing Hazardous Waste

1.

2.

3.

4.

5.

I 6.

7.

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C H A P T E R 6 R E F E R E N C E S

Ackerman, D. G., et al., The Capability of OceanIncineration—A Critical Review and Rebuttal ofthe Kleppinger Report (Redondo Beach, CA:TRW Energy and Environmental Division, 1983).Douglas, J., and Grothaus, D., “Trucker Dies inFiery Crash, ’ The Houston Post, July 31, 1985,p. 1A.Hazardous Cargo Bulletin, “Tank Containers, ”Hazardous Cargo Bulletin 5(7):30, July 1984.Kleppinger, E. W., and Bond, D. H., Ocean In-cineration of Hazardous Waste: A Critique (Wash-ington, DC: EWK Consultants, Inc., 1983).Kleppinger, E. W., and Bond, D. H., Ocean In-cineration of Hazardous Waste: A Revisit to theControversy (Washington, DC: EWK Consultants,Inc., 1985).Lankes, W., “Incineration At Sea: ExperienceGained With the M/T Vesta, ” in Wastes in theOcean, vol. 5, D.R. Kester, et al. (eds.) (NewYork: John Wiley & Sons, 1985), pp. 115-124.Marcus, H. S., and Daniel, C. T., Logistical Sys-tems To Support Ocean Incineration of LiquidHazardous Wastes, prepared for U.S. Departmentof Transportation, Maritime Administration, Of-fice of Maritime Technology, Maritime Adminis-tration Research & Development (Washington,DC: August 1982).

8<

9.

10.

11.

12.

Marcus, H. S., and Glucksman, M. A., Planninga Port Interface for an Ocean Incineration System,prepared for the U.S. Department of Transporta-tion, Maritime Administration (Springfield, VA:National Technical Information Service, August1985).U.S. Congress, Office of Technology Assessment,Transportation of Hazardous Materials, OTA-SET-304 (Washington, DC: U.S. GovernmentPrinting Office, July 1986).U.S. Department of Transportation, U.S. CoastGuard, Polluting Incidents In and Around U.S.Waters, Calendar Years 1982 and 1983, Comman-dant Instruction M16450.2F (Washington, DC:1983).U.S. Environmental Protection Agency, Office ofPolicy, Planning and Evaluation, “BackgroundReport I: Description of Incineration Technology, ”Assessment of Incineration as a Treatment Methodfor Liquid Organic Hazardous Wastes (Washing-ton, DC: March 1985).U.S. Environmental Protection Agency, ScienceAdvisory Board, Report on the Incineration of Liq-uid Hazardous Wastes by the Environmental Ef-fects, Transport and Fate Committee (Washington,DC: April 1985), p. 21.

Chapter 7

Comparison of Land-Based andOcean Incineration Technologies

Contents

PageComposition of Incineration Products . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. ....119

Plume Gases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...119Residual Parent Compounds and Products of Incomplete Combustion (PICs) . ........119Metals and Particulate. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1’20Solid Residues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ............121

Comparison of ’Technical and Regulatory Requirements. . . . . . . . . . . . . . . . . . . . . . ........122Waste Analysis and Waste Limitations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..122Performance Standards . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .......123Operating Conditions . . . . . . . . . . . . . . . . . . , . 125Air Pollution Control Technology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..............127Sampling and Monitoring Requirements and Procedures . . . . . . . . . . . . . . . . . . . . . .. ...128.Additional Provisions Not Required of Land-Based Incineration . . . . . . . . . . . . . ..129

Chapter 7 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..129

Table

T a b l e N o . Page

12. Performance Standards Applicable to Land-Based and Ocean Incineration. . . .124

Chapter 7

Comparison of Land-Based andOcean Incineration Technologies

Although liquid organic wastes are currently This chapter describes the nature of the combus-managed in various ways, ocean incineration’s pri- tion products arising from both land-based andmary competition and closest analog is land-based ocean incineration and compares and contrasts theirincineration. Therefore, it is important to compare respective technical and regulatory requirements.and contrast their technical features, the nature andextent of their regulation, and their relative risksof environmental release and adverse impacts.

C O M P O S I T I O N O F I N C I N E R A T I O N P R O D U C T S

The products resulting from incineration of haz-ardous waste, whether on land or at sea, can re-sult from complete or partial thermal oxidation ofwaste components. The products can be groupedas follows: plume gases, residual parent com-pounds, products of incomplete combustion (PICs),metals and particulate, and solid residues. A briefdescription of each category is provided below.

Plume Gases

Total combustion of simple, nonhalogenatedchemicals generates carbon dioxide and water asend products. If combustion is incomplete, carbonmonoxide is also formed, and its level in emissionsindicates the degree of incomplete combustion. In-cineration of halogenated compounds generates acidgases (e. g., hydrogen chloride) and much smalleramounts of chlorine gas, in addition to carbon di-oxide and water. The incineration of liquid wastescontaining sulfur or nitrogen can produce a vari-ety of sulfur oxides and nitrogen oxides.

Except for acid-forming emissions (dominatedby hydrogen chloride), the Environmental Protec-tion Agency (EPA) has not promulgated or pro-posed regulations limiting emissions of stack gasesfrom hazardous waste incinerators. Relative tolarger combustion sources like powerplants, the in-cinerators probably are a relatively minor sourcefor most of these pollutants. For certain wastes orin certain geographic settings, however, hazardous

waste incineration may contribute significantly tothe risks posed by hazardous air pollutants.

Residual Parent Compounds and Productsof Incomplete Combustion (PICs)

Parent compounds refer to those present in theoriginal waste, a small fraction of which passthrough the incinerator intact. PICs include bothpartially destroyed compounds and new chemicalcompounds not originally present in the wastes.PICs, which all types of combustion processes gen-erate to some degree, include a wide range of com-pounds that are apparently synthesized during orimmediately after combustion through chemical re-actions or the recombining of molecular fragments.

PICs often bear little or no resemblance to theparent compounds from which they were derived;nor does the presence of a particular PIC neces-sarily correlate with the presence of a particularwaste component. Very little is understood abouthow PICs are formed. They have been detected inthe emissions from burning a wide range of mate-rials, both hazardous and nonhazardous (e. g., mu-nicipal garbage, wood). The generation of PIGsmight be correlated with the level of oxygen presentduring incineration and with the completeness ofcombustion.

Both dioxin and dibenzofuran compounds,known to be highly toxic to humans and in the envi-

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120 ● Ocean Incineration: /ts Role in Managing Hazardous Waste

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ronment, have been identified among PICs pro-duced from incinerating various materials, includ-ing municipal garbage. Our understanding of thepublic health significance of these emissions, or eventheir major sources, is far from complete.

The quantities of both residual parent com-pounds and PICs present in incinerator emissionsvary with operating conditions, such as residencetime, turbulence, and temperature. An EPA studyof land-based hazardous waste incinerators (13)found that the concentrations of PICs in the stackgases were typically as high as the concentrationsof parent compounds, but that both were rarelyabove 0.01 percent of the concentration of the par-ent compounds in the original waste. EPA’s Sci-ence Advisory Board’s analysis of available studiescharacterizing emissions from land-based inciner-ators, however, led the Board to conclude that:

It is apparent that even with the uncertaintiesrelated to sampling efficiencies and inadequatechemical analyses, as much as 1 percent of themass of the waste feed could exit an incineratoras compounds other than carbon dioxide, carbonmonoxide, water, and hydrochloric acid. (16)

Under such conditions, a total destruction effi-ciency (DE) of only 99 percent would be achieved,even though a much higher DE would probably bemeasured under EPA’s current definition (see dis-cussion of DE in ch. 2).

With respect to ocean incineration, EPA was un-able to detect any dioxins or dibenzofurans in stackemissions from the Vulcanus ships burning poly -chlorinated biphenyls (PCBs) or the defoliant AgentOrange. Questions have arisen, however, about theadequacy of sampling and analytic methodologyemployed during those monitoring efforts (see refs.3, 16; also see discussion of past U.S. burns inch. 11).

EPA is currently devoting considerable effort tocharacterizing the PICs that result from hazard-ous waste incineration, and the Agency considersit a research priority. PICs are currently unregu-lated, although EPA proposed regulations underthe Resource Conservation and Recovery Act(RCRA) in 1981 (46 FR 7684, Jan. 23, 1981). Theproposed Ocean Incineration Regulation would notinclude any specific limits on the emissions of PICs,

pending further study, but EPA is considering twoapproaches to their possible future regulation (seech. 2, and proposed Ocean Incineration Regula-tion, 50 FR 8247, Feb. 28, 1985).

Metals and Particulate

These incineration products are the largely non-combustible, inorganic (mineral) remainder fromthe combustion of waste. In addition, substantialamounts of particulate matter are sometimes de-rived from the refractory firebrick lining of the com-bustion chamber, itself. How much of these prod-ucts are generated depends on the type of wasteincinerated; for example, the quantity of particu-late from incineration of liquid wastes is gener-ally significantly less than from incineration of solidwastes.

Because metals are not destroyed by incinera-tion, those present in the waste feed are either de-posited in ash residues or are emitted from the com-bustion chamber. Metals can be emitted in eithera particulate (solid) or a volatilized (gaseous) state.Control strategies and environmental behavior varyconsiderably for these two forms and from metalto metal.

Incineration canof metals in severaldiscussed below.

alter the form and propertiesimportant respects, which are

Volatilization

The high temperatures typically employed inhazardous waste incinerators can volatilize heavymetals that are present in the waste; the degree ofvolatilization varies with the incinerator’s operat-ing conditions, and from metal to metal. Mercury,cadmium, and lead are generally considered mostproblematic because they are easily volatilized andare harmful if inhaled by humans. Although fewdata are available for hazardous waste incineration,one study examined the release of metals from in-cineration of sewage sludge at 1,6000 F in a facil-ity possessing air pollution control equipment (6).At least 20 percent of the lead and cadmium, andessentially all of the mercury, were emitted becauseof the scrubber’s low efficiency at removing volati-lized metals.

Ch. 7—Comparison of Land-Based and Ocean Incineration Technologies . 121

Volubility

Incineration can also alter the chemical form andvolubility of metals found in wastes, thereby alter-ing the metals’ potential availability and routes ofexposure to organisms or humans. For example,incineration might change a water-insoluble formof cadmium in an organic wastestream to a moresoluble form; when the resultant ash is disposed ofin a landfill, the cadmium would be more likely toleach into nearby groundwater. Incineration in-creases the water volubility of cadmium and cop-per and decreases the water volubility of chromium,nickel, and lead (4).

Bioavailability 1

Incineration can alter the bioavailability of cer-tain metals. The ability of living organisms to ab-sorb and detoxify a particular metal greatly dependson the metal’s chemical form. Because metal chem-istry can be greatly altered by high temperature,the potential for incineration to increase or decreasethe bioavailability of a metal must be considered.Although this problem has been insufficiently stud-ied, some data indicate that incineration increasesthe bioavailability of arsenic and chromium (4).

Although emissions standards for specific metalsdo not exist, for either land-based or ocean inciner-ation, EPA has limited the total allowable quan-tity of particulate material from land-based inciner-ators, which should lower emissions of those metalsbound to particulate matter. For ocean incinera-tion, EPA has proposed limiting the individual con-centrations of particular metals in waste acceptedfor incineration and, furthermore, the concentra-tions of metals in the final blended waste, as ameans of reducing the quantity of emitted metals(see next section). Many observers, however, havecalled for further characterization and regulationof actual metal emissions, based on their potentialcontribution to the risk posed by hazardous air pol-lutants (see chs. 2 and 9).

‘A bioavailable metal is one that can be taken up by a living organismand incorporated into its makeup or metabolic processes. Only cer-tain metals, and only certain chemical forms of metals, are taken up,and the bioavailability of a particular metal also varies from one organ-ism to another.

Solid Residues

These products include ash left behind in thecombustion chamber and wastes generated whenair pollution control equipment (e. g., scrubbersludges) is used.

Ash

The quantity and composition of ash resultingfrom incineration varies widely and primarily de-pends on the waste itself. For example, incinera-tion generates substantially greater amounts of ashfrom solid wastes than from liquid wastes. Oper-ating conditions can also influence the quantitiesof residuals. Ocean incineration typically producesvery little or no ash, although periodic cleaning ofthe combustion chamber is necessary to removeslag.

Sludges and Dusts

Land-based incinerators that employ air pollu-tion control equipment generate additional waste,including sludges and effluents (from the use of wetscrubbers) and dusts (from the use of dry scrub-bers and other collection devices). The quantity ofthese additional wastes, which can be substantial(see ch. 8), depends on what waste is incinerated.

The existing regulations governing land-basedincinerators (40 CFR 261 .3(c)2) and those proposedfor ocean incineration (50 FR 8268, Section 234.56(j),Feb. 28, 1985) define ash and pollution controlresidues as hazardous wastes and specify that theybe handled as such. Under RCRA, however, a var-iance can be granted if the residue is shown to benonhazardous (Sections 264.351 and 261 .3(d)).Residues can also be delisted on a case-by-case basisby the EPA Administrator, under a provision ofthe 1984 RCRA Amendments.

The latter procedure may be used to delistresidues from incineration of dioxin-contaminatedmaterials generated by a mobile incinerator oper-ating in Times Beach, Missouri (5). It may alsobe used to reclassify such residues as hazardous,rather than acutely hazardous (the designationgiven to all dioxin-contaminated materials). EPAsees such a step, which would significantly ease res-idue disposal requirements, as necessary to en-courage incineration of dioxin wastes, but the rea-soning is based on a controversial model of dioxintoxicity (7).


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C O M P A R I S O N O F T E C H N I C A L A N D

R E G U L A T O R Y R E Q U I R E M E N T S

This section summarizes and compares the vari-ous regulatory provisions that impose technical re-quirements on the use of land-based and ocean in-cineration. For land-based incineration, referencesare generally to EPA’s Incinerator Standards forOwners and Operators of Hazardous Waste Man-agement Facilities (46 FR 7666-7683, Jan. 23,1981) and subsequent amendments (47 FR 27516-27535, June 24, 1982), developed under the statu-tory authority of RCRA. For ocean incineration,references are to the proposed Ocean IncinerationRegulation (50 FR 8222-8288, Feb. 28, 1985),which was developed under the statutory author-ity of the Marine Protection, Research, and Sanc-tuaries Act (MPRSA).

Waste Analysis and Waste Limitations

An operating permit for either land-based orocean incineration must specify what range ofwastes an incineration facility has demonstrated itscapability to satisfactorily treat. This range of wastesmust be specifically tested in a trial burn. In speci-fying the wastes, the permit may limit waste com-position, if necessary to meet performance or emis-sions standards. Some limitations are specific to aparticular facility, whereas others apply to all in-cinerators.

Regulations for both land-based and ocean in-cineration require facility operators to perform peri-odic waste analyses in order to identify constitu-ents to which performance standards apply (seebelow) and to ensure compliance with the terms ofoperating permits. The stringency of this require-ment, however, differs considerably. For ocean in-cineration, a waste analysis would be required be-fore each voyage; for land-based incineration, ananalysis is required only when requested by EPA.

Wastes to be incinerated on land must be char-acterized with respect to the following:

●

●

●

●

heat value,viscosity,physical form, andidentification and approximate quantificationof RCRA-hazardous organic constituents.

The waste description required for ocean inciner-ation is somewhat more extensive than that for land-based incineration. In addition to those listed above,the following waste properties or components mustbe identified:

•●

●

●

●

●

moisture, solid, and ash content;specific gravity (density);presence of polychlorinated terphenyls;main inorganic constituents;halogens, sulfur, and nitrogen constituents;andother organic compounds not listed as hazard-ous under RCRA.

Limitations on chlorine content are commonlywritten into operating permits for land-based in-cinerators, in order to meet emissions standards orto stay within the operating limits of scrubbers.Solid or metal content may be similarly limited.If PCBs are to be incinerated, maximum concen-trations of PCBs in the waste are specified for bothland-based and ocean incineration.

Under the proposed Ocean Incineration Regu-lation, two additional kinds of waste limitationswould be specified. First, EPA would specificallylimit how much of each of the following 14 metalscould be present in waste accepted for incinerationat sea:

aluminum iron silverarsenic lead thalliumcadmium mercury tinchromium nickel zinccopper selenium

Concentrations would be limited to a maximumof 500 parts per million (ppm) per metal. No limitson the aggregate quantity of metals in the wasteor in the emissions would be specified.

Second, certain metals (and potentially other sub-stances) would be limited by a proposed environ-mental performance standard (see next section).Under the standard, concentrations of particularwaste constituents in the final blended waste to beincinerated would be limited to amounts that wouldprevent the resulting mixture of incinerator emis-sions and seawater from exceeding marine water

Ch. 7–Comparison of Land-Based and Ocean Incineration Technologies ● 123

quality criteria.2 EPA has determined that limitsfor mercury, silver, and copper would have to bebelow 500 ppm to meet marine water quality cri-teria (50 FR 51362, Dec. 16, 1985).

Both technical and regulatory distinctions be-tween land-based and ocean incineration accountfor the differences in waste limitations and require-ments for waste analysis. Limitations on chlorinecontent are not considered necessary for ocean in-cineration, because of natural seawater’s ability toneutralize hydrochloric acid gas. This phenome-non is also the reason EPA would not require in-cineration vessels to carry air pollution controlequipment. Because the lack of scrubbers would al-low the emission of essentially all metals presentin the waste, however, the metal content of wastesincinerated at sea would be strictly controlled.

The waste analysis requirements are more strin-gent for ocean incineration than for land-based in-cineration, partly because the two activities are reg-ulated under entirely different statutes. Oceanincineration falls under the definition of oceandumping specified in MPRSA. In general, inter-national and domestic regulation of ocean dump-ing has strictly controlled the types of waste thatcould be dumped and has, therefore, mandated ex-tensive waste analysis as a condition for obtainingpermits.

Performance Standards

EPA’s approach to regulating land-based andocean incineration has relied primarily on stand-ards for incinerator performance rather than stand-ards governing incinerator design. Thus, any fa-cility that possessed a combination of designfeatures capable of meeting minimum performancestandards would be eligible for an operating per-mit. This capability has typically been demon-strated by trial burns carried out prior to the grant-ing of operating permits. For ocean incineration,EPA has proposed a combination of incinerator per-formance and environmental performance stand-

‘w’here there are no critera, the mixture could not exceed a ma-rine aquatic life no-effect level or a toxicity threshold defined as 1 per-cent of an ambient marine water concentration shown to be acutelytoxic to appropriate sensitive marine organisms (in a bioassay car-ried out in accordance with EPA-approved procedures). Marine waterquality criteria have been developed for each of the 14 metals speci-fied by EPA,

ards. The latter are proposed as alternatives to theland-based incinerator performance standards gov-erning hydrogen chloride and particulate emissions.

Table 12 summarizes incinerator and environ-mental performance standards applicable to land-based and ocean incineration facilities. Each ofthese standards is defined and discussed below.

Combustion Efficiency (CE)

This measure of incinerator performance indi-cates the overall efficiency of the combustion processand can be monitored on a continuous basis. CEis represented by the relationship between the con-centrations of carbon dioxide (CO2) and carbonmonoxide (CO) in the incinerator exhaust:

C E = [ C O2 - [ c o ] x 100[ C 0 2 ]

The CE standard is more stringent for ocean thanfor land-based incineration in two respects: thestandard applies to all wastes, not only PCBs; andit is numerically higher (see table 12). The highervalue is required because regulations promulgatedunder MPRSA must equal or exceed internationalregulations developed under the London DumpingConvention, which specifies a minimum CE of99.95 *0.05 percent for all wastes.

Destruction Efficiency (DE) or Destructionand Removal Efficiency (DRE)

These measures of incinerator performance in-dicate the extent to which particular compoundsthat were present in the waste feed are absent fromemissions. DE and DRE must be calculatedseparately for each designated compound and, be-cause the chemical analysis is complex and time-consuming, cannot be determined on a continu-ous basis. Consequently, the usefulness of DE andDRE in monitoring incinerator performance islimited.

DE and DRE are defined as follows:

DE or DRE = [Wi n] - [ Wo u t] x 1 0 0[Win]

Where [Win] is the concentration of a particularcompound in the waste feed and IWout] is the con-centration of the same compound in the emissionsvented to the atmosphere.

—.


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Table 12.-Performance Standards Applicable to Land”Based and Ocean Incineration

Performance standard Land-based incineration Ocean incineration

99.95 *0.05°/0 for all wastes

alncineration of pCB~ ~equire~ ~ separate approval from the Assistant Administrator of the Office of pesticides and Toxic Substances, in compliance with TSCA (40

CFR 761.70). EPA believes (and generally requires) that a CE >99.9°/. results in a DRE >99.9999Y0. (U.S. Environmental Protection Agency, Office of Policy, Planningand Evaluation, ‘Summary and Conclusions,” Assessment of Incineration as a Treatment Method for Liquid Organic Hazardous Wastes (Washington, DC: 1985).)

SOURCES: Land-baaed incineration: Incinerator Standards for Owners and OPerators of Hazardous Waste Management Facilities (46 FR 7666-7663, Jan. 23, 1981) andsubsequent amendments (47 FR 27516-27535, June 24, 1982). Ocean incineration: The proposed Ocean Incineration Regulation (50 FR 8222-8288, Feb. 28,1985). PCBS: TSCA PCB incineration regulations (40 CFR 761.70).

The only difference between DE and DRE is thatany removal of compounds accomplished by air pol-lution control equipment is included in the calcu-lation of DRE, because DRE is measured after thedevices have acted on emissions. Because air pol-lution control equipment is generally poor at re-moving organic constituents (2, 13, 15), however,DE and DRE are often functionally equivalent.

The waste destruction standard would be iden-tical for land-based and ocean incineration (see table12). Thus, despite their lack of scrubbers, inciner-ator vessels would have to achieve an emission ratefor organic materials no higher than that allowedfor land-based facilities.

Hydrogen Chloride (HC1) Emissions

Incineration of chlorinated wastes generateshighly corrosive HCl gas. On land, if the rate ofHCl production exceeds 1.8 kg/hr (4 lbs/hr), scrub-bers must be employed to limit emissions to lessthan that amount or to remove 99 percent of thetotal, whichever results in the larger emission. EPAregards 99 percent removal as achievable using cur-rent technology.

For a land-based incinerator operating at mediancapacity (1 ,250 lbs/hr), any waste whose chlorinecontent was greater than 0.3 percent could be ex-pected to exceed the HCl emission limitation of 4lbs/hr and, hence, would require a scrubber. Onceequipped with a scrubber that achieves 99 percent

HCl removal, the same facility could incineratewaste with a chlorine content of up to about 30 per-cent without emitting more than 4 lbs/hr of HCl.

Incineration of waste with a chlorine contentgreater than 30 percent would be legal as long as99 percent of the HCl were removed, but otherpractical constraints (e. g., corrosion, scrubber ca-pacity, formation of chlorine gas) limit chlorine con-tent to a maximum of about 35 percent.

For ocean incineration, EPA has proposed anenvironmental performance standard that wouldlimit emissions to an amount that would result inno more than a 10 percent change in alkalinity ofseawater in the release zone, measured 4 hours af-ter release. EPA has calculated that this standardwould be met even for incineration of pure carbontetrachloride, whose chlorine content is over 90 per-cent, at the very high feed rate of 25 metric tonsper hour, Given the significantly lower chlorinecontent and feed rates that would realistically beemployed, it is highly unlikely that this environ-mental performance standard would ever be ex-ceeded.

Particulate Emissions

The existing particulate standard for land-basedincinerators is 180 mg per dry standard cubic me-ter, measured after correction to 50 percent excessair. The correction is designed to prevent opera-tors from achieving the standard by simply dilut-

Ch. 7—Comparison of Land-Based and Ocean Incineration Technologies • 125

ing the emissions with excess air rather than actu-ally controlling particulate.

The rationale for controlling particulate is two-fold: First, particulate matter itself can be hazard-ous, because it can include toxic metals, which arenot destroyed during incineration; and second,other hazardous constituents, including unburnedor partially burned organic compounds, can adsorbto particulate matter. Although the chemical anal-ysis used to calculate DRE accounts for unburnedparent compounds bound to particulate matter, theDRE standard does not in any way measure or limitpartial combustion products (e. g., PICs) or metals.

The particulate standard applicable to land-basedhazardous waste incinerators is identical to that re-quired of municipal incinerators under the CleanAir Act’s New Source Performance Standards (12).

For ocean incineration, EPA has proposed anenvironmental performance standard for metals in-stead of establishing a direct particulate emissionsstandard. The proposed environmental standardwould limit incinerator emissions so that:

. . . the effect of the emissions would not unrea-sonably degrade or endanger human health, wel-fare, or amenities, or the marine environment,ecological systems, or economic potentialities orrecreational or commercial shipping or boating orrecreational use of beaches or shorelines (Section234.48(b) of EPA’s proposed Ocean IncinerationRegulation, 50 FR 8266, Feb. 28, 1985).

EPA has interpreted this rather vague languageto mean that concentrations of particular constit-uents in wastes to be incinerated would be limitedto amounts that would prevent the resulting mix-ture of incinerator emissions and seawater from ex-ceeding marine water quality criteria.3

This standard would theoretically apply to anysubstance present in incinerator emissions. In prac-tice, however, criteria and toxicity thresholds havebeen developed for few chemicals, and this stand-ard would primarily be used to limit metal concen-trations allowed in wastes incinerated at sea. Be-cause liquid wastes suitable for ocean incinerationtypically generate low levels of particulate, EPAconsiders the proposed limitations to be a justifia-

3See footnote 2.

ble alternative to requiring particulate control de-vices on incinerator vessels.

Although the environmental performance stand-ard appears to address harmful metal emissions,whether it can adequately control emissions of PICsassociated with particulate is controversial. EPAargues that at the high temperatures employed inocean incineration, essentially all organic com-pounds would be in a volatilized state and not ad-sorbed to particulate matter. Thus, particulateremoval equipment would not help to reduce PICemissions (l). However, some observers argue thatcertain organic compounds, including PCBs, di-oxins, and dibenzofurans, can to some extent asso-ciate with particulate matter even at high temper-atures. In addition, these observers maintain, othermechanisms exist for including organic matter inthe particulate fraction of incinerator emissions(9,10).

Further research will probably be essential forresolving this controversy. EPA’s proposed researchstrategy for ocean incineration would include testsdesigned to address the issue (14).

Operating Conditions

Operating permits for both land-based and oceanincineration facilities specify sets of operating con-ditions that were demonstrated in trial burns to becapable of achieving the performance standards dis-cussed above. A set of conditions is determined foreach waste feed expected to be burned. Periodicwaste analyses must be performed to demonstratethat wastes actually incinerated are within the rangefor which a permit is written.

Land-Based Incineration

For land-based incinerators, each set of operat-ing conditions includes limits on at least the fol-lowing parameters:

●

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the carbon monoxide level in the exhaust stackgas (indicates combustion efficiency, complete-ness, or upset);waste feed rate;combustion zone temperature, with locationof sensor specified;appropriate indicator of combustion gas ve-


locity (indicator of residence time in the com-bustion zone); and

. air pollution control device operating con-ditions.

In addition to these waste feed-specific conditions,several operating requirements are uniformly ap-plied to all land-based incinerators:

●

●

●

during startup and shutdown, hazardouswastes cannot be fed to incinerators unless theyare operating under specified conditions;combustion zones must be completely sealedand maintained under negative pressure in or-der to control fugitive emissions; andautomatic shutoff systems must be employedto halt waste feed when operating conditionsdeviate from specified limits.

Incineration of PCBs requires separate approvalfrom the Assistant Administrator of the Office ofPesticides and Toxic Substances, in complianceIwith the Toxic Substances Control Act (TSCA).Additional operating conditions are specified:

● 1,200 + 1000 C, 2.0 second residence time,3 percent excess oxygen; or

● 1,600 + 1000 C, 1.5 second residence time,1 2 percent excess oxygen.I

Photo credit: SCA Chemlca/ ServicedAir Pollution Control Assoc/atlon

The computerized control room at a land-basedincineration facility.

Other operating conditions are allowed if theycan be demonstrated to achieve the required DRE.

Ocean Incineration

The proposed Ocean Incineration Regulationwould also use a trial burn to determine appropri-ate sets of operating conditions and waste feeds. Forcertain wastes specified in London Dumping Con-vention (LDC) regulations, if a contracting partyto the Convention “has doubts as to the thermaldestructibility of the wastes, ” then a separate testburn would have to be conducted to ensure thatall standards could be met. Because of the antici-pated difficulty in achieving their complete ther-mal destruction, the following wastes would receivespecial attention:

● polychlorinated biphenyls (PCBs);• polychlorinated terphenyls (PCTs);● tetrachlorodibenzo-p-dioxin (TCDD);● benzene hexachloride (BHC); and● dichlorodiphenyl trichloroethane (DDT).

EPA considers available data sufficient to documentthe ability of incinerators to destroy PCBs, BHC,and DDT to the level specified by the LDC (50 FR8228, Feb. 28, 1985). Because a 99.9999 percentstandard applies to PCBs and TCDD and data arelacking for PCTs, however, test burns would bemandated for these three substances.

Operating permits for incineration vessels wouldhave to specify allowable limits for at least two oper-ating conditions:

gases, and. waste feed rate t. the incinerator.

The proposed regulation specifically sets limitson the following additional operating parameters:

●

●

●

●

For

minimum flame temperature of 1,2500 C;minimum wall temperature of 1,1000 C;minimum 3 percent oxygen concentration inthe combustion gases; andresidence time in the combustion zone of atleast 1.0 second.

all of these except residence time, alternatevalues could be substituted in the operating per-mit, if other conditions were demonstrated in a trialburn to be capable of achieving the performancestandards.

Ch. 7—Comparison of Land-Based and Ocean Incineration Technologies • 127

The proposed regulation also specifies a set ofgeneral operating requirements that would applyto all vessels at all times:

●

●

●

●

no black smoke or flame may extend abovethe stack plane;between startup and shutdown, hazardouswaste could not be fed to incinerators unlessthey were operating under specified con-ditions;automatic shutoff systems would have to beemployed to halt waste feed when operatingconditions deviated from specified limits; andall residues would have to be incinerated atsea or transported back to land for properdisposal.

This comparison of requirements for operatingconditions shows that the proposed Ocean Inciner-ation Regulation generally tends to specify valuesfor more operating parameters and leaves less tothe judgment of individual permit writers than dothe regulations governing land-based facilities.

Air Pollution Control Technology

Effect of Scrubbers on Emissions FromHazardous Waste Incinerators

Currently available air pollution control equip-ment generally controls emissions of particulateand acidic gases very effectively but removes or-ganic compounds (parent compounds and PICs),certain metals (e. g., mercury), and nitrogen oxidesvery poorly.

An EPA study of land-based incinerators foundthat, for various wastestreams, scrubbers had lit-tle or no detectable effect on the levels of unburnedwaste (parent compounds) present in emissions(13). Based on these and other data, air pollutioncontrol devices cannot be expected to remove re-sidual parent compounds or PICs from incinera-tor exhausts or to provide an extra margin of safetyin the event of operation upset (2, 15).

Although scrubbers effectively control emissionsof particulate metal oxides and gaseous sulfur ox-ides, controlling volatilized metals and nitrogen ox-ides is exceedingly difficult, particularly for haz-ardous waste incinerators, This is because: 1) wetscrubbers are ineffective at removing them; and 2)other control measures often entail decreasing the

operating temperature, which must be maintainedto ensure complete combustion of hazardous wastes.


Scrubbers are required for land-based incinera-tors that burn wastes whose chlorine or particulatecontent would otherwise cause emissions standardsto be exceeded. EPA estimates that about 45 per-cent of land-based incinerators currently operating,including the large commercial incinerators, carrysome sort of air pollution control equipment (8).Scrubber technology, especially for removing par-ticulates, is well-developed but expensive.

