Ocean Incineration: Its Role in Managing

Hazardous Waste

August 1986

NTIS order #PB87-100327
Library of Congress Catalog Card Number 86-600566

For sale by the Superintendent of Documents

U.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 is

moving with some urgency toward development and greater utilization of methods that

destroy, treat, recycle, or reduce the generation of hazardous wastes.

Within this context of change, one of the many distinct technologies for managing

hazardous 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 the

past? By burning hazardous wastes far from land, are we reducing risks to human health

or simply shipping our problems out to sea? Is the small but real risk of a catastrophic

spill worth the benefit of actually destroying most of the wastes? These and other questions have been the focus of considerable public attention over the last several years, and

various congressional committees have responded by holding half a dozen hearings since

1983.

In 1984, two congressional committees—the House Committees on Merchant Marine and Fisheries and on Public Works and Transportation—requested the Office of Technology Assessment to undertake a broad study of wastes in marine environments, including an examination of ocean incineration. At that time, the Senate Committee on

Commerce, Science, and Transportation endorsed the study. More recently, the original

requesting committees and the House Committee on Science and Technology asked OTA

to prepare a full report on ocean incineration. In response to the latter request, this assessment, Ocean Incineration: Its Role in Managing Hazardous Waste, provides a comprehensive examination of ocean incineration technology. A second assessment responding

to the initial request is in preparation.

This assessment of ocean incineration includes consideration of the adequacy of regulations; risks to human health and the marine environment relative to the risks of comparable activities; existing and emerging alternatives; the capabilities and limitations of

ocean incineration in managing hazardous wastes; and how its use might affect efforts

to develop superior waste treatment and reduction practices. Particular attention is addressed to areas of intense public concern over the use of this technology. This report is

offered to aid Congress in its deliberation of the fate and design of the ocean incineration

program.

Many individuals in government, industry, the public interest and environmental

communities, and academia contributed to the effort represented by this report. In particular, OTA wishes to thank the advisory panel and the many reviewers who devoted

time and energy to this undertaking. Their involvement does not necessarily indicate endorsement of the report or agreement with its findings: OTA bears sole responsibility.

Director

. . . Ill
—.

Wastes in Marine Environments Advisory Panel

Thomas Clingan, Chairman

University of Miami School of Law

Walter Barber George Lutzic

Waste Management, Inc. New York City Department of Environmental

Protection Willard Bascom

Scripps Institute of Oceanography William J. Marrazzo

(formerly with Southern California Coastal City of Philadelphia

Waters Research Project) Joseph T. McGough, Jr.

Rita Colwell Parsons Brinckerhoff

Department of Microbiology (formerly with the New York City Department

University of Maryland of Environmental Protection)

A. Myrick Freeman III Michael G. Norton

Department of Economics British Embassy

Bowdoin College Jerry Schubel

John Gosdin ‘Marine Sciences Research Center

Governor’s Office State University of New York at Stony Brook

State of Texas Richard F. Schwer

Jon Hinck DuPont

Greenpeace, USA

Kenneth Kamlet

URS-Dalton

(formerly with National Wildlife Federation)

John A. Knauss

Graduate School of Oceanography

University of Rhode Island

NOTE: OTA appreciates and is grateful for the valuable assistance and thoughtful critiques provided by the advisory panel

members. The panel does not, however, necessarily approve, disapprove, or endorse this report. OTA assumes full

responsibility for the report and the accuracy of its contents.

Related OTA Reports

●

●

●

●

●

●

●

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 ; $9.50

Technologies and Management Strategies for Hazardous Waste Control. OTA-M-196; March 1983.

NTIS order #PB 83-189241.

iv
OTA Project Staff

John Andelin, Assistant Director, OTA

Science, 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.

v
Acknowledgments

Many individuals and organizations have contributed to this report by providing valuable information, guidance, and substantive reviews of draft material. OTA wishes to extend its gratitude to the following for their time and energy.

Captain Ken Allan

Marine Container Equipment Certification

Corporation

Michele Anders

Environmental Protection Agency

Deyaun Boudreaux

Gulf Coast Coalition for Public Health

Darrell Brown

Environmental Protection Agency

William Y. Brown

Waste Management, Inc.

Lisa Bunin

Greenpeace, USA

Eric Butler

Office of Technology Assessment

Ruth A. Chemerys

National Oceanic and Atmospheric

Administration

Ann G. Daniels

Environmental Defense Fund

Tudor Davies

Environmental Protection Agency

John Ehrenfeld

Abt Associates

Lieutenant Lee Ellwein

U.S. Coast Guard

Dan Farrow

National Oceanic and Atmospheric

Administration

Melanie La Force

Environmental Protection Agency

Butch Fries

Inside E.P.A.

Sue Ann Fruge

Gulf Coast Coalition for Public Health

Jack Gentile

Environmental Protection Agency

Richard J. Gimello

New Jersey Hazardous Waste Facilities Siting

Commission

Vincent G. Grey

SeaBurn, Inc.

Nan Harlee

Office of the Maritime Administrator

U.S. Maritime Administration

Commander Charles Huber

U.S. Coast Guard

David S. Hugg III

Department of Natural Resources and

Environmental Control

State of Delaware

Lieutenant Commander Stephen V. Hughes

U.S. Coast Guard

Peter Johnson

Office of Technology Assessment

Paul Kerkhoven

Office of Senator Roth

United States Senate

Sally Lentz

Oceanic Society

Jackie Lockett

Gulf Coast Coalition for Public Health

Henry S. Marcus

Ocean Engineering Department

Massachusetts Institute of Technology

Francis Mardula

U.S. Maritime Administration

Rosalie T. Matthews

Matthews Consulting and Construction, Inc.

Susan Mulvaney

Congressional Liaison

Environmental Protection Agency

vi
George Nassos

Waste Management, Inc.

Judy Nelson

Environmental Protection Agency

Donald Oberacher

Environmental Protection Agency

Timothy Oppelt

Environmental Protection Agency

Edith Page

Office of Technology Assessment

Matthew Perl

Environmental Protection Agency

Stephanie Pfirman

Committee on Science and Technology

U.S. House of Representatives

Marjorie A. Pitts

Environmental Protection Agency

David Redford

Environmental Protection Agency

Joe Retzer

Environmental Protection Agency

Jerry A. Riehl

Environmental Oceanic Services

Larry Rosengrant

Environmental Protection Agency

Kenneth I. Rubin

Congressional Budget Office

United States Congress

John Sandstedt

At-Sea Incineration, Inc.

Lee Santman

U.S. Maritime Administration

Richard Schwabacher

Office of Representative Hughes

U.S. House of Representatives

Diane B. Sheridan

League of Women Voters of Texas

Douglas Shooter

Arthur D. Little, Inc.

Ellen Silbergeld

Environmental Defense Fund

William W. Stelle, Jr.

Committee on Merchant Marine and Fisheries

U.S. House of Representatives

Sue Stendebach

formerly with the Office of the Governor

State of Texas

Sharron Stewart

Gulf Coast Fishermen’s Environmental Defense

Fund

David Sussman

Environmental Protection Agency

John Thomasian

Congressional Budget Office

United State Congress

Patrick Tobin

Environmental Protection Agency

Christopher Tulou

Office of Representative Carper

U.S. House of Representatives

Marc Turgeon

Environmental Protection Agency

George Vander Velde

Waste Management, Inc.

John Waesche

Marine and Energy Division

Jardine Insurance Brokers, Inc.

Richard C. Wills

At-Sea Incineration, Inc.

Terry F. Yosie

Science Advisory Board

Environmental Protection Agency

vii
Contents

Chapter Page

l. 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 for

Incinerable 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

Page

Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

The Role of Congress . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

Major Public Concerns . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

Evaluating Ocean Incineration in a Broad Context . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Major Findings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

The Potential Role of Land-Based and Ocean Incineration . . . . . . . . . . . . . . . . . . . . . . . . . 9

Comparison of Land-Based and Ocean Incineration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

Releases of Wastes to the Marine Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

Past and Current Use of Hazardous Waste Incineration . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

Recovery, Recycling, and Reduction of Incinerable Wastes . . . . . . . . . . . . . . . . . . . . . . . . . 16

The Use of Ocean Incineration by Other Nations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

Deciding the Fate of Ocean Incineration: Major Policy Options . . . . . . . . . . . . . . . . . . . . . . . 18

Policy Options and Their Implications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

Determining the Scale of an Ocean Incineration Program . . . . . . . . . . . . . . . . . . . . . . . . . . 21

Shaping an Ocean Incineration Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

Regulation of Incinerator Emissions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

Transportation Risks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

Comparison of Different Ocean Incineration Technologies . . . . . . . . . . . . . . . . . . . . . . . . . . 26

Equitable Regulation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

Public Involvement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

The Effect of Ocean Incineration on the Development of Better Alternatives . . . . . . . . . . 27

Unresolved Questions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

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

Box Page

A. What Is Ocean Incineration? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
Chapter 1

Findings and Policy Options

OVERVIEW

Few practices, even in the tumultuous arena of

hazardous waste management, have engendered as

much controversy and polarization as has the concept of burning hazardous wastes in incinerators

mounted on ocean-going vessels. Critics have characterized ocean incineration vessels as ‘‘outmoded,

unforgiving technology’ and ‘‘nothing more than

old-fashioned pot-bellied stoves without the smokestack, whereas proponents see ocean incineration

as ‘‘a way to prevent the cancer that chemicals may

cause’ and ‘‘to destroy hazardous wastes before

they destroy us. When the U.S. Environmental

Protection Agency (EPA) held a public hearing on

ocean incineration in Brownsville, Texas, in 1983,

more than 6,000 people attended, which vividly

demonstrates the level of public concern over this

technology. ’ Such concerns have temporarily halted

the development of ocean incineration in this

country.

The debate over ocean incineration reflects the

tenor of change taking place in the American approach to managing hazardous waste. The Hazardous and Solid Waste Amendments of 1984,2 which

amended the Resource Conservation and Recovery

Act (RCRA), responded to the growing recognition that the methods used in the past to dispose

of hazardous wastes should no longer be used.

Mounting evidence of groundwater contamination

and other problems associated with leakage of

wastes from the growing list of Superfund sites lent

a new sense of urgency to finding new approaches.

To replace the old practices, Congress has called

for the development of environmentally sound

methods for disposing of, treating, destroying, and

recycling hazardous wastes, and for reducing their

generation. It is against this background of transition that Congress must decide what role, if any,

ocean incineration should play in managing

America’s hazardous wastes.

‘This public hearing was the largest in EPA’s history. At issue was

whether to grant a permit for incinerating PC B- and DDT-containing

wastes at an ocean site in the Gulf of Mexico.

‘Referred to throughout this report as the 1984 RCRA Amendments ( 13).

Existing and developing methods for managing

hazardous wastes are commonly organized into a

hierarchy that accords preferred status to methods

that reduce risk by reducing the quantity and degree of hazard of wastes.