Land-based incinerators regulated under RCRA(or TSCA for PCBs) are also subject to controlson scrubber waste disposal. Scrubber operationgenerates very large amounts of scrubber water (seech. 8), which is itself classified as a hazardous waste.Several methods, all subject to RCRA regulation,are used for treating this residual. The methods in-clude impoundment, deepwell injection, treatment,and landfilling. Treatment generates two products:a sludge, which is generally disposed of in a haz-ardous waste landfill; and an effluent, which canbe legally discharged to surface waters or into sewersystems if the effluent meets the requirements ofthe Clean Water Act,

Ocean Incineration

Proposed domestic regulations, as well as exist-ing international regulations, do not require the useof any air pollution control equipment on inciner-ation vessels. Separate rationales are offered for thetwo major categories of incinerator emissions: acidgases and particulate. EPA argues that acid gasesemitted from the stack would be effectively neu-tralized on contact with seawater because of its nat-ural buffering capacity. As an additional control,the proposed Ocean Incineration Regulation wouldimpose an environmental performance standard foracid gas -emissions (see previous section).

EPA also considers that burning only liquidwastes at sea would generate very low levels of par-ticulates and that controls over metal content inwaste would further limit harmful metal emissions.Limitations on metal content of wastes burned atsea would be based on EPA’s interpretation of theLondon Dumping Convention’s guidelines withreference to water quality criteria.


Two companies, SeaBurn, Inc., and Environ-mental Oceanic Services, Inc., have proposed plansfor incineration vessels that would be equipped withseawater scrubbers, but their purpose would onlybe to dilute the plume and direct it more quicklyinto the ocean. The scrubbers, therefore, would notgenerate any scrubber residuals (see ch. 6).

Sampling and Monitoring Requirementsand Procedures

Three levels of monitoring are generally dis-cussed with regard to incineration: monitoring oftrial burns; routine monitoring of emissions andincinerator operating conditions; and ambient mon-itoring of surrounding air, water, and biota. Eachof these is discussed below for land-based and oceanincineration.


Sampling and analysis procedures for incinera-tor emissions are specified in Federal regulationsand EPA manuals. For the trial burn, actual loca-tions for sampling and monitoring devices are in-dicated, and data collected are used to determineperformance of the incinerator by providing for thefollowing:

●

●

●

●

●

●

●

quantitative analysis of waste feed, stack emis-sions, scrubber water, and ash and otherresidues;computation of DE or DRE;acid gas removal efficiency;quantification of particulate emissions;measurement of average, maximum, and min-imum combustion temperature;continuous measurement of carbon monoxideconcentration in the stack gases; andidentification of the sources of fugitiveemissions.4

Operating permits for routine incinerationspecify waste analysis and monitoring require-ments. A waste analysis plan is required and mustprovide for periodic verification of the chemical andphysical composition limits specified in the permit.RCRA requires that temperature, carbon monox-ide, waste feed rate, and combustion gas velocity

‘Fugitive emissions are small, sporadic losses of waste from sourceslike leaking valves, vents, and seals.

be continuously monitored during operationalburning and that an automatic waste feed shutoffsystem be continuously operated, as well. Wastefeed shutoff is triggered by deviation from permitlimits in any of several operating parameters, asdetermined by the continuous monitoring devices.Sampling and analysis of waste feed or emissionsmust be conducted on request by the EPA RegionalAdministrator. All sampling and monitoring datamust be recorded.

RCRA does not require ambient monitoring forland-based incinerators, although some individualStates might have such requirements under theClean Air Act. EPA offers three reasons for notmandating ambient monitoring: the Agency be-lieves that if stack emissions are within regulatorylimits, no adverse effects will occur; accurate andreliable ambient monitoring would not be feasiblebecause concentrations are extremely low; andother industrial activities contribute similar or iden-tical emissions, which would impede attempts toassign sources to emissions or their effects.

Ocean Incineration

For trial burns, proposed Federal regulationsspecify sampling and analysis procedures for par-ent compounds. Routine operations would requirecontinuous monitoring, which would have to berecorded in sealed tamper-resistant devices, of thefollowing parameters:

●

●

●

●

●

●

incinerator wall and flame temperatures;oxygen, carbon dioxide, and carbon monox-ide concentrations in the combustion gases;waste and auxiliary fuel feed rates to the in-cinerator;air flow to the combustion chamber;status of the flame (to monitor continuouscombustion); andamount of waste incinerated.

An automatic waste feed shutoff system would haveto be operated continuously and be triggered bydeviations from specified limits for: minimum walltemperature and minimum oxygen and maximumcarbon monoxide in combustion gases; flame-outs;or failure in continuous monitoring devices.

Tests of ballast waters, tank washings, pump-room bilge waters, and wash waters from decon-tamination operations would have to be performed

Ch. 7—Comparison of Land-Based and Ocean Incineration Technologies ● 129

and recorded to ensure compliance with permit re-quirements.

Vessel operators would be required to monitorambient air, water, and biota, using approvedmethods under the direction of EPA. The moni-toring would be conducted periodically or at therequest of the permit program managers. Costswould be borne by individual vessel operators.

EPA would have authority to review and approvethe qualifications of all personnel involved in col-lecting and analyzing samples for monitoring emis-sions and the ambient environment.

As was the case for operational requirements,proposed sampling and monitoring requirementsare generally more detailed and stringent for oceanincineration than for land-based incineration.

Additional Provisions Not Required ofLand-Based Incineration

The proposed Ocean Incineration Regulationcontains several requirements that do not havecounterparts in RCRA regulations governing land-based incineration. These requirements include thefollowing:

. all data from waste analyses and monitoringwould have to be submitted to EPA;

●

●

●

●

●

●

operators would have to meet additional re-quirements regarding the collection andreporting of monitoring data. The require-ments would specify, for example, the fre-quency of recording and the use of tamper-resistant devices;a full-time EPA shiprider would be requiredon each voyage, and the U.S. Coast Guardcould require an additional shiprider;facilities and records would be inspected yearlyby the U.S. Coast Guard and on request byEPA;permit applicants would have to assess the ef-fects of their activities on endangered or threat-ened species, and EPA would have to conductand periodically update its own endangeredspecies assessment, under the authority of theEndangered Species Act;the activity would have to be consistent withthe Coastal Zone Management Act; andoperators must demonstrate the need for oceanincineration (see ch. 2).

Although many of these requirements address con-cerns arising from the fact that ocean incinerationtakes place far from land, together they reinforcethe conclusion that the proposed Ocean Incinera-tion Regulation would be considerably more ex-plicit and stringent than the corresponding regu-lations for land-based incineration.

C H A P T E R 7 R E F E R E N C E S

1. Ackerman, D. G., et al., The Capability of OceanIncineration—A Critical Review and Rebuttal ofthe Kleppinger Report (Redondo Beach, CA: TRWEnergy and Environmental Division, 1983).

2. Arthur D. Little, Inc., Overview of Ocean Inciner-ation, prepared by J. R. Ehrenfeld, D. Shooter, F.Ianazzi, and A. Glazer, for the U.S. Congress, Of-fice of Technology Assessment (Cambridge, MA:May 1986).

3. Bond, D. H., ‘ ‘At-Sea Incineration of HazardousWastes, ” Environ. Sci. Technol. 18(5): 148A-152A,1984.

4. Booz-Allen & Hamilton, Inc., “An Overview of theContaminants of Concern in the Disposal and Utili-zation of Municipal Sewage Sludge, Revised Draft,prepared for the U.S. Environmental ProtectionAgency, Sludge Task Force (Bethesda, MD: Feb.11, 1983).

5. Environment Reporter, “Wastes From Burning Di-oxin in Mobile Unit Would Be Excluded From ListUnder Proposal, ’ Environment Reporter, June 14,1985, p. 276.

6. Gerstle, R. W., and Albrinck, D. N., “AtmosphericEmissions of Metals From Sewage Sludge Inciner-ation, ”J. Air Pollut. Control Assoc. 32(11):1119-1122, November 1982.

7. Inside EPA, ‘ ‘EPA May Weaken Regulation ofDioxin-Containing Incinerator Wastes, InsideEPA 6(31):2, Aug. 2, 1985.

8. Keitz, E., Vogel, G., Holberger, R., et al., A Pro-file of Existing Hazardous Waste Incineration Fa-cilities and Manufacturers in the United States,EPA No. 600/2-84-052, prepared for the U.S. Envi-ronmental Protection Agency, Office of Researchand Development (Washington, DC: 1984).

9. Kleppinger, E. W., and Bond, D. H., Ocean In-

130 • Ocean Incineration: its Role in Managing Hazardous Waste

10.

11

12.

13.

cineration of Hazardous Waste: A Critique (Wash-ington, DC: EWK Consultants, Inc., 1983).Kleppinger, E. W., and Bond, D. H., Ocean In-cineration of Hazardous Waste: A Revisit to theControversy (Washington, DC: EWK Consultants,Inc., 1985).League of Women Voters of Texas EducationFund, “Independent Observations on Ocean In-cineration, A League Member’s Experiences onVulcanus II Voyage, November 4-9, 1983, ” pre-pared by D.B. Sheridan (Austin, TX: League ofWomen Voters of Texas Education Fund, 1983).Pahl, D., ‘ ‘EPA’s Program for Establishing Stand-ards of Performance for New Stationary Sources ofAir Pollution, ” J. Air Pollut. Control Assoc.33(5):468-482, May 1983.Trenholm, A., German, P., and Jungclaus, G.,Performance Evaluation of Full-Scale HazardousWaste Incinerators, EPA/600/S2-84, contract report

14.

15.

16.

17.

prepared for the U.S. Environmental ProtectionAgency (Washington, DC: May 1984).U.S. Environmental Protection Agency, Office ofWater, Incineration-At-Sea Research Strategy(Washington, DC: Feb. 19, 1985).U.S. Environmental Protection Agency, Office ofPolicy, Planning and Evaluation, “Background Re-port I: Description of Incineration Technology, ”Assessment of Incineration as a Treatment Methodfor Liquid Organic Hazardous Wastes (Washing-ton, DC: March 1985), p. 30.U.S. Environmental Protection Agency, ScienceAdvisory Board, Report on the Incineration of Liq-uid Hazardous Wastes by the Environmental Ef-fects, Transport and Fate Committee (Washington,DC: April 1985), pp. 20, 23.Zurer, P. S., ‘‘Incineration of Hazardous Wastes atSea—Going Nowhere Fast, ” Chem. Engr. News,Dec. 9, 1985, pp. 24-42.

Chapter 8

Environmental Releases FromOcean Incineration

Contents

PageData Limitations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... , . . . . .......133

Types of Environmental Releases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ........133Marine Spills . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ........................134Incinerator Upset . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .142Fugitive Emissions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..........143Normal Stack Emissions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...144

Summary and Comparison of Total Releases From Land-Based and Ocean Incineration ..l52

Chapter 8 References. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...............154

Tables

Table No. Page

13. Accidental Releases From Land-Based and Ocean Incineration . ...................13614. Annual Tonnages of Hazardous Materials and Crude Petroleum Passing Through

Various U.S. Ports in 1984 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ., .........,..14115. Average Annual Tonnages of Petroleum Products and Chemicals in Mobile Bay .. ...14216. Shipments of Petroleum and Hazardous Substances in the Gulf of Mexico,

Fiscal Year 1983 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ....14217. Average Expected Annual Releases From Storage and Transfer Operations. . ........14418. Estimated Inputs of PCBs to Various Marine Waters . . . . . . . . . . ...................14619. Maximum Concentrations of Three Metals Allowed in Wastes

To Be Incinerated At Sea . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .....................14720. Comparison of Inputs of Seven Metals to the Gulf of Mexico From Incineration

and Land-Based Sources. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . . . . . . . .14821. Metal Concentrations Resulting From Ocean Incineration Under Three Different

Scenarios for Mixing of Emissions in Seawater . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...15022. Comparison of Metal Inputs From Ocean Incineration to Background Metal

Concentrations in the Uppe r60 Meters of the Open Ocean . ......................15023. Summary of Annual Incineration Releases for Two Model Wastestreams . . . . ........153

Figures

Figure No. Page9. Step-by-Step Flowchart for Land-Based and Ocean Incineration. . . . ................135

10. Spill Rates for the Vulcanus II in Mobile and Delaware Bays . ....................13711. Comparative Size Scale of an Incineration Vessel (the Apollo I)

and Other Typical Commercial Ships . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .139

Chapter 8

Environmental Releases FromOcean Incineration

Incineration is a technology primarily intendedto destroy hazardous wastes. However, as with anyhazardous waste technology, each phase of opera-tion has at least the potential to release waste orwaste products into the environment.

A full quantitative analysis of the magnitude andprobability of releases from incineration is not pos-sible, primarily because insufficient data exist onwhich to base such an analysis. This chapter firstcomments on these data limitations and then de-scribes the nature of releases associated with oceanincineration. It then presents and analyzes avail-

able data on the probability of such releases occur-ring, and compares these risks with those from sim-ilar activities (i. e., land-based incineration, marinetransportation of hazardous materials, and addi-tional sources of marine pollution).

The chapter ends with a summary and compara-tive discussion of the total releases expected fromland-based and ocean incineration. This summaryties together the large amount of information pre-sented in the chapter and provides an overview thatmay suffice for readers who do not wish to explorethe subject in detail.

D A T A L I M I T A T I O N S

Any discussion of risks arising from land-basedand ocean incineration is greatly hampered by alack of data on many key aspects. This chapter oftenrefers to such data gaps, particularly those cited byEPA’s Science Advisory Board. Significantly, ourunderstanding of risks from both land-based andocean incineration is comparably constrained bythis lack of needed data. Indeed, many of these datagaps apply to many or all other hazardous wastemanagement technologies as well.

Without sufficient data, a very large degree ofuncertainty taints all of the risk calculations andsome of the overall conclusions, as well. At the sametime, given the truism that no method for manag-ing hazardous wastes is risk-free, the most impor-tant information is that which provides for a com-parative assessment of risks. Although this task isdifficult and by no means free of uncertainties, an

evaluation of relative risk can be developed nowand subsequently refined as the information baseimproves.

For ocean incineration, data with which to as-sess the potential for both accidental and routinereleases are particularly scant, in part because ofthe relative lack of experience with this technology(at least in the United States). This necessitates areliance on indirect historical data for such releases(i.e., data collected for related activities such as haz-ardous materials transportation). In addition, thelack of experience has provided only limited oppor-tunities to collect data on routine releases occur-ring under a wide range of operating conditions.

‘OTA has examined the risks involvedardous materials, including waste (19).

T Y P E S O F E N V I R O N M E N T A L R E L E A S E S

Environmental release of waste from incinera- result from normal or routine

in transporta( ;on of haz-

operations, when,tion operations can occur as a result of accidents, for example, small fractions of unburned waste aresuch as vessel or truck collisions, leaking tanks, or emitted from incinerator stacks or waste or resid-upsets in incinerator operation. Releases can also ual ashes are handled. A full analysis of the envi-

133

1 3 4 . O c e a n I n c i n e r a t i o n : I t s R o l e

ronmental effects of land-based and ocean inciner-ation will ultimately require that both kinds ofreleases be characterized and quantified.

Several important distinctions can be drawn be-tween these two types of events.

Accidental releases are not predictable with re-spect to time or place, although historical data canbe used to develop estimates of their probability ofoccurrence. For events that occur relatively often,as do, for example, vehicle accidents, historical datacan provide accurate risk estimates. However, forrare events such as ship grounding, or for eventsarising from unique aspects of a new technology,historical data either are nonexistent or producemuch less reliable estimates.

Both the frequency and the magnitude of ac-cidental releases are subject to influence by regu-latory and technical factors. For example, use ofcontainerized systems for transporting wastes candecrease the quantity of wastes released in the eventof accidents, and restrictions on vessel transit dur-ing storm conditions should reduce the likelihoodof accidents.

Routine releases are easier to predict and quan-tify. Although the magnitude of routine releases canIbe minimized through technological design and

i careful practice, some release is inevitable from es-sentially any system.

Routine releases resulting from incineration caninvolve either the waste itself or products gener-ated as a result of the incineration. Accidental re-leases virtually always involve loss of the originalwaste itself.

This section describes the various types of envi-ronmental releases and, wherever appropriate,draws distinctions between land and ocean basing.The types of releases considered include the follow-ing: accidental releases from spills and incineratorupsets; and routine releases from fugitive emissions,normal stack emissions, and air pollution controldevice effluents.

Available data are discussed from two perspec-tives: First, the additional activities and risks spe-cifically associated with ocean incineration are high-lighted; and second, these risks are compared torisks associated with related activities, to providea broad context in which to view ocean incineration.

Marine Spills z

Typically, handling and transport of hazardouswaste to be incinerated involves many similar oridentical steps for both land-based and ocean in-cineration. Figure 9 presents a schematic represen-tation of such steps for land-based and ocean in-cineration. The potential for a spill to occur mustbe evaluated at each of these steps. For ocean in-cineration, an extra transfer and transport step isrequired to bring wastes to dockside, load them ontothe vessel, and transport them to the incinerationsite. This factor tends to increase the risk of acciden-tal release of wastes. (As discussed in ch. 6, imple-mentation of the containership concept, in whichwastes would be transferred directly from sourceto vessel in sealed containers, might substantiallyreduce this risk during handling on land and dur-ing vessel loading; increased handling of containerson board could increase the risk of a spill duringthe voyage. )

Table 13 summarizes steps in the waste flowwhere accidents can occur, and indicates the causeand type of, release in each case.

With respect to additional transportation andhandling risks applicable to ocean incineration,EPA estimated the probability of release for a shipwith characteristics similar to the Vulcanus II, oper-ating in two locations: 1) out of Mobile Bay in Ala-bama and incinerating at the designated Gulf ofMexico Incineration Site (app. C in ref. 22); and2) out of Philadelphia and Delaware Bay and in-cinerating at the proposed North Atlantic Inciner-ation Site (8). These analyses were based on con-sideration of historical safety and engineering datafor the maritime bulk chemical industry. Specifi-cally, bulk chemical transport data for tank shipsof comparable size operating worldwide between1969 and 1982 formed the basis of the analysis. Thedata were adjusted to account for the following spe-cial circumstances and the somewhat stricter de-sign and operational requirements applicable to in-cinerator ships:

• relative ease of maneuvering and use of sophis-ticated navigational equipment;

‘In this discussion, the term spill refers to a release caused by thebreaching of a cargo tank. Other releases caused by leaking valves,etc. , are considered later in the section on fugitive emissions.

Ch. 8—Environmental Releases From Ocean Incineration • 135

I


Table 13.—Accidentai Releases From Land-Based and Ocean incineration

Activity Cause of release Type of release Relevant mode

Waste pickup/loading/unloading:Drums . . . . . . . . . . . . . . . . . . . Mishandling Spill on land Land/ocean, bulkBulk liquids . . . . . . . . . . . . . .Overfilling, line break Spill on land Land/ocean, bulkContainers ., . . . . . . . . . . . . . Mishandling Spill on land Land/ocean, containerized

Road or rail transit . . . . . . . . . .Vehicle accident, tank or Spill on land Land/ocean, bulk/containerizedvalve leak Fire

Storage:At dockside . . . . . . . . . . . . . .Tank or container failure Spill on land OceanAt incinerator . . . . . . . . . . . .Tank or container failure Spill on land Land

Vessel loading. . . . . . . . . . . . . .Overfilling, line break Spill on land, water, Ocean, bulkor ship

Vessel transit . . . . . . . . . . . . . .Collision or grounding Spill to water or Ocean, bulkon ship

Incineration . . . . . . . . . . . . . . . . Upset or malfunction Increased emissions Land/ocean, bulk/containerizedBulk Iiquids or containers. . Mishandling Spill

SOURCE: Arthur D. Little, Inc., Overview of Ocean incerneration, prepared by J.R. Ehrenfeld, D. Shooter, F. Ianazzi, and A. Glazer, contract report prepared for the U.S.

●

●

●

●

●

●

●

Congress, Office of Technology Assessment (Washington, DC: May 1986).

segregated ballast design and dedicated bal-last and cargo tanks;double-hull and double-bottom design;dedicated port facility;specially trained crew;weather restrictions during transit;U.S. Coast Guard transit requirements (e. g.,moving safety zone); androutes to be used.

The probability of an accident occurring duringvarious segments of the transit was separatelyassessed for four locations: the pier or harbor, Mo-bile or Delaware Bay, the coastal zone, and theburn site. Four types of accidents were separatelyaddressed as well: collisions (ship/ship); rammings(ship/nonship); grounding; and nonimpact events(e. g., explosions, fires, structural failures, capsiz-ing).3 In addition, accident data were adjusted toaccount for the fact that not all accidents result inactual release of waste.

The resulting estimates are of two sorts: first, esti-mates of the probability of a spill (i. e., spill rate)of any size occurring at a given location or froma given type of accident; and second, a probability

‘Adjustments of the data were made where appropriate to accountfor conditions specific to a location and an accident type. For exam-ple, probabilities for vessel grounding in Delaware Bay were adjustedupward based on the higher rate of grounding in this region relativeto that experienced worldwide; probabilities for grounding in the Gulfof Mexico were adjusted downward to account for soft bottom condi-tions. No adjustments of data for nonimpact accidents were made,due to lack of sufficient information.

distribution that predicts the frequency of spills ofvarious sizes.

Estimation of Spill Rates

For a Vulcanus H-type ship, EPA’s estimatedspill rates for the Gulf of Mexico and for DelawareBay are presented in figure 10. The total spill ratesare the sum of those for the four locations or thefour types of accidents. These data suggest thatabout half of all spills in both locations can be ex-pected to occur at dockside or in the harbor or bay.Nonimpact casualties (e. g., explosions, fires, struc-tural failures, capsizing) are predicted to accountfor almost half of all spills in the Gulf of Mexico,but less than a third of those in Delaware Bay. Spillsdue to grounding are over four times more likelyin Delaware Bay than in the Gulf, largely becauseof differences in bottom conditions. Based on his-torical accident rates, a major fraction of spills inthe pier/harbor area are expected to take place whilethe vessel is moored, rather than during transit.

Based on these data, EPA predicts that the over-all spill rate for all accident types and locationswould be 6 per 100,000 voyages for the Gulf ofMexico and 9 per 100,000 voyages for DelawareBay. As can be seen from figure 10, most of thedifference in these two estimates is because of thehigher probability of grounding in the DelawareBay, due to harder bottom conditions.

These estimated spill rates for the Vulcanus IIare seven- to ten-fold lower than the historical spill


Figure 10.—Spill Rates for the Vulcanus // in Mobileand Delaware Bays

A. Spill Rates by Location

6

5

Pier/ Bay Coastal Burn Totalharbor area zone

Mobile Bay

Col l is ions Grounding Rammings Nonimpact Total

Accident type

Mobile Bay I!?,lT. Delaware Bay

SOURCES: MolWa Bay: U.S. Environmental Protection Agency, Office of Policy, Planningand Evaluation, “Background Report IV: Comparison of Risks From Land-Based and Ocean-Baeed Incineration,” Assessment of Incfneratlon as a Treat-ment Method for L/qu/d Organic Hazardous Wastes (Washington, DC: March19S5); Delaware Bay: Engineering Computer Optecnomics, Inc., “Analysis ofthe Risk of a Spill During a Single Voyage of the Vu/carrus // From the Portof Philadelphia to the Incineration Site in the Atlantic Ocean, ” prepared forthe U.S. Environmental Protection Agency (Annapolis, MD: Apr. 30, 1980).


rate for all tank ships of comparable size operatingworldwide between 1969 and 1982 (61 per 100,000voyages). Such a result is expected because of theadjustments made to account for the special safetyfeatures of incineration vessels and their operation.

Using EPA’s assumption of an average of 14voyages per ship per year, these spill rates indicatethat one accident could be expected to occur every800 years (Delaware Bay) to 1,200 years (Gulf ofMexico). These estimates are per ship; thus, if threeships were in operation, one spill would be expectedevery 270 to 400 years on average.

EPA’s spill rate estimates are subject to a num-ber of limitations. For example, spill rates only rep-resent a Vulcanus II-type vessel operating in spe-cific regions, and cannot be expected to apply toother vessel designs or locations. In addition, spillsof hazardous material go unreported to a signifi-cant degree. No upward adjustment was made toaccount for the number of unreported accidents andspills. Such an adjustment would affect the abso-lute probability of a spill for the Vulcanus II, butnot its safety relative to that of all tank ships oper-ating worldwide. 4

EPA’s spill rate estimates are highly sensitive tothe magnitude, reliability, and appropriateness ofadjustments made to historical spill data. For ex-ample, if it is assumed that only a quarter of allmarine spills are reported, then the actual spill fre-quency would be increased by a factor of 4. Theresulting spill rates would now be 1 per 200 to 300years (again per ship). If three ships were operat-ing, a spill could be expected every 67 to 100 years;if a larger fleet of 30 ships were employed, a spillcould be expected every 7 to 10 years.

Conversely, the downward adjustments made tohistorical spill data might be too conservative. Forexample, nonimpact accidents may well be affectedby design and operational features that are em-ployed (e.g., double-hull construction; sophisticatedfirefighting equipment). These factors were ex-cluded from EPA’s analysis due to a lack of quan-

4A number of other criticisms of the EPA analysis have been raised(6), based primarily on U.S. Coast Guard data on polluting incidentsin and around U.S. waters (20). However, most of these data are notrelevant to evaluating the risk of a spill from an incinerator vessel,in that: 1) the incidents did not result in any release of waste; 2) theincidents involved sources other than vessels; or 3) the vessels involvedwere of significantly less safe design (e. g., river barges).

titative information. Their consideration would re-sult in actual spill rates that would be even smallerthan EPA has estimated.

The factors listed above represent only some ofthe many inherent sources of uncertainty that af-fect the reliability of spill rate estimates. Even ifonly small uncertainties accompanied each of theindividual factors that influenced the calculation ofa spill rate, the combined uncertainties could leadto a highly questionable result. For this reason, theabsolute magnitude of such risk estimates must beused with great caution.

Comparing the relative risks for activities thatare subject to the same or similar uncertainties,however, can still be informative. Thus, a majorconclusion that is clearly supported by EPA’s spillrate analysis is that the operation of incinerationvessels should result in a significantly lower per-ship rate of spills than the rate for tank ships ingeneral.

Estimation of Spill Size

EPA rejected use of direct historical data on spillsize for tank ships, because such data are skewedtoward conventional single-hull tankers whose aver-age tank size is comparable to the entire cargo ofthe Vulcanus II. Instead, historical data on the ex-tent of damage caused by accidents were used toestimate the probability of occurrence of each ofthe following categories of events leading to cargoloss:

. involvement of a single cargo tank—80 per-cent of spill events,

. involvement of two adjacent tanks—15 per-cent of spill events, and

. involvement of three or more tanks—5 per-cent of spill events.

In each case, it was assumed that the entire con-tents of a tank involved in an accident were lost.Because the Vulcanus II is designed to remain afloateven after the loss of two of its tanks, cargo lossesfrom events involving damage to one or two tankswould be limited to their corresponding volume(about 100,000 and 200,000 gallons, respectively).However, for events involving three or more tanks,loss of the entire cargo (about 800,000 gallons) wasassumed. These assumptions are quite conserva-tive because of the unlikelihood that all the con-


Figure 11.–Comparative Size Scale of an Incineration Vessel (the Apollo l) and Other Typical Commercial Ships

.

Staten Island Ferry (Avg.)Length 300 feetGross Tonnage 2,576 tons

At-Sea Incineration's Apollo ILength 369 feetGross Tonnage 4,850 tons

SOURCE: At-Sea Incineration, Inc

tents of a tank would be lost in all accidents. These‘‘worst-case’ data suggest that an average spillfrom an incineration vessel would result in the re-lease of 19 percent of the total cargo, which wouldcorrespond to about 150,000 gallons in the case ofthe Vulcanus II.

Unfortunately, essentially no data are availablefor vessels of comparable size and possessing thedesign and operational features of incineration ves-sels. Moreover, because historical data collectedover only a few years may by chance include or ex-clude the very rare event that generates a very largespill, their reliability is highly questionable. Theseand the other limitations discussed above clearlyillustrate the problems associated with using his-torical data to estimate the average magnitude ofa low-probability, high-consequence event such asa marine spill.

Whatever its absolute magnitude or uncertainty,the average expected spill size from an incinera-tion vessel can logically be assumed to be signifi-cantly smaller than that resulting from a typicaltanker accident, where both tank and total cargosize tend to be much larger (see fig. 11).

Estimates of spill rate and size are certain to varybetween vessels, port locations, and burn sites.Thus, an analysis based on any one operation isof limited applicability to others, whereas a genericanalysis tends to obscure the potential for signifi-cant variation. This fact underscores the need forcomparing various vessel designs and operationplans as an integral part of assessing the safety ofocean incineration (see ch. 6).

Comparison of Releases From Transportationon Land and At Sea

EPA estimated the magnitude of releases thatwould be expected to occur as a result of accidentalspills during land and ocean transportation (21,22).Based on this comparison, EPA suggested that theocean transportation phase would contribute about20 percent of releases of waste caused by spills. Re-leases caused by spills during land transportationare estimated to be more than three times higherthan releases caused by spills during ocean trans-portation. Releases caused by spills during trans-fer and storage operations would be slightly lowerthan releases caused by spills during ocean transpor-


tation. Because spill releases from land transporta-tion, transfer, and storage are estimated to be iden-tical for land-based and ocean incineration, EPAsuggested that the total expected release due to spillsfor ocean incineration would be about 20 percenthigher than that for land-based incineration.

Even if accurate, however, such estimates do notadequately reflect the relative environmental con-sequences of releases. To do so would require con-sideration of such factors as the ease of cleaning upspills, the transport and fate of spilled material, thenature of exposure to organisms and humans, andthe actual health effects of the substances presentin the waste. Compared to estimation of spill rateand size, far more uncertainty and absence of dataaccompany the estimation of these additional fac-tors, which are considered in chapter 9.

Comparison of Marine Transportation ofHazardous Waste and Nonwaste Materials

Available data indicate that, with respect to num-ber of transits, quantities and types of material car-ried, and expected releases, ocean incineration en-tails a very small incremental increase in risk overthat routinely borne in the marine transport of haz-ardous materials. Even if a fleet of 30 vessels wereemployed, marine transport of hazardous ma-terials would increase by about one-tenth of 1percent; quantities of material spilled in the ma-rine environment would increase by an evensmaller fraction.

A discussion of the risks of accidental releases ofwastes while at sea or dockside should consider boththe types and quantities of hazardous non waste ma-terials (e. g., petroleum products, raw chemicalfeedstocks) that are handled and transported bysimilar means and routes on a routine basis.

Types of Material Carried.—Critics of ocean in-cineration argue that transport of hazardous wasteposes a greater risk than transport of hazardousnonwaste materials for two reasons: first, that wastematerials are more toxic or concentrated; and sec-ond, that incineration vessels would carry complexmixtures of different substances, whereas tank shipscarry pure substances, which are easier to clean upif spilled.

Typical liquid cargoes carried by tank ships in-clude crude oil, petroleum products, petrochemi-cals, liquefied gases, and nonpetroleum-based

chemicals. Thus all of the major categories of ocean-incinerable wastes are represented among materi-als routinely transported in raw form. In addition,many tank ships are designed and authorized tocarry numerous substances in various combina-tions, for example, petroleum products and non-petroleum-based chemicals. These materials, how-ever, are segregated in separate tanks, reducing thelikelihood that a mixture of substances would bereleased in a tank ship spill.

With respect to toxicity and concentration, themajority of waste suitable for incineration at seais derived from industrial processes that use a widevariety of chemicals in pure form. The composi-tion of waste generated by a given industrial proc-ess, therefore, tends to reflect rather closely the com-position of the feedstocks initially used.