The highest tier in the hierarchy includes those

methods—collectively referred to as waste reduction—that actually avoid the generation of wastes.3

Disposal practices that attempt to contain waste or

actually disperse them in the environment occupy

the lowest tier. Between these tiers are those

methods—distinct from disposal practices—that reduce risks by recovering, treating, or destroying

wastes after they are generated. For example, a

properly operating incinerator can destroy more

than 99 percent of certain hazardous wastes, greatly

reducing both their quantity and degree of hazard.4

In such a hierarchy, the technology of ocean

incineration falls midway between most disposal

practices, which are generally inferior, and most

reduction, recycling, and advanced treatment technologies, which are generally superior. For what

hazardous wastes could ocean incineration be used?

Of all hazardous wastes, only a fraction (up to 20

percent) is amenable to incineration. Of these incineralde wastes, only those in liquid form (up to

about 8 percent of all hazardous wastes) could be

incinerated at sea. For liquid wastes that are highly

chlorinated, several technical factors partially constrain the ability of available land-based alternatives to effectively manage such wastes. Because

these limitations do not apply to ocean incineration, it is one of only a few technologies available

to manage highly chlorinated wastes.

3Not all practices that are commonly considered waste reduction

actually lead to risk reduction. For example, process modifications

can reduce the quantity of waste or alter its composition without necessarily reducing the degree of hazard of any resulting waste. As used

in 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 environment. Concerns about incineration generally focus to a greater

degree on the magnitude and impact of these releases than on the magnitude and benefit of the destruction achieved.

3
—. —

4 ● Ocean Incineration: Its Role in Managing Hazardous Waste

The fundamental choice that must be faced is

whether to develop an ocean incineration program.

This decision must consider a variety of factors,

both technical and nontechnical. Because no methods are risk-free, the risks that ocean incineration

poses—to human health and the marine environment—and the benefits that it provides—by actually destroying most of the wastes—must be weighed

against those of the land disposal practices and other

treatment methods that are currently used for liquid incinerable wastes.

OTA finds that ocean incineration could be

an attractive, though not essential, interim option for managing liquid incinerable wastes, in

particular highly chlorinated wastes. Indeed,

from several perspectives, the use of ocean incineration occupies a ‘‘middle ground. In a temporal

sense, it is one of several options that could help

bridge the gap between the practices of the past,

which are being abandoned, and the preferred practices of the future (waste reduction, recovery, and

recycling), whose capacity is only now developing.

Several technical and economic factors would confine its applicability to a relatively small portion (less

than 10 percent) of all hazardous wastes, although

they are among the most toxic and concentrated

of such wastes. Finally, with respect to both risks

and benefits, ocean incineration falls midway between past and developing practices. For these reasons, ocean incineration could be a useful option

today but is clearly not a panacea. Multiple waste

management options must be developed if the Nation’s hazardous waste problems are to be solved.

One of the major public concerns voiced over

ocean incineration is that a need for the technology has not been demonstrated. Although it could

play a role in meeting the expected near-term demand for alternatives to land disposal, OTA finds

that an absolute need for ocean incineration cannot be analytically demonstrated for a number of

reasons. The Nation could continue to rely on

methods that are generally less tractable for such

wastes. Moreover, predicting the rate at which preferred waste management practices will supplant

the need for destruction methods such as ocean incineration is exceedingly difficult. (A legal requirement to demonstrate a need for ocean dumping—

including ocean incineration—is contained in domestic and international regulations. No consensus

exists, however, as to how this requirement should

be interpreted and specifically applied to ocean incineration. )

OTA expects that ocean incineration would in

general have only a limited effect on incentives for

implementing preferred waste management practices. Nevertheless, to ensure that the shift

toward use of preferred practices is not impeded,

any program for ocean incineration should be

regarded as interim. It is important to ensure that,

if permitted, reliance on ocean incineration can be

lessened as we develop greater capacity in better

waste management practices and reduce the generation of hazardous wastes. Within this context,

ocean incineration could provide an attractive option for interim management of certain wastes.

The Role of Congress

Despite its major involvement in shaping hazardous waste management policy, Congress has

never directly addressed the issue of what role, if

any, ocean incineration should play. As a result,

the Federal Government’s regulation of ocean incineration has evolved without any explicit indication of congressional intent. Although few hazardous waste management technologies have required

direct congressional consideration, several special

features of ocean incineration may necessitate that

Congress examine public policy regarding this technology.

First, despite the fact that ocean incineration is

used to destroy hazardous wastes, in many respects

it falls outside of the policy and regulatory framework that Congress created, a framework that seeks

to establish ‘‘cradle-to-grave’ management of hazardous wastes. Because it takes place at sea rather

than on land, ocean incineration has been placed

into a different regulatory arena—under the umbrella of ocean dumping. The factors that originally

motivated the regulation of ocean dumping, however, are somewhat at odds with the technology of

ocean incineration, which involves wastes that cannot be directly dumped under present policy. Moreover, 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 avoid

the need for direct dumping (on land or at sea). a

Second, because of its nature and setting, ocean

incineration entails a wide, variety of activities that

are regulated under numerous Federal statutes and

agencies. These include:

● land transportation of hazardous material by

truck or rail;

. use and development of port facilities;

--- . . — -..

‘To a significant degree, this intent is accomplished; however, those

wastes that are not destroyed are re!eased directly into the marine environment.

●

federally regulated activity in States’ coastal

zones;

marine transportation of hazardous material;

transportation, storage, treatment, and disposal of hazardous waste;

activities that can result in air or water pollution; and

activities that can affect endangered species,

Third, the activities and possible consequences

of ocean incineration typically cross political boundaries to encompass multiple State and municipal

jurisdictions. 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 waste

products released into the environment by ocean

incineration may travel significant distances, and

the site in the Gulf of Mexico designated by the

United States is near the waters of other nations.

Moreover, the potential for U.S. actions to set

precedents for other nations must be considered.

Fourth, the level of controversy and significant

public involvement in the debate over ocean incineration may warrant congressional attention. Although the initial public response often centered

on local or regional concerns, the debate has become national in scope. As a result, ocean incineration is increasingly viewed in a broad context, as

only one component in the process of shaping a national strategy for managing hazardous wastes.

These factors are not unique to ocean incineration, but their sheer number and systematic involvement in every application of this technology

indicate a special need for an explicit policy toward

ocean incineration, clearly defining what role, if

any, the technology should play in managing hazardous wastes.

. . . . . . Congressional involvement m decisions regarding ocean incineration could take any of several

forms. The fundamental decision of whether and,

if so, how to proceed with ocean incineration requires consideration of numerous different technical

and nontechnical factors. Many of these are regulatory in nature, but may require oversight or direction from Congress. However, other aspects of

ocean incineration identified throughout this report

raise questions regarding the adequacy and appropriateness of the current statutory authority for regulating ocean incineration. The inclusion of ocean

incineration under the rubric of ocean dumping and

the lack of statutory authority to develop comprehensive regulations governing ocean incineration

are two examples of such issues. If ocean incineration is permitted, resolution of these questions may

necessitate clarifying legislative action on the part

of Congress.

Finally, Congress could take specific action to

decide the fate of the ocean incineration program.

Such action would directly establish national policy toward use of this technology, and could help

guide EPA and the public in determining whether

and how ocean incineration should fit into the Nation’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 United

States is an open question.

Major Public Concerns

Despite the routine use of ocean incineration for

more than 15 years in Europe and more than a decade of trial experience in the United States, a regulatory program for ocean incineration has not yet

been implemented. g Indeed, commercial ocean incineration, which has occurred only sporadically

in this country, has been delayed at least temporarily, pending (at a minimum) final regulations and

one or more research burns. A primary reason for

the Nation’s hesitance to embrace ocean incineration as a hazardous waste management technology

has been the strong public opposition to it. The opposition reflects a broad spectrum of concerns,

some specific to ocean incineration itself, and others

symptomatic of the much larger problem of hazardous waste management in general. 10 These concerns,

which are evaluated in greater depth throughout

this report, include the following questions:

●

●

●

●

●

whether EPA has fully considered both existing and developing alternatives to ocean incineration;

whether ocean incineration is needed, in light

of the available alternatives;

whether the risks and consequences of spills

on land or at sea resulting from transporting

or handling of waste are sufficiently understood, and in particular, whether available

means of responding to a spill are adequate;

whether shipboard incinerators can adequately

destroy wastes without posing unacceptable

risks to the marine environment or to humans;

whether the regulations, monitoring, and enforcement provisions proposed by EPA are

sufficient to govern all phases of ocean incineration activities; and

‘EPA proposed regulations for ocean incineration in February 1985

(50 FR 8222, Feb. 28, 1985). For the purposes of this report, this

Ocean Incineration Regulation will be used to represent EPA’s current approach to regulating ocean incineration, although numerous

changes are expected in the final regulation.

10A thorough and thoughtful discussion of the major areas of public concern is contained in the recent Hearing Officer’s Report on

the Tentative Determination to Issue the Incineration-at-Sea Research

Permit HQ-85-001 (20), issued by EPA on May 1, 1986, and in the

Summary of Public Comments accompanying that report.

● whether Sufficient research has been conducted

to justify the use of ocean incineration, given

our level of understanding of the marine environment and the value of its resources.

In addition, the following areas of need have been

identified in the public debate over ocean incineration:

●

●

●

the need to develop an overall hazardous waste

management strategy that would place greater

emphasis on reducing wastes at their source

and would clarify the role, if any, of ocean incineration in such a strategy;

the need for adequate measures to ensure that

users of ocean incineration are fully liable for

environmental releases or damages resulting

from ocean incineration, and, in particular,

the need for measures to address the claims

of injured parties in such cases; and

the need to consider the integrity and past

records of applicants for ocean incineration

permits.

In addition to these and other specific issues, an

overriding area of public concern is whether EPA

can regulate ocean incineration in an effective and

objective manner and be truly responsive to the

public. The lack of public trust in EPA has its roots

in the somewhat thorny history of U.S. involvement with ocean incineration, which is perhaps best

illustrated by examining the provisional nature of

the current regulatory program. 11

With regard to ocean incineration, the U.S. Government has undertaken three very different activities: research, regulation, and promotion. The

relationships and boundaries between these activities have often been ill-defined, and EPA has not

always fully appreciated the potential for conflicts

of interest, or even the appearance of conflicts of

interest. As a result, several such conflicts have

arisen, three of which are discussed below:

1. EPA has never clearly communicate; when

and in what sequence it would conduct its

ocean incineration research and develop its

regulations. Consequently, questions have

I (This issue was first clearly identified in the Hearing officer’s Report (20) on EPA’s proposed research burn; several additional provisional elements bearing on ocean incineration in general are listed

here, 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 research

burns carried out under the research strategy

would be part of the data on which regulations would be based or whether EPA intended to develop and issue regulations before granting any permits (research or

otherwise). Such unanswered questions have

made the entire process appear haphazard. 12

The government’s promotional role culminated in the U.S. Maritime Administration

granting a guaranteed loan to finance the construction of two incineration vessels by a private company.

13 Although the government’s

promotion of ocean incineration may well

have been based on a genuine belief that the

technology was both needed and environmentally sound, many members of the public have questioned the wisdom of promoting

the technology before developing a regulatory

program. In the eyes of its critics, EPA has

compromised its ability to fairly assess the

merits and risks of ocean incineration.

EPA proposed to conduct its research burn

in the North Atlantic Ocean at a site that has

not been formally designated, and the Agency

has yielded to other agencies the authority to

regulate several important activities related to

ocean incineration. Although clearly allowed

or even required under existing regulations

and statutes, such an approach makes the regulatory program seem tentative and fragmentary.