However, industrial processes can alter the com-position of subsequent waste products in at leastthree respects. First, contaminants can be intro-duced; for example, solvents used for cleaning anddecreasing may contain dirt, grease and oil, andmetals not originally present in the feedstocks. Sec-ond, water content can be increased, diluting theoriginal material. Third, different substances canindeed become mixed in the process that generatesthe waste.

Thus, contamination or mixing can renderwastes resulting from industrial processes morecomplex than the nonwaste materials from whichthey were derived; at the same time, the concen-trations of particular toxic constituents may wellbe less than those of the raw materials. Becauseenvironmental toxicity is a function of both con-centration and composition, any generalizationabout relative toxicities of wastes and raw materi-als is impossible; rather, analysis on a case-by-casebasis is required.

Much public attention has focused on the trans-port of PCBs, which are no longer routinelyproduced or transported for industrial or other com-mercial purposes. Although PCBs are a small frac-tion of ocean-incinerable wastes, they are amongthe most environmentally persistent of all toxic ma-terials transported at sea, and have considerablepotential to be accumulated by exposed organismsand introduced into the food chain. For this rea-son, special regulatory attention is warranted forPCBs. (See box B in ch. 3.)


Quantities of Material Carried.-EPA has esti-mated that the amount of hazardous waste thatwould be transported by the six existing or plannedincinerator ships would be 0.03 percent of the to-tal volume of hazardous substances handled byU.S. ports in 1983 (50 FR 8226, Feb. 28, 1985).This calculation was based on U.S. Army Corpsof Engineers data reporting a total of 1.38 billionmetric tons5 of hazardous materials passing throughU.S. ports in 1983.

Table 14 provides a summary of U.S. ArmyCorps of Engineers data on the annual tonnagesof hazardous materials and petroleum passingthrough various U.S. ports in 1984, These amountsare compared to the quantities that would be car-ried by 1 or 30 incineration vessels similar in sizeto the Vulcanus ships or the significantly largerApollo ships.

Gulf of Mexico and Mobile Bay. —EPA has ex-amined data on shipments of petroleum and haz-

5The quantity cited by EPA is 8.70 billion barrels of hazardous sub-stances; this is roughly equivalent to 1.38 billion metric tons.

ardous substances in Mobile Bay and the Gulf ofMexico. The data distinguish between crude pe-troleum, petroleum products, and hazardous chem-icals. Table 15 presents data for shipments in andout of Mobile Bay between the years 1977 and1981. Table 16 presents similar data for the Gulfof Mexico in 1983 and indicates the total numberof shipments made.

The data in tables 15 and 16 provide the basisfor the following conclusions:

● Each incineration vessel with an annual capac-ity of 65,000 metric tons operating full timeout of Mobile Bay would increase total car-riage there by the following amounts:—for all commodities listed: 0.8 percent, and—excluding crude petroleum: 1.6 percent.

● Each such vessel would increase carriage in theGulf of Mexico by the following amounts:—for all commodities listed: 0.01 percent, and—excluding petroleum: 0.02 percent.

● Assuming that each such vessel made 14 tran-sits annual] y, the number of hazardous ma-terial shipments in the Gulf of Mexico would

Table 14.—Annual Tonnages of Hazardous Materials and Crude PetroleumPassing Through Various U.S. Ports in 1984

Quantity Transported in 1984(millions of metric tons)

Hazardous Crude Quantity normalized toLocation materials petroleum Total one Vulcanus vessel

Total for all U.S. ports (1983)b . . . . . . . . . . . . . . — — 1,364 21,290

Port of New York . . . . . . . . . . . . . . . . . . . . . . . . . 104 8 112 1,723Delaware River/Bay . . . . . . . . . . . . . . . . . . . . . . . 26 46 72 1,108Port of Mobile, AL . . . . . . . . . . . . . . . . . . . . . . . . 3 3 6 92Port of Lake Charles, LA . . . . . . . . . . . . . . . . . . 20 7 27 415Houston Ship Channel, TX. . . . . . . . . . . . . . . . . 46 11 57 877San Francisco Bay, CA. . . . . . . . . . . . . . . . . . . . 25 26 51 785

Annual quantityc

One incineration vesselVulcanus . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 0.065 1Apollo . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 0.100 1.5

30 incineration vesselsVulcanus . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2.0 30Apollo . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3.0 46

alncjudes the following commodhjes:Sodium hydroxjde Basjc chemicals Jet fuelCrude tar, ojls, gas Pajnts KeroseneDyes, pigments Gum, wood chemjcals Distillate fuel oiiAlcohols Insecticides, disinfectants Residual fuel oilBenzene and toiuene Miscellaneous chemjcais Lubricating oil and greaseSulfuric acid Gesoiine Naptha, petroleum solvents

%his 1983 quantity is cited in the preamble to EPA’s proposed Ocean Incineration Regulation, 50 FR 8228, Feb. 28,1985. The data are orfginaily derived from the WaterborneCommerce Statistics of the U.S. Army Corps of Engineers. A nationai total for 1984 was not avajiable at the tjme of publication of this report.

cEstimates based on information obtained from vessel owners.

SOURCE: Office of Technology Assessment, based on U.S. Army Corps of Engineers, Waterborne Commerce of the United States, Freight Traffic Tables for CalendarYear 1984.


I

I

Table 15.—Average Annual Tonnages of PetroleumProducts and Chemicals in Mobile Bay

(thousands of metric tons)

Commodity Tonnage a

Crude petroleum . . . . . . . . . . . . . . . . . . . . . . . . . 3,848Gasoline, jet fuel, kerosene, fuel oil,

and solvents . . . . . . . . . . . . . . . . . . . . , . . . . . . 4,018Benzene, toluene, and basic chemicals. . . . . . 155

Total. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7,821aAnnual averagea for the period 1977~1.

SOURCE: U.S. Environmental ProtectIon Agency, Office of Policy, Planning andEvaluation, “Background Report IV: Comparison of Risks From Land-Sased and Ocean-Baaed Incineration, ” Assessment of Inclneratlon asa Treatment Method for L/quid Organic Hazardous Wastes (VVashing-ton, DC: 19S5).

Table 16.—Shipments of Petroleum and HazardousSubstances in the Gulf of Mexico, Fiscal Year 1983

Volume ofshipments Number of

Commodity (mmt) shipmentsPetroleum. . . . . . . . . . . . . . . . . . 270 44,917Hazardous substances. . . . . . . 274 14,978

Total . . . . . . . . . . . . . . . . . . . . 544 59,895SOURCE: U.S. Environmental Protection Agency, Office of Policy, Planning and

Evaluation, “Background Report IV: Comparison of Risks From Land-Baaed and Ocean-Baaed Incineration,” Assessment of Irrcineratlon asa Treatment Method for Liquid Organic Hazardous Wastes (Washing-ton, DC: 19S5).

increase by about 0.09 percent, or less than 1per 1,000. If petroleum were included, the in-crease would be 0.02 percent, or 2 per 10,000.

EPA argues that stricter design and operationalrequirements applicable to incineration vesselswould decrease actual releases of hazardous mate-rial to the environment even further. Design fac-tors include the smaller tank and total cargo size,double hull, greater maneuverability, and shallowerdraft of incineration vessels. Operational require-ments include weather restrictions and U.S. CoastGuard controls on vessel transit. If such factors aretaken into account, EPA expects releases from eachincinerator ship operating in the Gulf to be lessthan 0.002 percent (or one fifty-thousandth) ofthose from routine transport of petroleum and haz-ardous material in the Gulf.

set would be limited because of the requirement forautomatic shutoff of waste to the incinerator in theevent of a malfunction. Nevertheless, during thistime waste could be expected to enter—and exit—the incinerator under conditions that deviated frompermit requirements. A significant amount of com-bustion would continue to occur because of the re-maining heat in the combustion chamber, althoughthe degree of combustion would almost certainlybe lower than the efficiency standard.

The amount of additional release would dependon both the length of the upset and the destructionefficiency attained under upset conditions. To il-lustrate the magnitude of the expected additionalrelease, a worst-case scenario might involve a 10-second delay in waste feed shutoff (see ref. 23; theproposed Ocean Incineration Regulation would al-low only 4 seconds). Assuming that during this 10seconds the destruction efficiency (DE) fell (in theworst case) to 90 percent, the quantity of unburnedwaste released would be equivalent to 2.8 hours ofoperation at a DE of 99.99 percent, or 280 hoursat a DE of 99.9999 percent. G

For a PCB burn requiring a DE of 99.9999 per-cent, about 10 such upsets during a 12-day (288-hour) burn would reduce the average DE by a fac-tor of 10, to 99.999 percent. If a DE of only 99.99percent were required (i.e., for incineration of non-PCB wastes), about 1,000 such upsets would beneeded to reduce the DE by a factor of 10, to 99.9percent.

This calculation highlights the fact that the higherthe desired DE is, the more sensitive the systemis to temporary incinerator upsets. Unfortunately,data are not available on the expected frequencyof upsets associated with either land-based or oceanincineration. Nor does evidence exist showing thatocean and land-based incineration technologies ex-perience different frequencies of upset. This issueof variation in operating conditions during extendedincineration is one area identified by EPA’s Sci-

Incinerator Upset

A second category of accidental release involvesany malfunction of the incinerator that results inthe release of undestroyed or partially destroyedwaste. The expected duration of an incinerator uP-. .

‘A reduction in DE from 99.99 percent to 90 percent would increasethe rate of emissions a thousand-fold; if the lower DE lasted for 10seconds, the amount of emissions would be equivalent to that nor-mally released in a period 1,000 times longer, or 10 seconds X 1,000= 10,000 seconds = 2.8 hours. Similarly, if the reduction in DE were

from 99.9999 percent to 90 percent, emissions would be equivalentto that normally released in 10 seconds X 100,000 = 1,000,000 se-conds = 280 hours.


ence Advisory Board (23) as warranting furtherstudy and attention. 7

Fugitive Emissions

Fugitive emissions, which are commonly asso-ciated with the transfer and storage phases of in-cinerator operation, are typically small, slow, orsporadic releases of waste from a variety of sources,including leaking seals, pumps, pipes, valves, andstorage tank vents. Unlike spills, most fugitive emis-sions are released to the atmosphere through vola-tilization; only rarely are fugitive emissions of anature or magnitude that would lead to the con-tamination of marine waters. Such releases can be

7The Science Advisory Board has suggested that operation on roll-ing and pitching seas may conceivable affect operating conditions. Op-ponents contend that there would necessarily be an inherent reduc-tion in the performance of a moving incinerator, while proponentsargue that such effects would be negligible and draw an anology tothe fuel injection system of a sports car.

largely controlled through design modifications andgood operating practices.

With respect to estimating magnitude, some fu-gitive emissions (e. g., small, intermittent pump orvalve leaks) are probabilistic (random) in nature.Others (e.g., breathing losses from storage tanksand working losses during the filling and empty-ing of tanks) are continuous, at least during a par-ticular activity. EPA has estimated fugitive emis-sions for an ocean incineration operation using anintegrated port facility of the type that ChemicalWaste Management, Inc., had proposed to buildat Chickasaw, Alabama. The calculation assumedthat one of the following two wastestreams was in-cinerated: an annual throughput of 56,000 metrictons of waste containing 35 percent PCBs, or 68,000metric tons of waste containing 50 percent ethy-lene dichloride (EDC).8

8Fugitive emissions from these wastestreams would probably be com-posed largely of volatile waste components, rather than PCB or EDCthemselves (app. B in ref. 22).


Under this scenario, EPA calculated that the re-lease of either waste through fugitive emissionswould be about 0.7 metric tons annually, or aboutone-thousandth of 1 percent (0.001 percent) of thetotal amount of waste handled (22). In each case,storage tanks, not waste transfer and handling, werethe major source of emissions, accounting for over80 percent of the total release.

EPA also estimated fugitive emissions from anocean incineration system using an intermediatewaste storage facility of considerably older design(Chemical Waste Management’s facility in Emelle,Alabama). EPA found that fugitive emissions couldbe expected to increase because of two factors: first,the extra transfers of waste to and from the Emellefacility; and second, the less airtight design of the

I Emelle storage tanks. Total fugitive emissions un-der this scenario would be 4.9 and 5.5 metric tonsannually for the PCB and EDC wastes, respectively(app. B in ref. 22). These levels would be sevento eight times higher than those resulting from the

I more modern, single-step operation in an integratedport facility like the one that was proposed forChickasaw.

Fugitive emissions calculated under each of thesescenarios represent the largest of all sources of re-leases for the handling and transfer phases of oceanincineration. Table 17 compares the various sourcesof releases for three systems: ocean incinerationusing a modern integrated port facility (e. g., theone planned for Chickasaw); an equivalent land-based incineration system; and ocean incinerationusing an older intermediate storage facility requir-

Table 17.—Average Expected Annual Releases FromStorage and Transfer Operations (metric tons per year)

Planned ExistingChickasaw Emelle Land-based

Release source facility facility equivalentTruck unloading/

loading (spills). . . . 0.03 0.1 0.03Transfer/storage

(spills) . . . . . . . . . . . 0.5 0.4 0.5Fugitive emissions . . 0.7 5.2 0.6

Total . . . . . . . . . . . . 1.2 5.7 1.1aAn annu~ w~te throughput of 59,000 metric tons iS assumed.

SOURCE: U.S. Environmental Protection Agency, Office of Policy, Planning andEvaluation, “Background Report IV: Comparison of Risks From Land-Based and Ocean-Baaed Incineration: Appendix B,” Assessment ofIncineration as a Treatment Method for Liquid Organic HazardousWastes (Washington, DC: 19S5).

ing a two-step transfer procedure (e. g., the exist-ing facility at Emelle). Total expected releases rangefrom 0.002 percent (Chickasaw and land-based) to0.01 percent (Emelle) of waste throughput.

Comparison to Land-Based Incineration

Using an approach similar to the one outlinedabove, EPA has estimated the amount of fugitiveemissions that could be expected from the additionalwaste storage and handling that ocean incinerationwould entail. This analysis indicated that, afteraccounting for all phases of operation, releases dueto fugitive emissions would be about 15 percenthigher for ocean incineration than for land inciner-ation (22).

Comparison to Other Sources ofFugitive Emissions

Data to compare levels of fugitive emissions fromocean incineration to levels from other sources aregenerally lacking. Numerous other sources exist atU.S. ports, given the very large quantities of haz-ardous materials handled by such ports. For exam-ple, in the Port of Mobile, about 30 waterfront fa-cilities are currently licensed to handle or storehazardous substances (22). In addition, there are,of course, thousands of other facilities locatedthroughout the United States that handle such sub-stances.

Normal Stack Emissions

Because incineration cannot completely destroywastes, stack emissions have at least the potentialto contain harmful levels of hazardous substancesand to convey them to the environment. These sub-stances include:

• unburned waste;● products of incomplete combustion (PICs);● toxic metals; and● acid gases (hydrochloric acid, sulfur oxides,

and nitrogen oxides).

The following discussion addresses the quanti-ties of each of these classes of emissions that couldbe expected to be released to the environmentthrough ocean incineration.

Ch. 8—Environmental Releases From Ocean Incineration . 145

Unburned Waste

This category of wastes is defined (in a regula-tory sense) through the selection of a few com-pounds considered to be representative of the en-tire waste. The selection is based on one of twocriteria: the compounds are present in the wastein high concentration or are judged to be particu-larly difficult to destroy through incineration. Thesecompounds are termed principal organic hazard-ous constituents, or POHCs. The regulatoryadvantage of such a system is that destruction effi-ciency need only be measured for a small set ofPOHCs, because their destruction to a particularlevel is assumed to indicate equal or greater destruc-tion of all the unmeasured components of the waste.Potential shortcomings of this definition are dis-cussed at length in chapter 2.

If the assumptions behind the definitions ofPOHCs and DE are accepted, and if the desiredDE is actually achieved, then the quantity of un-burned waste released through stack emissions canbe calculated in a straightforward manner. Thequantity is simply the product of the unburned frac-tion of the waste ([100— DE]+ 100) and the totalquantity of waste burned. Thus, if an incinerationvessel burned 50,000 metric tons of a waste con-taining 35 percent PCBs in a given year, and if theburns met the DE standard of 99.9999 percent, thequantity of unburned PCBs released would be:

100 - 99.9999 x 50,000 x 0.35 = 0.0175 metric tons, or100 17.5 kilograms

(38.5 pounds) annually

The magnitude of such releases would be ex-tremely sensitive to changes in the DE. For exam-ple, if a DE of only 99.99 percent were achieved,almost 2 metric tons of PCBs would exit the stackannually.

The unburned waste emitted by an incinerationvessel would be released over a rather large area,because of the movement of the ship during inciner-ation and the dispersion of the plume after release.This material would be further dispersed upon en-try into the sea, due to currents and wave action,although there is potential for concentration of emis-sions in the surface microlayer (see ch. 9).

The significance of releases of unburned wasteto the environment is unresolved. One approach

commonly used for evaluating significance is tocompare expected releases from ocean incinerationwith releases from other sources. Ocean incinera-tor emissions are typically released to the atmos-phere (unless a seawater scrubber is employed), butthey generally settle over the ocean surface, so thecontributions of other sources to both the atmos-phere and marine waters are germane. Availabledata for each of these environments are discussedbelow, using the example of PCBs.

Releases to the Atmosphere.—In the Gulf ofMexico, ambient (i.e., background) concentrationsof PCBs in the atmosphere have ranged between0.05 and 0.5 nanograms per cubic meter (ng/m3)(app. I in ref. 22). This atmospheric concentrationis estimated to result in 7 to 70 grams of PCBs be-ing annually deposited onto each square kilome-ter of the Gulf’s surface (g/km2 per year). Usingthis rate of deposition, EPA has estimated that eachyear between 10 and 100 metric tons of PCBs enterthe waters of the Gulf from the atmosphere (app.I in ref. 22).

Using this range as a measure of the backgroundflux of PCBs entering the waters of the Gulf fromthe atmosphere permits an estimation of the in-crease that could be expected to occur because ofocean incineration. The area of the ocean surfaceaffected by the incinerator plume is estimated tobe about 90,000 square kilometers (app. I in ref.22). Assuming a throughput of 50,000 mt of 35 per-cent PCBs and a DE of 99.9999 percent, the esti-mated flux of unburned PCBs from ocean inciner-ation would be about 0.2 g/km2 per year. g Thiswould yield an increase above background flux of0.3 to 3 percent over the affected area.

Averaged over the entire Gu]f these data indi-cate that each incineration vessel operating at a DEof 99.9999 percent would cause a 0.02 to 0.2 per-cent increase in the quantity of PCBs entering thewater from the atmosphere. At the upper end ofthis range, an increase in the number of vesselsoperating in the Gulf or a decrease in the DEachieved could result in a significant increase abovebackground.

9 17.5 kglyr + 90,000 km2 = 0.2 g/km2 per year,


Releases Directly Entering Marine Waters.—PCBs also enter marine waters from a variety ofother sources, including waste discharges, dump-ing, and rivers. For comparative purposes, table18 lists several estimates of direct PCB inputs tovarious marine waters from various sources.

The data indicate that ocean incineration em-ployed on a modest scale would cause an incre-mental increase in the total input of PCBs to ma-rine waters. Clearly, the relative magnitude andsignificance of such an increase would also vary withrespect to location. For example, in contrast to mostof the inputs from sources shown in table 18, theemissions from ocean incineration would be ex-pected to enter marine waters at considerable dis-tances from the coast. At these deep ocean sites,the emissions could represent a greater fractionalinput of PCBs, but would be dispersed over a muchlarger volume and have less adverse impact on ma-rine life or humans. Unfortunately, few data areavailable with which to assess the absolute signifi-cance of the consequences of the incremental in-crease in PCBs that would be caused by ocean in-cineration (see ch. 9 for a discussion of one study).

Table 18.—Estimated Inputs of PCBsto Various Marine Waters

Affected waters: Annual PCBsource loading (kg/yr)

New York Bight:a

Sewage sludge dumping . . . . . . . . . . . 800-2,000Dredge materials dumping . . . . . . . . . 3,500POTW discharges . . . . . . . . . . . . . . . . . 200-1,000Upstream sources. . . . . . . . . . . . . . . . . 3,100

Southern California Bight:b

Sewage . . . . . . . . . . . . . . . . . . . . . . . . . . 2,000

One incineration vesselat 99.9999% DEC . . . . . . . . . . . . . . . . . . 18

One incineration vesselat 99.99% DEC . . . . . . . . . . . . . . . . . . . . 1,800

aJ< o’~nnor, J. Klo@ and T. Knelp, “Sources, Sinks and Dletrtbutlon of orgmicContamlnant$ In the New York Bight Ecosystem,” Ecological Stress and theNew York B/@rt, G. Mayer (ad.) (Charleston, SC: Estuarine Research Faderatlon,19s2), pp. 931453.

bM. @nnor, “statement on Incineration of Hazardous Waate At B%” In HearingBefore the Subcommittee on Fisheries and Wildlife Conservation and theEnvironment and the Subcommittee on Oceanography of the Houee Committeeon Merchant Martne and Fisheries, 9Sth Cong., Ist sese., Dec. 7, 19S3, SerialNo. 9S-31 (lA@hington, DC: U.S. Government Printing Of fIce, 19S4).

cAssumes a throughput of 50,0W metric tons per year of u% PCB-laden waste.EPA haa proposed the higher DE of 99.8999% for ocean incineration of PCBS.

SOURCE: Office of Technology Assessment.

Products of Incomplete Combustion (PICs)

Data on the formation of PICs are scant for bothland-based and ocean incineration. Indeed, EPA’sScience Advisory Board has identified the lack ofdata on the formation of PICs as a major gap inour understanding of incineration, one that pre-cludes an accurate assessment of the full extent ofexposure and the impacts of incinerator emissions.

Emissions of PICs were studied in each of theprevious U.S. ocean burns, and in a number ofland-based incineration trials. Many questions re-main regarding the adequacy of sampling and analy-sis undertaken during the trials, especially withrespect to identifying and detecting PICs. The mostglaring shortcoming, which was common to virtu-ally all such measurements, was that only a smallfraction of all compounds in the emissions (bothparent compounds and PICs) was actually identi-fied and individually measured (app. E in ref. 22).Thus, the fraction of emissions that is actuallyPICs, as opposed to residual parent compounds,is unknown.

This factor alone can lead to underestimation ofPIC emissions by several orders of magnitude. Forexample, in past burns the sum of the amounts ofindividually identified and measured PICs typicallyaccounted for about 1 percent of the total unburnedhydrocarbons present in emissions (app. E in ref. 22).

Moreover, in most past trial burns, measure-ments were attempted for only a few PICs. In theocean incineration trials involving PCBs, for ex-ample, analysis was performed for only a singlePIC: tetrachlorodibenzo-p-dioxin (TCDD).

Other sources of uncertainty in estimating PICemission rates from existing data include the fol-lowing (app. E in ref. 22):

●

●

●

●

●

inconsistency in definitions of what constitutesa PIC;variations in sampling procedures and detec-tion limits for PICs;inconsistency in lists of compounds for whichsampling and analyses were undertaken;variations in waste feed, which is thought tobe a partial determinant of PIC composition;andvariations in incinerator type and operatingconditions.

Ch. 8—Environmental Releases From Ocean Incineration ● 147

What is needed is a systematic examination ofPICs to provide a consistent and comparative setof data for evaluating both land-based and oceanincineration. Currently, both the quality and quan-tity of existing data are insufficient to provide thebasis for any sound scientific conclusions.

Toxic Metals

Because ocean incinerators would be expectedto burn only liquid wastes with low solids content,metal emissions would be directly proportional tothe quantity of metals present in the waste feed.Essentially all metals present in the waste wouldexit the stack during the course of the burn.

EPA has proposed placing a regulatory limit onallowable concentrations of metals in wastes ac-cepted for incineration at sea (see ch. 7). Each of14 specified metals would be limited to no morethan 500 parts per million (ppm) in such wastes.At a throughput of 50,000 metric tons annually,a maximum of 25 metric tons (ret) of each of thesemetals would be released through incineration.

In addition, the proposed Ocean IncinerationRegulation would further limit the concentrationsof certain of these metals in the final blended wasteto be incinerated. This further limitation would beaccomplished through compliance with an environ-mental performance standard based on water qual-ity criteria for each metal (see ch. 7). EPA has calcu-lated the maximum quantity of particular metalsthat could be emitted without exceeding applicablewater quality criteria, using a model for plumedispersal and surface water mixing. For 3 of the14 specified metals, the model requires a wasteconcentration of less than 500 ppm. Allowable con-centrations of these three metals, along with re-sultant annual emissions (again assuming an an-nual throughput of 50,000 metric tons), are shownin table 19 (50 FR 51363, Dec. 16, 1985).

Because EPA would not limit the aggregatequantity of metals allowable in waste to be inciner-ated at sea, each individual metal could theoreti-cally be present up to its individual limit, Thiswould place a maximum theoretical limit on totalemissions for all 14 metals, calculated as follows:1.1 mt (silver) + 0.5 mt (mercury) + 17.5 mt (cop-per) + 275 mt (11 other metals at 25 mt each) =294 metric tons/year.

Table 19.—Maximum Concentrations of Three MetalsAllowed in Wastes To Be Incinerated At Sea

Allowableconcentrations Expected emissions

Metal (parts per million) (metric tons/year)

Silver . . . . . . . . 21.3 1.1Mercury . . . . . . 9 0.5Copper . . . . . . . 350 17.5aAsaumes an annual throughput of 50,000 metric tons.

SOURCE: U.S. Environmental Protection Agency, 50 FR 51363, Dec. 16, 1965.

This calculation greatly overestimates total metalemissions, because no waste would be likely to con-tain all 14 metals at concentrations even approach-ing the maximum levels indicated above. The fewavailable data that quantify the metal content ofwastes likely to be incinerated at sea indicate thatthe concentration of individual metals in liquid or-ganic wastes is typically one to three orders of mag-nitude lower than the 500 ppm standard (3). Themetal content of wastes actually incinerated at seain Europe and the United States is comparably low(1 ,9, 14).10 Nevertheless, in the following compar-isons, emissions of metals at the theoretical maxi-m urn are used as a means of considering worst-case conditions.

Comparison With Other Releases of Metalsto Marine Waters. —Metal emissions expectedfrom ocean incineration may be compared with in-puts of metals into marine waters from othersources.

Coastal Waters. —Resources for the Future (16)developed a database that estimates marine dis-charges of seven different metals (arsenic, cad-mium, chromium, copper, lead, mercury, and zinc)from land-based sources. Table 20 indicates theirestimate of the total amount of these metals dis-charged annually to the Gulf of Mexico. These in-puts can be compared to the theoretical maximuminput of the same seven metals that would resultfrom the operation of an incineration vessel.

The data indicate that land-based sources annu-ally deposit about 5,600 metric tons of these sevenmetals in the Gulf of Mexico. In contrast, basedon the proposed limits for ocean incineration, the

1OThe PCB waste that Chemical Waste Management, Inc. (4), pro-

posed to incinerate in the recently canceled EPA research burn con-tained four metals at detectable levels: chromium (35 ppm), lead (61ppm), nickel (16 ppm), and zinc (61 ppm).


Table 20.—Comparison of Inputs of Seven Metals to the Gulf of MexicoFrom Incineration and Land-Based Sources (metric tons)

Maximum percentAnnual land-based Maximum annual increase due

Metal loading to Gulfa incinerator emissionb to incinerationMercury. . . . . . . . . . . . . . . . . 27 0.5 1.9Copper . . . . . . . . . . . . . . . . . 628 17.5 2.8Cadmium . . . . . . . . . . . . . . . 645 25.0 3.9Arsenic . . . . . . . . . . . . . . . . . 757 25.0 3.3Lead. . . . . . . . . . . . . . . . . . . . 828 25.0 3.0Chromium . . . . . . . . . . . . . . . 1,317 25.0 1.9Zinc . . . . . . . . . . . . . . . . . . . . 1,405 25.0 1.8

Total . . . . . . . . . . . . . . . . . 5,607 143.0 2.6SOURCES: aResources for the Future, Renewable Resources DbAsion, Pollutant Discharges to Surface Wafers for Coasta/

Reg/ens, prepared for the U.S. Congress, Office of Technology Assessment (Washington, DC: February 1988).bEpA propo9~ Ocean Incineration Regulation 50 FR =22, Feb. 28, 1~5

theoretical maximum on incinerator emissionswould be 143 metric tons per ship per year.11 Thus,even if incinerated wastes contained the maximumallowable amounts of these metals, each incinera-tion vessel operating in the Gulf would increase theinput of these seven metals by about 2.6 percent.

Adding estimates for a number of metals ob-scures the fact that significant variation commonlyexists in the amount of various metals in wastes.This is true for both incinerable wastes and theother sources of metal inputs discussed above. TheIvariation takes on greater significance in light of,the fact that metals differ significantly with respectto human and environmental toxicity.

To illustrate this variation, table 20 indicates thequantities of individual metals contributed by land-based sources and (in the worst case) by operationof an incineration vessel. The data indicate thatmercury and zinc are discharged in the smallest andlargest amounts, respectively, from land-basedsources; inputs of zinc into the Gulf are more than50 times greater than inputs of mercury.

Also shown in table 20 is the maximum percentincrease in inputs of each of the seven metals thatwould result from the operation of an incinerationvessel. Interestingly, despite the fiftyfold differencein the actual quantity of mercury and zinc enter-ing the Gulf, the predicted relative increases in theinputs of these two metals resulting from incinera-tion are almost identical (1.9 percent for mercuryversus 1.8 percent for zinc). This similarity is due

1117.5 mt (copper) + 0.5 mt (mercury) + 125 mt (5 X 25 mt forthe other five metals) = 143 mt per ship per year.

to the fact that the proposed limitation on inciner-ator emissions specified for zinc is fiftyfold higherthan that proposed for mercury.

Finally, the data in table 20 indicate that, evenin the worst case, the incremental increase in metalinputs caused by incineration would be small forall seven metals, ranging between 1.8 percent (zinc)and 3.9 percent (cadmium).

Other available data on toxic metal inputs tocoastal marine waters include estimates for six me-tals in the New York Bight (13) and eight metalsin the Southern California Bight (24). The sourcesconsidered in these studies included municipal andindustrial wastewaters, atmospheric deposition, andstorm runoff. These data indicate annual metal in-puts of about 3,500 metric tons (in the SouthernCalifornia Bight) and 24,500 metric tons (in theNew York Bight). Using maximum emissions limitscalculated for these metals, one incinerator shipcould theoretically contribute about 4 percent(Southern California) and 0.5 percent (New York)of the respective metal burdens already enteringthese marine waters.12

Open Ocean Waters. —Currently some 300,000metric tons of acid and alkaline wastes are directlydumped into the ocean each year (7). This prac-tice is expected to continue for the foreseeable fu-ture. The maximum quantity of five toxic metals

]2The emissions from oce~ incineration, in contrast to these co~t~

inputs, would be expected to enter marine waters at considerable dis-tances from the coast. At these ocean sites, they might be a greaterfraction of total inputs, but also could be expected to disperse overa much larger volume and to cause less adverse impact on marinelife or humans.


(cadmium, chromium, copper, lead, and zinc) pres-ent in this waste is estimated to be about 630 met-ric tons (7). Relative to the maximum theoreticallimit on incinerator emissions for these five metals(1 17.5 metric tons annually), the amount dumpeddirectly into the ocean is about five times greaterthan the amount an incinerator vessel would emitin the worst case.

As a final comparison, metal emissions fromocean incineration can be compared to the quan-tity of metals present in sewage sludge that isdumped in the ocean. An estimate for the concen-trations of the five predominant metals (cadmium,chromium, copper, nickel, and zinc) present inNew York City’s sewage sludge was developed forthe City’s Department of Environmental Protec-tion (ref. 12, cited in ref. 17).13 The ocean dump-ing of New York City’s sewage sludge is estimatedto contribute approximately 540 metric tons annu-ally of these five metals, or almost five times themaximum theoretical quantity of these same metalsthat one incinerator ship could emit in a year.Because New York City’s sewage sludge repre-sents only about half of the total amount currentlydumped in the ocean (1 1), this source of metals tothe marine environment is even larger than theabove comparison indicates.

Comparison With Land-Based Incineration.—Land-based incinerators that would otherwise ex-ceed the particulate standard specified under theResource Conservation and Recovery Act (RCRA)(see ch. 7) are required to be equipped with stackscrubbers designed to control particulate emissions,Because most metals are strongly bound to partic-ulate matter, scrubbers should significantly reducemetal emissions from hazardous waste incineration.

EPA (22) compared expected emissions of me-tals from land-based and ocean incineration, usinga model liquid wastestream containing 100 ppm ofeach of four metals (arsenic, cadmium, chromium,and nickel). Arsenic is the most volatile of these,and EPA estimates that scrubbers remove only

about 50 percent of it; the other three metals areassumed to be removed at 90 percent efficiency.Using these assumptions, EPA predicts that totalmetal emissions from land-based incineration of thismodel wastestream would be one-fifth of those fromocean incineration.

EPA’s estimates of the scrubbers’ removal effi-ciencies might be too high for the incineration ofliquid wastes, because resulting particulate wouldfall at the low end of the particulate size range andwould be removed at a lower efficiency than aver-age (2). Nonetheless, incineration of waste at seawould clearly result in greater emissions of metalsthan incineration of the same waste on land at fa-cilities equipped with scrubbers.

Comparison With Background Metal Concen-trations in the Open Ocean.—EPA used anatmospheric plume/ocean transport model to esti-mate the rate at which metals would be depositedand how large an area would be affected by emis-sions from ocean incineration. For the model (4-metal) wastestream described in the previous ex-ample, the total amounts of each of the four me-tals deposited per unit area were calculated. Thesubsequent mixing of metals in seawater was ex-plored under three scenarios and the resulting metalconcentrations were calculated. Table 21 presentsthese scenarios and concentrations (app. I in ref.22).

Some limited field data provide estimates of back-ground metal concentrations in the open ocean.Background concentrations were calculated for theupper 60 meters, allowing a direct comparison tothe estimated input from ocean incineration underScenario 3. Table 22 presents the results of thiscomparison (App. I in ref. 22).

These data indicate that, for mixing to 60meters, 14 three of the four metals would be well be-low background. Only cadmium could be expectedto exceed its very low background concentration;its level in the affected area would roughly double

13New York city>~ sewage sJudge, as well as that from sever~ other

sewerage authorities in New York and New Jersey, is currently dumpedat a site in the New York Bight. Under current regulations to be com-pletely in effect by the end of 1987, all of this sludge, as well as thatfrom two newly constructed treatment plants in New York City, isto be dumped at the 106-mile Sewage Sludge Dump Site, located im-mediately adjacent to the proposed North Altantic Incineration Site.

l+ EPA’s pmPsed Ocea Incineration Regulation (50 FR 8245, Feb.28, 1985) would define the release zone for incinerator emissions ascomprising the upper 20 meters of surface water; this represents anestimate of the depth of the surface thermocline, above which the ini-tial mixing would be expected to occur. Initial mixing would be de-fined as “dispersion or diffusion of incinerator emissions into the re-ceiving water which occurs within four hours after release from theincinerator” (50 FR 8258, Feb. 28, 1985).


Table 21.—Metal Concentrations Resulting FromOcean Incineration, Under Three Different Scenarios

for Mixing of Emissions in Seawater

Resultingconcentration a

Scenario 1:All metals are deposited within thesurface microlayer, represented bythe upper 0.1 millimeter of the oceansurface in the affected area . . . . . . . . . . 320,000 pptb

Scenario 2:All metals are evenly mixed in theupper 1 meter of the affected area . . . . 32 ppt

Scenario 3:All metals are evenly mixed inthe upper 60 metersc of theaffected area . . . . . . . . . . . . . . . . . . . . . . . 0.53 ppt

aA99urnes that four metals (arsenic, cadmium, chromium, and niCkeO are Presentin the incinerated waste at 100 ppm each.

bPpt = parts per trllllon.CEPArS pro~~ ocean Incineration Re@atlon (50 FR S245, Feb. 28, l%) Would

define the releaae zone for Incinerator am18sions as comprising the upper 20meters of surface water this represents an estimate of the depth of the surfacethermocline, above which the Initial mixing would be expected to occur.

SOURCE: U.S. Environmental Protection Agency, Office of Policy, Planning andEvaluation, “Background Report IV: Comparison of Risks From Land-Based and Ocean-Based Incineration: Appendix l,” Assessment ofIncineration as a Treatment Method for Liquid Organic HazardousWastes (Washington, DC: 19S5).

under this scenario. Even if metals from emissionswere confined to the upper 1 meter of water, onlycadmium could be expected to exceed its back-

t ground level; in this case, however, the cadmiumlevel would be about 100 times its background con-centration.

In contrast, if all emissions were somehow en-tirely confined to the microlayer, all four metalswould far exceed background levels. This wouldbe true despite the fact that background levels ofmetals measured in the surface microlayer exceedthose measured in surface waters by a factor of any-

where from 1 to 50 (app. I in ref. 22). The signifi-cance of the microlayer is an area of considerablecontroversy, and is discussed in chapter 9.

Acid Gases

Because ocean incineration is not expected to em-ploy scrubbers to remove acid gases, the level ofacid emissions can be calculated directly from thechlorine (or other halogen) content of the wastefeed. Almost all of the organic chlorine content ofwastes would be converted through incineration tohydrogen chloride (HCl) gas, with much smalleramounts exiting in the form of other chloride salts,elemental chlorine gas, or organic chlorine (i. e.,as residual POHCs and PICs).

To examine the possibility that incineration ofhighly chlorinated wastes at sea might exceed theproposed environmental performance standard forHCl (see ch. 7), EPA (50 FR 8245, Feb. 28, 1985)developed a worst-case scenario by assuming thefollowing:

●

●

●

pure carbon tetrachloride, 92 percent chlorinecontent, is incinerated at a rate of 25 metrictons per hour;all chlorine exits as HCl at a rate of 23.7 met-ric tons per hour; andall HCl is deposited within 100 meters of theship and mixed to a depth of 20 meters (theestimated depth of the thermocline definingthe 4-hour mixing zone), which makes the totalvolume of the mixing zone 22 billion liters.

Under these extreme conditions, EPA estimated,the resulting decrease in alkalinity of seawater inthe mixing zone would be only about 1.3 percent,

Table 22.—Comparison of Metal Inputs From Ocean Incineration toBackground Metal Concentrations in the Upper 60 Metersa of the Open Ocean

Upper 60 meters Upper 60 meters Ratio of backgroundMetalb background level (ppt)c Scenario 3 level (ppt) to Scenario 3Arsenic . . . . . . . . . 1,100 0.53 2,075Cadmium . . . . . . . 0.3 0.53 0.57Chromium. . . . . . . 268 0,53 506Nickel . . . . . . . . . . 146 0.53 275aEPA’s proposed ocean Incineration Regulation (50 FR S245, Feb. 28, 19S5) would define the release zone fOr lfrcinera!or ernl9-

slons as comprising the upper 20 meters of surface watec this represents an estimate of the depth of the surface thermocline,above which the initial mixing would be expected to occur.

bASsumes that these four metals are present In the incinerated bVSSte a! 100 pprn each.cppt - pans ~r trilllon.

SOURCE: U.S. Environmental Protection Agency, Office of Pollcy, Planning and Evaluation, “Background Report IV: timpari-son of Risks From Land-Based and Ocean-Baaed Inclneratlon: Appendix l,” Assessment of /incineration as a Treat-ment Method for Liquid Organic Hazardous Wastes (Washington, DC: 19S5).


Photo credit: Fred Ward @ 1985 National Geographic Society

The Vulcanus // incinerator ship, now owned byChemical Waste Management, Inc., operating in theNorth Sea. The plume from the ship is composed

mostly of steam and hydrochloric acid.

well below the 10 percent change allowed by theproposed standard.

This scenario has been challenged on the basisthat it ignores potential impacts that could occurat the higher concentrations of acid that would ex-

ist before initial mixing was achieved (i. e., before4 hours had elapsed). In particular, regions of thesurface microlayer that came in direct contact withthe incinerator plume might well be exposed to veryhigh (though transient) HCl concentrations. In thatevent, a large proportion of the organisms in thisarea could be impaired or possibly killed.

However, given the intermittent nature of oceanincineration, the relatively small size of the affectedarea, and the high renewal rate of the surfacemicrolayer resulting from new growth and replen-ishment from adjacent areas, the long-term net lossof biomass would probably be small or non-existent.A more extensive discussion of the nature and sig-nificance of the surface microlayer is presented inchapter 9.

Acid wastes are currently directly dumped intothe ocean at two sites in the North Atlantic Ocean(7), The rate of dumping of this waste and the sizeof the dumping area are such that the concentra-tion of acid entering surface waters greatly exceedsthat expected from an incineration vessel, by a fac-tor of about 250 (9). In some cases, transient (1to 4 hours) perturbations in the alkalinity of sea-water have been observed following the dumpingof acid waste, although no significant effects on ma-rine life have been observed. In contrast, exten-sive monitoring of past ocean incineration burnshas not detected any change in seawater alkalinity(see ch. 11).

Air Pollution Control Device Effluents

This waste, which is generated in very largequantities by land-based incinerators equipped withscrubbers, contains all of the particulate, metals,and acid gases removed from incinerator emissions.EPA (app. Fin ref. 22) calculated the following an-nual composition and quantity of scrubber effluentfrom a land-based incinerator burning 50,000 met-ric tons of PCB waste annually and complying withall RCRA standards (waste metal content was as-sumed to be 100 ppm each of arsenic, cadmium,chromium, and nickel):

● total quantity— 1.34 million metric tons (morethan 99 percent wastewater);

. chlorine content—9,30() metric tons (O. 7 per-

cent of the total), mostly dissolved salts; and. ~et~ content—4. 5 metric tons each of cad-


mium, chromium, and nickel and 2.5 metric charged under a Clean Water Act permit as non-tons of arsenic. hazardous waste. Sludges generated through treat-

Scrubber effluents are typically neutralized,ment are normally considered hazardous underRCRA, and must be disposed of as such.

treated to remove particulate matter, and dis-

S U M M A R Y A N D C O M P A R I S O N O F T O T A L R E L E A S E S F R O M

L A N D - B A S E D A N D O C E A N I N C I N E R A T I O N

This section summarizes and compares estimatesof the total amounts of waste released by land-basedincineration and by ocean incineration. The com-parison highlights major differences between thesetechnologies with regard to their potential to causeexposure and adverse impacts.

IThe EPA incineration study (21) attempted to

quantify releases from each phase of operations forboth land-based and ocean incineration. The studyevaluated the incineration of two different wastes-.— --—- - — nfi m -- — * – :-.: — — . – –A – .- -—: . I . r -: -.urcdms: a PCB-contaminating waste typlcaJ 01 exisl-ing stockpiles; and an ethylene dichloride (EDC)waste representing a common (though simplified)industrial chlorinated wastestream. Table 23presents estimates of how much of each of thesewastes would be released during various phases ofincineration operations. For a full discussion of thederivation of these estimates and the assumptionsand uncertainties involved, the reader should con-sult the EPA study.

The absence of reliable data, particularly for PICemissions, and the need to invoke numerous as-sumptions that are difficult to verify, cast consid-erable doubt on the estimates and greatly limitstheir use for setting policy. In particular, the abso-lute quantities probably do not accurately reflectreleases from any actual operation.

The following discussion uses the data presentedin table 23 for comparative purposes only, to iden-tify substantial differences between the releases ex-pected from land-based and ocean incineration.

Within the limits of accuracy of EPA’s releaseestimates, land-based and ocean incineration ap-pear to pose comparable hazards with respect tothe overall quantities of wastes and waste productsreleased into the environment. However, the na-ture and location of the releases also play majorroles in determining the potential for humans and

the environment to be exposed to or harmed by thereleases. By highlighting these differences, chap-ter 9 compares risks to humans and the environ-ment posed by land-based and ocean incineration.

As an aside, data presented on the last line oftable 23 underscores the general advantage of in-cineration (on land or at sea) over land disposal asa means of managing hazardous waste. Expressedas a percentage of total throughput, releases ofwaste from incineration are minute, indicating thetremendous potential for incineration to reduceboth the quantity and degree of hazard associatedwith these wastes.

Ocean incineration can be expected to releasesomewhat greater quantities of waste and wasteproducts to the environment than land-based in-cineration. Increased releases are expected fromseveral phases of ocean incineration operations.

Transfer and Storage.—Ocean incinerationwould entail at least one extra step, namely thetransfer of wastes to the vessel itself. This additionalactivity would slightly increase the expected quan-tity of fugitive emissions and the likelihood of a spilloccurring.

Ocean Transportation.—Ocean transportationof hazardous waste, which would obviously occuronly for incineration that took place at sea, wouldincrease the risk of waste being released throughspillage. Assigning an annual average quantity tosuch an event is highly problematic, because it doesnot adequately reflect either the probability of a spilloccurring or the size of the spill. Available datastrongly suggest that a marine spill from an oceanincineration vessel represents a very low-probabilityevent; however, it is equally clear that the conse-quences of such an event could be catastrophic (seech. 9).


Table 23.—Summary of Annual Incineration Releases for Two Model Wastestreams

PCB wastes EDC wastesAssumptions:Concentration of PCB or EDC . . . . . . . . . . . . . . . . . . . . . . 350/0 50 ”/0Metal content (As, Cd, Cr, Ni) . . . . . . . . . . . . . . . . . . . . . . 100 ppm each 100 ppm eachAnnual throughput. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50,000 mt 68,500 mtDestruction efficiency. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 99.99990/0 99.99 ”/0Use of modern transfer facility . . . . . . . . . . . . . . . . . . . . . Yes Yes

Ocean Land Ocean LandEstimated reieases (mt/yr)a:Land transportation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2.1Transfer and storage . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1.2Ocean transportation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 0.6

Subtotal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3.9Normal stack emissions:

Unburned wastes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 0.1PICs b . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . <<0.1Metals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22.4

Stack subtotal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22,5Scrubber effluent metals . . . . . . . . . . . . . . . . . . . . . . . . . . —Total releases (mt/yr). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26.4

(as percent of throughput) . . . . . . . . . . . . . . . . . . . . . . . 0.053

2.11.1—

3.2

0.1<<0.1

4.54.6

17.9

25.70.051

2.71.20.84.7

6.820.627.454.8

—

59.50.087

2.71.1—

3.8

6.80.65.5

12.921.9

38.60.056

aTh~ ~elea~e~from land ocean tran~wflation and fr~nltransferand storage include both routifle (e.g., fugitiveemissions) and accidental EdeaS!3S. For releases due

to accidental events such as spills orincinerator upset, theestimates presented here must be interpreted with caution since they represent Iong-term averages; actualreleases from such events are probabilistic, and in a given year could range from zero to avery large amount.

All estimates have been rounded up to the nearest 0.1 metric ton for ease of calculations. Useof ascrubber is assumed for land incineration.bEsti matesof plc emissi ons are far more unce~ain thantheotherrough estimatespresented here, and are of questionable use even in the crude comparison for

which these data are intended. See text for a discussion of the variation in these values between land and ocean modes and between PCB and EDC wastestreams.The symbol “<< “ indicates that the estimated value is much less than 0.1 metric tons.

SOURCE: U.S. Environmental Protection Agency, Office of Policy, Planning and Evaluation, “Summary and Conclusions,” Assessment of Irrcineratlorr as a TreatmentMethod for Liquid Organic Hazardous Wastes (Washington, DC: 1985).

For these reasons, comparing the risks of spillsfrom incineration vessels to the risks of spills frommarine transportation of hazardous substances ingeneral is more appropriate than comparing themto transportation risks from land-based incinera-tion. This more appropriate comparison is pre-sented earlier in this chapter.

As expected, table 23 indicates a somewhat larger(20 percent) release from transporting and handlingwaste for ocean incineration than for land-basedincineration, primarily because of the additionalmarine transportation that would be involved. Theslightly larger releases expected for the EDC wasterelative to PCBs is due mostly to the higher as-sumed throughput.

Incineration. —For both land-based and oceanincineration, and for both types of wastestreams,the incineration process itself would be the majorsource of expected releases. Each of the three ma-jor categories comprising total incinerator emissionsis discussed below.

Unburned Waste. —More unburned EDC wastethan PCBs would be released because a lower de-

struction efficiency and a higher annual through-put apply to the EDC waste. Under the assump-tions employed, no differences in quantities ofundestroyed waste released from land-based andocean incineration are expected.

PICs. —All of the estimates for PIGs are basedon extremely limited field data, and cannot serveas the basis for sound generalizations. Thus, EPA’sestimates that much higher PIC emissions wouldbe expected from ocean incineration of EDC wastethan from land-based incineration, and from burn-ing EDC waste than from burning PCBs, cannotbe considered reliable (see previous section onPICs). The only possibly valid generalization is thatachievement of a higher DE should logically leadto lower PIC emissions. However, even this straight-forward prediction must await further field verifi-cation for both land-based and ocean incineration.

Metals. —The quantity of metals resulting fromburning the same type of waste is not expected todiffer between land-based and ocean incineration.However, the use of air pollution control equip-ment on some land-based incinerators (which rep-

I

I

154 ● Ocean /incineration: Its Role in Managing Hazardous Waste

resents a major regulatory distinction between thesetechnologies) is expected to alter the final disposi-tion of such metal emissions. For both the PCB andEDC wastestreams, the sum of metals present instack releases and scrubber effluents from land-based incineration would be equal to the stack re-leases of metals from ocean incineration.

The data in table 23 suggest that metals accountfor the great majority of releases from land-basedand ocean incineration. These estimates, however,depend entirely on the assumptions made about

metal content, which appear to have been substan-tially overestimated (see previous section on esti-mating releases of metals).

As is the case with PIC emissions, our presentunderstanding of metal emissions, both qualitativeand quantitative, is far from adequate for both land-based and ocean incineration. This major data gaplimits our ability to accurately assess the potentialfor exposure to and harm from incineration of haz-ardous wastes.


1.

2.

3.

i

4.

5.

Ackerman, D. G., and Venezia, R. A., “Researchon At-Sea Incineration in the United States, inVVastes in the Ocean, vol. 5, D.R. Kester, et al.(eds.) (New York: John Wiley& Sons, 1985), pp.53-72.Arthur D. Little, Inc., Overview of Ocean Inciner-ation, prepared by J.R. Ehrenfeld, D. Shooter, F.Ianazzi, and A. Glazer, for the U.S. Congress, Of-fice of Technology Assessment (Cambridge, MA:May 1986).Castaldini, C., Willard, H, K., Wolbach, C. D., etal., A Technical Overview of the Concept of Dis-posing of Hazardous Wastes in Industrial Boilers,EPA No. EPA-600/2-84-197, prepared for the U.S.Environmental Protection Agency, Office of Re-search and Development, Industrial EnvironmentalResearch Laboratory (Washington, DC: December1984).Chemical Waste Management, Inc., “Applicationfor a Research Permit To Incinerate HazardousWaste At Sea: Exhibit B“ (Oak Brook, IL: May24, 1985).Connor, M., “Statement on Incineration of Haz-ardous Waste At Sea, Hearing Before the Sub-committee on Fisheries and Wildlife Conservationand the Environment and the Subcommittee onOceanography of the House Committee on Mer-chant Marine and Fisheries, 87th Cong., 1st sess.,Dec. 7, 1983, No. 98-31 (Washington, DC: U.S.Government Printing Office, 1984).

6. Department of the Public Advocate, Division ofPublic Interest Advocacy, “Comments of the De-partment of the Public Advocate on EPA’s ProposedOcean Incineration Regulations” (Trenton, NJ:June 28, 1985).

7. EG&G Washington Analytical Services Center,Inc., Oceanographic Services, Industrial Waste Dis-

8,

9.

10.

11.

12.

13.

14.

poszd in Marine Environments, prepared by J.Cura, J. Borchardt, and C. Menzie, for the U.S.Congress, Office of Technology Assessment (Walt-ham, MA: February 1986).Engineering Computer Optecnomics, Inc., “Anal-ysis of the Risk of a Spill During a Single Voyageof the Vulcanus 11 From the Port of Philadelphiato the Incineration Site in the Atlantic Ocean, pre-pared for the U.S. Environmental ProtectionAgency (Annapolis, MD: Apr. 30, 1986).Fay, R. R., and Wastler, T. A., “Ocean Incinera-tion: Contaminant Loading and Monitoring, ” inWastes in the Ocean, vol. 5, D.R. Kester, et al.(eds.) (New York: John Wiley & Sons, 1985), pp.73-90.League of Women Voters of Texas EducationFund, “Independent Observations on Ocean In-cineration, A League Member’s Experiences onVulcanus 11 Voyage, November 4-9, 1983, ” pre-pared by D.B. Sheridan (Austin, TX: 1983).Leschine, T. M., and Broadus, J. M., “Economicand Operational Considerations of Offshore Dis-posal of Sewage Sludge, ‘‘ in Wastes in the Ocean,vol. 5, D.R. Kester, et al. (eds. ) (New York: JohnWiley & Sons, 1985), pp. 287-315.Metcalf & Eddy of New York, Inc., and Lawler,Matusky & Skelly Engineers, “Industrial Pretreat-ment Program for the City of New York Depart-ment of Environmental Protection, Task 4: Deter-mination of Technical Information Required Forthe Development of an Updated Industrial WasteOrdinance” (New York: Metcalf & Eddy of NewYork, Inc., May 1983), p. 53.Mueller, J. A., Jeris, J. S., Anderson, A. R., et al.,“Contaminant Inputs to the New York Bight, ”NOAA Tech. Memo, ERL MESA-6, 1976.Nauke, M. K., “Development of International Con-


trols for Incineration At Sea, in Wastes in theOcean, vol. 5, D.R. Kester, et al. (eds.) (New York:John Wiley & Sons, 1985), pp. 33-52.

15. O’Connor, J., Klotz, J., and Kneip, T., “Sources,Sinks and Distribution of Organic Contaminants inthe New York Bight Ecosystem, Ecological Stressand the New York Bight, G. Mayer (cd. ) (Charles-ton, SC: Estuarine Research Federation, 1982), pp.631-653.

16. Resources for the Future, Renewable Resources Di-vision, PoZlutant Discharges to Surface Waters forCoastal Regions, prepared for the U.S. Congress,Office of Technology Assessment (Washington,DC: February 1986).

17. Science Applications International Corp., “Assess-ment of Ocean Waste Disposal Case Studies, pre-pared for the U.S. Congress, Office of TechnologyAssessment (McLean, VA: Science Applications In-ternational Corp., Oct. 3, 1985).

18. U.S. Army Corps of Engineers, Waterborne Com-merce Statistics Center, Waterborne Commerce ofthe United States (New Orleans, LA: 1984).

19. U.S. Congress, Office of Technology Assessment,Transportation of Hazardous Materials, OTA-SET-304 (Washington, DC: U.S. GovernmentPrinting Office, July 1986).

20. U.S. Department of Transportation, U.S. CoastGuard, Polluting Incidents In and Around U.S.

Waters, Calendar Years 1982 and 1983, Comman-dant Instruction M16450.2F (Washington, DC:1983).

21. U.S. Environmental Protection Agency, Office ofPolicy, Planning and Evaluation, ‘ ‘Summary andConclusions, Assessment of Incineration as aTreatment Method for Liquid Organic HazardousWastes (Washington, DC: March 1985).

22. U.S. Environmental Protection Agency, Office ofPolicy, Planning and Evaluation, “Background Re-port IV and Appendices: Comparison of RisksFrom Land-Based and Ocean-Based Incineration, ”Assessment of Incineration as a Treatment Methodfor Liquid Organic Hazardous Wastes (Washing-ton, DC: March 1985).

23. U.S. Environmental Protection Agency, ScienceAdvisory Board, Report on the Incineration of Liq-uid Hazardous Wastes by the Environmental Ef-fects, Transport and Fate Committee (Washington,DC: April 1985).

24. Young, D. R., Moore, M. D., Alexander, G. V., etal., Trace Elements in Seafood Org-anisms AroundSouthern California Municipal Wastewater Out-falZs, Publication No. 60 (Sacramento, CA: Cali-fornia State Water Resources Control Board, 1978).

25. Zurer, P. S., ‘ ‘Incineration of Hazardous Wastes AtSea—Going Nowhere Fast, ” Chem. Engr. News,Dec. 9, 1985, pp. 24-42.

Chapter 9

Comparison of Risks Posed byLand-Based and Ocean Incineration

Contents

PageRisks of Human Exposure and Impact. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ., . .........159

Risks of Environmental Exposure and Impact . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 161Impacts From Routine Emissions . . . . . . . . . . . . . . . . . . . . . . ......................,..161Impacts From Accidental Spills . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...............162The Role of the Surface Microlayer . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. ...165

Additional Factors Relevant to a Comparison of Land-Based and Ocean Incineration ....166Onsite Versus Offsite Incineration, . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ............166Cost to Generators . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .....................167Ease of Monitoring and Surveillance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .,.,........,168Degree and Nature of Public Participation ....,, . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...168

Chapter 9 References. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ........169

Table

Table No. Page24. Major Areas of Concern Identified by EPA in Its Ocean Incineration

Research Strategy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..........164

Chapter 9

Comparison of Risks Posed byLand-Based and Ocean Incineration

Each of the several types of releases from land-based and ocean incineration has the potential toadversely affect exposed humans or organisms inmarine and terrestrial environments. This chap-ter explores the key differences between land-basedand ocean incineration technologies in terms of therelative risks they pose to human health and to theenvironment. The chapter also discusses the con-troversial topic of the surface microlayer’s role andthe potential for ocean incineration to adversely af-fect it.

An extensive literature describes the potential forthe various aspects of incineration to adversely af-fect humans and the environment. A full analysisof this literature is well beyond the scope of thisstudy. Moreover, such information rarely providessignificant insight into the comparative aspects of

risks posed by land-based and ocean incineration,partly because many risks cannot be quantified atall, and partly because the fundamentally differ-ent nature of the risks often precludes comparison.For example, no accepted methodology exists forcomparing a risk to human health with a risk tothe marine environment. Yet the comparative as-pects of risk are the most relevant in the policy set-ting that surrounds the issue of ocean incineration.

Because of such limitations, the discussion is re-stricted primarily to two subjects: the primary typesof risks posed by incineration technologies; and thedifferences between land-based and ocean inciner-ation that bear on the risks each poses to humanand environmental health. Where direct compari-son of risks is possible, available data are discussedaccordingly.

RISKS OF HUMAN EXPOSURE AND IMPACT

One of the major conclusions of EPA’s inciner-ation study was that ocean incineration would posea substantially lower risk of human exposure andhealth effects than land-based incineration poses.This conclusion was reached by estimating directexposures and the resulting incremental cancer risksassociated with each of the several types of stackreleases (POHCs, PICs, and metals).

The analysis, however, has several shortcomings:

●

•

●

it only evaluated cancer risks, ignoring the po-tential for other health effects; in addition, theaccuracy of the cancer risk estimates is ques-tionable;it considered in detail only direct exposure toemissions via inhalation and did not suffi-ciently assess other routes of exposure (e. g.,ingestion of seafood or terrestrial food cropscontaminated through bioaccumulation ofemission products);it analyzed risks for a hypothetical ‘‘most ex-posed individual, and not for the population

●

as a whole; although the level of risk wouldcertainly be greater for the former, relativerisks could differ if assessed for the populationas a whole; andit considered only routine stack releases assources of exposure and excluded spills, fugi-tive emissions, and releases due to incinera-tor upset.

Many exclusions were necessitated by the lackof data required to quantify the risks. For exam-ple, data on health effects other than cancer are gen-erally lacking for many of the substances presentin stack emissions. Similarly, estimation of risk toan entire population would require a quantifica-tion of exposure to various sectors of the popula-tion, which would be exceedingly difficult (and con-troversial) to perform.

Despite these shortcomings, however, the gen-eral conclusion that ocean incineration poses sub-stantially less risk to human health than does land-based incineration appears both logical and reason-

159


able, if judged from within the limits of our cur-rent level of understanding. Several lines of rea-soning support this conclusion.

The major releases from incineration are fromthe incineration process itself, and incineration atsea is much further removed from human popula-tions than is land-based incineration.

The general population would be exposed to sub-stantially fewer releases from ocean incinerationthan from land-based incineration. The two proc-esses would release roughly comparable quantitiesof material, and several plausible or demonstratedroutes could expose humans to waste products re-leased even in the open ocean. Such factors asatmospheric and ocean dilution volumes, the rela-tive human dietary intake of marine versus terres-trial food products, and distance, however, wouldlessen the exposure from ocean incineration.

EPA’s estimates assign the major portion of in-cremental cancer risk to metal emissions, which arepredicted to be higher for ocean incineration be-cause scrubbers would not be required on inciner-ation vessels. Nonetheless, the risks to humanhealth from exposure to metals would probably not

~ be greater for ocean incineration than for land-18 based incineration, for the following reasons:

● The 55 percent of land-based incinerators notequipped with scrubbers would release metalsin the same uncontrolled fashion as ocean in-cinerators, but because land-based incinera-tion occurs closer to humans, it would producea higher exposure.

● Regulations governing land-based incinerationdo not specify limitations on metal content ofwastes, as would the proposed regulation forocean incineration.

● Although land-based incineration regulationscontrol particulate (but not metals per se) andrequire scrubbers for wastes that would other-wise exceed the standard, the removal effi-ciency of scrubbers for metals is probably lowerthan assumed by EPA, particularly for the liq-uid wastes relevant to this discussion. Inciner-ation of liquids generates only low levels ofsmaller than average particulate, and scrub-bers operate less efficiently at low particulatedensity and on small particulate (l).

● Although toxic metals removed by scrubbersare deposited in scrubber effluents and sludges,EPA’s study did not assess the considerablepotential for human exposure to these wastes,for example, via groundwater for landfilledsludges, and drinking water for discharged ef-fluent.

One recent study modeled the exposure of hu-mans to emissions of PCBs, through both direct andindirect pathways, and concluded that exposurewould be considerably lower from ocean incinera-tion than from land-based incineration (9). Forland-based incineration, the study evaluated hu-man exposure to PCBs that could result from in-halation, drinking water, and diet (terrestriallygrown food); for ocean incineration, it evaluatedhuman exposure that could result from a seafooddiet (fish and shellfish). In considering dietary ex-posures to PCBs, the study compared average ex-posures from land-based incineration with worst-

case exposures from ocean incineration (i. e., indi-viduals were assumed to receive all seafood fromthe ocean incineration site).

The study concluded that dietary exposures toPCBs would still be 20 times higher from land-based incineration. Predicted exposures from in-halation were two orders of magnitude higher forland-based incineration, and predicted exposuresfrom drinking water were comparable to those ex-pected from ingestion of seafood.

Because of a lack of information, the study didnot model exposures that would result from the con-centration of emissions in the ocean surfacemicrolayer (see later section in this chapter). If themicrolayer is an important contributor to the ma-rine food chain, the relative magnitude of dietaryexposures could be altered significantly.

One possible major exception to the generaliza-tion that ocean incineration would pose no greaterrisk to human health than land-based incinerationposes is the unlikely event of a catastrophic spill,particularly one occurring close to shore. Estimat-ing the extent of health risk from direct and indirecthuman exposure to spilled waste materials is fraughtwith difficulties. However, such risks would prob-ably, under some circumstances, be much greaterfor ocean incineration than for land-based inciner-

Ch. 9—Comparison of Risks Posed by Land-Based and Ocean Incineration ● 161

ation, because the size of a spill could be expectedto be much greater at sea than on land.