Many of the public concerns about ocean incineration can be addressed through technical or regulatory means, but the lack of credibility and public trust are, in many respects, far more difficult

to overcome. If ocean incineration is to play a role

in hazardous waste management, the government

12EPA recently decided (51 FR 20344, June 4, 1986) to deny a Proposed permit application for a research burn that the Agency had earlier

solicited to serve as one component of its Ocean Incineration Research

Strategy (16). In the decision, EPA stated that no permits, research

or otherwise, will be granted until final regulations are promulgated.

Although this statement clarifies current EPA policy, it raises questions about how the regulatory development process will be affected

by the absence of information from the research burn that was intended to aid in that process.

IJThe company, Tacoma Boatbui]ding, Inc. , recently filed bankruptcy proceedings, and its subsidiary, At-Sea Incineration, Inc., was

forced to default on its loan payments, due in large part to its inability

to obtain operating permits for the vessels.

must not only address the specific issues listed

above, but must also provide for meaningful public involvement in the decisionmaking process in

a manner that restores public confidence.

Evaluating Ocean Incineration in a

Broad Context

As the previous discussion suggests, developing

a policy for ocean incineration will require Congress to reexamine its policy towards the management of hazardous wastes as a whole. Legitimate

concerns have been raised over the need for ocean

incineration, the risks it poses to the environment,

and the numerous unresolved questions and uncertainties regarding its use. These concerns are best

viewed in the context of the corresponding availability, risks, and unknowns associated with alternative methods for managing incinerable waste.

This is true for at least two reasons: no methods

are free of risk and uncertainty, and a decision not

to employ one method necessarily results in the use

of other methods.

Thus, resolution of the debate over ocean incineration will require a thorough and objective comparative assessment of the technology. In particular,

the full range of available choices and the tradeoffs they entail must be clearly communicated.

In developing the analysis presented in this report, OTA encountered many issues whose dimensions extend well beyond the confines of ocean incineration, and often beyond those of hazardous

waste management in general. Some of these issues include:

●

●

●

●

●

●

the possibility that allowing the use of existing treatment and disposal methods would

serve as a disincentive for developing and

using better methods;

the risks and regulation of hazardous materials transportation;

problems with regulatory enforcement;

the government’s capacity to monitor for adverse environmental impacts;

the complexity of the hazardous waste market and its response to changes in the regulatory or economic climate;

the adequacy of liability provisions applicable

to 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 those

ardous waste management facilities; and aspects of each issue that are unique to ocean in-

● the need to develop appropriate means of in- cineration, or for which specific approaches can be

volving the public in the decisionmaking offered for their resolution. Wherever possible, conprocess. cerns regarding ocean incineration are considered

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

these issues within the limited context of ocean inwith related or comparable activities.

MAJOR

The Potential Role of Land-Based and

Ocean Incineration14

As much as 10 to 20 percent of the estimated

250 million metric tons of hazardous wastes generated in the United States each year could in

theory be incinerated. Nearly half of all incinerable wastes (up to about 8 percent of all hazard14These findings are drawn from material presented throughout the

body of the report. Wherever appropriate, chapters containing a full

discussion of the basis of these findings have been indicated and should

be consulted.

FINDINGS

ous wastes) are liquids that could be incinerated

at sea. Currently, however, only about 1 percent of hazardous waste is actually incinerated,

and all of the incineration occurs in land-based

facilities.

A broad range of practices is used for managing incinerable hazardous wastes today. Significant quantities of such wastes (as much as onethird) are recovered or recycled. Even larger

quantities (as much as 65 percent), however, are

being disposed of on land (in underground injection wells. landfills, or surface impound-
10 ● Ocean Iincineration: Its Role in Managing Hazardous Waste

ments) or burned as fuel in boilers and furnaces. 15

Although a number of innovative treatment technologies now under development will ultimately be

preferable to incineration, today’s land-based and

ocean incineration technologies represent a significant improvement over land disposal of incinerable wastes. A properly operating incinerator can permanently destroy 99.99 percent or more

of such wastes, in marked contrast to land disposal,

in which wastes remain hazardous for long periods

of time.

Numerous studies have examined future demand

for incineration capacity in general. Surveys conducted by both private and governmental organizations (including EPA, the Congressional Budget

Office, numerous State and regional hazardous

waste management planning commissions, and several waste generating industries) predict that this

demand will continue to grow into the foreseeable future. Projections indicate that increased

quantities of hazardous waste will be generated and

will be managed through incineration. For example, current regulations mandate that waste containing high concentrations of polychlorinated

biphenyls be incinerated (see box B in ch. 3), In

addition, if implemented even roughly on schedule, the 1984 RCRA Amendments will restrict the

land-based alternatives traditionally used for disposing of incinerable wastes and are expected to

substantially increase the amount of waste available for incineration (see ch. 3).

Despite this expected demand, existing incineration capacity is significantly below what

would be needed to burn all incinerable wastes.

Moreover, this shortfall is likely to increase with

time, largely as a result of two factors: first, the

increase in demand described above; and second,

the very slow development of new capacity. Indeed,

efforts to increase incineration capacity have encountered many obstacles, including public opposition, limited availability of liability insurance, and

difficulties in facility siting.

Despite this shortfall, a future need for ocean incineration (or land-based incineration, or any other

hazardous waste management technology) may

never be demonstrated or quantified from an analytic standpoint. (See ch. 2 for a discussion of the

legal requirement to demonstrate a need to incinerate at sea. ) The regulatory status, economic attractiveness, capacity, and actual use of each technology for managing incinerable waste vary widely,

change with time, and are exceedingly difficult to

predict. It is the complex interaction of these factors that determines the market or need for any individual option. Thus, although establishing or

estimating a specific need for ocean incineration

is virtually impossible, a need clearly exists for

having available a number of technologies capable of managing incinerable wastes.

For highly chlorinated wastes, ocean incineration may be preferable to available alternatives,

with respect to human health risks and costeffectiveness (see section below on technological limitations).

For other wastes, certain existing technologies

may offer economic or environmental advantages over both land disposal and incineration.

Current competing alternatives such as industrial

boilers and furnaces burn wastes with high heat

content to recover energy; these practices, however,

are currently subject to significantly less regulatory

control than is incineration and may, in some cases,

pose significant environmental or human health

risks. Other alternatives allow the recovery of materials from the waste. Solvent distillation, oil reclamation, chlorination processes, and hydrogen chloride recovery are examples of this approach. The

use of such technologies for managing hazardous

wastes, including developing a proper regulatory

framework, should be explored further.

Certain emerging waste reduction and treatment options will ultimately prove to be an even

greater improvement over the incineration technologies now available, although accurately estimating their near-term availability and capacity is not currently possible.l6 In any case, the

need for waste treatment and disposal options will

continue because of the sheer quantities of wastes,

the time required to implement waste reduction

measures and to develop sufficient capacity for recy -

lbsee Ch. LI for a brief discussion of these emerging methods. Another

OTA assessment (14) is examining the potential for reducing the generat 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 not

all wastes will lend themselves to such techniques.

For a fuller discussion of the potential role of

land-based and ocean incineration, see chapters 3

and 5.

Comparison of Land-Based and Ocean

Incineration

If additional capacity to incinerate liquid

wastes is developed, the choice between expanding land-based incineration or developing ocean

incineration cannot currently be resolved on a

technical basis. Nor will the collection of more information be likely to significantly aid in answering this question. When specific technical factors

are analyzed one at a time, one technology may

seem clearly preferable to the other, but when all

such factors are considered as a whole, the analysis does not lead to an unambiguous choice. Several areas of comparison between land and ocean

incineration are particularly important to consider.

Regulation

In general, the proposed regulatory framework for ocean incineration is more stringent

and explicit than the existing regulations that

govern land-based incineration. Technical limitations and performance standards, as well as requirements for obtaining permits, monitoring, and

reporting, tend to be more involved and leave less

to the judgment of those issuing permits for ocean

incineration.

In part, the regulatory differences reflect the fact

that the two technologies are addressed under different primary statutes. However, they also appear

to reflect two other factors: heightened public concern over ocean incineration, and greater perceived

and actual difficulties in monitoring an activity that

takes place far from shore.

For a fuller discussion of regulation, see chapter 7.

Releases of Waste

Releases of waste from the actual incineration

process should be equivalent for land-based and

ocean incineration, although the nature and

location of these releases could differ substantially. Because ocean incineration requires additional transportation and handling of hazardous wastes, however, it is likely to result in a

somewhat greater release of waste to the environment than would land-based incineration.

EPA proposes that incineration vessels not be required to have air pollution control equipment,

which is required on some, but not all, land-based

incinerators. 17 This factor would not alter the total quantity of waste products released during the

actual incineration process. The quantity of such

products directly released through the stack would

be greater for ocean incineration than for land-based

incinerators equipped with scrubbers. However,

operating a scrubber generates a hazardous waste

containing pollutants that would otherwise have

been emitted; this waste must be disposed of and

may itself be released to the environment, with potential to contaminate groundwater or surface

water.

The size of a release is only one factor that influences the severity of impact. The nature and location of expected releases must also be considered.

Land-based and ocean incineration differ significantly with respect to these factors. See chapter 8

for a fuller discussion of waste releases from landbased and ocean incineration.

The Issue of Scrubbers

The major technological and regulatory difference between land-based and ocean incineration is

the absence of scrubbers on ocean incineration vessels. Scrubbers are present on approximately 45

percent of existing land-based incinerators (see ch.

5), including all of the large commercial facilities

that would offer the most direct competition to

ocean incineration.

The debate over the need for scrubbers on incineration vessels has been clouded by two common misperceptions regarding scrubber and incinerator performance. The first involves the issue

of which particular waste products are actually removed by scrubbers. Scrubbers are generally very

1 TFO~ convenience, Such equipsnent will be referred to h general

as { ‘scrubbers. ” Land-based incinerators burning chlorinated liquid

wastes or solid wastes generally possess scrubbers, as do the large landbased commercial incinerators. Other land-based incinerators that burn

other types of liquid wastes often do not; use of these facilities generates emissions equivalent to incinerators at sea burning the same waste.

This issue is discussed at greater length in the next section on scrubbers, and in chs. 2 and 7.
12 ● Ocean Incineration: Its Role in Managing Hazardous Waste

effective at removing acid gases (e. g., hydrogen

chloride) and particulate emissions (which include

a large portion of toxic metals), but are not effective at removing residual organic material—

unburned wastes or products of incomplete combustion (refs. 11,17; also see ch. 7).

A second misperception is that a difference exists between the emissions of organic material that

are allowed for land-based and ocean incineration.