Despite many years of operating experience, theactual impact of land-based incineration has beenvery difficult to study and ascertain. In part, thisis because of a general lack of understanding of twoissues identified by EPA’s Science Advisory Board(16)—the transport and fate of incineration prod-ucts in terrestrial ecosystems and the use of moni-

toring strategies and technologies that are less thanstate-of-the-art. Environmental monitoring is com-plex on land, however, because similar emissionscan arise from other land-based sources of pollu-tion, greatly complicating attempts to assign ex-posure or impacts to land-based incinerators or evento study the transport and fate of incineratoremissions.

RISKS OF ENVIRONMENTAL EXPOSURE AND IMPACT

Comparing the environmental consequences ofland-based and ocean incineration is much moredifficult (if not impossible) than comparing theirrisks to human health, because marine and terres-trial environments and the potential impacts in-volved are so fundamentally different. Even whendata allowing risks to be quantified are available,no accepted means exist for comparing the risksfaced by different organisms or environments.

Because of these difficulties, the discussion in thissection is limited to a description of the nature andexpected extent of environmental risks posed byocean incineration, and a sketch of aspects or re-sources unique to marine environments that mightbe affected by ocean incineration. Potential adverseeffects of routine emissions and of accidental spillsare discussed separately.

Impacts From Routine Emissions

The first area affected by incinerator emissionswould be the ocean surface contacted by the inciner-ator plume. Particular attention has been focusedon the so-called surface microlayer, representedby the skin or uppermost fraction of a millimeterof the ocean. This micro-environment has beenshown to contain high concentrations of both livingorganisms and contaminants, relative to the waterimmediately below the surface. Information con-cerning the nature and ecological significance of themicrolayer habitat is only beginning to emerge.With respect to ocean incineration’s potential ef-fect on it, EPA’s Science Advisory Board (16) hasidentified the surface microlayer as a priority forfurther study and testing, partly because of its prob-able key role in the food chain of the ocean. The

current state of knowledge regarding this habitatis discussed later in this chapter.

Various types of marine organisms have thepotential to be affected by incinerator emissions.Plankton, which are microscopic organisms presentin immense numbers in the water column, couldsuffer both short- and long-term damage from vari-ous components of incinerator emissions. Duringpast U.S. burns, attempts were made to sampleplankton and to look for short-term effects causedby changes in chlorine content, alkalinity, and theintroduction of trace amounts of organochlorinecompounds and metals. In addition, physiologicalindicators of plankton health (chlorophyll andadenosine triphosphate content) were also moni-tored. Although no effects were detected for anyof these parameters, the number and size of sam-ples analyzed may have been too small to detectchanges. Moreover, an adequate method of meas-uring long-term effects has not been developed, sothey cannot currently be assessed.

Fish and other swimming organisms near thesettling plume might be affected briefly by thechanges described above. These effects would beexpected to be limited both temporally and spatiallybecause of the mobility of affected organisms andthe relatively rapid neutralization or dilution of theresidual constituents to background levels.

Somewhat longer term effects can be studied byusing certain physiological measures of stress causedby exposure to toxic pollutants. Laboratory andfield experiments conducted during one of the pastU.S. ocean burns, in fact, detected such a stressresponse (ref. 11; also see discussion of past U.S.burns inch. 11). Activation of an enzyme-detoxifi-


cation system was detected in fish taken from theexposure zone, and similar results were obtainedin parallel laboratory tests involving direct exposureof fish to raw (unburned) waste material. In thelaboratory studies, enzyme levels decreased to nor-mal levels when fish were returned to clean water,indicating that the response was a transient one.

These experiments provided the first direct evi-dence for an environmental effect attributable toocean incineration. Because the response was tran-sient and the duration and scale of the experimentwere limited, the full significance of these resultscannot yet be determined. EPA plans to study thisphenomenon further as part of the Agency’s OceanIncineration Research Strategy (14).

Longer term or more subtle impacts (e. g., ef-fects on reproduction or growth) are much moredifficult to study, especially in the field, and havenot been examined during past ocean burns. EPA’sResearch Strategy includes limited efforts to exam-ine such effects.

Bottom-dwelling organisms could be affectedby contaminants adsorbed to particles that even-tually became incorporated into bottom sediments,Because water at existing or proposed incineration

, sites is deep, such effects would probably be mini-mal, exceedingly difficult to detect, and long termin nature.

Prior to settling or dispersion of the incineratorplume, there is potential for adverse impact onmigratory and open-ocean species of birds. Boththe Gulf incineration site and the proposed NorthAtlantic site lie in known migratory routes. Theroutes are extremely broad, and the incinerationsites cover only a small fraction of their width.These facts, together with the intermittent natureof incineration activities and the typically high al-titude of migratory paths, should limit the extentof this type of impact. However, migrating birdsoften seek out ships or other platforms for resting;indeed, some reports suggest that birds may be at-tracted to incineration vessels, particularly at nightwhen the glow of the furnaces is visible for consid-erable distances. Whether birds would avoid theincinerator plume itself is not known (6,18).

The potential for adverse impact to marinemammals and turtles has also generated consid-

erable debate. The proposed Ocean IncinerationRegulation would require an endangered speciesassessment to be conducted and periodically up-dated, in compliance with the Endangered SpeciesAct.

Several endangered or threatened species havebeen identified in the vicinity of existing or pro-posed burn sites. This issue has recently been raisedin the context of EPA’s designation process for theNorth Atlantic Incineration Site. An EnvironmentalImpact Statement (EIS) on the site completed in1981 concluded that the site lay in migratory routesfor certain marine animals (13). New informationfrom the National Marine Fisheries Service(NMFS), however, indicated that the site also laywithin a high-use area for several marine mammals,including the endangered sperm whale (2).

Based on EPA’s updated assessment of the sitefrom the perspective of endangered species (17),NMFS granted conditional approval to using thesite for a research burn (7). Final designation ofthe North Atlantic Incineration Site will require amore formal biological opinion fully addressing thiscontroversial issue.

Impacts From Accidental Spills

The most severe environmental impacts associ-ated with ocean incineration would be those result-ing from an accidental spill of hazardous wastes.There is a general consensus that, under most cir-cumstances, spilled material would be impracticalor impossible to clean up, especially as distancefrom the loading dock increases. Although a spillis considered an unlikely event, the severity of itsconsequences and the difficulty of cleanup warranta comprehensive evaluation of the risk involved.

Unfortunately, few data are available for assess-ing the magnitude of the damage that would re-sult from a major spill of hazardous wastes in ma-rine waters. Innumerable determinants of fate andeffects must be understood in order to undertakesuch an analysis. These include the following:

● the nature of the waste: factors such as den-sity and volubility would determine the waste’ssubsequent behavior (e. g., sinking, floating,or dissolution in the water column);

Ch. 9—Comparison of Risks Posed by Land-Based and Ocean Incineration • 163

the composition of the waste: the fate of mix-tures of different wastes would be complex andhard to predict;the properties of individual constituents: fac-tors like toxicity, persistence, and potential forbioaccumulation would dictate subsequent ex-posure and impact;the location and characteristics of the spill site(harbor, coastline, open ocean): water depthand bottom terrain; currents, tides and otherdeterminants of dispersal rate; the presenceand value of resources; nature and extent ofbiological activity; and ecological sensitivitywould all influence the magnitude of impactsfrom the spill; andthe potential for cleanup or recovery: the dis-tance from shore and the expense and avail-ability of appropriate technologies would af-fect response to a spill.

For most hazardous materials, a significant spillin almost any location would result in considerableimmediate destruction of biomass and loss of mostorganisms in and around the spill. Acute effectscould result from physical impacts (e. g., smother-ing of bottom-dwelling organisms, or coating ofbirds’ wings) as well as from the immediate toxiceffects of caustic or other highly reactive substances.Chronic effects would be more widespread andlong-lasting, particularly for toxic and persistentchlorinated hydrocarbons, which are among themost likely candidates for ocean incineration.

The following discussion of the possible effectsof spills focuses on two PCB wastes—one heavierthan water (sinking) and one lighter than water(floating)-and on two possible spill locations—either an open-ocean setting, such as the burn siteitself, or an enclosed harbor or bay, such as Mo-bile. Many of the effects described would be likelyto occur only in a worst-case situation. 1 Effects frommaterials that differ from PCBs in toxicity or per-sistence would be more or less severe and long--lasting.

1 Note that PC, 13s are only one of many wastes that could be inciner-ated at sea Although they are highly persistent in the environment,the} arc not the most toxic of such wastes (see box B in ch. 3). I.argequantities of chlorinated hydrocarbon nonwasfe materials are routinelytransported by sea (see ch. 8),

A spill of sinking material in the deep water ofthe incineration site would probably pose the leasthazard, but would also be most difficult to cleanup. Acute effects on plankton or other organismswould largely be limited to those caught in the wastemass itself as it descended toward the bottom, Cur-rents and waste volubility, among other factors,could serve to further disperse waste as it passedthrough the water column, thereby increasing thearea of immediate impact. The bottom-dwellingcommunity would be immediately and most heavilyaffected in this scenario. In the worst case, a sig-nificant portion of the organisms in the affectedzone could be eliminated, and long-term contami-nation of bottom sediments could severely limitrecolonization. Chronic effects would be most likelyfor surviving bottom-dwelling organisms, althoughremobilization of contaminated sediments by bot-tom currents, bioturbation, or other means couldincrease the size of the affected area.

A floating waste spilled at the incineration sitewould probably spread over a broad area relativelyrapidly. Damage would be greatest for the surfacemicrolayer and for organisms living in or frequent-ing water near the surface. A significant portionof such organisms would experience acutely toxicor even lethal effects, whereas organisms with lessexposure could be expected to show chronic effectsfrom more gradual accumulation.

Compared to a spill in the open ocean, the con-sequences of a spill in a confined and shallow area,such as a harbor or bay, would probably be moresevere. Planktonic effects from the high concentra-tions of PCBs could be expected. Because PCBstend to adsorb strongly to organic matter, organ-isms like shrimp larvae, which feed on organic mat-ter, could suffer serious acute and chronic effects.In the worst case, a sinking waste would kill mostor all bottom-dwelling organisms. Greater oppor-tunities for resuspension of contaminated sedimentsexist in shallow waters, so continued release of wastematerials to the water column could be expected.

A floating waste spilled close to land would prob-ably be the most likely to afford opportunities forpartial cleanup. But it could also harm not only ma-rine organisms, but humans and other shore life(e. g., birds, shellfish beds, and wetlands), as well.Volatilization of waste constituents from the sur-


face slick could pose direct inhalation risks to nearbyresidents. Many or most marine commercial andrecreational activities in the region would be af-fected immediately and possibly for the long term.

The potential effects of a PCB spill in the Dela-ware River and Estuary were recently assessed inrelation to a proposed research burn in the NorthAtlantic Ocean (10). For a spill of about 800 met-ric tons2 of waste containing 10 to 30 percent PCBs,three scenarios were modeled: 1) an upstream spillat or near the loading dock in Philadelphia, 2) amidstream spill near Wilmington, and 3) a spill atthe midpoint of the Delaware Estuary. Conserva-tive assumptions regarding the dispersion and fateof PCBs were used to generate a ‘ ‘worst-case’prediction.

For the first two scenarios, the results indicatedthat during the first several hours at a given loca-tion, water quality criteria and aquatic toxicitylevels would be exceeded and most fish would prob-ably be killed. Predicted long-term concentrationsin the river water or sediments would be muchlower, probably below those that have been dem-onstrated to cause any ecological effects. For thethird scenario—an estuarine spill-a kill also wouldoccur during the first several hours, affecting fish,plankton, and invertebrates, and in the worst caseinvolving the entire estuary. Long-term effects re-sulting from sediment contamination could includeaccumulation of measurable quantities of PCBs inshellfish such as oysters.

Most of the effects discussed above are difficultor impossible to quantify. Much of the criticism ofocean incineration identifies and focuses on themany sources of uncertainty inherent in determin-ing actual risk. Indeed, uncertainty is a clear themethroughout this entire discussion of risks.

Both EPA and its Science Advisory Board rec-ognize that much more information is needed toevaluate the full extent of risks posed by ocean in-cineration. Both have identified unresolved issuesand areas that need further research. The SAB (16)noted the following topics as needing more at-tention:

. understanding the role of the microlayer in the

‘Equivalent to one-fourth of the capacity of the Vukanus ZI, cor-responding to the loss of the entire contents of two of its eight cargotanks.

●

●

●

●

marine food web and the nature of its appar-ent high biological activity and ability to trapcontaminants;field-testing of the numerous models used byEPA in estimating impacts;better understanding the routes of exposure,food chains, and community structures in ma-rine environments;determining toxicities and bioaccumulationpotential of wastes and waste products in ma-rine settings; anddeveloping better means of assessing long-term—and sublethal effects on marine organisms,communities, and ecosystems.

EPA has developed a research strategy for oceanincineration (14), which specifically addresses manyof the remaining areas of uncertainty, and outlinesadditional research plans in both laboratory andfield settings. Table 24 lists the major areas of con-cern identified in EPA’s research strategy.

The SAB emphasized that uncertainty was byno means the exclusive domain of ocean incinera-tion, and that many of the areas the Board identi-fied also applied to land-based incineration andeven to other common combustion processes. Thediscussions in previous chapters concerning risksassociated with land-based hazardous waste disposaland with marine transportation of hazardous ma-

Table 24.–Major Areas of Concern Identified by EPAin its Ocean incineration Research Strategy

1. Composition of emissionsA. Development of appropriate sampling and analysis

methodsB, Determination of the composition of emissions

from an at-sea PCB research burnIl. Exposure assessment

A. Incineration research site selectionB. Environmental baseline samplingC. Environmental sampling during research burnD. Worst-case exposure scenariosE. Laboratory transport testingF. Transport model development, atmospheric and

aquaticG. Transport model validation

Ill. Biological effects assessmentA. Acute and chronic toxicityB. BioconcentrationC. GenotoxicityD. Effects on the surface microlayer

IV. Comparative environmental risk/hazard assessmentSOURCE: U.S. Environmental Protection Agency, Office of Water, /m3rreratiorr-

At-Sea Research Strategy (Washington, DC: Feb. 19, 1965).

Ch. 9—Comparison of Risks Posed by Land-Based and Ocean Incineration . 165

terials are indicative of uncertainties in these areas,as well. It is essential, therefore, to conduct a com-parative assessment of risks and to view any singleactivity such as ocean incineration in as broad acontext of related activities or risks as possible.

The Role of the Surface Microlayer3

The ocean’s uppermost surface, or microlayer,is in many respects an environment unto itself, onethat has properties distinct from the sea immedi-ately below and the air immediately above. Yet themicrolayer also appears to play a vital, but onlypoorly understood, role as an interface and mediumof transfer between sea and air.

The dimensions and composition of the surfacemicrolayer have not been thoroughly defined. Al-though it is most commonly visualized as a surfaceslick, which may be patchy, it is present even whenit is not visible. Its thickness, which is mostly de-fined operationally through sampling procedures,ranges from less than one-tenth of a millimeter toseveral centimeters. Many studies have demon-strated that the microlayer can be enriched in a va-riety of materials, including organic matter, me-tals, toxic organic chemicals, and active populationsof organisms (1 2). The organisms include a widerange of bacteria, minute animals or plants (the sur-face subset of plankton), and the eggs and larvaeof many different fish and crustaceans. Certain spe-cies are entirely unique to the microlayer (8).

The enrichment of various materials in themicrolayer can result in concentrations that are any-where from 2 to 10,000 times higher than thosefound just a few centimeters below the surface (8).However, the level of enrichment varies with timeof day, season, weather conditions, location, andthe particular substance or organism being consid-ered. This variability greatly complicates the studyand definition of the microlayer.

3This discussion is based on information from papers presented atan EPA-sponsored workshop on the Sea-Surface Microlayer, held inArlie, VA, on Dec. 18 and 19, 1985.

Various mechanisms for depositing and remov-ing materials and organisms from the microlayerhave been identified. These include wave andwhitecap formation, surface interaction of gas bub-bles, the natural buoyancy of eggs and larvae, thehydrophobic (water-repelling) nature of some or-ganic materials, surface flows and currents, andwind action. The combined effect of these mecha-nisms is a steady turnover, in which loss andreplenishment of essentially all components of themicrolayer occurs continuously. For example, vari-ous organic compounds and metals can remain inthe microlayer anywhere from a few seconds tomany hours (3). Mixing by surface flows, wave ac-tion, or other means drives surface material down-ward to underlying waters, which is now recognizedas an important transport mechanism for materi-als deposited on the ocean surface (19).

The ecological significance of the living portionof the microlayer is poorly understood. The enrich-ment of organic matter in the microlayer providesa food source for the minute plants and animalsthat reside there and accounts for their high densi-ties in the microlayer. These surface organisms, inturn, may play an important role in the marine foodweb, because they provide a basic food source forthe plankton that live in immediately underlyingwaters (8). These questions are currently under in-tense study, which should rapidly increase our un-derstanding of the microlayer’s role in marine com-munities.

The microlayer also appears to serve as an es-sential, if temporary, habitat for the embryonic lifestages of many fish and crustaceans, includingmany commercially important species (e. g., shrimpin the Gulf of Mexico).

The surface microlayer’s apparently vital rolesand its ability to become enriched in toxic organiccompounds and metals raise legitimate concernsover whether accidental spills and emissions fromocean incineration would cause significant environ-mental damage. Unfortunately, an evaluation ofpossible consequences must await further study, in-cluding the development of an adequate method-ology to sample and monitor the surface microlayer.


ADDITIONAL FACTORS RELEVANT TO A COMPARISON OFLAND-BASED AND OCEAN INCINERATION

This section presents several additional points ofcomparison and contrast relevant to a considera-tion of hazardous waste incineration technologies.These issues have been raised repeatedly in the de-bate over ocean incineration and are particularlygermane to determination of policy. The follow-ing discussion does not attempt to resolve these is-sues, but it presents common arguments that illus-trate the range of existing opinion.

Onsite Versus Offsite Incineration

Ocean incineration is, by definition, an offsiteactivity, in which the manager of wastes is distinctfrom the generator of wastes. Virtually all currentcommercial land-based incineration also occurs off-site, whereas private incineration typically entailsa generator processing wastes in a facility locatedat the site of generation.

Two concerns are raised about offsite incinera-tion, and indeed, about all offsite hazardous wastemanagement activity. The first is that offsite man-agement generates additional risks (because of ex-tra transportation and handling requirements) thatcould be avoided by management at the site of gen-eration. The second concern stems from the factthat the party who actually disposes of or treatswaste offsite is different from the party who gener-ated it. Some observers believe that the generator’saccountability for the generation and subsequenthandling of waste is substantially weakened, whichnecessitates elaborate regulatory mechanisms fortracking wastes from ‘‘cradle to grave. Further-more, because the waste managers are paid for ren-dering their service, these observers fear that profitbecomes a primary determinant of how carefullyand safely wastes are handled. Addressing this con-cern requires a more elaborate set of regulations

Photo credit: SCA Chemical Servicea/Ak Pollution Control Association

A commercial rotary kiln incineration facility,

Ch. 9—Comparison of Risks Posed by Land-Based and Ocean Incineration • 167

to ensure proper waste management than wouldotherwise be needed.

Many other observers argue, however, that thedevelopment of large, offsite management capabil-ity is desirable because it centralizes hazardouswaste management activities. According to thisargument, centralization takes advantage of econ-omies of scale and eases the tremendous regulatoryburden of permitting, monitoring, and ensuring theregulatory compliance of many smaller facilities.Moreover, given the number of waste generatorsthat cannot afford to manage their own wastes oruse the best technological means available, com-mercial facilities in the business of managing wastesmay be in a better position to do so safely and incompliance with regulatory requirements.

Both arguments have been legitimately raised inthe debate over the relative merits of land-basedand ocean incineration. Such a debate bears as wellon the larger issue of the roles and responsibilitiesof the public and private sectors in solving com-plex societal problems such as hazardous wastemanagement,

Cost to Generators

A related issue involves how much generatorswould have to pay for ocean incineration, relativeto the price of commercial land-based incineration.Many critics of ocean incineration argue that it isan inexpensive option that would be used in placeof more expensive but environmentally sounderpractices. The major reason cited for the low costof ocean incineration, relative to land-based inciner-ation, is the absence of a requirement for costly airpollution control equipment.

Many widely varying estimates of the cost ofocean incineration have been offered (4,5, 15). Thereliability of any of these estimates is questionable,however, because the many variables involved aredifficult or impossible to determine in advance.Some of the variables include:

●

●

size of the market for incineration of liquidwastes;type of wastes, including high-value markets(e.g., PCBs) and low-value markets (e.g.,aqueous organic wastes);

●

●

●

●

costs of other options for such wastes (com-petitive pricing);regulatory requirements, such as liability in-surance levels and monitoring and analysis re-quirements;port and incineration site locations; andnature and cost of required port facility de-velopment.

In light of such hard-to-predict factors, estimatedprices cover a broad range. For example, the fol-lowing price ranges (expressed in 1983 dollars permetric ton), averaged for several waste types, havebeen estimated for land-based and ocean inciner-ation and (for purposes of comparison) for land-filling (5):

Landfilling . . . . . . . . . . . . . $ 55 to $240Land-based incineration . . $360 to $500Ocean incineration ., . . . . $ 2 0 0 t o $ 4 0 0

Other studies exhibit wide ranges and variationsin price estimates, but virtually all support severalgeneralizations:

●

●

●

Incineration, whether on land or at sea, is con-sistently more expensive than traditional landdisposal alternatives. Indeed, cost is cited asthe primary reason for generators’ minimaluse of incineration to date.The gap between costs for disposal and in-cineration is expected to narrow as restrictionson land disposal are implemented and in re-sponse to generators’ growing concerns abouttheir long-term liability for wastes.On an average, ocean incineration is predictedto cost waste generators somewhat less thanland-based incineration, although price rangesare likely to overlap substantially. Despite ar-guments that ocean incineration’s lower costswould stem from the lack of a requirement forexpensive air pollution control equipment, twooperating factors are likely to be equally ormore determinative:1.

2.

ocean incineration’s annual throughputwould be higher, enhancing income-gener-ating potential; andocean incineration would concentrate on ahigh-value waste market, predominantly onwastes with high chlorine and energy con-tents and on easy-to-burn liquid wastes,


rather than on a mixture liquids, solids, andsludges.

Whatever ocean incineration’s eventual price, itprobably will for the foreseeable future lie betweenthe low costs of land disposal and the much highercosts of the new and emerging technologies dis-cussed in chapter 4.

Ease of Monitoring and Surveillance

The fact that ocean incineration occurs far fromshore has provoked two reasonable but opposinglines of argument by participants in the ocean in-cineration debate. Proponents point to the fact thatthe residual quantities of wastes or waste productsreleased during incineration are far less likely toharm humans if the incineration occurs far fromhuman populations. Opponents, however, considerocean incineration an ‘‘out-of-site, out-of-mind’solution to the hazardous waste problem. Indeed,monitoring and enforcement probably would bemore troublesome for an activity that occurs be-yond the horizon. In the absence of compensatorymeasures, the government’s (and perhaps equallyimportant, the public’s) ability to monitor the activ-ity and to detect regulatory violations could be ex-pected to decrease with distance from shore.

In response to such concerns, EPA has proposedseveral special regulatory provisions to be requiredonly of ocean incineration. These include require-ments for a full-time EPA shiprider on each voy-age, use of tamper-proof or tamper-detectablerecording devices for all automatic monitoring data,submission of all monitoring and waste analysisdata to EPA after each voyage, and, on request,inspections of facilities and records. Not surpris-ingly, the adequacy of such measures is also thesubject of considerable controversy.

Interestingly, a similar line of argument has beenapplied to private (onsite) incineration and other

noncommercial hazardous waste management fa-cilities. Concerns have been raised about the easewith which the government or the public couldmonitor such operations or could gain access to pri-vate information that was in the public interest.These concerns have arisen, for example, in de-bates over the siting of such facilities.

Degree and Nature of PublicParticipation

The high degree of public participation (and ingeneral, opposition) in the debate over ocean in-cineration is somewhat surprising, in light of thecommonly heard concern that the ocean has littlepolitical representation (“fish don’t vote”) and is‘ ‘in no one’s backyard. This level of participa-tion partly reflects the fact that designating specificports and sites for ocean incineration does haveclear local and regional consequences. The debatehas broadened beyond these concerns, however,and has taken on national dimensions; indeed, abroad-based ‘‘ocean constituency’ has developed.One result of this phenomenon is that the role ofocean incineration is increasingly being viewed ina broad context, as only one component in the de-bate over the shaping of a national hazardous wastemanagement strategy.

In contrast, land-based incineration remains achiefly local concern. Although public concern andopposition to the siting of land-based incineratorsis often equally intense, broader issues are less likelyto be raised in the process.

The government and the various interest groupsworking toward solutions to hazardous waste prob-lems have an obligation to recognize and considerthe interrelationships between these issues of localand national concern in order to raise the level andscope of the debate.

Ch. 9—Comparison of Risks Posed by Land-Based and Ocean Incineration ● 169


1.

2.

3.

4.

5.

6.

7<

8.

9.

10.

Arthur D. Little, Inc., Overview of Ocean inciner-ation, prepared by J. R. Ehrenfeld, D. Shooter, F.Ianazzi, and A. Glazer, for the U.S. Congress, Of-fice of Technology Assessment (Cambridge, MA:May 1986).Bigford, T. E., letter dated Mar. 20, 1985, fromThomas E. Bigford, Chief of the Habitat Conser-vation Branch, National Marine Fisheries Service,to David P. Redford, Marine Permits and Moni-toring Branch, U.S. Environmental ProtectionAgency.Carlson, D.J., ‘‘Organic Chemistry of the Sea Sur-face Microlayer, ” paper presented at the Sea-Surface Microlayer Workshop, Arlie, VA, Dec. 18,1985.Chemical Week, “Waste Disposal by Burning AtSea, ” Chemiczd Week, Apr. 11, 1979, p. 44.Emison, J., “Review of Incineration At Sea, ” EPAMemorandum, July 15, 1983.GESAMP (Joint Group of Experts on the ScientificAspects of Marine Pollution), “Scientific Criteriafor the Selection of Waste Disposal Sites At Sea, ’No. 16 in Reports and Studies of the Inter-Governmental Maritime Consultative Organization(London: 1982).Gordon, W. G., letter dated Sept. 10, 1985, fromWilliam G. Gordon, Assistant Administrator forFisheries, National Marine Fisheries Service, toTudor Davies, Director of the OffIce of Marine andEstuarine Protection, U.S. Environmental Protec-tion Agency.Hardy, J. T., ‘‘Phytoneuston: Plants of the Sea-Surface Microlayer, ” paper presented at the Sea-Surface Microlayer Workshop, Arlie, VA, Dec. 18,1985.Holton, G. A., Travis, C, C., and Etnier, E. L., “AComparison of Human Exposures to PCB Emis-sions From Oceanic and Terrestrial Incineration,Hazardous Waste and Hazardous Materials2(4):453-471, 1985.ICF Technology, Inc., “Potential Effects to theDelaware River and Estuary Resulting From aHypothetical PCB Spill From the Vulcanus II, ”prepared for Chemical Waste Management, Inc.(Washington, DC: Dec. 13, 1985).

11.

12.

13,

14

15<

16

17

18.

19.

Kamlet, K. S., ‘‘Ocean Disposal of OrganochlorineWastes by At-Sea Incineration, Ocean Dumpingof Industrial Wastes, B.H. Ketchum, et al. (eds. )(New York: Plenum Publishing Corp., 1981), pp.295-314.Meyers, P. A., ‘‘Processes Contributing to the Con-centration of Polychlorinated Biphenyls at the Sea-Surface Microlayer, ” paper presented at the Sea-Surface Microlayer Workshop, Arlie, VA, Dec. 18,1985.U.S. Environmental Protection Agency, Office ofWater Regulations, Criteria and Standards Divi-sion, Environmental Protection Agency Final Envi-ronmentzd Impact Statement (EIS) for North At-lantic Incineration Site Designation (Washington,DC: Nov. 25, 1981).U.S. Environmental Protection Agency, Office ofWater, Incineration-At-Sea Research Strategy(Washington, DC: Feb. 19, 1985).U.S. Environmental Protection Agency, Office ofPolicy, Planning and Evaluation, “Summary andConclusions, Assessment of Incineration as aTreatment Method for Liquid Organic HazardousWastes (Washington, DC: March 1985).U.S. Environmental Protection Agency, ScienceAdvisory Board, Report on the Incineration of Liq-uid Hazardous Wastes by the Environmental Ef-fects Transport and Fate Committee (Washington,DC: April 1985).U.S. Environmental Protection Agency, MarineOperations Division of the OffIce of Marine and Es-tuarine Protection, Assessment of the Impact of In-cineration of Chemical Wastes in the ProposedNorth Atlantic Incineration Site on Endangered andThreatened Species (Washington, DC: July 9,1985).Wastler, T. A., Offutt, C. K., Fitzsimmons, C. K.,et al., DisposaJ of Organochlorine Wastes, EPA-430/9-75-014, contract report prepared for the U.S.Environmental Protection Agency (Washington,DC: July 1975).Weller, R. A., “Mixing Down From the Micro-layer: The Role of Three-Dimensional Flows, ” pa-per presented at the Sea-Surface Microlayer Work-shop, Arlie, VA, Dec. 18, 1985.

Chapter 10

Overview of Federal Laws andRegulations Governing Incineration

Contents

Land-Based Incineration . . . . . . . . . . . . . . . . . . . . . . . . . .

Ocean Incineration. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Statutes Governing Related Activities . . . . . . . . . . . . . . .Designating Ocean Incineration Sites . . . . . . . . . . . . .

Page. . . . . . . . . . . . . . . . . . . . . . . . . . . . 174

. . . . . . . . . . . . . . . . . . . . . . . . . . . . 175

. . . . . . . . . . . . . . . . . . . . . . . . . . . . 175

. . . . . . . . . . . . . . . . . . . . . . . . . . . 175

Chapter 10 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...,..176

Table

Table No, Page25. Summary of Federal Regulatory Framework for Incineration . .....................173

Chapter 10

Overview of Federal Laws andRegulations Governing Incineration

Land-based and ocean incineration are regulated incineration. Table 25 provides a summary of stat-under different primary statutes and regulations. utes applicable to land-based or ocean incinerationVarious additional statutes cover activities (e. g., or both, along with a description of the regulatedland transportation) related to both technologies. activities. Many of the specific details of existingThis chapter provides an overview of the statutory requirements and provisions are reviewed earlierand regulatory framework for land-based and ocean in other chapters.

Table 25.—Summary of Federal Regulatory Framework for Incineration

Activi t ies

Statute/reguIation Agency Ocean incineration Land-based incinerationResource Conservation

and Recovery Act . . . . . . . . . . . . . . U.S. EnvironmentalProtection Agency(EPA)

Marine Protection, Research,and Sanctuaries Act . . . . . . . . . . . . EPA

Coast GuardToxic Substances Control Act . . . . . EPA

Coastal Zone Management Act. . . . . States

Hazardous MaterialsTransportation Act . . . . . . . . . . . . . Department of

Transportation

Coast Guard

Port and Tanker Safety Act . . . . . . . . Coast Guard

Port and Waterways Safety Act . . . . Coast Guard

Endangered Species Act . . . . . . . . . . EPA

Clean Water Act . . . . . . . . . . . . . . . . . EPACoast Guard

Comprehensive EnvironmentalResponse, Compensation, andLiability Act (Superfund). . . . . . . . . EPA

Coast Guard

Waste storageWaste contentLand transportationResiduals disposal

Ocean incineration

Incineration of PCBs

Activities affecting land orwater use in the coastalzone

Hazardous wastetransportation by truck orrail

Transportation by water

Design, construction,certification, operation ofincinerator vessels

Vessel movement throughports; waste storage,transfer at waterfront

Compatibility of designatedsites with protection ofwildlife

Cleanup of spills in territorialwaters

National Contingency Plan,cleanup of spills

Waste storageWaste contentLand transportationLand-based incinerationResiduals disposal

—

Incineration of PCBsActivities affecting land or

water use in the coastalzone

Hazardous wastetransportation byor rail

——

—

—

truck

Cleanup of spills in inlandwaters

National Contingency Plan,cleanup of spills

SOURCE: Office of Technology Assessment

173


LAND-BASED INCINERATION

Although hazardous waste incineration has beenwidely used by industry for some time, explicit reg-ulation of the practice was only recently initiated.The 1976 Resource Conservation and RecoveryAct (RCRA) provided a mandate to regulate haz-ardous waste incineration on land, because opera-tions fell under the definition of treatment, storage,and disposal facilities for hazardous waste. Regu-lations finalized in 1981 (46 FR 7666, Jan. 23,1981) and amended in 1982 (47 FR 27520, June24, 1982) established standards for land-based in-cineration and required that all land-based incin-eration facilities obtain RCRA operating permits.These regulations specified the basic requirementsfor land-based incinerator design, performance, per-mitting, waste analysis, monitoring, and reporting.

Because it is covered under RCRA, hazardouswaste incineration on land is effectively exemptedfrom coverage under the Clean Air Act (CAA).Municipal waste incinerators, however, are cov-ered under the CAA. New source performancestandards for municipal facilities were promulgatedin 1981 but include only a single standard for par-ticulate emissions. A numerically identical stand-ard has been incorporated into the RCRA regula-tions governing land-based hazardous wasteincineration.

The Toxic Substances Control Act, passed inthe same year as RCRA, banned the manufactureof PCBs and was followed by regulations govern-ing their treatment and disposal, including the useof incineration (see box B in ch. 3). Under RCRA,an application to incinerate PCBs requires specialapproval by the EPA Administrator before author-ization can be incorporated into a RCRA (for land-based incineration) or MPRSA (for ocean inciner-ation) permit. Currently, only six incinerators arepermitted to incinerate PCBs. These are owned andoperated by ENSCO (Arkansas); Rollins Environ-mental Services (Texas); SCA Chemical Services,

Photo credit: GA Technologies, Inc.

A transportable fluidized bed incinerator that wasrecently granted a permit for PCB incineration.

owned by Waste Management, Inc. (Illinois);Pyrotech (Tennessee); General Electric (Massachu-setts); and EPA (a mobile unit currently stationedin New Jersey). In addition, GA Technologies(California) recently received a permit for a trans-portable incinerator which, when completed, canbe used anywhere in the country for PCB in-cineration.

Ch. 10—Overview of Federal Laws and Regulations Governing Incineration ● 175

OCEAN INCINERATION

Primary statutory authority for regulating oceanincineration resides in the Marine Protection, Re-search, and Sanctuaries Act (MPRSA). AlthoughEPA initially claimed that its jurisdiction underMPRSA did not extend to ocean incineration, l theAgency became persuaded of its authority becauseof rising concern that failure to regulate ocean in-cineration might frustrate the purposes of MPRSA.

In 1974, ocean incineration without a Federalpermit was prohibited. Initial permits were issuedusing general administrative and technical criteriafrom the Ocean Dumping Regulations (40 CFR220). Also relied on were the London DumpingConvention’s regulations and technical guidelines,including a set of standards for destruction andcombustion efficiency, operating conditions, andmonitoring parameters (see ch. 12).

The Ocean Dumping Regulations include exten-sive criteria for use in evaluating permit applica-tions to dispose of waste by ocean dumping. Theseinclude criteria for evaluating environmentaldamages; the need for ocean dumping; and the im-pact of dumping on esthetic, recreational, and eco-nomic values and on other uses of the ocean.

Because the Ocean Dumping Regulations do notspecifically address ocean incineration, EPA has re-

‘The basis of EPAs quandary was whether Congress intendedMPRSA to cover air pollutants emitted at sea.

cently begun developing an Ocean IncinerationRegulation. The proposed regulation, which wasissued by EPA’s Office of Water (50 FR 8222, Feb.28, 1985), specifies application procedures for re-search, trial, and operational permits as well as re-quirements governing incinerator operation, wastespecifications, site designation, and operational andenvironmental monitoring. Specific provisions ofthe proposed Regulation are discussed throughoutthis report.

During the public comment period, five publichearings and several public meetings were heldaround the country. In September 1985, EPA re-leased a summary of the approximately 4,500 com-ments received during these sessions (l).

Activities of the London Dumping Convention(LDC) are germane to domestic policy on oceanincineration, as the United States is a signatory tothe convention. All U.S. regulations regardingocean dumping and ocean incineration must beconsistent with those of the LDC, and MPRSAserves as the primary statutory instrument foradherence to the LDC. (See ch. 12 for more infor-mation on the LDC. )

Amendments to MPRSA also authorize researchand monitoring for ocean incineration and forocean dumping activities in general, to be carriedout by EPA, the National Oceanic and Atmos-pheric Administration, and the U.S. Coast Guard.

STATUTES GOVERNING RELATED ACTIVITIES

For wastes managed using ocean or land-basedincineration, the incineration process itself is thelast step, except for disposal of incineration resid-uals, in the ‘‘cradle-to-grave’ management of haz-ardous wastes. For operations on land and at sea,various Federal authorities are involved at differ-ent stages; Table 25 summarizes the statutes, agen-cies, and jurisdictions for all incineration supportactivities.

Various responsibilities also fall on State and localjurisdictions. These include hazardous waste facilitysiting, enforcement authority, and emergency re-sponse.

Designating Ocean Incineration Sites

The proposed Ocean Incineration Regulationcontains detailed procedures for the formal desig-nation of sites for ocean incineration (50 FR 8271,Feb. 28, 1985). EPA proposes using the same site-seleciion criteria for ocean incineration as thosespecified in the Ocean Dumping Regulations, withthree additions:

1. the effect of incinerator emissions on endan-gered species in or near the site must be ex-amined;

2. the site’s carrying capacity must be calcu-


3.

lated and any requirements that are necessary and the most prevalent organic compounds ex-to ensure that it is not exceeded must be in- pected to be incinerated.corporate into individual permits; and Although burns occurring under research ora plan to monitor the environmental effects emergency permits could occur at undesignatedof emissions must be developed for each site. sites, burns occurring under operational permits

Before formally proposing an incineration site could only occur in sites designated through the for-for designation, EPA would prepare an environ- mal rulemaking process. Use of designated sitesmental assessment of the use of the site for inclu- would be regulated on a permit-by-permit basis,sion in an Environmental Impact Statement where with respect to carrying capacity, and throughrequired by EPA policy. As part of this assessment, evaluation of data obtained from the mandatorythe carrying capacity and loading rates at the site environmental monitoring plan specified for eachwould be calculated for acid emissions, 14 metals, site.


1. U.S. Environmental Protection Agency, Incinera- ards Division, ‘‘Summary of Public Comments ontion-At-Sea Regulation Development Task Force, the Proposed Ocean Incineration Regulation’OffIce of Water Regulations, Criteria and Stand- (Washington, DC: September 1985).

Chapter 11

History of U.S. Ocean Incineration

Contents

Past Burns . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Shell Chemical Organochlorine Wastes in the Gulf ofShell Chemical Organochlorine Wastes in the Gulf ofAgent Orange Wastes in the South Pacific . . . . . . .PCB Wastes in the Gulf of Mexico . . . . . . . . . . . . . .Organochlorine Wastes in the North Sea Using theCanceled Burns. . . . . . . .

Adequacy of PastPast Incidents .

Site Designation .Gulf Site . . . . .

Burns in. . . . . . . .

. . . . . . . .

. . . . . . . .North Atlantic Site. . . . .Other Possible Sites . . . .

Recent EPA Efforts . . . . . .

. . . . . . . . . . . . . . . . . . . . . . .

. .

. .

Page. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 179Mexico: First Series . ...........179Mexico: Second Series. . ........179. . . . . . ., . . . . . !

Vulcan us. . . . . . . . .

. . . . . . . . . . . . . . . . . . . . . . . 181181

~~ : : : : : : : : : : : : : : : : : : ; : : 182. . . . . . . . . . . . . . . . . . . . . . . 182

Demonstrating the Safety of Ocean Incineration. . ...........183. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Science Advisory Board (SAB) Study . . . . . . . . . . . . . . . . . . . . . . . . .Incineration Study . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Ocean Incineration Research Strategy . . . . . . . . . . . . . . . . . . . . . . . .Proposed Research Burn . . . . . . . . .The Usefulness of Research Burns:

Chapter 11 References. . . . .

Table

Table No.26. Summary of Past Ocean

Figure

Figure No.

Incineration Burns

12. Location of the Designated (Gulf of(North Atlantic) Incineration Sites .

Page. . . . . . . . . . . . . . . . . . 180

Mexico) and Proposed

Chapter 11

History of U.S. Ocean Incineration

This chapter discusses several facets of the his- tion, and recent Environmental Protection Agencytory of ocean incineration in the United States. Past (EPA) activities, including the recently denied pro-burns, the designation of sites for ocean incinera- posal for a PCB research burn, are discussed.

PAST BURNS

Four sets of research or interim burns occurredunder EPA’s authority between 1974 and 1982. Allfour used the Vulcanus I and included varyingdegrees of monitoring and analysis of stack emis-sions and the marine environment. In addition,EPA monitored a test of the Vulcanus II in theNorth Sea in 1983. This section describes each ofthese burns and discusses the reported results. Ta-ble 26 presents a summary of these five sets ofburns, indicating locations, types of waste inciner-ated, destruction efficiencies, and other reportedresults. In each case, a primary reference is indi-cated for additional information.

Shell Chemical Organochlorine Wastesin the Gulf of Mexico: First Series

Use of ocean incineration was first proposed inthe United States in 1974, when Shell ChemicalCo. sought permission to use the Dutch-owned ves-sel Vulcanus I to incinerate liquid organochlorinewastes. This type of waste had previously beendumped in the Gulf of Mexico, until EPA haltedthe practice in 1973. The waste proposed for in-cineration was a mixture of chlorinated hydrocar-bons derived from production of vinyl chloride andother chemicals. The chlorine content of the wastewas 63 percent.

In October 1974, EPA granted Shell a researchpermit to incinerate one shipload (4,200 metrictons, or mt) of the waste at a site 190 miles fromland in the Gulf of Mexico. Because several prob-lems arose during the monitoring of this burn, asecond research permit for another shipload wasgranted, and a second burn took place in December1974. The generally favorable results led EPA togrant a special interim permit for the incinerationof two remaining shiploads of waste, which were

burned in late December 1974 and early January1975.

EPA reported that destruction efficiencies for thisset of burns averaged 99.95 percent, measured onthe basis of total organic carbon. No separate meas-urement of individual principal organic hazardousconstituents (POHCs) or products of incompletecombustion (PICs) was undertaken. Seawater sam-ples taken from the area of contact between the in-cinerator plume and the ocean surface were ana-lyzed for organochlorines, pH, chlorine content,and trace metals. EPA was unable to detect anychanges over background levels.

Shell Chemical Organochlorine Wastes inthe Gulf of Mexico: Second Series

In 1977, Shell obtained a special permit to con-duct another set of burns in the Gulf of Mexico,and again used the Vulcanus I to incinerate fourshiploads, or about 16,000 mt, of organochlorinewastes. EPA conducted extensive testing of the firstof these burns. Trace amounts of known waste con-stituents (POHCs) were detected in the stack gassamples; these measurements were used to calcu-late the POHC-specific destruction efficiencies re-ported in table 26. The analysis of emissions foundvery low amounts of other compounds, which hadnot been identified in the waste, and which mayhave been PICs.

EPA reported that the DE for total hydrocarbonsranged from 99.991 to 99.997 percent. The DE forthe major waste constituent, trichloropropane,ranged from 99.92 to 99.98 percent.

The environmental monitoring of these burns re-vealed the first evidence of an environmental ef-fect from ocean incineration. Fish in towed cages

179

Ch. 11—History of U.S. Ocean Incineration ● 181

were exposed to surface water in the area of con-tact between the incineration plume and the oceansurface. Assays were then conducted on three en-zyme systems that increase in activity in responseto physiological stress induced by the presence ofpollutants. One enzyme system (Cytochrome P-450) showed a significant increase in activity.

When the exposed fish were placed in clean waterfor several days in the laboratory, the activities ofall three systems were found to be normal. AlthoughEPA interpreted the temporary nature of the ef-fect optimistically, detection of such an effect illus-trates the need for caution and further monitoringand research of ocean incineration activities. Thiswould be particularly important if incineration atparticular sites became frequent or routine, becauselonger term exposures to marine organisms mightresult.

Agent Orange Wastes in theSouth Pacific

Another set of burns employing the Vulcanus Ioccurred later in 1977, in the South Pacific about120 miles west of Johnston Atoll. The waste inciner-ated was the herbicide Agent Orange, which camefrom an Air Force stockpile of many separate drumsremaining from production that occurred duringthe Vietnam War. The waste consisted of roughlyequal amounts of 2,4-D and 2,4,5-T (see table 26for full chemical names), contaminated with thehighly toxic dioxin TCDD at a level that rangedfrom O to 47 milligrams per kilogram (mg/kg) andaveraged 1.9 mg/kg. Total chlorine content wasabout 30 percent.

A total of about 10,400 mt of Agent Orange wasincinerated in three separate burns. An initial burnof 3,520 mt took place under an EPA research per-mit. Favorable monitoring results led EPA to au-thorize incineration of the remaining stock, about6,880 mt in two shiploads, under a special permit.

Destruction efficiencies were reported in severalforms by EPA. For all three burns, the DE for thetwo main components of Agent Orange, 2,4-D and2,4,5-T, and for total chlorinated hydrocarbons,exceeded 99.999 percent. In fact, none of these sub-stances was detected at all in the emissions. Theminimum DE of 99.999 percent was reported, eventhough the actual DE might have been higher, be-

cause the detection limits of the sampling and ana-lytical instruments employed did not allow meas-urement of a higher DE. Destruction efficienciesfor total hydrocarbons ranged from 99.982 percentto 99.992 percent.

Emissions were also analyzed for the presenceof TCDD (dioxin), which was found only in sam-ples from the second trial; its detection in these samp-les may have been caused, however, by interfer-ence from other substances. Because TCDD wasbelow the limit of detection in burns 1 and 3, thereported DEs again represent minimum values:99,99 percent for burn 1 and 99.96 percent for burn3. A DE of 99.88 percent was calculated for thesecond burn.

Only limited environmental monitoring was con-ducted during the Agent Orange burn. Planktonsamples at the site collected before and after thefirst burn showed no consistent differences in num-bers or species composition, No other tests wereperformed on marine organisms.

PCB Wastes in the Gulf of Mexico

An additional set of burns occurred in the Gulfof Mexico, beginning in late 1981/early 1982 andcompleted later in 1982. Both sets of burns werecarried out under research permits. In the firstburn, about 3,500 mt of PCB-containing waste wasincinerated aboard the Vulcanus I (which by thenhad been acquired by Chemical Waste Manage-ment, Inc., of Oakbrook, Illinois). EPA monitoredthe burn, but later indicated that the data collectedwere ‘ ‘inconclusive because of major problemswith sampling and analysis. This test in particularis cited by critics of ocean incineration as evidenceof the unreliability, if not total unacceptability, ofincineration at sea.

The Vulcan us I was also used for a second burnof about 3,500 mt of PCB wastes conducted in Au-gust 1982. The waste composition included 27.5percent PCBs, 7 percent chlorobenzenes, and traceamounts (estimated at 0.0000048 percent) of highlytoxic tetrachlorodibenzofurans (TCDF). None ofthe emissions samples analyzed showed any traceof these components, which means that the reportedDEs again represent minimum values. These DEsare as follows:

● PCBs . . . . . . . . . , . . . >99.99989 percent


● Chlorobenzenes . . . . >99.99993 percent● TCDF . . . . . . . . . . . . >99.96 percent.

Both waste and emissions were analyzed for thepresence of TCDD, none of which was detected inany samples. The plume itself was also sampled forPCBs and other organochlorine compounds, andnone was detected. However, some nonchlorinatedcompounds were detected in the plume, and EPAsuggested that they either were PICs or arose fromthe vessel’s propulsion engines.

Marine sampling and monitoring was conductedduring the second burn, and no detectable increasein PCBs was found in water samples or organisms.Nor did any physiological indicators of exposure-related stress exceed normal levels.

Organochlorine Wastes in the North SeaUsing the Vulcanus II

With EPA in attendance, the newly built Vul-canus II was tested in February 1983, burningwaste from vinyl chloride production at the desig-nated incineration site in the North Sea. The wasteconsisted almost entirely of four compounds: tri-chloroethane (39 percent), chloroform (26 percent),carbon tetrachloride (20 percent), and dichloro-ethanes (15 percent). The waste’s total chlorine con-tent was 84 percent; in addition, two of the waste’scomponents (chloroform and carbon tetrachloride)are ranked by EPA as among the most difficultcompounds to destroy thermally, because of theirhigh chlorine content. Thus, this waste providedan unusually difficult test of the incinerator.

The reported DEs were high, ranging from99.998 percent for carbon tetrachloride to morethan 99.999995 percent for trichloroethane.

Canceled Burns

In October 1983, EPA proposed issuing two 3-year special permits and one 6-month research per-mit to Chemical Waste Management, Inc., to in-cinerate 300,000 mt of PCB-containing waste and900 mt of DDT-containing waste in the Gulf ofMexico. EPA based its tentative approval on thesuccessful 1982 PCB burn (using Vulcanus I) andthe 1983 European organochlorine burn (usingVulcanus II).

Major public opposition mounted, culminatingin a public hearing in Brownsville, Texas, on No-vember 21, 1983, attended by more than 6,400 peo-ple, the largest public hearing in EPA history. InMay 1984, EPA denied the permits and announcedthat no further operating permits would be issueduntil the Agency had promulgated specific oceanincineration regulations and completed several on-going studies.

In December 1985, EPA published its tentativedetermination to issue a research permit to Chem-ical Waste Management, Inc., for incineration atsea using the Vulcanus II (50 FR 51360, Dec. 16,1985). EPA initially solicited the research permitas part of its Ocean Incineration Research Strat-egy (26).1 The permit would have authorized theincineration of one shipload (about 700,000 gallons)of a waste consisting of 10 to 30 percent PCBs infuel oil. The waste was to have been loaded at thePort of Philadelphia, transported through DelawareBay, and incinerated at the North Atlantic Inciner-ation Site. In its application, Chemical Waste Man-agement indicated that the waste it planned to burnwould actually contain 12 percent PCBs, and wouldbe transported by rail from its storage facility inEmelle, Alabama (8).

The Coastal Zone Management Act, which is ad-ministered at the Federal level by the NationalOceanic and Atmospheric Administration (NOAA),grants States the right to review Federal activitiesaffecting their coastal zones for consistency withState management plans. As part of its applicationprocedure, Chemical Waste Management, Inc.sought coastal zone management (CZM) consist-ency determinations from three coastal States: Dela-ware, New Jersey, and Pennsylvania. These Stateswere consulted because the Vulcan us II would passthrough their coastal waters en route to the inciner-ation site. Pennsylvania granted approval withoutconditions for the single research burn. Delaware

1 EPA received a separate application from At-Sea Incineration, Inc.(ASI), for the Apolfo 1. However, ASI’S parent company, TacomaBoat, filed Chapter 11 bankruptcy proceedings in the fall of 1985.This move, brought on partly by delays in the finalization of EPA’sregulations, forced ASI to default on $68 million in guaranteed loansgranted earlier by the U.S. Maritime Administration for construc-tion of its two incineration vessels ( 14). The loan was paid in full bythe Maritime Administration. The uncertain financial status of ASIled EPA to hold its permit application in abeyance pending resolu-tion of the situation (50 FR 51361, Dec. 16, 1985).

Ch. 11-History of U.S. Ocean Incineration • 183

also reached a determination of CZM consistencybut limited transit to daylight hours and requiredprior notification of the ship’s movement (13). Inaddition, Delaware was considering suing EPA torequire the agency to prepare a separate Environ-mental Impact Statement on the transit route (13).

New Jersey originally placed several conditionson its finding of CZM consistency. These includedprohibiting transit during the summer, extendingthe moving safety zone, modifying Coast Guardcontingency plans for managing a spill, allowing60 days for the State to verify waste composition,and requiring State approval of the level of liabil-ity coverage. In the course of litigation, however,New Jersey withdrew its conditions regarding themoving safety zone and contingency plans, andmodified its waste analysis requirement.

In early 1986, the State of Maryland appealedto NOAA for the right to make a CZM consistencydetermination, claiming that the proposed test burncould adversely affect the States coastal zone.Maryland argued that, although the vessel wouldnot pass through Maryland waters, those waterscould nevertheless be adversely affected by the ac-tivity. In February, NOAA ruled in favor of Mary-land, despite strong opposition from EPA. Mary-land was granted 6 months to conduct its reviewand reach a consistency determination (letter citedin ref. 1 1).

In response to the NOAA decision and the strictconditions imposed by New Jersey, ChemicalWaste Management filed suit in March againstNOAA and EPA (15). The suit contended thatMaryland was not entitled to conduct a consistencyreview for an activity that would occur outside ofits coastal zone. In addition, Chemical Waste Man-agement contended that the Marine Protection, Re-search, and Sanctuaries Act preempts New Jerseyfrom imposing conditions.

Prior to any decision in the suit, the State ofMaryland and Chemical Waste Management reacheda settlement in which Maryland withdrew its re-quest to conduct a CZM consistency review of thisresearch permit but retained its right to pursue sucha review in the future (16).

Following the announcement of its tentative de-termination to grant a research permit to Chemi-cal Waste Management, EPA held a series of publichearings in Philadelphia; Red Bank, New Jersey;Wilmington, Delaware; and Ocean City, Mary-land. Through the course of these hearings, strongpublic opposition again surfaced, focusing particu-larly on the land and nearshore marine transpor-tation risks. These concerns led to the issuance ofa Hearing Officer’s report (31) that called for theresolution of several major issues of public concernbefore proceeding with the burn.

In May 1986, EPA announced its decision todeny the research permit, and to grant no permits,research or otherwise, until finalization of its OceanIncineration Regulation (51 FR 20344, June 4,1986). In its decision, EPA argued that the natureof the issues raised in considering the research per-mit could be more appropriately addressed throughthe regulatory development process.2

As a result of EPA’s decision, the suit broughtby Chemical Waste Management was dismissedwithout a ruling on the circumstances under whichpermit applicants are required to demonstrateCZM consistency or the rights of States to placeconditions on their finding of CZM consistency(11).

2The PCB wastes that were to have been incinerated under the re-search permit are now expected to be transported to Chicago for in-cineration in Chemical Waste Management land-based incinerator,

ADEQUACY OF PAST BURNS IN DEMONSTRATING THE SAFETYOF OCEAN INCINERATION

All of the burns discussed above took place under only 99.9 percent. Therefore, all but one of the re-EPA regulations that incorporated the technical reported DEs met the required standard. (The ex-quirement of the London Dumping Convention ception was the reported DE for TCDD in the sec-mandating a minimum destruction efficiency of ond burn of Agent Orange, which appears to have


been anomalous and may have resulted from in-terference by chemically related compounds. )

In 1981, EPA adopted rules requiring land-basedhazardous waste incinerators to achieve a 99.99 per-cent DE. In addition, the Toxic Substances Con-trol Act requires a minimum 99.9999 percent DEfor PCBs. EPA has proposed that the same valuesbe adopted in the regulations governing ocean in-cineration. The ability of ocean incineration toachieve this DE has not yet been demonstrated.Past test burn data for PCBs was derived from anal-ysis of samples that were not large enough to defini-tively establish that the Vulcanus I is capable ofmeeting a 99.9999 percent DE. However, EPA be-lieves that this DE was achieved in the burn andis achievable using ocean incineration (28).

No consensus exists with regard to the adequacyand accuracy of EPA’s past efforts to monitor oceanincineration. Based on its monitoring of incinera-tor performance and the environment during pastocean incineration activities, EPA reported that ithad been unable to detect any increase in back-ground levels of waste constituents in ambient air,water, or marine organisms. Many members of thepublic and EPA’s own Science Advisory Board(SAB), however, have expressed concerns aboutthese conclusions and the methods and adequacyof EPA’s monitoring efforts. (For further criticaldiscussion of these past efforts, see refs. 6,7,18,19,29).

In response to these concerns, EPA has calledfor additional test burns before operating permitsare issued. The test burns would be intended to pro-vide more accurate assessments of the performance,levels of emissions, and environmental conse-quences of ocean incineration. In addition, the pro-posed regulations governing ocean incineration con-tain provisions for comprehensive environmentalmonitoring, which would be conducted by EPAwith the participation of permitters.

Past Incidents

Several small spills and contamination of the ves-sel occurred during three of the sets of burns de-scribed in this chapter.

During the incineration of Agent Orange in thePacific (l), several small spills of herbicide occurred,

caused by accidental breakage of a sampling bot-tle; sloshing of liquid through a tank hatch, as a re-sult of rough seas; and overfilling of a tank duringrinsing. One or more of these spills was apparentlytracked by personnel, leading to the contaminationof other areas of the vessel. This contamination wasdetected during routine monitoring of the vesselperformed as a precautionary measure.

There have also been reports of a more seriousrelease of waste from this burn, caused by the in-tentional discharge of bilge water, which was appar-ently contaminated with Agent Orange, into a la-goon at Johnston Atoll (12,22). Sampling of lagoonwater in the immediate vicinity of the bilge waterdischarges revealed concentrations of herbicide thatsignificantly exceeded water quality criteria. Re-ported concentrations were as high as 3 to 5 partsper million, and the total release of herbicide wasestimated to have been about 270 pounds (12). Inaddition, a visible orange cloud in the water wasnoted, although the captain of the Vulcanus I main-tained that the color was caused, not by herbicide,but by rust (22).

Several small spills on deck were reported dur-ing the first of the PCB burns that took place inthe Gulf of Mexico in 1981-82 (2,25), Some con-tamination of other parts of the vessel (the burnerroom, pumproom, and a gangway) was also re-ported, identified during routine monitoring of thevessel.

During the Agent Orange burns (1) and the 1977organochlorine burns in the Gulf of Mexico (9),several ‘ ‘impingements’ of the incinerator plumeonto the deck of the vessel were reported. Thesewere attributable to momentary flameouts causedby water in the waste being incinerated or to highwind velocities and erratic wind direction, and insome cases resulted in brief exposure of crew mem-bers to emissions. Based on consideration of the cir-cumstances surrounding these incidents, steps weretaken to avoid or reduce their subsequentoccurrence.

Several other incidents have been reported or al-leged to have occurred during ocean burns thatoccurred in Europe. These are discussed in refer-ence 20.

Certain provisions of EPA’s proposed Ocean In-cineration Regulation directly address these types

Ch. 11-History of U.S. Ocean Incineration . 185

of incidents. In particular, bilge and ballast waters required to maintain a course and speed which, inand tank washings would have to be tested for the combination with the prevailing wind speed, wouldpresence of waste constituents and, if contaminated, yield a combined effective wind speed over the ves-either incinerated at sea or disposed of in an ap- sel of 3 knots or more, to ensure that the plumeproved land-based facility (50 FR 8236, Feb. 28, remained aft of the vessel and would not come into1985). In addition, the vessel would at all times be contact with the crew (50 FR 8251, Feb. 28, 1985).

SITE DESIGNATION

Under the Marine Protection, Research, andSanctuaries Act, incineration sites must be desig-nated by EPA, and operational permits for oceanincineration may only be granted for designatedsites. The site designation process falls under for-mal rulemaking procedural requirements mandat-ing public hearings. In addition, an EnvironmentalImpact Statement (EIS) must be prepared for eachsite.

The following discussion highlights the status ofdesignation activities for ocean incineration sites.

Gulf Site

Currently, only one site has been designated forocean incineration. The final EIS for the Gulf ofMexico Incineration Site was issued in 1976 (23).This site lies in the middle of the Gulf, about 190miles from land, and occupies an area of 4,900square kilometers (see figure 12). The site is be-yond the edge of the continental shelf, in watersranging in depth from 1,000 to 2,000 meters (5).

The Gulf Site was initially designated in 1976(41 FR 39319, Sep. 15, 1976) and redesignated in1982 (47 FR 17817, Apr. 26, 1982). The 1982 ruledesignated the Gulf Site for ‘‘continued use. Theproposed Ocean Incineration Regulation wouldlimit designation of the Gulf Site to a period of 10years, assuming that the additional proposed re-quirements for site designation were met (see ch.10). Some members of the public and elected offi-cials have called for the designation process for theGulf Site to be reopened, based on new informa-tion and developments since 1976 (see ch. 2).

North Atlantic Site

In 1981, a final EIS for the North Atlantic In-cineration Site was released (24). This site, whichhas not been formally designated, lies about 140miles east of the coasts of Delaware and Marylandand covers 4,250 square kilometers (see figure 12).The site lies beyond the continental shelf on the con-tinental rise, in waters ranging in depth from 2,400to 2,900 meters. Due north and adjacent to the pro-posed incineration site is the 106-mile Ocean WasteDisposal Site, which is expected to be used fordumping industrial acid and alkaline wastes as wellas municipal sludge for the foreseeable future.

Since the development of the 1981 EIS, the Na-tional Marine Fisheries Service (NMFS) has foundthat the proposed North Atlantic Incineration Sitelies in a “high use” area for several species of en-dangered or threatened marine mammals (see ch.9). In response to this finding, EPA reevaluatedthe site and concluded that endangered specieswould not be affected by incineration there (30).NMFS has concurred with this conclusion with re-spect to limited use of the site for research burns.However, NMFS must develop a formal biologi-cal opinion for consideration prior to EPA’s finaldesignation of the site.

Other Possible Sites

EPA-sponsored studies have tentatively exam-ined areas off the coasts of California and Floridaas possible future sites for ocean incineration. How-ever, no steps in the actual site designation proc-ess have taken place to date.


Figure 12.-Location of the Designated (Gulf of Mexico)and Proposed (North Atlantic) incineration Sites

Designatedincineration

site

SOURCE: Office of Technology Assessment.

RECENT EPA EFFORTS

In conjunction with the development and issu- human and environmental health and comparedance of its proposed Ocean Incineration Regula- and contrasted the current level of understandingtion, EPA sponsored several studies. of land-based and ocean incineration technologies.

Although stating that ‘‘incineration is a valuable

Science Advisory Board (SAB) Study and potentially safe means for disposing of hazard-ous chemicals, and that the report’s intent was

In April 1985, EPA’s SAB released its “Report to ‘‘strengthen already existing incineration pro-on the Incineration of Liquid Hazardous Wastes grams rather than to discontinue what is alreadyby the Environmental Effects, Transport, and Fate in place, the SAB identified several major areasCommittee” (29). The report examined various sci- where existing data are insufficient. In particular,entific issues bearing on incineration’s impacts on the SAB found that no reliable characterization of

Ch. 11-History of U.S. Ocean Incineration ● 187

incinerator emissions or their toxicities was avail-able, which meant that the potential for environ-mental or human exposure and impact could notbe assessed. The study challenged EPA’s measure-ment of destruction efficiency, which addresses onlya few selected compounds, as a basis for evaluat-ing the total performance of incinerators. It rec-ommended that EPA undertake a complete charac-terization of emissions, including products ofincomplete combustion (PICs).