The performance of ocean incinerators (as well as

land-based incinerators lacking scrubbers) is to

be measured by calculating a destruction efficiency

(DE). The performance of land-based incinerators

that carry scrubbers is measured by calculating a

destruction and removal efficiency (DRE), after

emissions have passed through the scrubber. The

DE standard proposed for ocean incineration is

identical to the DRE standard for land-based incinerators with scrubbers. Hence, emissions from

ocean incinerators could not be any greater than

those from land-based incinerators, even after

accounting for any incidental removal of organic

material accomplished by the scrubber. In other

words, even if scrubbers were effective at removing organic material from stack gases, ocean incinerators would still be held to the same overall

destruction performance standard.18

For these reasons, an evaluation of the need for

scrubbers at sea should focus on hydrogen chloride

and particulate emissions. For these pollutants,

EPA’s rationale for not requiring scrubbers on incineration vessels is that:

hydrogen chloride gas emissions would be rapidly neutralized because of the high natural

buffering capacity of the marine atmosphere

and seawater, and

particulate emissions would be minimal because of the specific limits placed on metal content of wastes to be incinerated at sea and the

fact that incineration of liquid wastes generates fewer particulate than does incineration

of solid or mixed wastes.

Hydrogen Chloride Gas Emissions.—A review

of available data reveals little documentation for

lasever~ sho~cornin~ in the o~rationd definitions Of DE ~ci DRE

have been identified (see ch. 2). Because the shortcomings apply equally

to land-based and ocean incineration, however, they do not aid in

the comparative evaluation.

any significant adverse environmental impacts attributable to hydrogen chloride gas released from

incineration vessels. Before 1979, incineration in

the North Sea took place at a site only 23 miles off

the Dutch coast. Although no causal link to ocean

incineration was established, the presence of a

slightly irritating acidic atmosphere along the coastline was reported and was one factor leading to the

movement of the incineration site to a new area

more than 60 miles from the nearest shore (4,21).

Designated or proposed U.S. sites are 140 to 190

miles from the nearest shoreline.

Acid wastes of a much higher concentration than

would be emitted through ocean incineration are

directly dumped at two industrial waste disposal

sites in the North Atlantic Ocean (3). Although this

direct dumping has caused some short-term and

localized perturbations in the alkalinity of the seawater, complete neutralization occurs within a few

hours after the dumping and no adverse effects on

marine life have been detected. In ocean incineration, the much lower concentrations of acid would

be deposited over a larger area and over a longer

period of time than is the case in direct dumping.

Indeed, past monitoring of ocean trial burns did

not detect any change in the alkalinity of surface

waters that came into direct contact with the incinerator plume (see ch. 11). The potential for damage to occur to organisms in the surface microlayer

prior to dispersion or neutralization, however, has

not been adequately addressed (see ch. 9).

EPA has proposed an environmental performance standard that would allow only a very small

change in the alkalinity of seawater at an incineration site. EPA’s calculations indicate that this standard would easily be met even under extreme circumstances (see chs. 7 and 8).

According to the chairman of the committee that

prepared the Science Advisory Board report on

ocean incineration (19), these and other considerations led the SAB to conclude that using the buffering capacity of the ocean to neutralize acidic emissions from ocean incinerators did not pose any

major problems (5).

Particulate Emissions. —Incinerating hazardous waste generates particulate matter that is composed primarily of metals, along with other inorganic material originally present in the waste. The
Ch. l—Findings and Policy Options ● 1 3

chief motivation for controlling particulate emissions is that, in the process, a significant portion

of toxic metals is also controlled.

Toxic metals are “conservative” pollutants; that

is, they are not destroyed in the environment or

even in a process such as incineration, although

their chemical form and degree of hazard can be

altered. Thus, any toxic metals present in the original waste remain after incineration, either in the

residual ash left in the combustion chamber or in

the exhaust stream exiting the incinerator stack.

Two different approaches to controlling metal

emissions have been applied to land-based and

ocean incineration. On land, stack scrubbers are

utilized to trap particulate, but relatively little control is exercised over the metal content of wastes

to be incinerated. At sea, rather than require scrubbers, EPA has proposed to limit the metal content

of wastes accepted for incineration. Emissions of

some metals would be further limited by an environmental performance standard that would prohibit applicable marine water quality criteria to be

exceeded (see ch. 7).

In addition to the amount of a metal present, its

chemical form affects its behavior in the environment, its potential to cause adverse impact, and in

some cases the efficiency with which it is removed

by a scrubber (see ch. 7). The insufficient characterization of incinerator emissions described previously extends to determining the chemical form,

as well as quantity, of particular metals. It is essential that such a characterization be undertaken if the absence of a requirement for scrubbers on incineration vessels is to be justified.

Further regulation of metal emissions may well be

warranted, given EPA’s finding that most of the

human health risks associated with ocean incineration are derived from metal emissions (18).

Determining the appropriate limits for metals in

wastes to be incinerated at sea certainly requires

further scrutiny, but in general EPA’s proposed approach to limiting metal emissions is a reasonable

alternative to requiring scrubbers on ocean incinerators. Such an approach, however, must be coupled with rigorous environmental monitoring to determine if unacceptable impacts occur.

As a final consideration, available data indicate

that even under the most extreme circumstances

allowed under EPA’s proposed regulation, the total amount of metals released into the marine environment from ocean incineration would be very

small in comparison to the amount from other

sources and permitted activities (see ch. 8).

Therefore, based on the available information,

OTA finds that the lack of a requirement for air

pollution control equipment on ocean incineration vessels appears justified, so long as operating conditions and the metal content of wastes

incinerated at sea are appropriately regulated

and such activity is linked to a rigorous environmental monitoring program.

Two additional arguments have been offered

against requiring air pollution control equipment

on ocean incineration vessels. First, the costs of installing, maintaining, and operating such equipment are substantial, and could significantly reduce

the competitive status of ocean incineration relative to other alternatives. Second, the installation

of scrubbers on incineration vessels faces major design impediments, including spatial, weight, and

fresh water requirements (15). Such constraints are

especially applicable to retrofitting existing ships,

which have short vertical stacks. (Other proposed

designs would utilize seawater ‘ ‘scrubbers’ on

horizontally oriented incinerators, but the scrubber effluent would be discharged directly into the

ocean, making the term scrubber somewhat of a

misnomer. )

Although further research into using true scrubbers aboard ships is certainly warranted, their immediate application appears difficult if not impossible. In their absence, EPA’s reliance on an

appropriate combination of waste and emissions

limitations, incinerator performance standards, and

environmental monitoring requirements appears to

be a reasonable alternative approach.

Health and Environmental Risks

Land-based and ocean incineration each involve

several kinds of risks, some of which are unique

to one technology, others common to both. Their

primary risks differ substantially, however, thus
14 ● Ocean Incineration: Its Role in Managing Hazardous Waste

constraining any quantitative comparison of these

technologies. Consideration of these primary risks

is, nevertheless, essential in determining policy

toward the use of incineration.

Because land-based incineration occurs relatively close to human populations, its primary

risk is the potential for adverse impact on human health-resulting from exposure to routine

or normal releases of waste or waste products.

A full understanding of the magnitude of this risk

is constrained by our lack of knowledge concerning the nature of incinerator emissions and the

difficulties associated with environmental monitoring of land-based incinerators.

In contrast, ocean incineration’s primary risk

is to the marine environment. Most of this risk

derives from the potential for a major accidental spill. By all estimates, such an event would be

extremely unlikely to occur, even less likely than

a spill resulting from the transportation of nonwaste

hazardous materials. However, a major spill of either hazardous waste or nonwaste material could

have catastrophic consequences; for example, if it

occurred in a sensitive estuarine area, large-scale

loss of fish and bottom-dwelling organisms could

result. The situation would be exacerbated by the

acknowledged difficulty or impossibility of cleanup.

The major risk to human health from ocean

incineration is expected to arise from exposures

due to the transport and handling of wastes on

land. In this respect, land-based and ocean incineration appear to be quite similar.

For further discussion of risks to human and

environmental health posed by land-based and

ocean incineration, see chapter 9.

Unanswered Questions

EPA’s Science Advisory Board has identified

many unanswered questions, regarding performance and emissions, that apply to both land and

ocean modes of incineration and, in some cases,

to all combustion processes. 19 For example, the SAB

stated that no reliable characterization of emissions

or 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 wood

in fireplaces.

which means that the potential for exposure and

adverse impact to the environment or to humans

cannot be adequately assessed. The study also challenged EPA’s method of evaluating the total performance of both land-based and ocean incinerators by measuring destruction efficiency for only

a few selected compounds. The SAB recommended

that EPA undertake a complete characterization of

emissions and products of incomplete combustion

arising from both technologies. These well-founded

concerns are addressed in more detail in chapter 2.

Technological Limitations

Because land-based and ocean incineration each

possess inherent capabilities and limitations, from

a technical perspective certain wastes are better

managed by one or the other technology. Two

examples of such factors are discussed below.

First, because they cannot incinerate solids

and sludges, ocean incinerators are inherently

less versatile than land-based rotary kiln incinerators, despite their greater capacity. Such a limitation can be especially important in local or regional settings, where a variety of waste types may

need to be incinerated. In addition, applying waste

recovery and recycling technologies to incinerable

wastes is expected to increase the amounts of incinerable solids and sludges at the expense of incinerable liquids (see ch. 3). For these and other

reasons, a number of States20 plan to build landbased rotary kiln facilities to meet their anticipated

needs. It is not known how much and how soon

such efforts might affect the shortfall between capacity and demand for incineration.

Second, despite the limitation discussed above,

incineration of highly chlorinated wastes at sea has

commonly been preferred over their incineration

on land. Indeed, in both Europe and the United

States, ocean incineration has been employed

almost exclusively for highly chlorinated wastes.

The extensive rationale for this is based on the fact

that incinerating such wastes generates high concentrations of corrosive and toxic hydrogen chloride gas. For numerous reasons related to this finding, incineration of highly chlorinated wastes at

sea may be advantageous:

● Incineration of such wastes on land requires

ZtlFor eXarn#e, see refS. 2,7.
Ch. l—Findings and Policy Options ● 1 5

the use of scrubbers, which are costly and difficult to operate and maintain.

● Scrubber operation generates additional hazardous waste that must be disposed of, typically through neutralization and discharge into

sewers or surface impoundments. These practices can in turn contaminate groundwater or

surface water,

● Limitations on the chlorine content of waste

are often written into the operating permits

of land-based incinerators, for three reasons:

—Certain highly chlorinated wastes can, in

fact, exceed the feasible capacity of scrubbers for removing hydrogen chloride gas.

—The energy content of a waste decreases as

the chlorine content increases. Thus, for a

given feed rate, as chlorine content increases

a point is reached where insufficient energy

is present to ensure combustion.

—Free chlorine gas, which is even more toxic

to humans than hydrogen chloride gas and

is not efficiently removed by scrubbers, is

generated during the incineration of highly

chlorinated wastes. As a result, an upper

limit on the chlorine content of wastes must

be set, usually at about 30 percent (23).

In light of these factors, highly chlorinated

wastes can be burned on land only if they are

blended with auxiliary fuel or nonchlorinated

wastes to reduce the chlorine content and increase the energy content of the waste being

incinerated. The net effect is a reduction in

the effective capacity of land-based incinerators for chlorinated wastes.

● Ocean incineration vessels are not required to

have scrubbers, because of the capacity of seawater to neutralize hydrogen chloride gas, and

because the incinerators operate at a location

far removed from human populations. (See

section above on scrubbers and chs. 2 and 7.)

● Because they lack scrubbers, ocean incinerators can burn chlorinated wastes at a much

higher rate than can land-based incinerators.

Consequently, ocean incineration has a greater

capacity for chlorinated wastes. Moreover, the

higher feed rate reduces or obviates the need

to use supplementary fuel or high energy

wastes.

Thus, from the perspectives of human health

risks, capacity, and cost-effectiveness, incinerating highly chlorinated wastes at sea may be

preferable to incinerating them on land. These

benefits must be balanced against the potential

risks ocean incineration poses to the marine environment.

Releases of Waste to the Marine

Environment

Releases of waste and risks of impact from ocean

incineration should properly be viewed in the context of releases and risks from comparable activities and from other sources of marine pollution.

Only in such a context can the significance of such

risks in relation to potential benefits be fully

assessed.

Ocean incineration entails a very small incremental increase in risk relative to that routinely

borne by this Nation in the marine transport of

hazardous (nonwaste) materials. This is the case

with respect to the number of transits, quantities

and types21 of material carried, and the expected

frequency and size of releases. However, given the

potentially catastrophic consequences of a major marine spill, the acknowledged difficulty or

impossibility of cleanup, and the intense public concern focused on this issue, extensive regulatory attention would be warranted if ocean

incineration were permitted. This should include

consideration of measures beyond the already substantial provisions that exist or have been proposed

by EPA and the U.S. Coast Guard (see ch. 2).

In certain settings, the normal operation of incineration vessels may represent a small but potentially significant contributor of some pollutants to

the marine environment. This contribution, however, is expected to be considerably smaller than

that of other permitted activities that introduce

pollutants to marine waters. Furthermore, pollutants released during normal incineration operations would result in virtually no detectable longterm increase over background levels, except in extreme circumstances.

ZIOne major exception is speci~ wastes, such as PC Bs, which are

no longer commercially produced and are therefore not routinely transported, except as waste. See box B in ch. 3.
16 ● Ocean Incineration: Its Role in Managing Hazardous Waste

Prior to dispersing, pollutants emitted by ocean

incinerators could cause short-term adverse impacts

upon contact between the incinerator plume and

the ocean surface. Although the affected region is

expected to be limited to a small area along the path

of the ship, in this region significant damage could

result. Further study of such impacts, particularly

on the surface microlayer (see ch. 9), is warranted.

For further discussion of releases of waste from

ocean incineration relative to other sources of marine pollution, see chapter 8.

Past and Current Use of Hazardous

Waste Incineration

Currently, all U.S. incineration of hazardous

wastes takes place in land-based facilities. EPA has

estimated that there are currently 240 to 275 landbased hazardous waste incinerators in the United

States (6, 10). About 210 to 250 of these facilities

are located at sites where the incinerated wastes are

generated. These onsite facilities are generally used

solely for incinerating wastes generated by their

owners. Approximately 30 others are commercial,

offsite, facilities used to incinerate waste generated

by industrial clients. Estimates of the annual quantity of wastes destroyed by incineration range from

about 1.7 million metric tons (mmt) in 1981 (22)

to 2.7 mmt in 1983 (12). In 1980, about 0.4 mmt

was incinerated at commercial facilities (l).

Ocean incineration has been employed in the

United States only on a research or interim basis,

but has been used routinely in the North Sea for

European wastes for more than a decade. Two incinerator ships are currently operating in Europe;22

two have recently been built in the United States,

but have yet to be employed commercially. Several other companies have expressed interest in the

market.

The technological performance and environmental effects of ocean incineration have been subjected to considerable testing (see ch. 11). Unfortunately, the results of this effort are hotly contested,

and do not aid substantially in evaluating the safety

of ocean incineration. The test data appear to support two somewhat conflicting findings:

ZZThe two Vesse]s are the Vulcan us 11 and the Vesta; the Vukanus

Z is operationa] but not currently active.

1. Ocean incineration can, at least under certain

conditions, meet applicable regulatory and

technical requirements and achieve very efficient destruction of hazardous wastes.

2. The technology’s ability to perform in such

a manner consistently has not been demonstrated for complex mixtures of wastes or the

broad range of operating and environmental

conditions likely to be encountered.

For further discussion of the use of hazardous

waste incineration at sea and on land, see chs. 3,

5, and 11.

Recovery, Recycling, and Reduction of

Incinerable Wastes23

Recovery, recycling, and reduction practices are

generally given preferred status in the hazardous

waste management hierarchy discussed previously.

Many critics of ocean incineration argue that allowing its development would impede efforts to implement these preferred practices. (In the following

discussion, a distinction is drawn between waste

recycling/recover y and waste reduction. )

Some wastestreams comprising incinerable waste

are very amenable to recovery and recycling processes. Much of this potential, however, is already being realized. For example, large quantities of waste

solvents (as much as 70 percent) and oils (about 10

percent) are currently recovered (see ch. 3). Several

advanced thermal destruction techniques can recover

or reutilize the chlorine content of chlorinated wastes.

These technologies, however, have only been used

on a small scale, primarily in Europe, and are not

competitive with other sources of the recovered material. They have not been employed commercially

in the United States and provide little or no capacity

at the present time, Thus, only modest increases in

recovery and recycling of liquid organic hazardous wastes are expected in the near future.

Much of the anticipated increase in recovery

and recycling of hazardous wastes in the near

future will involve wastestreams that have litZs’rhese issues are explored in ref. 14. Based on the definition used

in that study, the term waste reduction is distinguished in this report

from recycling and recove~; it generally refers only to those practices that reduce waste at its source. This definition excludes waste

recycling, for example, unless it occurs as an integral part of an industrial process. Also see footnote 3
Ch. l—Findings and Policy Options • 17

tle or no potential for incineration, for example, metal-containing liquids and sludges. Development of ocean incineration and expansion of

land-based incineration would not be expected to

affect incentives for recycling or recovery of these

nonincinerable categories of waste.

Estimating to what extent the implementation

of waste reduction practices will affect the quantity of incinerable wastes generated is virtually

impossible. In large part, this uncertainty is due

to the lack of data and even appropriate means

to measure waste reduction. The visibility and application of waste reduction measures are clearly

increasing, and their potential to reduce the generation of hazardous waste is enormous. It is equally

clear, however, that major institutional, economic,

and attitudinal obstacles impede its widespread application in the near future (14).

Even the most optimistic observers of ocean incineration project a total industry of only several

ships, which together would be capable of incinerating a small fraction of incinerable liquid waste,

and an even smaller fraction of all hazardous waste.

This probable market picture—together with limited or uncertain application of reduction, recovery, and recycling practices to incinerable wastes—

argues that the development of ocean incineration, as an interim option, would be expected

to have a very limited effect on overall incentives for using these practices (see chs. 2 and 3).

There is no consensus, however, regarding this conclusion. Indeed, some critics strongly contend that

ocean incineration will have a significant adverse

effect on such incentives. OTA’s policy options (discussed below) include provisions that could be used

to ensure that the shift toward use of preferred practices is not impeded.

Recovery processes applied to liquid wastes generally produce residuals. Thus, increasing use of

such processes is likely to increase the quantities

of incinerable sludges and solids (which cannot be

incinerated at sea) relative to the quantities of

ocean-incinerable liquids. Many residuals from

product purification as well as recovery processes,

however, are in liquid form and are prime candidates for ocean incineration.

Thus, although significant long-term potential remains for further application of recovery

and other emerging technologies, in the nearterm they appear unlikely to substantially reduce the amount of incinerable waste (liquids

as well as sludges and solids) requiring management through currently available means.

The Use of Ocean Incineration by

Other Nations

Ocean incineration of hazardous wastes has been

used routinely in Europe since 1969, and two incineration vessels are currently operating full-time

in the North Sea. Opinions and positions regarding the future use of ocean incineration vary greatly

among European and other developed nations.

General agreement exists that incineration at sea

should be viewed as an interim method for managing wastes, to be used only when preferable landbased alternatives are unavailable. No consensus

currently exists, however, regarding when it will

be 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 will

meet before the first of January 1990 to establish

a final date for the termination of incineration at

sea‘‘ in the Oslo Convention area (i. e., the North

Sea). In 1985, a survey of Member States was undertaken to determine the feasibility of ending

ocean incineration in the North Sea on or about

that date. The survey documented the following

trends:

● There is a potential shortfall in the capacity

of land-based incinerators and other 1and-

●

●

based treatment methods to dispose of the

wastes currently being incinerated at sea.

Spare capacity on land is considered far from

sufficient, and very little increase in such capacity is expected in the near future.

The major constraint blocking termination of

ocean incineration is the lack of land-based capacity for chlorinated hydrocarbon wastes.

It is expected that by 1990 wastes will remain

for incineration at sea.

Certain nations, such as Denmark and Sweden,

argue for termination as soon as possible; some nations, such as The Netherlands and the Federal

Republic of Germany, regard ocean incineration

as a necessary method for the foreseeable future because 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 the

best practicable environmental option.24

Conclusion

The preceding discussions suggest the possibility that ocean incineration, carried out under a

sufficiently rigorous and comprehensive regulatory

framework (see discussion of policy options later

in this chapter and ch. 2), could be one of several

options to fill an interim need in hazardous waste

Z4There are further indications of the ambiguity with which Europeans view ocean incineration. For example, both The Netherlands

and West Germany have reported that they anticipate significant decreases in their reliance on ocean incineration as a result of increases

in land-based capacity. More recently, however, The Netherlands announced plans to conduct a trial burn of PCBS, in anticipation of the

need for the ocean incineration option resulting from the loss of the

country’s land-based incineration capacity for PCBS (see ch. 12).

management. Under such a scenario, ocean incinerators would focus on highly chlorinated liquid

wastes (possibly including special wastes such as

PCBs) that can be advantageously burned at sea

because of the absence of a requirement for scrubbers. Land-based incinerators might concentrate

on wastes that could not be burned elsewhere—

organic sludges and solids with relatively high metal

content and relatively low energy value. Liquids

with high heat content but little or no chlorine might

continue to be burned in industrial boilers and furnaces, though under stricter regulation where appropriate. Much of the expected application of

waste recovery and recycling to incinerable wastes

is expected to be applied to such liquids, and thus

will produce organic sludges appropriate for landbased incineration. As capacity develops in better

technologies, and as waste reduction practices are

increasingly implemented, the use of ocean incineration should be concomitantly decreased.

DECIDING THE FATE OF OCEAN INCINERATION:

MAJOR POLICY OPTIONS

Out of the controversy and polarization surrounding the development of ocean incineration,

several disparate perspectives have emerged regarding whether and, if so, how to use this technology.

The fundamental choice of whether to proceed cannot be resolved on a technical basis; it will require

difficult political choices as well. Much of the debate has focused on the whether question in an allor-none fashion. Certain intermediate alternatives,

however, might be considered that would allow

some use or further investigation, carried out in

a manner that directly addresses the areas of disagreement.

Because ocean incineration has the potential to

play an important but limited interim role in managing hazardous wastes, there is a need to consider

a broad range of possible approaches to its use, including certain intermediate options. This intent

is reflected in four distinct policy options OTA has

identified: :25

zsThiS discussion is limited to consideration Of policy options that

affect the fate of ocean incineration. If a decision were reached to proceed with ocean incineration, numerous additional issues and options

●

●

●

Option 1: Halt the development of ocean incineration permanently and rely entirely on

land-based options.