The report stressed that the uncertainties theSAB had identified applied equally to land-basedand ocean incineration and, in many cases, to othercommon combustion processes, such as the burn-ing of fossil fuels. The report also argued that, be-cause it destroys waste, incineration is preferableto current methods of disposal, such as landfillingand deep-well injection.

Incineration Study

EPA’s Office of Policy, Planning and Evalua-tion (OPPE) (27) published an “Assessment of In-cineration as a Treatment Method for Liquid Or-ganic Hazardous Wastes” in March 1985. Thestudy compared and evaluated land-based andocean incineration with respect to technology, reg-ulation, commercial market potential, relative envi-ronmental and health risks, and public concerns.The major conclusions are the following:

. incineration, whether at sea or on land, is avaluable and environmentally sound treatmentoption for destroying liquid hazardous wastes,particularly when compared to land disposaloptions now available;

● there is no clear preference for land-based orocean incineration in terms of risks to humanhealth and the environment; and

● future demand for hazardous waste incinera-tion will significantly exceed capacity as otherdisposal alternatives are increasingly restricted.

Ocean Incineration Research Strategy

EPA’s Office of Water published an Ocean In-cineration Research Strategy (26) detailing themeans by which EPA intends to address the areasof uncertainty identified in the SAB and OPPEreports, in previous research burns, and in com-

ments received from the public. The strategy callsfor several research burns, both on land and at sea.Initial dockside burns with diesel fuel would allowdevelopment and testing of methodology; subse-quent burns of hazardous waste would be designedto gather data on incinerator performance, thequantity and composition of emissions, and envi-ronmental effects.

Proposed Research Burn

As described earlier in this chapter, EPA pro-posed to issue a research permit for incinerationat sea as part of its research strategy (50 FR 51360,Dec. 16, 1985). The burn was planned to be con-tinuous for 19 days, during which EPA would con-duct extensive sampling and monitoring of allaspects of operation. The following specific testswere planned:

●

●

●

●

●

●

determination of flow characteristics and com-bustion efficiency at all points in the stack;sampling and analysis of emissions to allowmeasurement of: 1) semi-volatile trace organiccompounds, including PCBs, for calculationof destruction efficiency; 2) volatile organiccompounds; 3) particulate; and 4) total chlo-rinated organic compounds;collection of samples for toxicity testing;actual toxicity bioassays on five marine plantand animal species, testing for acute toxic ef-fects and chronic effects on growth and repro-duction;plume sampling and modeling; andcollection and analysis of samples of air, water,and indigenous organisms for determining thepresence of, or effects from, incineration-derived substances.

The Usefulness of Research Burns:Opportunities and Limitations

Recent EPA developments are likely to consider-ably delay issuance of the final Ocean IncinerationRegulation and any subsequent research burns.Clearly, ocean research burns are necessary to re-solve some of the technical questions about oceanincineration. In addition, if a decision were madeto proceed with ocean incineration, informationfrom research burns could aid in modifying the reg-ulatory program, if necessary.


Nonetheless, there are limits to the usefulness ofthe data that could be obtained from ocean researchburns. Foremost among these is the fact that thedata would not resolve the basic issue of whetherto proceed with the ocean incineration program.Technical analysis is only one of many factors in-fluencing such a decision.

Moreover, one or even a series of research burnswould still leave many technical questions un-resolved. For example, the recently denied EPA re-search burn would have used a waste composed ofrelatively homogeneous PCBs in fuel oil (8). Thiswaste was chosen because toxicity characteristicsand detection methods for PCBs are well studied,and because EPA wanted to have as little interfer-ence from other chemicals as possible. Typicalocean incineration wastestreams, however, would

be more likely to contain complex mixtures of manychemicals, which limits the applicability of resultsfrom this test burn to “real” situations. Conversely,choosing a heterogeneous wastestream for the re-search burn would have introduced a different butcomparable set of constraints.

Finally, to be most useful, ocean incinerationresearch must be coupled to research on other al-ternatives. A proper comparative analysis wouldrequire research on both land-based and ocean tech-nologies. EPA does have an ongoing research pro-gram on land-based incineration, and EPA’s oceanincineration research strategy contains a land-basedincinerator component—primarily to allow testingof the protocols for sampling, analysis, and toxic-ity tests to be used during an ocean research burn.


1. Ackerman, D. G., Fisher, H.J., Johnson, R.J., etal., At-Sea Incineration of Herbicide Orange On-board the M\T Vulcanus, EPA Technology SeriesNo. EPA-600/2-78-186, prepared for the U.S. Envi-ronmental Protection Agency, Industrial Environ-mental Research Laboratory, Office of Researchand Development (Washington, DC: April 1978).

2. Ackerman, D. G., ‘‘Observations During the FirstPCB Research Burn, ” and Attachments, Commu-nication to U.S. Environmental Protection Agency,Incineration Research Branch, Cincinnati, OH,Feb. 18, 1982.

3. Ackerman, D. G., McGaughey, J. F., and Wagoner,D. E., At-Sea Incineration of PCB-ContainingWastes Onboard the M\T Vulcanus, EPA-600/7-83-024, prepared for the U.S. EnvironmentalProtection Agency (Research Triangle Park, NC:1983).

4. Ackerman, D. G., Beimer, R. G., and McGaughey,J. F., Incineration of Volatile Organic Compoundsby the M\T Vulcanus 11, prepared for ChemicalWaste Management, Inc., Oak Brook, IL (Redon-do Beach, CA: TRW Energy and EnvironmentalDivision, 1983).

5. Ackerman, D. G., and Venezia, R. A., “Researchon At-Sea Incineration in the United States, inWastes in the Ocean, vol. 5, D.R. Kester, et al.(eds.) (New York: John Wiley& Sons, 1985), pp.53-72.

6. Bond, D. H., ‘ ‘At-Sea Incineration of Hazardous

Wastes,” Environ. Sci. Technol. 18(5) :148A-152A,1984.

7. Bond, D. H., “Ocean Incineration of HazardousWastes: An Update, ” Environ. Sci. Technol.19(6):486-487, 1985.

8. Chemical Waste Management, Inc., “Applicationfor a Research Permit To Incinerate HazardousWaste At Sea: Exhibit B“ (Oak Brook, IL: May24, 1985).

9. Clausen, J. F., Fisher, H.J., Johnson, R.J., et al.,At-Sea Incineration of Organochlorine Wastes On-board the M\T Vulcanus, EPA Technology SeriesNo. EPA-600/2-77-196, prepared for the U.S. Envi-ronmental Protection Agency, Industrial Environ-mental Research Laboratory, Office of Researchand Development (Washington, DC: 1977).

10. Environment Reporter, “NOAA Decision Allow-ing Maryland Review May Delay Ocean Test BurnUntil Mid-1987, ” Environment Reporter 16(42):1878, Feb. 14, 1986.

11. Environment Reporter, “Federal Court Defers toEPA Review in Waste Incineration Permit Dis-pute, ” Environment Reporter 17(9):264, June 27,1986.

12. Graffeo, A. P., and Thomas, T., “Ocean Disposalof Agent Orange—Land-Based EnvironmentalMonitoring at Johnston Island, ” paper presentedat the Third International Ocean Disposal Sympo-sium, Woods Hole, MA, Oct. 12-16, 1981.

13. Inside EPA, “Delaware Eyes Suing EPA To Force

Ch. 11-History of U.S. Ocean Incineration ● 189

14.

15.

16,

17,

18.

19.

20

21

22.

23

Ocean Incineration Transit Route, EIS, ” InsideEPA 6(41):2, Oct. 11, 1985.Inside EPA, “EPA Okays At-Sea Research Burns,But Pool of Applicants Dwindles, ” Inside EPA6(48):5, Nov. 29, 1985.Inside EPA, “EPA, NOAA Sued for AllowingMaryland Incineration-At-Sea Review Rights, ’ in-side EPA 7(12):8, Mar. 21, 1986.Inside EPA, “Justice Asks Court To Dismiss In-dustry Incineration-At-Sea Suit, ’ Inside EPA7(18):3-4, May 2, 1986.Kamlet, K. S., ‘‘Ocean Disposal of OrganochlorineWastes by At-Sea Incineration, ” Ocean Dumpingof Industrial Wastes, B.H. Ketchum, et al. (eds. )(New York: Plenum Publishing Corp., 1981), pp.295-314.Kleppinger, E. W., and Bond, D. H., Ocean In-cineration of Hazardous Waste: A Critique (Wash-ington, DC: EWK Consultants, Inc. , 1983).Kleppinger, E. W., and Bond, D. H., Ocean in-cineration of Hazardous Waste: A Revisit to theControversy (Washington, DC: EWK Consultants,Inc., 1985).Lentz, S. A., Testimony Before the Subcommitteeon Oceanography, House Committee on MerchantMarine and Fisheries, U.S. Congress, Hearing on‘ ‘Incineration of Hazardous Waste At Sea, ” Nov.11 and Dec. 3, 1985, Serial No. 99-25 (Washing-ton, DC: 1986).Metzger, J. F., and Ackerman, D. G., “A Summaryof Events, Communications, and Technical DataRelated to the At-Sea Incineration of PCB-Containing Wastes Onboard the M/T Vulcanus,20 December, 1981-4 January, 1982, ” preparedfor the U.S. Environmental Protection Agency,March 1983.Smith, G., ‘‘The Burning Question, San Fran-cisco Chronicle, This World, May 12, 1985, pp.7-9.U.S. Environmental Protection Agency, Office ofWater and Hazardous Materials, Division of Oiland Special Materials Control, Final EnvironmentalImpact Statement of Designation of a Site in theGulf of Mexico for Incineration of Chemical Wastes(Washington, DC: 1976).

24.

25.

26.

27.

28.

29.

30.

31

32

U.S. Environmental Protection Agency, Office ofWater Regulations, Criteria and Standards Divi-sion, Environmental Protection Agency Find Envi-ronmental Impact Statement (EIS) for North At-Jantic Incineration Site Designation (Washington,DC: Nov. 25, 1981).U.S. Environmental Protection Agency, ‘ ‘Prelimi-nary Report, Research Permit for Incineration AtSea of PCB Wastes, HQ 81-002, Results of TestBurn on M/T Vulcanus, ” May 20, 1982, p. 57.U.S. Environmental Protection Agency, Office ofWater, Incineration-At-Sea Research Strategy(Washington, DC: Feb. 19, 1985).U.S. Environmental Protection Agency, Office ofPolicy, Planning and Evaluation, “Summary andConclusions, Assessment of Incineration as aTreatment Method for Liquid Organic HazardousWastes (Washington, DC: March 1985).U.S. Environmental Protection Agency, Office ofPolicy, Planning and Evaluation, “Background Re-port I: Description of Incineration Technology, ”Assessment of Incineration as a Treatment Methodfor Liquid Organic Hazardous Wastes (Washing-ton, DC: March 1985).U.S. Environmental Protection Agency, ScienceAdvisory Board, Report on the Incineration of Liq-uid Hazardous Wastes by the Environmental Ef-fects, Transport and Fate Committee (Washington,DC: April 1985).U.S. Environmental Protection Agency, MarineOperations Division of the Ofilce of Marine and Es-tuarine Protection, Assessment of the Impact of In-cineration of Chemical Wastes in the ProposedNorth Atlantic Incineration Site on Endangered andThreatened Species (Washington, DC: July 9,1985).U.S. Environmental Protection Agency, “HearingOfficer’s Report on the Tentative Determination ToIssue the Incineration-At-Sea Research Permit HQ-85-001” (Washington, DC: May 1, 1986).Wastler, T. A., Offutt, C. K., Fitzsimmons, C. K.,et al., Disposal of Organ ochlorine Wastes, EPA-430/9-75-014, contract report prepared for the U.S.Environmental Protection Agency (Washington,DC: July 1975).

Chapter 12

The Regulation and Use ofOcean Incineration by Other Nations

Contents

PageHistorical Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..........................193

International Bodies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .....................194London Dumping Convention . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .................194Oslo Commission . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .194Commission of the European Communities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ........195European Parliament . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...............-......195

Use of Ocean Incineration by Other Nations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ......195Incineration Vessels . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ........................195Quantities of Waste Incinerated . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ................195Number of Voyages . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ............................197Characteristics of Waste Incinerated .,... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .......197

Profiles of IndividualMajor ConclusionsBelgium . . . . . . . . .Canada . . . . . . . . . .Denmark . . . . . . . .Finland . . . . . . . . . .France . . . . . . . . . .

Nations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...............198. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 198. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...... . . . . . . . . . . . . . 198. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..... 199. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 199. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 199. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 199

Federal Republic of Germany . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .................200The Netherlands . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..........................200Norway . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .......201Sweden . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ........................-....201Switzerland . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...201United Kingdom . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .............................201

Chapter 12 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... ...202

Tables

Table No.27. Incineration Vessels Employed in Europe, 1969 to

PageP r e s e n t . . . . . . . . . . . . . . . . . . . . . . . . 1 9 6

28. Type of Waste Incinerated and Country of Origin, 1982 . . . . . . . . . . . . . . . . . . . . . . . . . .197

Figure

Figure No. Page13. Quantities of Waste Annually Incinerated At Sea, 1969-84 . . . . . . . . . . . . . . . . . . ......196

Chapter 12

The Regulation and Use ofOcean Incineration by Other Nations

This chapter provides overviews of the past,present, and future use of ocean incineration bynations other than the United States. The first sec-tion provides a brief history of international use andregulation of ocean incineration. The second sec-tion discusses the various international and regionalconventions and other deliberative bodies that haveaddressed the use of ocean incineration and de-

scribes several important recent actions. The thirdsection presents a summary of data on the past andpresent use of ocean incineration by other nations.The fourth and final section briefly discusses thepolicies and practices of 11 individual nations, basedon information from several sources, including asurvey of foreign embassies conducted by OTA.

HISTORICAL BACKGROUND

Commercial use of ocean incineration by othernations dates back to 1969, when the first inciner-ation vessel, a modified chemical tanker namedMathias I, was launched under the flag of the Fed-eral Republic of Germany. Development of oceanincineration for the purpose of incinerating or-ganochlorine wastes was initially motivated by fivefactors (12):

1.

2.

3.

4.

5.

the many problems encountered on land inoperating and maintaining scrubbers in thepresence of the corrosive gases produced byincinerating organochlorine wastes;the ability of seawater to neutralize the gases,thereby negating the need for scrubbers;additional problems arising from treating anddisposing scrubbing effluents and sludges;the advantage of a centralized, large-scale sys-tem for collecting and incinerating organo-halogen wastes, which could potentially bebetter controlled and monitored, as well asmore economical, than other alternatives; andunacceptable impacts from ocean dumping ofcertain organochlorine wastes, such as tarsarising from the production of ethylene di-chloride.

Consideration of these factors led to an increase inthe European market for ocean incineration andthe launching of two additional ships, the MathiasII and the Vulcanus I, in the early 1970s. All threeships operated exclusively in the North Sea.

Also at this time, international concern was in-creasing over environmental impacts of ocean dis-posal of wastes in general. These concerns led tothe development of the worldwide London Dump-ing Convention (LDC) and the regional Oslo Con-vention, both established in 1972. Although theseconventions did not initially address ocean inciner-ation, proposals to begin incineration in the Med-iterranean Sea prompted two developments. First,the Barcelona Convention, established in 1976,decided to prohibit incineration in the Mediterra-nean Sea (12). Second, the LDC and the OsloCommission began developing special provisionsand codes of practice to govern the use of inciner-ation at sea. Groups of experts convened by bothconventions developed sets of technical guidelinesfor incorporation into the conventions. The guide-lines covered the following topics:

●

●

●

●

●

●

control and approval of incinerator system de-sign and specifications,control over the nature of wastes to be inciner-ated at sea,criteria for the selection of incineration sites,control over vessel design and operation,requirements for monitoring and the use ofrecording devices, andreporting requirements and procedures for in-cineration activities.

The next section examines the approaches andrecent activities of these and other internationalbodies with regard to ocean incineration.

193


INTERNATIONAL BODIES

London Dumping Convention

The LDC considers incineration at sea as legallyconstituting ocean dumping and has developed ex-tensive procedural and operational requirements,which are contained in Annexes to the Convention(8). Under the LDC, incineration at sea is viewedas an interim method of waste management, asreflected in LDC Regulation 2.2:

Contracting parties shall first consider the prac-tical availability of alternative land-based meth-ods of treatment, disposal or elimination, or oftreatment to render the wastes or other matter lessharmful, before issuing a permit for incinerationat sea in accordance with these Regulations. In-cineration at sea shall in no way be interpretedas discouraging progress towards environmentallybetter solutions including the development of newtechniques.

At a meeting of the LDC’s Scientific Group onDumping (SGD) in 1985, a working group onocean incineration was convened to identify anddiscuss several unresolved questions regarding theperformance of and monitoring capabilities for in-cineration at sea (7). These issues include the fol-lowing:

● the relationship between destruction and com-bustion efficiencies over a broad range of oper-ating conditions;

• the ability to sample incinerator stack gasesin a mannner that is representative of the en-tire emission;

• the ability to accurately sample particulatematter in stack emissions; and

● the nature and significance of newly synthe-sized compounds (products of incomplete com-bustion, or PICs) in stack emissions.

A group of experts jointly drawn from the LDCand the Oslo Commission is to undertake furtherdiscussion of these issues at an intersessional meet-ing in 1986 or 1987. This discussion was to be basedin part on new information provided by the U.S.PCB research burn (10); given its cancellation, thetiming of formal international consideration of thesequestions is not clear.

The International Maritime Organization(IMO) is designated under the LDC to serve as Sec-retariat. The IMO, therefore, is responsible forcollecting data from Contracting Parties on oceanincineration activities, including the number andstatus of permits, as well as the quantities and typesof wastes authorized for incineration at sea. Themost recent of these data (for activities in 1982) arediscussed later in this chapter.

0slo Commission

Rule 2.3 of the Oslo Commission Rules, adoptedin 1981, stipulates that ‘‘the Commission will meetbefore the 1st of January 1990 to establish a finaldate for the termination of incineration at sea’ inthe North Sea, which comprises the Oslo Conven-tion area (15). The 1990 date was formulated ata time when few controls existed over the use ofocean incineration. Since that time, international(LDC and Oslo Commission) and national regu-lations have been developed to cover most aspectsof this technology, leading some Oslo Commissionnations to see the need to terminate use of oceanincineration in the near future as less pressing; othermembers, however, remain committed to its ter-mination by 1990 (see profiles of individual nationslater in this chapter).

At the Commission’s 11th meeting, held June11-13, 1985, The Netherlands presented the resultsof a survey of member nations, which was under-taken to gauge the availability of alternative meansof disposing wastes currently incinerated at sea (1 7).The survey provided an initial step toward assess-ing the practicality of fulfilling the language of Rule2.3. Responses to The Netherlands survey were re-ceived from all but two members (France andSpain). Its conclusions are as follows:

●

●

There is a potential shortfall in the capacityof land-based incinerators and other land-based treatment methods to dispose of thewastes currently being incinerated at sea.Spare capacity on land is considered far fromsufficient to match the wastes currently being

Ch. 12—The Regulation and Use of Ocean Incineration by Other Nations • 195

incinerated at sea, and very little increase insuch capacity is expected in the near future.

● It is expected that by 1990 wastes will remainfor incineration at sea.

In 1987, at its 13th meeting, the Oslo Commis-sion expects to draft a policy statement on the ter-mination of incineration at sea, contingent on theavailability of adequate capacity in acceptable land-based alternatives (16).

The Commission’s Standing Advisory Commit-tee for Scientific Advice (SACSA) examined dataregarding the location of the current North Seaincineration site, and concluded that ‘ ‘there is nobetter compromise between meteorological andlogistical requirements (shorter approach to the in-cineration site resulting in higher cargo safety).This finding was endorsed by the commission atits 11th meeting in 1985 (16).

Commission of the EuropeanCommunities

This commission exists under the auspices of theEuropean Economic Community (EEC). In July1985, the commission submitted to its Council ofMinisters a proposal for a council directive on thedumping of waste at sea (2). Ocean incinerationis explicitly included in the definition of ‘‘dump-ing at sea. The intent of the directive would beto reduce and terminate all dumping at sea by EECMember States as soon as possible. Under the direc-

‘‘temporary’ disposal option to be used ‘ ‘only ifthere are no practical alternative methods of land-based treatment, as determined on a case-by-casebasis.

EEC Member States would be required to sub-mit to the commission by January 1, 1990, infor-mation required for setting a final date for terminat-ing incineration at sea. The council would berequired to act on the information within 6 monthsof that date.

If adopted, the directive would prohibit the grant-ing of any new special permits for incineration af-ter January 1, 1988. Permits already in effect couldbe renewed until January 1, 1990, for up to 5 years,but Member States would be required to decreasethe quantities of waste incinerated at sea each yearby 10 percent.

European Parliament

The European Parliament also exists under theauspices of the EEC. A Parliament report (4) is-sued by the Committee on the Environment, PublicHealth, and Consumer Protection in December1983 identified ocean incineration as a contribu-tor to pollution of the North Sea through the re-lease of ash, hydrogen chloride gas, and small quan-tities of unburned waste to the atmosphere. Thereport suggested that ocean incineration be relo-cated to a less sensitive location in the AtlanticOcean.

tive, ocean incineration ‘would be

U S E O F O C E A N

regarded as a

INCINERATION BY OTHER NATIONS

This section presents available data on Europeanincineration vessels, the number of voyages theyhave made, and the quantities and types of Euro-pean wastes that have been incinerated at sea.

ated exclusively in the North Sea. All but the Mat-thias III, which was only used for a brief time, aremuch smaller than typical tank ships.

Quantities of Waste IncineratedIncineration Vessels

A total of six vessels have been built and em-ployed to incinerate European wastes at sea. Ta-ble 27 provides a summary of the most importantfeatures of these six vessels, including dates of oper-ation. All but one vessel (the Vulcan us I) have oper-

Quantities of wastes managed by ocean inciner-ation steadily increased from 1969, when inciner-ation began in the North Sea, until about 1979,when quantities stabilized at the present level ofabout 100,000 metric tons annually (fig. 13). Thegreat majority of all waste has been incinerated in


Table 27.-incineration Vessels Employed in Europe, 1969 to Present

Matthias I Matthias II Matthias III Vulcanus I Vulcanus II Vesta

Dates of service . . . . . . . . . . . . 1968-76 1970-83 1975-77 1972-present 1982-present 1979-presentSite of operation . . . . . . . . . . . . Exclusively in the North Sea North Sea North Sea North Sea

United StatesPacific

AustraliaNumber of incinerators . . . . . . 1 1 1 2 3 1Total cargo (ret). . . . . . . . . . . . . 550 1,200 15,000 3,500 3,200 1,400Total gross tons . . . . . . . . . . . . 438 999 12,636 3,100 3,100 999SOURCE: Office of Technology Assessment based on M.K. Nauke, “Development of International Controls for Inclneratlon At Sea,” Wastes in the Ocean, vol. 5, D.R.

Kester, et al. (eds.) (New York: John Wiley & Sons, 19S5), pp. 33-52; and Ocean Combustion Service, 15 Years of Waste lnclneratkm At Sea: H/story, Stateof the Art, Control, Errvkorwrrenta/ Impact (Rotterdam, The Netherlands: February 19S5).

Figure 13.–Quantities of Waste Annually incinerated At Sea, 1969-84

180

r

1969

Australia*

uGulf of Mexico

1970 1971 1972 1973 1974 1975 1977‘ear

1978 1979 1980 1981 1982 1983 1984

-, Pacific

North Sea

‘This waste was generated In Australia and incinerated while the ship was en route to Singapore.

SOURCE: Ocean Combustion Service, “15 Years of Waste Incineration At Sea: History, State of the Art, Control, Environmental Impact” (Rotterdam, The Netherlands:Ocean Combustion Service, February 19S5); M.K. Nauke, “Development of Internatlonai Controls for Incineration At Sea,” in Wastes in the Ocean, vol. 5,D.R. Kester, et al. (ads.) (New York: John Wiley& Sons, 19S5), pp. 33-52; and International Maritime Organization, “Consideration of Report on Dumping, DraftReport of Permits Issued in 19S2,” document LDC/SG.SJINF.3, prepared for 8th Meeting of Scientific Group on Dumping (London: Dec. 20, 19S4).

Ch. 12—The Regulation and Use of Ocean Incineration by Other Nations ● 197

the North Sea, but smaller amounts were burnedby the Vulcanus I in the Gulf of Mexico (Shellwastes and PCBs), in the Pacific Ocean (AgentOrange), and in one burn near Australia. Figure13 presents the estimated quantities burned between1969 and 1984.

Many different European countries, as well asAustralia and Japan, have used ocean incineration.Each member nation must report annually to theLDC, providing data on the quantities of waste sentfor incineration at sea. Table 28 presents the mostrecent available compilation of such data, cover-ing the year 1982.

These data indicate that 14 LDC nations in addi-tion to the United States incinerated wastes at seain 1982. Actual quantities sent for incineration var-ied significantly, ranging from 200 metric tons(Spain) to 53,000 metric tons (Germany). Mostwastes are sent for loading at Antwerp, Belgium,although other ports have also been used (e. g., Rot-terdam in The Netherlands and Le Havre inFrance); in addition, permits have been granted forexporting wastes from nations such as Finland.Four vessels were used to incinerate wastes in theNorth Sea in 1982. Of the 94,000 mt of waste ac-tually incinerated in the North Sea in 1982, the fol-

Table 28.—Type of Waste Incinerated andCountry of Origin, 1982

Country Type of wasteAustralia . . . . . . . . .Vinyl chloride and PCB

wastesAustria . . . . . . . . . . . Organohalogen wastesBelgium . . . . . . . . . . Organohalogen wastesFinland . . . . . . . . . .Organohalogen wastesFrance . . . . . . . . . . . Organohalogen wastesGermany . . . . . . . . . Organohalogen wastesItaly . . . . . . . . . . . . .Organohalogen wastesJapan . . . . . . . . . . . . Oily sludgesThe Netherlands . . Organohalogen wastesNorway . . . . . . . . . . Organohalogen wastesSpain . . . . . . . . . . , . Organohalogen wastesSweden . . . . . . . . . . Organohalogen wastesSwitzerland . . . . . . . Organohalogen wastesUnited Kingdom . . .Organohalogen and

organophosphorouswastes

Quantitya

4,820

49010,6432,7506,582

52,7513,4311,4889,3968,000

2106,4203,711

6,194

Total . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 116,886aaThe5e are quantities for which permits were granted; in some caSes, the amountof waste actually incinerated in 1982 was smaller,

SOURCE: International Maritime Organization, “Consideration of Report onDumping, Draft Report of Permits Issued in 1982,” DocumentLDC/SG.8/lNF.3, prepared for 8th Meeting of Scientific Group onDumping (London: Dec. 20, 1984).

lowing proportions were incinerated by each ves-sel: Matthias II, 29 percent; Vulcanus I, 25 percent;Vesta, 42 percent, and the newly commissionedVulcanus II, 4 percent.

Number of Voyages

EPA formulated estimates of the number ofvoyages, as well as quantities of waste incinerated,by the two Vulcanus ships and the Vesta from theirlaunch dates through 1983 (app. C in ref. 19).These data indicate that the ships made 322 voyagesand incinerated more than 650,000 mt of waste.Comparable data were not available for the threeMatthias vessels.

The total number of incineration voyages is likelyto be substantially higher, because almost twice asmuch waste was incinerated at sea by all six ves-sels over the period 1969-84 (see figure 13).

Characteristics of Waste Incinerated

The vast majority of waste incinerated in theNorth Sea is organochlorine waste. Of the 100,000mt incinerated in the North Sea in 1981, about 80percent consisted of organochlorines (6). Many ofthese wastes have appreciable chlorine content, esti-mated to average between 60 and 70 percent (1 1).The waste burned during testing of the VulcanusII in 1983 (see ch. 11) was derived from vinyl chlo-ride production in Norway and had a chlorine con-tent of 84 percent. Chemical Waste Management,Inc., estimated that 65 percent of the waste inciner-ated by the Vulcanus ships in the North Sea hadchlorine contents greater than 35 percent (l).

Few data are available characterizing Europeanwastes with respect to metal content; the availableanalyses, however, indicate that metals are typi-cally in the parts per million range (12). The OsloCommission (17) has estimated that approximately90 percent of the emissions of heavy metals fromincineration at sea originate from wastes with chlo-rine content less than 45 percent. Wastes with highmetal content (and low chlorine content) are in-creasingly being diverted to land-based incinera-tion (3).

With respect to emissions of heavy metals, theOslo Commission (17) estimates that the total con-

I@ ● Ocean Incineration: Its Role in Managing Hazardous Waste

tribution of ocean incineration to the Dutch partof the North Sea (encompassing the incinerationsite) represents less than 0.3 percent of the total in-put of metals. The German Hydrographic Insti-tute has compared such emissions to the averageinput of metals entering the North Sea via theRhine River (cited in ref. 3). The contribution fromthe Rhine River is estimated to be 1,000 to 10,000times higher than that from ocean incinerationemissions, for each of six toxic metals.

No PCBs have been incinerated at sea in Eur-ope; LDC regulations list PCBs as a waste aboutwhich there is doubt regarding its thermal destruct-ability. However, The Netherlands has announcedplans to conduct a research burn using PCBs in late1986 or 1987. The loss of land-based incinerationcapacity (located in England and France) previouslyused for PCBs by The Netherlands necessitatedreconsideration of the at-sea incineration option(10,18).

PROFILES OF INDIVIDUAL NATIONS

This section describes the policies and practicesof 11 individual nations regarding the use of oceanincineration for managing hazardous wastes. All11 are signatories to the LDC, and all but two(Canada and Denmark) have used ocean in-cineration.

Sources for the information presented in this sec-tion, unless otherwise noted, include The First Dec-ade, a report of the Oslo and Paris Conventionspublished in 1984 (ref. 14), and letters from for-eign embassies received in response to an OTA re-quest for information on practices and policies re-garding ocean incineration.

Major Conclusions

The data presented below, as well as that con-tained in the survey of Oslo Commission membersdescribed above, provide the basis for two majorconclusions regarding the use of ocean incinerationby other nations:

1.

2.

The major constraint blocking termination ofocean incineration is the lack of sufficient land-based capacity for treating organochlorinewastes.A broad range of opinion and position regard-ing future use of ocean incineration existsamong European nations. For example, theUnited Kingdom holds a quite favorable view,whereas Denmark argues for termination assoon as possible. Other nations, such as TheNetherlands and the Federal Republic of Ger-many, are attempting to reduce their relianceon ocean incineration but regard it as a nec-

essary option for the foreseeable future dueto lack of land-based capacity.

Belgium

Belgium estimates that it generates about 100,000mt of hazardous waste each year, an unreportedfraction of which is incinerated on land. About10,000 mt of hazardous waste generated in Belgiumwas incinerated at sea in 1982.

Belgium regards incineration at sea to be “anacceptable solution whenever difficult technicaland/or economic problems arise regarding inciner-ation on land. For Belgium, ocean incinerationis ‘‘a fairly attractive method as the burners andfurnaces can be relatively simplified and it is notnecessary to provide for the neutralization of thecombustion gases due to the buffering capacity ofseawater. The method’s main drawback is that atsea it is more difficult to efficiently control the ef-fectiveness of the incineration process and the wayin which these operations are carried out.

Antwerp, Belgium, has served as the major portfor incineration vessels operating in the North Sea.Currently, the loading and transit of incinerationvessels occur two or three times each month. Be-cause this activity involves the burning of wastesfrom numerous European countries, importationand storage of hazardous wastes at Antwerp is rou-tine. For example, in 1982, Antwerp received about70,000 mt of hazardous waste destined for inciner-ation in the North Sea. This waste originated inseven European nations in addition to Belgium (9).