Option 2: Halt commercial ocean incineration

temporarily, until more research is completed.

The research would probably require a few

burns at sea to collect data needed to evaluate incinerator performance, to characterize

emissions, and to assess environmental

impacts.

Option 3: Proceed with a commercial ocean

incineration program under the regulatory

framework being developed by the Environmental 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 on

the part of EPA or oversight on the part of Congress; others may necessitate additional legislative action. Detailed discussion of these issues is presented in ch. 2.

zcIn this report, EpA’s developing regulatory framework iS represented, for the most part, by EPA’s proposed Ocean Incineration Regulation (50 FR 8222, Feb. 28, 1985). Several substantial changes are

expected during finalization of this regulation, some of which may

directly bear on issues discussed under option 4.
Ch. l—Findings and Policy Options ● 1 9

● Option 4: Proceed with a modified ocean incineration program that would accomplish one

or

A.

B.

c.

more of the following:

include provisions that impart an interim

status to the program;

strengthen regulatory requirements where

necessary to address areas of deficiency or

continuing public concern; and/or

provide for greater direct involvement by

the government in the actual operation of

ocean incineration.

For options 3 and 4, numerous factors would determine the scale of the program. These include influences from market factors, government intervention, public opposition, and modification of the

regulatory program in response to new information. Many of the factors could be subject to direction through regulatory or economic measures, but

others would be more difficult to predict or control.

Policy Options and Their Implications

Each of these policy options has certain implications when viewed in the context of overall management of hazardous wastes. Moreover, each

choice necessarily engenders additional decisions

that must be made. Some of the possible implications of each option are presented below.

Option 1:

Halt the development of ocean incineration permanently and rely entirely on

land-based options.

Implications

1. Land-based incineration capacity for incinerable wastes would lag even further behind demand.

If three of the existing incineration vessels27 were

used, the commercial incineration capacity for liquid wastes would roughly double. In their absence,

efforts to expand the capacity of land-based incineration or other alternative technologies would need

to increase.

2. The increased shortfall between incineration

capacity and demand might cause some limited increase in incentives for waste reduction, recycling,

and innovative treatment of incinerable liquids.

The need for currently available waste treatment

options would clearly continue into the foreseeable

future, however, because of the sheer quantities of

wastes, the time required to implement waste reduction measures and to develop sufficient recycling capacity, and the fact that not all wastes will

lend themselves to such techniques.

3. The incentive for waste generators to manage their incinerable liquid wastes onsite would be

expected to increase somewhat, which might mean

an increase in noncommercial incineration or other

treatment capacity. Reliable estimates of the extent of this increase do not exist.

4. If sufficient alternative capacity were not developed, wastes would continue to be disposed of

on land, often using practices that pose demonstrated risks to the environment and human health.

Under the Hazardous and Solid Waste Amendments of 1984, wastes to be banned from land disposal could be granted variances or extensions if

sufficient alternative treatment, recovery, or disposal capacity were not available.28

5. More incineration would take place in landbased facilities closer to human populations, thereby

increasing direct human exposure to incinerator

emissions. At the same time, the risk of a spill or

other adverse impact on the marine environment

would not be increased.

6. Prices charged to generators to dispose of at

least some incinerable hazardous wastes (e. g.,

PCBs) would probably rise, because of increased

demand on available capacity. This same factor

might also increase existing pressures to dispose of

hazardous waste illegally.

Option 2:

Halt commercial ocean incineration temporarily, until more research is completed. The research would probably require a few burns at sea to collect data

needed to evaluate incinerator performZTIt is assumed that three incineration vessels would operate primarily in the United States: the Apollos Z and 11 and the Vulcan us

ZZ. The remaining vessels are assumed to continue operating in Europe.

Zesec. 2(I I (h) of the amendments specifies that such variances or

extensions may be granted for a maximum of 2 years. The course

of action that would ensue after 2 years if alternative capacity were

still unavailable is not clear.
20 . Ocean Incineration: Its Role in Managing Hazardous Waste

ance, to characterize emissions, and to

assess environmental impacts.

Implications (in addition to those for

Option 1)

1. A climate of extended regulatory uncertainty

probably would significantly impede or halt new

investment in the ocean incineration industry. The

recent bankruptcy of the builder of the Apollo incineration vessels and their owner’s subsequent loan

default are widely attributed to their inability to obtain an operating permit. Some companies currently awaiting program development might decide

to abandon plans to enter the market.

2. Research would probably answer some questions and narrow the overall window of uncertainty.

It should be relatively easy, for example, to improve

our understanding of the composition of incinerator emissions and at least their initial environmental

behavior. Nevertheless, numerous questions, especially those involving the risk of spills or cumulative adverse environmental impacts, would probably only be resolved through experience on a larger

scale.

3. If a decision were ultimately made to proceed

with ocean incineration, the ensuing program

would probably benefit from information gleaned

through research. Incorporating such information

into a regulatory program during its development

would probably be easier than modifying an ongoing program.

4. The question of when enough research had

been done would have to be faced. Comparable attention to information gaps in other alternatives

would be necessary, including land-based incineration, to provide a valid comparative risk assessment. After any amount of research, some level of

uncertainty would always remain, and decisions

would have to be made in the face of incomplete

information.

5. Criteria for determining the type and number of ocean research burns to conduct would need

to be developed and evaluated. For example, EPA’s

Ocean Incineration Research Strategy (16) calls for

using PCB waste because both the toxicity characteristics and the detection methods for PCBs have

been well studied. Because typical ocean incineration wastestreams would probably be composed of

complex mixtures of many different chemicals,

however, the applicability of results from this test

burn to real situations would be limited.

6. The question of who should do the research

would also need to be faced. Widespread public

mistrust currently exists as to whether EPA or industry could objectively carry out the research. Addressing this credibility gap or identifying alternative ways to perform the studies or to assure credible

results would not be an easy task.

Option 3:

Proceed with a commercial ocean incineration program under the regulatory

framework being developed by the Environmental Protection Agency.

Option 4:

Proceed with a modified ocean incineration program that would accomplish

one or more of the following:

A.

B.

c .

include provisions that impart an interim status to the program;

strengthen regulatory requirements

where necessary to address areas of deficiency or continuing public concern;

and/or

provide for greater direct involvement

by the government in the actual operation of ocean incineration.

In contrast to the first two options, options 3 and

4 both involve a choice to employ ocean incineration on a routine basis.29 Options 3 and 4 differ

from each other primarily in how much they would

dictate or influence the scale of the ocean incineration program. The discussion of these options,

therefore, begins below by examining factors that

might influence the extent to which ocean incineration would be used. The discussion also explores

some of the implications of proceeding with ocean

incineration on various scales.

Option 4 goes beyond the status quo approach

of option 3, by suggesting several approaches to addressing certain of the key deficiencies or potenZg”rhe actua] shaping of an ocean incineration program would involve numerous additional technical and policy factors that are discussed in ch. 2.
Ch. l—Findings and Policy Options ● 2 1

tial uses of ocean incineration that OTA has identified. The discussion considers several possible

departures from EPA’s proposed program, both to

address specific shortcomings and to illustrate the

potential for modifying the current approach to

using ocean incineration. Most importantly, the

discussion suggests certain mechanisms that might

help to ensure that any ocean incineration program

that developed would be instituted in an interim

manner, allowing the reliance on ocean incineration to decrease as capacity in better alternatives

develops.

Determining the Scale of an Ocean

Incineration Program

Influences

Although innumerable factors would influence

the scale of an ocean incineration program, many

could be directly controlled through regulatory or

economic measures. Depending on how much control the government exerted, the scope of the program could be tentative or experimental in nature,

could evolve in an essentially free market setting,

or could entail active government promotion or involvement.

Regardless of the intent and extent of the controls, however, predicting the actual scale of ocean

incineration would be difficult. This source of uncertainty would complicate the task of estimating

resource allocation and regulatory needs, and of

predicting how ocean incineration would affect hazardous waste management in general. Sufficient resources must be available for regulatory and monitoring activities to ensure safe operation and to

allow the collection of reliable data on which to base

future decisions. Moreover, the question of who

should pay for these activities must be addressed.

The availability of resources, particularly in a time

of fiscal restraint, must be seriously considered in

developing and designing a regulatory program.

Four categories of “scaling” factors are discussed

below:

1. Market Factors: These are factors that directly

influence the costs of doing business either for

those who generate wastes or for those who

own and operate incineration facilities. These

costs would, of course, be strongly influenced

2.

by regulations or other government actions

(see below). Market factors would include how

much waste generators would have to pay for

ocean incineration services compared to how

much other alternatives cost; the availability

and regional distribution of ocean incineration sites and of port facilities for storage and

transfer of wastes; and how much new capital investment would be required to develop

such facilities.

The current economic status of incinerable

liquids with high fuel value (i. e., energy content) exemplifies the influence of market factors. Such wastes currently represent a very

competitive market, comprised of industrial

boilers and furnaces, recovery and recycling

operations, and land-based incinerators. The

predictable result is that wastes move in the

direction of lowest costs to generators (within

regulated bounds). The entry of ocean incineration into such a market would result in adjustments based largely on how competitively

priced the new services were.

Government Intervention: Ocean incineration, if developed, would obviously be subject to tremendous governmental attention,

which could take both regulatory and nonregulatory forms. Regulatory requirements

could, for example, influence the market for

ocean incineration by affecting the quantities

and types of waste available for ocean incineration (e. g., limitations on waste composition;

requirements to demonstrate a need to incinerate at sea) or the costs of doing business

(e.g., requirements for liability and financial

responsibility; fees for monitoring and permitting). Nonregulatory influences might include

economic incentives or disincentives or direct

government support measures (e. g., loan

guarantees; taxes assessed on the quantity of

waste generated or disposed; government ownership or operation of incineration vessels).

Broader government regulatory actions influencing hazardous waste management in

general could exert significant indirect influence over the use of ocean incineration. Examples of such factors include the extent and

schedule of implementation of the 1984 RCRA

restrictions on land disposal and the development of siting criteria for disposal facilities.
22 ● Ocean Incineration: Its Role in Managing Hazardous Waste

3.

4.

Piblic Opposition: EPA’s attempt to develop

a regulatory program for ocean incineration

has encountered growing public opposition to

all phases of operation: locating port facilities

for storing and transferring wastes; transporting wastes over land to port sites; designating sites for ocean incineration; setting requirements for permits and liability; and

regulating the incineration process itself. The

public has also been critical of the adequacy

of mechanisms for ensuring meaningful public

education and participation.

Perhaps most important, the public has

questioned whether EPA can objectively develop and administer a regulatory program

for ocean incineration, Indeed, legitimate

public concern exists over the potential for significant conflict of interest between EPA’s

promotional and regulatory roles. Clearly,

additional means of addressing public concerns must be developed as part of any future

program.

‘‘Feedback Another factor that would influence the scale of an ocean incineration program would be any response taken to account

for new information obtained through experience or monitoring. As operations proceeded

on any scale, data would need to be gathered

and analyzed to answer unresolved questions

and to evaluate the adequacy of the regulatory program. Such data might relate to accident rates, the relative safety of different

technologies, the effectiveness of particular

regulatory measures, the results of environmental monitoring, or the program’s influence

on progress toward implementing measures

to reduce waste or developing preferable treatment alternatives.

The regulatory program’s ability to respond

to the new information would depend on numerous factors, such as the effectiveness of the

data-collection efforts, the ability of the regulatory and political processes to accommodate needed changes in a timely manner, and

the nature of the gathered information itself.

Mechanisms would have to be developed for

modifying the scale of the program if the data

indicated that adjustments were warranted.

Two examples illustrate the potential need for

adjustments:

1.

2.

Further controls or incentives might be required if the market outlook for ocean incineration conflicted with waste management policy. For example, as capacity in preferable

alternatives such as recycling and recovery developed, economic or regulatory measures

might be needed to redirect wastes from ocean

incineration to these options. Such measures

could be particularly important to ensure the

interim status of the ocean incineration

program.

New scientific information or regulatory requirements might arise. For example; the

cumulative effects of large-scale incineration

at a single site could become significant and

require attention.

Specific Approaches

The proposed regulatory framework for ocean

incineration contains few provisions that would

directly limit the scale of the program. As currently

formulated, it could be expected to result in a relatively open-ended (although highly regulated) system, whose size would largely depend on private

initiative and investment and on the operation of

the market. This approach would be consistent with

the current regulatory approach to land-based incineration and certain other hazardous waste technologies.

Recent statutory and regulatory attempts to shift

hazardous waste management away from some

traditional land-based disposal options and toward

better treatment technologies provide examples of

the government’s intervention into the market for

the purpose of achieving a desired waste management goal. Congress and EPA might wish to consider analogous measures for controlling the use of

ocean incineration, particularly if interim status

were the desired goal. OTA has identified several

possible approaches.

Permit Ocean Incineration Only for Wastes

for Which a Need To Incinerate At Sea Can Be

Demonstrated.— Whether there is a need for ocean

incineration is the subject of both public and legal
Ch. l—Findings and Policy Options ● 2 3

concern. The issue of need is closely related to the

question of how ocean incineration would affect the

use of better waste management or waste reduction alternatives. (See ch. 2 for a fuller discussion

of both of these issues. ) OTA expects that developing ocean incineration would probably not significantly impede the development and implementation of preferable alternatives. Certain regulatory

measures could be applied to users of ocean incineration, however, to ensure that the best available

options are used to manage or reduce the generation of incinerable wastes.

Such measures, which could be implemented

through the permitting process, might require a

waste generator to demonstrate that ocean incineration would be better than (or at least not inferior

to) the other available options. Alternatively, the

measures could require the waste generator to demonstrate that no feasible land-based alternatives

were available for a particular waste. A third approach would be to use the permitting process to

link use of ocean incineration to compliance with

a schedule for achieving particular levels of waste

reduction, recovery, or recycling.

For these sorts of measures to succeed, several

implementation problems would have to be resolved

(see ch. 2). Nonetheless, mechanisms of this sort

could provide concrete means to ensure that ocean

incineration was indeed employed in an interim

manner.

Direct Certain Wastes Toward or Away From

Ocean Incineration. —OTA’s finding that highly

chlorinated wastes might be more beneficially incinerated at sea than on land suggests the possibility of encouraging or even requiring the use of

ocean incineration for such wastes (assuming they

meet other applicable criteria).

EPA has proposed limiting the metal content

of wastes to be incinerated at sea. The adequacy

of the proposed limits, however, is at issue (see ch.

2), and will likely require further scrutiny and possible revision of the proposal. If the final regulation maintains the lack of a requirement for scrubbers on incineration vessels, adequate control over

metals will be an essential regulatory element.

Limiting the metals would, in turn, affect the types

of incinerable wastes that could qualify as candidates for ocean incineration.

The energy content of wastes might also be a

factor in determining which wastes would be incinerated at sea. High-energy wastes are currently

managed using several different technologies or

practices, as described previously. Land-based incineration companies compete for such wastes to

use as fuel in order to reduce the need for supplementary raw fuel to burn low-energy wastes

(e.g., various organic solids and sludges; see ch.

2). Industrial boilers and furnaces can also burn

high-energy wastes in order to recover their energy

content, again as an alternative to burning raw fuel.

If the government were to decide that public benefit (as opposed to private economic benefit30) was

sufficient to justify such uses, then a restriction

might be placed on the burning of high-energy

wastes at sea.

Finally, considerable attention has focused on

using ocean incineration to burn special wastes,

such as PCBs and DDT. Proponents of ocean incineration cite the properties that render such chemicals so troublesome (environmental persistence,

toxicity, ability to bioaccumulate, and resistance

to burning) as reasons why these special wastes

should be burned at sea, whereas opponents of

ocean incineration cite the same properties as reasons why such wastes should not be burned at sea.

The dichotomy in this debate reflects whether one’s

main concern is with direct exposure and impact

to humans or the marine environment. The potential use of ocean incineration for such wastes would

need further evaluation. Such an evaluation would

be particularly important in light of current regulations requiring incineration of PCBs (see box B

in ch. 3).

Both regulatory and economic approaches to

directing particular wastes toward or away from

ocean incineration might be warranted if Congress

or EPA decided to encourage or restrict the use of

ocean incineration for any of the wastes described

above. Obviously, because they could significantly

affect 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 incineration companies in their opposition to ocean incineration (see ref. 9,

for example). Proponents of ocean incineration claim that the landbased companies are simply wary of more competition, and that the

market should decide where such wastes go (see ch. 2).
24 ● Ocean Incineration: Its Role in Managing Hazardous Waste

eluded wastes, such measures would therefore need

to be assessed from a broad perspective.

Geographically Restrict the Transportation of

Wastes To Be Incinerated At Sea. —Transporting

and importing wastes generated in one area to

another area for storage and loading onto an incineration vessel has engendered a significant

amount of public concern. These issues have raised

questions of equity with respect to who should bear

the risks and enjoy the benefits of using ocean incineration. Such questions are by no means unique

to the issue of ocean incineration.

Implementation of geographic limitations on the

transportation of wastes for the purpose of incineration at sea might help to address some of the public

concern. These limitations might take any of several forms, including specifying a maximum distance for land transport, directing wastes to ports

most suitable for handling them, or requiring the

use of particular burn sites for particular wastes.

In conjunction with designating multiple sites for

ocean incineration and with developing port selection criteria (see ch. 2), geographic limitations could

help to address the equity issue by requiring wastes

to be managed near their points of origin.

Because most incinerable wastes are generated

in coastal States (see ch. 3), geographic restrictions

probably would not significantly reduce the potential market for ocean incineration. The restrictions

could pose difficulties, however, if several companies wished to operate out of the same port. It could

also place unprecedented restrictions on one set of

commercial activities—ocean incineration—without

affecting comparable activities such as land-based

incineration 31 or marine commerce in hazardous

materials.

Restrict the Number of Operating Permits.—

If the Nation were to proceed with a provisional

or experimental program of ocean incineration,

Congress or EPA might want to specifically limit

the size of the fleet or the number of vessels in operation at any given time. This could be accomplished

by granting permits only to existing vessels or to

some predetermined number of vessels, based on

J 1 The Scarcity of commercj~ land-based incinerators in some regions of the country commonly results in wastes being transported

considerable distances to reach existing facilities—in some cases, further than would be required to reach port facilities.

particular criteria such as the expected market size,

the desired frequency of operation of incineration

vessels at existing sites, or the level at which monitoring could be feasibly performed.

The public has repeatedly raised the question of

the credibility of private companies and their ability to comply with all regulatory requirements.

Some observers have called for the development of

criteria to allow consideration of a company’s compliance record as an integral part of the permitting

process. In addition, demonstrating financial responsibility would be a minimum requirement for

receiving a permit, although the level and the nature of liability to be required for ocean incineration have yet to be determined (see ch. 2).

Using criteria such as these to restrict the number of permits granted would limit the scale of the

program and would specifically address key public concerns. However, this approach might severely

curtail new investment into ocean incineration and,

therefore, could limit expansion of the fleet that

might be desired at a later date or hamper research

and development aimed at improving existing

ocean incineration technology.

Restrict the Period for Which Permits Are

Granted. —EPA’s proposed Ocean Incineration

Regulation would grant individual ocean incineration operating permits for 10 years, subject to

renewal after 5 years (or more frequently at the request of the Assistant Administrator). Critics have

raised legitimate questions over whether a 10-year

permit length would be appropriate in a new program. To attract private investment, of course,

some degree of business certainty and sufficient opportunity for making profits would be necessary.

In any event, determining the appropriate length

of’ permits provides an additional opportunity for

controlling the scale of an ocean incineration program, and should be a consideration in resolving

the ongoing debate on this issue. See chapter 2 for

further discussion of this issue.

Implement One or More of the Above Conditions During a “Trial Period. ’’—Regardless

of the nature and number of research burns undertaken, numerous questions will remain unanswered until an actual ocean incineration program

is operating. Even if an open-ended program were

the eventual goal, however, gaining some opera-
Ch. l—Findings and Policy Options ● 2 5

tional experience on a limited scale in the beginning would be useful, if not essential. Thus, even

if the approaches discussed above were deemed too

restrictive or unworkable in the long run, invoking them at the start of the program might still be

warranted.

The appropriate length for such a trial period

would be difficult to determine in advance. Predicting when enough experience has been gained

to make a final decision—to proceed with a larger

program, to maintain a limited program, or to terminate the activity entirely—would be difficult because some uncertainties and risks would remain

after any period.

Provide for the Government To Own or Operate Incineration Vessels. —This option is arguably the most extreme of those considered, because

of its radical departure from the traditional and

widespread private approach to hazardous waste

management in this country, and the potential conflicts of interest associated with direct entry of the

government into such a controversial enterprise.

This approach, however, would provide a very

direct mechanism for controlling the scale of an

ocean incineration program, in that the government

could determine the quantities and types of wastes

it would burn in its own ships .32 Moreover, because

government-sponsored ocean incineration could potentially occur in a nonprofit-driven setting, the

government could more easily reduce or terminate

the program, if and when that were deemed desirable. This approach could very directly and relatively

easily ensure that ocean incineration would be

viewed and conducted as an interim program.

Serious obstacles to government ownership,

however, are equally apparent. Perhaps the most

troublesome is that it would juxtapose regulatory

and promotional roles that many members of the

public regard as too close already. Indeed, the potential for significant conflict of interest would

greatly increase and would need to be specifically

addressed. Given the already low degree of public

confidence that EPA could objectively develop and

administer a regulatory program for private ocean

incineration, the concept of public ownership may

simply 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 its

subsidiar~’, At-Sea Incineration. Inc.

SHAPING AN OCEAN INCINERATION PROGRAM

The fundamental policy issue concerning ocean

incineration is whether to proceed with development of a regulatory program. Although this decision will require difficult political judgments,

analyzing particular issues from a technical perspective can help clarify the implications of various alternatives and help design ensuing programs if ocean

incineration is allowed. To this end, OTA has identified and analyzed a large number of technical factors that bear directly on such a decision. Several

key policy issues have emerged from this analysis,

and are briefly introduced below. Chapter 2 discusses each of these issues in greater depth, and analyzes various regulatory and policy options that

might be implemented to resolve these issues.