Ch. 12—The Regulation and Use of Ocean Incineration by Other Nations ● 199

Belgium’s land-based treatment capacity forhighly chlorinated wastes is limited to a few pri-vate onsite destruction facilities. Thus, chlorinatedwastes for which no other alternative exists will con-tinue to be sent for incineration at sea. Belgiumhas experienced little change in the amount ofwastes incinerated at sea over the past decade andanticipates little change for the next 5 years. A newpublicly owned incineration plant, scheduled forcompletion in 1988, should cause some decrease(17).

Canada

Canada views the use of ocean incineration as‘‘one of many options which, if properly controlled,could help in the management of hazardousw a s t e s . Canada anticipates having only smallquantities of waste suitable for ocean incineration,has not incinerated any wastes at sea, and has noimmediate plans to do so. However, a general ap-plication from Chemical Waste Management, Inc.,has promptedogy, based inLDC data.

a further evaluation of the technol-large part on a review of relevant

Denmark

Denmark is engaged in a substantial hazardouswaste management program administered by publicauthorities, with land-based incineration represent-ing the primary method of treatment or disposal.Of the 40,000 mt of chemical waste received at thecentral treatment facility (known as Kommune-kemi) in 1980, 80 to 90 percent is treated by in-cineration. Total incineration capacity of the facilityis about 90,000 mt annually.

No permits for ocean incineration have been is-sued by the Danish Minister for the Environment.Although Denmark regards thermal destruction tobe a “useful and acceptable disposal method, ”especially for organohalogen wastes, it believes that‘‘incineration at sea presents great problems in con-nection with the control of destruction and com-bustion efficiency. ” In addition, Denmark ex-presses concern about the large areas of the NorthSea that are unavailable for other uses because ofocean incineration, and concern about the poten-tial for the technology to aggravate regional prob-lems with acid rain.

The Danish Government, which has been themost vocal and consistent opponent of ocean in-cineration in the European community, continuesto press for an end to the practice, particularly inthe North Sea.

Finland

Finland estimates that it produced about 500,000mt of hazardous waste in 1975. The majority ofFinland’s oily wastes and about half of its solventwastes are burned, mostly in land-based incinera-tors. Finland currently lacks sufficient incinerationcapacity for PCBS and certain other chlorinatedwastes, and hence exports these wastes to theUnited Kingdom for destruction in a land-basedincinerator (1 7).

Finland has recently constructed (at Riihimki)a centralized hazardous waste treatment facility,which has a capacity of 70,000 mt annually. Land-based incineration is the major technology at thisfacility. It is unclear if and to what extent this willaffect the need for Finland to continue to exportPCBs and other wastes.

Incineration at sea has twice been used to de-stroy wastes (a total of 5,250 mt) from one of Fin-land’s petrochemical plants, which is closed at leastfor the time being. No definitive policy statementsby Finland regarding ocean incineration areavailable.

France

France estimates that it annually generates 18million mt of hazardous industrial waste, 2 millionmt of which are especially toxic or hazardous. In1982, approximately 200,000 mt of this waste wasincinerated at 10 ‘‘special collective plants’ locatedthroughout France. A comparable quantity was in-cinerated in onsite facilities operated by various in-dustrial firms. Of the 10 commercial facilities,which have a total annual capacity of 205,000 mt,4 are equipped to incinerate chlorinated wastes, and3 can burn only liquid wastes. These facilities com-pete with 5 cement kilns, which have recently in-creased their share of the market for wastes withhigh heat content.

France points to insufficient capacity and the highcost of land-based incineration of organochlorine


wastes as factors motivating its use of ocean inciner-ation. Waste to be incinerated in the North Sea isdirected to the ports of Le Havre, France, andAntwerp j Belgium, the latter receiving primarilyor exclusively wastes with high chlorine content.Waste generators do not have direct access to in-cineration vessels, which receive waste only fromtreatment plants. Annual quantities incinerated atsea since 1979 have ranged from 4,600 mt to 11,700mt, averaging about 10,000 mt.

France anticipates that a gradual increase in land-based incineration capacity and decreases in its costwill reduce the quantities of waste incinerated atsea.

Federal Republic of Germany

The Federal Republic of Germany (FRG) esti-mates that its annual production of industrial spe-cial or toxic waste amounted to about 4.5 millionmt in 1980. A total of 17 land-based incinerationplants handle an unreported portion of these spe-cial wastes.

The FRG has expressed a variety of views onthe use of ocean incineration. According to its sub-mission to the Oslo Commission (14), the FRGregards ocean incineration ‘‘to be ecologically thesoundest of the available methods for the disposalof halogenated hydrocarbons’ but not ‘‘an idealdisposal method, ” preferring to develop appropri-ate reuse and recycling efforts. These methods in-clude land-based thermal destruction technologiesthat provide for recovery or reuse of chlorineresidues released during the process, as well as moreconventional heat recovery.

Permits for incineration at sea are evaluated withrespect to need on a case-by-case basis, with theunavailability of alternative capacity on land be-ing the major criterion. Wastes to be incineratedat sea are prohibited from containing chlorinateddibenzofurans, PCBs or PCTs, dioxins, or DDT.Quantities of waste incinerated at sea have rangedas high as 100,000 mt annually but have graduallydecreased since 1980. For example, a reported41,000 mt of German waste was incinerated at seain 1983. Nevertheless, the FRG remains the great-est user by far of ocean incineration.

In its response to the OTA survey, the FRGstated its intent to make ‘‘every effort to terminateincineration at sea as soon as possible. The FRGanticipates significant decreases in future quanti-ties of waste incinerated at sea, especially for highlychlorinated wastes (those with chlorine contentgreater than 45 percent), because of completion ofa new land-based incinerator in 1987 and greaterapplication of perchlorination and other reuse tech-nologies (1 7). However, the lack of sufficient land-based capacity precludes the FRG froma date for ending ocean incineration.

specifying

The Netherlands

The Netherlands annually generates about 1 mil-lion mt of chemical waste, half of which is currentlytreated or disposed of offsite. Of the waste treatedoffsite, about 86,000 mt is incinerated on land orat sea. The AKZO treatment facility can inciner-ate wastes with a high chlorine content (as high as45 percent; see ref. 17) and regularly receives suchwastes from Sweden.

The Netherlands regards “incineration at sea,albeit an environmentally acceptable procedure, asa temporary expedient; land alternatives are to bep r e f e r r e d . Efforts are underway to develop fur-ther land-based incineration capacity and makegreater use of recycling methods.

A new land-based incinerator is scheduled to be-gin operation in 1987. If future policy analysis de-termines that this land-based incinerator constitutesa practical land-based alternative preferable t.ocean incineration, The Netherlands expects asharp decline in the quantities of waste incineratedat sea (1 7).

The Netherlands has played a central role inmuch of the testing of the Vulcanus ships that hasoccurred to date; as a result of these studies, it be-lieves that all international requirements are gen-erally being satisfied. As described previously, TheNetherlands plans to conduct an ocean incinera-tion research burn of PCB-containing wastes in late1986 or early 1987, motivated by the loss of land-based incineration capacity in the United Kingdomand France (10, 18).

Ch. 12—The Regulation and Use of Ocean Incineration by Other Nations • 201

Norway

Norway estimates that it annually generatesabout 120,000 mt of hazardous waste, 75 percentof which is used oil or oily wastes. Norway uses alarge-capacity cement kiln for destroying signifi-cant quantities of incinerable liquids and sludges.

Tar wastes from vinyl chloride production,amounting to some 8,000 mt annually, are cur-rently incinerated at sea. To provide an alterna-tive, Norway is considering the construction of aland-based incinerator equipped to reclaim hydro-gen chloride.

Norway’s official position is that ocean inciner-ation should be terminated as soon as possible. Al-though its use of incineration at sea has graduallyincreased, Norway anticipates gradually reducingits use over the next 5 years, as sufficient land-basedincineration capacity and recycling technologies aredeveloped.

Sweden

Sweden estimates that a total of 482,000 mt ofhazardous waste was generated in 1978. About halfof this quantity was treated or disposed of at thesite of generation. Most of Sweden’s waste that issent offsite is treated by the State-owned waste treat-ment network (SAKAB) or by 1 of about 20 othergovernment-licensed waste treatment companies.SAKAB has recently completed a new hazardouswaste treatment facility, which uses a large-capacityrotary kiln incinerator, but which cannot” handlehighly chlorinated wastes.

Sweden has taken a generally restrictive positionin international discussions on ocean incineration,stating that it ‘ ‘will accept incineration at sea asa last resort during a transition period, if no land-based treatment alternatives exist. A Swedish lawdating from 1971 prohibits dumping or ocean in-cineration from Swedish ports or Swedish vessels.However, Sweden has used incineration at sea onforeign vessels to a limited extent in recent years:6,420 mt of organohalogen wastes of Swedish ori-gin were incinerated at sea in 1982. No applica-

tions have been approved for such activity since1983.

Sweden regards land-based incineration as themost practical and preferable alternative to oceanincineration. However, the lack of sufficient capac-ity, especially to process chlorinated wastes, is citedas a major obstacle to ending Sweden’s 1imited reli-ance on ocean incineration.

Switzerland

Because of insufficient land-based incinerationcapacity within Switzerland, about 10,000 mt oforganic wastes are exported for incineration. Thosewastes with a high (greater than 15 percent) chlo-rine content are, without exception, sent for inciner-ation at sea. This quantity averages about 5,000mt annually and has been increasing over the lastseveral years. Switzerland expects that the quanti-ties of waste it incinerates at sea will continue toincrease at least in the short term, because of strictercontrols over land disposal and the length of timerequired to develop land-based capacity. For thelong term, Switzerland regards land-based inciner-ation to be environmentally preferable to ocean in-cineration because of the greater control the author-ities are able to exert on land.

United Kingdom

A total of 3.78 million mt of ‘hazardous and dif-ficult wastes’ are disposed or treated offsite in theUnited Kingdom each year. An estimated 2 per-cent (80,000 mt) is incinerated at 11 land-based fa-cilities. The recent closure of one very large land-based incinerator has increased demand for inciner-ation at sea (1 7).

In 1982, the United Kingdom used incinerationat sea for only 852 mt of waste, ‘‘which would havepresented special problems if incinerated in land-based units. Ocean incineration has been increas-ingly used since 1981: 2,700 mt in 1983 and 3,500mt in 1984 were incinerated at sea. The UnitedKingdom regards ocean incineration of certainwastes to be the best practicable environmental op-tion (5).


1.

2.

3.

4.

5.

6.

7.

8.

9.


Brown, W. Y., Testimony Before the Subcommit-tee on Natural Resources, Agricultural Researchand Environment, House Committee on Scienceand Technology, Hearing on ‘ ‘Ocean Incinerationof Hazardous Waste, “June 13 and 25, 1985, No.61 (Washington, DC: 1985).Commission of the European Communities, “Pro-posal for a Council Directive on the Dumping ofWaste At Sea, ” COM(85) 373 final (Brussels: July12, 1985).European Council of Chemical Manufacturers’Federations, Incineration At Sea History, State ofthe Art and Outlook, presented for considerationof the scientific group of the London Dumping Con-vention at the March 1985 meeting, February 1985.European Parliament, ‘ ‘Report Drawn Up on Be-half of the Committee on the Environment, PublicHealth, and Consumer Protection on the Combat-ing of Pollution in the North Sea, Working Doc-uments, 1983-1984, Document 1-1 173/83, Dec. 19,1983.Hazardous Waste Inspectorate, “First Report,Hazardous Waste Management, An Overview, ”Department of the Environment (United Kingdom:June 1985).Grogan, W, C., Input of Contaminants to the NorthSea From the United Kingdom, final report pre-pared for the Department of the Environment(Edinburgh: May 1984).Inside EPA, “International Group To Await U.S.Tests Before Studying Incineration At Sea, ” InsideEPA 6(12):7, Mar. 22, 1985.International Maritime Organization, Inter-Governmental Conference on the Convention onthe Dumping of Wastes At Sea, Final Act of theConference With Attachments Including the Con-vention on the Prevention of Marine Pollution byDumping of Wastes and Other Matter, LondonDumping Convention, Oct. 30 to Nov. 13, 1972(London: 1982).International Maritime Organization, ‘ ‘Consider-ation of Report on Dumping, Draft Report of Per-mits Issued in 1982, document LDC/SG.8/INF.3,prepared for 8th Meeting of Scientific Group onDumping (London: Dec. 20, 1984).

10.

11

12.

13.

14,

15.

16.

17.

18.

19.

International Maritime Organization, “Consider-ation and Adoption of the Report, Draft Report ofthe Scientific Group on Dumping, ” documentLDC/SG.9/WP.4, 9th Meeting of Scientific Groupon Dumping (London: May 1, 1986).Lankes, W., “Incineration At Sea: ExperienceGained With the M/T Vesta, ” in Wastes in theOcean, vol. 5, D.R. Kester, et al. (eds.) (New York:John Wiley & Sons, 1985), pp. 115-124.Nauke, M. K., “Development of International Con-trols for Incineration At Sea, in Wastes in theOcean, vol. 5, D.R. Kester, et al. (eds.) (New York:John Wiley & Sons, 1985), pp. 33-52.Ocean Combustion Service, “15 Years of Waste In-cineration At Sea: History, State of the Art, Con-trol, Environmental Impact’ (Rotterdam, TheNetherlands: Ocean Combustion Service, Febru-ary 1985).Oslo and Paris Commissions, The First Decade(London: The Chameleon Press Ltd, 1984).Oslo Commission, “Report on the Seventh Meet-ing of the Oslo Commission, Document OSCOMVII/1 1/1 (Brussels, Belgium: June 10-12, 1981).Oslo Commission, “Tenth Annual Report on theActivities of the Oslo Commission, ” 1985.Oslo Commission, “Alternative Means of Disposalfor Organochlorine Wastes, ’ Document OSCOM1 l/4/2-E, presented by The Netherlands at the Elev-enth Meeting of the Oslo Commission (Mariehamn,Finland: June 11-13, 1985).Spaans, L., North Sea Directorate, The Nether-lands, “Hazardous Waste Management in TheNetherlands, congressional staff briefing sponsoredby the German Marshall Fund and the KeystoneCenter, Washington, DC, Feb. 28, 1986.U.S. Environmental Protection Agency, Office ofPolicy, Planning and Evaluation, “Background Re-port IV and Appendices: Comparison of RisksFrom Land-Based and Ocean-Based Incineration, ”Assessment of Incineration as a Treatment Methodfor Liquid Organic Hazardous Wastes (Washing-ton, DC: March 1985).

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Acronyms and Abbreviations

Acronyms and Abbreviations

BAT —Best available technologyB H C —Benzene hexachlorideBtu —British thermal unitCAA —Clean Air ActC B O —Congressional Budget OfficeC E —Combustion efficiencyCERCLA—Comprehensive Environmental

C F RcoCO2C O T PC Z MD D TD ED O TD R EE D CEECEISEPA

F RF R GHCl

Response, Compensation andLiability Act

—Code of Federal Regulations—Carbon monoxide—Carbon dioxide—Captain of the Port—Coastal Zone Management—Dichlorodiphenyl trichloroethane—Destruction efficiency—Department of Transportation—Destruction and removal efficiency—Ethylene dichloride—European Economic Community—Environmental Impact Statement—U.S. Environmental Protection

Agency—Federal Register—Federal Republic of Germany—Hydrogen chloride

HWDMS —Hazardous Waste DataManagement System

I MI M O

L D CMPRSA

mmtmtNMFSN O A A

PCBP C TPICP O H C

R C R A

SABSACSA

S G DT C D DT C D FT D ETSCAUSCG

—Intermodal—International Maritime

Organization—London Dumping Convention—Marine Protection, Research and

Sanctuaries Act—Million metric tons—Metric ton—National Marine Fisheries Service—National Oceanic and Atmospheric

Administration—Polychlorinated biphenyl—Polychlorinated terphenyl—Product of incomplete combustion—Principal organic hazardous

constituent—Resource Conservation and

Recovery Act—Science Advisory Board—Scientific Advisory Committee for

Scientific Advice—Scientific Group on Dumping—Tetrachlorodibenzo-p-dioxin—Tetrachlorodibenzofuran—Total destruction efficiency—Toxic Substances Control Act—United States Coast Guard

215

Index

accidents: see spillsaccountability: 27,43,46acid gases (also see hydrogen chloride): 12,14,57,

114,119,127,150performance standard: 12,33,124,127,150

advanced oil recovery: 87afterburners: see secondary chambersAgent Orange: 120,180,181,183,184, 197air nozzle: see atomizationair pollution control equipment or wastes: see

scrubbersalkalinity: see acid gasesannual throughputs of incinerators: 101,102,107Apollo vessels: 6,101,107,108,109,139, 141,182aqueous waste: 55,57,59,143ash: 58,99,121atomization of waste: 93,115

rotary cup: 108,115spray nozzle: 108, 115

At-Sea Incineration, Inc.: 8,25,108,109,182Australia: 62,196,197Austria: 197automatic shutoff system: 126,127,128,142

background concentrations: 149,150ballast and bilge waters: 128,184,185Barcelona Convention: 193barges: 108,113,138

versus self-propelled vessels: 113Belgium: 143,197,198benzene hexachloride (BHC): 61,126best available technology: 26,39,40,110,115bioaccumulation: 60,61,140,160,163,164biological treatment/detoxification: 61,85birds: 162,163boilers and furnaces (also see cement kilns): 5,10,

49,60,76,84,93bottom-dwelling organisms: 162,163Brownsville, Texas: 3,182buffering capacity of seawater: 5,12,15,57,114,123,

127,193burner type: see atomization

cadmium: 36,120,122,147,149,150Canada: 199capacity: see hazardous waste, commercial incinera-

tion, ocean incineration, or land-based in-cineration

Captain of the Port (COTP): 38,41carbon monoxide: 119,120,123,125,126cargo transport and storage modes, see transpor-

tationcatalytic dehalogenation: 89

cement kilns: 49,57,84,85,201CERCLA: 46,47,48,173chemical treatment/detoxification processes: 61,63,

85,88Chemical Waste Management, Inc.: 61,108,109,

143,144,147,151,181, 182,197,199chlorinated and highly chlorinated wastes: 5,179,

180,193,197advantages of ocean incineration: 4,10,14,23,

57,167limitations of land-based incineration: 15,57,122

chlorination processes: 10,87chlorine content: 15,57,84,109,122,123,124,151,179,

197,200chlorine gas: 15,57,150chlorine recovery: 87Clean Air Act (CAA): 125,128,174Clean Water Act (CWA): 47,127,152,173Coast Guard: 37,38,39,41,108,110,1 13,114,129,

138,173Coastal Zone Management Act: 129,173,182combustion efficiency (CE): 33,123,124,125commercial incineration: 11,16,55,93,101,103, 166

capacity and demand: 10,19,69,73,74,102,187market: 48,73,75,167,187of PCBs: 61,174

Commission of the European Communities: 195comparison of land-based and ocean incineration

regulation: 11,40,122-129releases of waste (also see spills): 11,133

accidental: 14,133,134,136routine: 14,133,134

risks: 13,159-165to human health: 14,159-161to marine environment: 14,161-165

scrubbers: 11technologies: 119-129

comparison of marine transport of hazardous wasteand nonwaste materials: 15,134,138,140-142,163

PCBs: 61,140quantities and types of material carried: 140,141

comparison to other sources of marine pollution:15,146,147,149,198

compliance record of permit applicants: 24,49Comprehensive Environmental Response, Compen-

sation, and Liability Act: see CERCLACongress, role of: 4,38,40Congressional Budget Office (CBO): 10,63,67,72,

73,74,81containerization/containership vs. bulk storage and

transfer: 110,134,136credibility of EPA or ocean incineration companies:

24,49

219


data gaps: 44,45,63,67,100,133,152,154,161, 186DDT: 23,61,126,182,200dechlorination: 85,89deep-well injection: see underground injectiondemand: see hazardous wasteDenmark: 17,198,199Department of Transportation (DOT): 37,112,173destruction efficiency (DE): 12,14,26,33,34,39,62,

115,120,123,124,142, 145,183,184,187destruction and removal efficiency (DRE): 12,26,

123,124dibenzofurans: 35,119,120,124,125,200dioxin (TCDD): 35,55,56,61,85,119,120,121,124,

125,126,146,180,181,183,200dumping: see ocean dumping or landfill

emissions (also see individual type of emission):25,33,144,153,197

incinerator plume/plume gases: 114,119,151,161,182,184,187

toxicity of and testing of 35,164,187endangered species: 5,162,175,185Endangered Species Act: 129,162,173energy content: 5,23,55,59,109energy recovery: 10,99,101Environmental Oceanic Services Corp. (EOS):

108,109,128environmental performance standards: see acid

gases or particulate emissionsEPA (Environmental Protection Agency):

Ocean Incineration Regulation (proposed): 7,18,45,46,62,108,120,121,125,126, 129,147,149,175,184

Ocean Incineration Research Strategy: 8,20,162,164,182,187

promotional role in ocean incineration: 7,8,25ethylene dichloride (EDC): 143,144,152,153European Parliament: 195

Federal Republic of Germany: 17,18,62,193,197,198,200

financial responsibility: 46Finland: 197,198fish: 161,164,165flue gases: see emissionsfluid wall reactor: 88fluidized bed incineration: see land-based in-

cinerationfood chain: see bioaccumulationFrance: 197,198fuel, use of hazardous waste as: see hazardous wastefugitive emissions: 126,128,143,144future market: see hazardous wastes or ocean in-

cineration

geographic distribution of waste generation: seeocean-incinerable waste

geographic restrictions on transportation of wastes:24

Germany: see Federal Republic of GermanyGulf of Mexico Incineration Site: see ocean in-

cineration

halogenated solvents: 59,65,81Hazardous and Solid Waste Amendments of 1984:

see RCRAHazardous Materials Transportation Act: 173hazardous waste (also see RCRA)

capacity and demand for treatment facilities:73,194,198

generation/inventory: 59,65all hazardous waste: 63,70incinerable waste: 63,65ocean-incinerable waste: 65projection of future quantities: 66

management hierarchy: 3,83management strategy: 7,42,44transportation (also see comparison of marine

transport): 111,112,139,152,153geographic restrictions: 24risks: 26,37

use as fuel: 76,84,85Hazardous Waste Data Management System

(HWDMS): 100,103Hearing Officer’s Report: 7,41hearth incineration: see land-based incinerationhierarchy: see hazardous wastehigh temperature electric reactor: 88hydrochloric acid: see hydrogen chloridehydrogen chloride (also see acid gases): 5,12,14,33,

57,114,119,120,123,124, 150,151emission standard: see acid gasesrecovery: 87

incentives for preferred practices: 4, 17, 19,43,46incinerable waste: 9,55,70

projection of future quantities: 68incineration: see commercial, land-based, or ocean

incinerationincineration sites: see ocean incinerationincinerator upsets: see upsetsindustrial boilers and furnaces: see boilers and

furnacesindustries generating incinerable waste: 66,67information gaps: see data gapsinfrastructure: see portsinterim status of ocean incineration: see ocean in-

cinerationintermodal containers: 109-113,134

Index ● 2 2 1

International Maritime Organization: 194international use of ocean incineration: 193-201

implications and trends: 6,17,198number of voyages: 197ports used: 197,198practices and regulations: 17,194-198quantities incinerated: 195-197vessels used: 196-197

inventory: see hazardous wasteItaly: 197

Japan: 197

land-based incinerationcapacity: 15,17,101,103extent of use and number of facilities: 9,15,65,73,

100,102location of facilities: 101,102types:

fluidized bed: 97,100,174hearth: 96,100liquid injection: 37,93,94,95,100,102rotary kiln: 14,37,55,93,95,96,100, 102

land disposal: 9,10,74,81,83,187landfill: 9,60,81,83,127,167,187land transportation: see hazardous wasteliability: 7,42,43,46,48,167liquid extraction: 86liquid incinerable waste: see ocean- incinerable wasteliquid injection: see land-based or ocean in-

cinerationlocation of incinerators: see land-based incinerationLondon Dumping Convention (LDC): 36,45,62,

113,123,126,127,175, 183,193,194,197,198

marine mammals: 162,185Marine Protection, Research, and Sanctuaries Act

(MPRSA): 38,40,41 ,45,46,122,123,173,175,183,185

marine transportation: see hazardous wastemarine water quality criteria: 13,34,35, 122, 125Maritime Administration: 8,182market: see ocean incineration or commercial in-

cinerationMatthias vessels: 193,195-197mercury: 36,120,122,127,147metals: 120,125,147

bioavailability: 121chemical form: 13,36,58,121content in incinerable wastes: 36,58,154,197emissions: 13,26,34,35,36,121,153, 154,198limitations: 13,23,33,35,121 ,122,124,147scrubbers: 12,120volubility: 121volatilization: 58,120,149

microlayer: 12,16,114,145,150,151 ,161,163,164,165Minnesota hazardous waste study: 69,72,74mobile incinerators: 55,56,61,121,174molten glass: 88molten salt: 88monitoring and sampling: 112,128,161,168,175, 176,

179,181,182,184,193

National Marine Fisheries Service: 162,185National Oceanic and Atmospheric Administration:

182,183need for ocean incineration: see ocean incinerationNetherlands: 17,18,62,194,197,198,200neutralization

of acid gases: 57,114,123of dumped acid waste: 12,151of scrubber effluent: 99,152

New Jersey hazardous waste studies: 71,72,74New York Bight: 146,148nonhalogenated solvents: 57,58,59,65,81normal stack emissions, see emissionsNorth Atlantic Incineration Site: see ocean in-

cinerationNorth Sea: 12,16,17,107,143,151 ,179,180,182,

193-199Norway: 197,201

ocean dumping: 4,6,12,40,148,149,151, 179,193-195Ocean Dumping Regulations: 43,44,45,175ocean-incinerable waste: 9,43,55,58,66,70

characteristics of: 5,55-59,109geographic distribution of waste generation: 66,

68,69versus solids and sludges: 12,14,48,55,64,65,68,

69,70,75ocean incineration

capacity and demand: 15,75,107companies: see individual namescomparison of technologies: 110cost to generators: 13,43, 167design features or standards: 108,115,193

type I and type II: 108,113interim status: 4,18,19,21,22,194liquid injection technology: 55,93,107market: 21,48,167,193need for: 4,10,22,41,45,75,76, 129past burns: 16,61,120,161,179-185permit length and renewal provisions: 24,40,50permit types: 179,182quantities incinerated: 179-182,195-197scale of program: 21-25site designation: 8,12,38,49,66,175,193

Gulf of Mexico: 49,162,179,185,186North Atlantic: 49,134,162,182,185,186other possible sites: 185, 195


statutory authority to regulate: 6,38,40vessels: see individual names

Ocean Incineration Research Strategy: see EPAOcean Incineration Regulation: see EPAoils: see waste oilsonsite vs. offsite

incineration: 16,101,166,168other management technologies: 66,71,72,23,168

organic liquids: 59,65,81Oslo Convention/Commission: 17,193,194,195,

197,198oxidative ultraviolet light: 89

parent compounds: see POHCsparticulate emissions/material: 12,33,58,120,125,127

environmental performance standard: 13,122,123,124,147

past burns: see ocean incinerationPCBs: 5,10,15,18,20,23,34,41,58,60,62,63,65,85,

101,120,122,124-126, 140,142-146,152,153,160,163,164,174,180, 182-184,188,197-200

PCTs: 61,122,126,200permits: see ocean incinerationpersistence: 60,61,140,163PICs: 12,14,26,35,1 19,125,127,146,153,187plankton: 161,163-165,181plasma arc: 88plume: see emissionsPOHCs (principal organic hazardous constituents):

34,119,127,145pollution control devices, effluents: see scrubberspolychlorinated biphenyls: see PCBspolychlorinated terphenyls: see PCTsPort and Tanker Safety Act: 173Port and Waterways Safety Act: 173port facilities and infrastructure: 66,108,109,167port selection: 38principal organic hazardous constituents: see

POHCsproducts of incomplete combustion: see PICspublic concerns and involvement: 7,27,41,42,168pyrolysis: 88,93,96,98

RCRA: see Resource Conservation and RecoveryAct

recovery and recycling: see waste recovery andrecycling

reduction: see waste reductionresidence time: 36,102,103,115,120,126Resource Conservation and Recovery Act (RCRA):

40,46,56,63,120,121, 122,173,174amendments: 3,10, 19,44,46,48,60,67,73,74,76,

82,83,84,85,121classification of hazardous waste: 56,76

waste codes: 57,65risks: see comparison of land-based and ocean in-

cinerationrotary cup: see atomizationrotary kiln: see land-based incineration

Science Advisory Board: 12,14,34,37,120,133,142,146,161,164,184,186

scrubbers: 98,99,101,149,193capacity limitations: 15,57,122removal of combustion products: 12,26,57,120,

123,124,127waste (effluent or sludge): 11,15,58,63,99,114,

121,127,151,152,153, 193SeaBurn, Inc.: 108,109,111,112,113, 128seawater buffering capacity: see buffering capacityseawater scrubbers: 13,108,114,128,145secondary chambers: 36,93Shell Chemical Co.: 179,197shiprider: 37,41,129,168site designation: see ocean incinerationsludge wastes: see liquid incinerable wastes or

scrubberssmall quantity generators: 72,76solid wastes: see liquid incinerable wastessolvent recovery: 85,87Southern California Bight: 146,148Spain: 197spills: 14,15,111,113,133,134, 152,160,162,184

cleanup: 14,15,163rates: 136,137sizes: 138

standards: see acid gases, CE, DE, DRE, or partic-ulate emissions

mass emission concentration or rate standard: 34starved air incineration: 93statutory authority: see ocean incinerationsteam nozzle: see atomizationsupercritical fluid extraction: 87supercritical water reactor: 88Superfund: see CERCLAsurface impoundment: 9,81,83,127surface microlayer: see microlayerSweden: 17,197,201Switzerland: 197,201

Tacoma Boatbuilding, Inc.: 8,25,108,182tamper-proof or tamper-resistant devices: 128,129,

168tank containers: see intermodalTCDD: see dioxintemperature requirements: 126,128tetrachlorodibenzo-p-dioxin (TCDD): see dioxintetrachlorodibenzofurans (TCDF): see dibenzofurans

Index . 223

thermal destruction technologies (also see boilersand furnaces): 84,88,

thin film evaporation: 87total destruction efficiency (TDE): 34,120Toxic Substances Control Act (TSCA): 40,41,60,

62,63,101,124,126,173, 174,184toxicity of emissions: see emissionstransfer, handling, and storage: 139,144,152,153transportation of hazardous waste: see hazardous

wastetrial burn requirements: 123,126,128type I or type 11 vessel: see ocean incineration

unburned waste (also see POHCs): 12,119,127,145,153

underground injection: 9,57,81,83,127,187United Kingdom: 18,197,198,201upsets (malfunctions) or upset conditions: 35,125,

127,133,136,142U.S. Coast Guard: see Coast Guard

vessel construction and design standards: see oceanincineration

vessels: see individual names

Vesta: 107,108,196,197volatilization: see metalsVulcanus vessels: 9,101,108,109,134,136, 137,141,

143,151,164,179,180-182, 184,193,195-197,200

waste analysis requirements: 112, 122, 128waste end tax: 44waste limitations: see metalsWaste Management, Inc.: see Chemical Waste

Management, Inc.waste oils: 58,59,81,84

quantity: 65,66recovery and recycling: 58,86regulation as hazardous waste: 58,63,76,85,86

waste recovery and recycling: 9,10,16,63,65,67,68,70,71,76,85,87

waste reduction: 3,10,16,43,44,63,67,69,7 1,76,86water content: 55,109,140water quality criteria: see marine water quality

criteriaWestat survey: 63,72,73,100wet-air oxidation: 98