Regulation of Incinerator Emissions

One important policy issue is whether proposed regulations governing incinerator emissions are adequate. In regulating emissions from

ocean incineration, EPA has proposed to extend

the approach it originally developed for regulating

land-based incineration, which is based primarily

on measures of incinerator performance .33 This approach emphasizes the attainment of a particular

level of destruction of wastes, as opposed to establishing numeric limitations on each of the many

NEpA has also proposed certain en~’ironmcn[al performance standards that would indirectly apply to emissions.
26 Ž Ocean Incineration: Its Role in Managing Hazardous Waste

components of the emissions. The basis for this approach lies in the extreme complexity both of the

wastes and of the emissions that are generated when

hazardous wastes are incinerated. This complexity precludes routine measurement of all components.

To make the tasks of monitoring and regulating

incineration manageable, EPA limits the number

of compounds to be analyzed to a small set of compounds that is chosen to be as representative of the

entire waste as possible. Incinerator performance

is then gauged by measuring the destruction efficiency (DE) for these preselected compounds .34

EPA’s proposed reliance on the DE performance

standard has been criticized on several bases.

●

●

●

●

●

A

and

EPA’s definition of DE does not provide an

adequate measure of destruction for all components of the waste or for all possible sets of

operating conditions.

Methodologies for sampling emissions and

monitoring incinerator performance are not

well developed or have not been verified

through actual experience.

Incinerator emissions have been insufficiently

characterized and quantified to permit a valid

evaluation of the need for specific emission

standards, particularly for metals.

The toxicity of incinerator emissions, particularly with respect to possible long-term impacts, has not been sufficiently examined.

The identity, origin, and toxicity of products

of incomplete combustion (PICs) have been

insufficiently studied, precluding an assessment of their significance and of the possible

need for regulation.

Transportation Risks

second key policy issue concerns the extent

nature of land and marine transportation

risks associated with ocean incineration. The

transportation of hazardous waste is regulated unstFor land-based incinerators equipped with air pollution cOntrO]

devices (i. e., scrubbers), the destruction performance standard is actually a destruction and removal efficiency (DRE). DRE is measured

after the operation of scrubbers. In practice, however, EPA has found

that DE and DRE are functionally equivalent, because scrubbers are

very inefficient at removing the organic substances that are measured

in calculating DE or DRE.

der many authorities at the Federal, State, and local levels. For the purpose of regulating ocean incineration, EPA is proposing few specific controls

beyond those already generally applicable to incineration vessels and associated waste transportation and transfer activities. The adequacy of such

an approach has been questioned and several areas

needing additional attention have been identified:

●

●

●

●

A

Applicable regulations under other agencies

need to be referenced and applied specifically

to ocean incineration.

Explicit mechanisms are needed to ensure adequate interagency coordination and delegation

of authority for enforcement and monitoring.

Criteria are needed for selecting and designing ports to be used for ocean incineration.

Contingency plans and emergency response

capabilities need to be developed and coordinated.

Comparison of Different Ocean

Incineration Technologies

third key policy issue concerns the need for

a comparative evaluation of different technologies for ocean incineration. Several different designs exist or have been proposed for incinerator

vessels and associated facilities. These designs could

differ significantly with respect to safety and performance. A thorough comparative assessment of

different designs may be necessary to ensure the

use of the best available technology for ocean incineration. In addition, mechanisms for incorporating newly developed alternative or superior design

features into the regulatory program must be developed.

Equitable Regulation

A fourth key policy issue involves equity in

the regulation of land-based and ocean incineration. Because land-based and ocean incineration

are regulated under different statutes, numerous

differences exist in regulatory requirements and expectations. Many provisions that apply only to one

of the technologies, or are more stringent for one

or the other, have stirred considerable debate.

Often, such provisions are necessary or desirable

to account for differences between the technologies
Ch. l—Findings and Policy Options ● 2 7

in, for example, the kinds of risks they pose or

where they are used.

Given such differences, simply adopting identical sets of regulatory requirements is not likely to

accomplish equitable regulation of land-based and

ocean incineration. The technical and nontechnical bases for any differential regulations, however,

should be subjected to thorough scrutiny and made

as explicit and open to review as possible.

Public Involvement

A fifth key policy issue is whether public involvement in decisions regarding ocean incineration is adequate. Public opposition to ocean incineration has arguably been the major impediment

to development of a regulatory program. At the

same time, public involvement has played a substantial role in broadening the scope of the debate

over ocean incineration to include consideration of

the need to develop a national strategy for managing hazardous wastes.

The nature and extent of public opposition to

ocean incineration suggests that available mechanisms for involving the public in the decisionmaking process are woefully inadequate. Although this

problem is by no means confined to the subject of

ocean incineration, additional mechanisms aimed

at ensuring and encouraging meaningful public

participation and education are essential to any future regulatory program for ocean incineration. In

addition, if any ocean incineration program is to

go forward, specific steps must be taken to address

and resolve outstanding public concerns surrounding ocean incineration.

The Effect of Ocean Incineration on the

Development of Better Alternatives

A sixth key policy issue is how an ocean incineration program would affect the development and implementation of environmentally

preferable waste treatment, recovery, and reduction practices. A major point of contention has

been whether ocean incineration would undermine

existing incentives for using and developing better practices and technologies for hazardous waste

management. Although OTA’s analysis suggests

that such an effect is likely to be limited, prudence

may dictate taking steps to ensure that waste reduction is implemented wherever possible and that

the remaining incinerable wastes are, in fact,

directed toward the best available management

practices. To this end, certain policy directives or

regulatory requirements, specifically applying to

users of ocean incineration, might be desirable. Particularly deserving of serious attention are measures that would ensure and increase the accountability of waste generators that choose to utilize ocean

incineration. Other regulatory and economic means

of affecting the role that ocean incineration plays

in hazardous waste management may warrant congressional action.

Unresolved Questions

A seventh key policy issue concerns the seriousness of unresolved questions about the operation and impacts of ocean incineration. Significant debate centers on whether enough information

is currently available to allow an informed decision

on whether and, if so, how to proceed with a program for ocean incineration. Although most observers acknowledge that many unresolved questions remain, consensus is lacking on which

questions, if any, need to be answered before ocean

incineration can be permitted and on what means

should be used to answer such questions.

Many of the unresolved questions about ocean

incineration apply equally to already permitted

activities, such as land-based incineration. Consequently, questions arise regarding whether, how

much, and when research should be done on these

alternatives, and how such research should relate

to that required for ocean incineration.
28 ● Ocean Incineration: Its Role in Managing Hazardous Waste

CHAPTER 1 REFERENCES

1. Booz-Allen & Hamilton, Inc., “Review of Activities of Major Firms in the Commercial Hazardous

Waste Management Industry: 1982 Update, ” prepared for the U.S. Environmental Protection

Agency, Office of Policy Analysis (Bethesda, MD:

Aug. 15, 1983).

2. Environmental Resources Management, Inc., New

Jersey Hazardous Waste Facilities Plan, prepared

for New Jersey Waste Facilities Siting Commission

(Trenton, NJ: March 1985).

3. Fay, R. R., and Wastler, T. A., “Ocean Incineration: Contaminant Loading and Monitoring, in

Wastes 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 Scientific

Aspects of Marine Pollution), “Scientific Criteria

for the Selection of Waste Disposal Sites At Sea, ”

No. 16, in Reports and Studies of the Inter-Governmental Maritime Consultative Organization

(London: 1982), p. 31.

5. Hartung, R., “Uncertainties Associated With

Ocean Incineration Programs, ” MTS Journal

20(1):48-51, March 1986.

6. Keitz, E., Vogel, G., Holberger, R., et al., A Profile of Existing Hazardous Waste Incineration Facilities and Manufacturers in the United States,

EPA No. 600/2-84-052, prepared for the U.S. Environmental Protection Agency, Office of Research

and Development (Washington, DC: 1984).

7. Office of Appropriate Technology, “Alternatives to

the Land Disposal of Hazardous Wastes, An Assessment for California, Toxic Waste Assessment

Group, Governor’s Office of Appropriate Technology (Sacramento, CA: 1981).

8. Oppelt, E. T., “Hazardous Waste Destruction, ”

Environ. Sci. Technol. 20(4):312-318, 1986.

9. Philipbar, W., Testimony Before the Subcommittee on Natural Resources, Agricultural Research

and Environment, House Committee on Science

and Technology, Hearing on ‘ ‘Ocean Incineration

of Hazardous Waste, “ June 13 and 25, 1985, No.

61 (Washington, DC: 1985).

10. Stephan, D. G., letter of transmittal to Office of

Technology Assessment dated May 22, 1985, accompanying Keitz, et al., 1984.

11. Trenholm, A., German, P., and Jungclaus, G.,

Performance Evaluation of Full-Scale Hazardous

Waste Incinerators, EPA/600/S2-84, contract report

prepared for the U.S. Environmental Protection

Agency (Washington, DC: May, 1984).

12. U.S. Congress, Congressional Budget Office, Hazardous Waste Management: Recent Changes and

Policy Alternatives (Washington, DC: U.S. Government Printing Office, 1985), p. 24.

13. U.S. Congress, House of Representatives, Hazardous 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).

14. U.S. Congress, Office of Technology Assessment,

“Serious Reduction of Hazardous Waste for Pollution Prevention and Industrial Efficiency, ” in

press (Washington, DC: 1986).

15. U.S. Environmental Protection Agency, U.S. Department of Commerce Maritime Administration,

U.S. Department of Transportation Coast Guard,

and U.S. Department of Commerce National Bureau of Standards, Report to the Interagency Ad

Hoc Work Group for the Chemical Waste Incinerator Ship Program, NTIS No. PB-81-112849

(Springfield, VA: National Technical Information

Service, September 1980), app. B.

16. U.S. Environmental Protection Agency, Office of

Water, Incineration-At-Sea Research Strategy

(Washington, DC: Feb. 19, 1985).

17. U.S. Environmental Protection Agency, Office of

Policy, Planning and Evaluation, “Background Report I: Description of Incineration Technology, ”

Assessment of Incineration as a Treatment Method

for Liquid Organic Hazardous Wastes (Washington, DC: March 1985), p. 30.

18. U.S. Environmental Protection Agency, Office of

Policy, Planning and Evaluation, “Background Report IV and Appendices: Comparison of Risks

From Land-Based and Ocean-Based Incineration, ”

Assessment of Incineration as a Treatment Method

for Liquid Organic Hazardous Wastes (Washington, DC: March 1985), ch. 8.

19. U.S. Environmental Protection Agency, Science

Advisory Board, Report on the Incineration of Liquid Hazardous Wastes by the Environmental Effects, Transport and Fate Committee (Washington,

DC: April 1985).

20. U.S. Environmental Protection Agency, “Hearing

Officer’s Report on the Tentative Determination to

Issue the Incineration-At-Sea Research Permit HQ85-001” (Washington, DC: May 1, 1986).

21. Weitkamp, C., “Methods To Determine Hydrogen Chloride in Incineration Ship Plumes, ” in

Wastes 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, contract

report prepared by S. Dietz, M. Emmet, R.

DiGaetano, et al., for the U.S. Environmental Protection 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 Protection Agency, Office of Research and Development (Washington, DC: May 1985), p. 53.
Chapter 2

Shaping an Ocean Incineration

Program: Key Policy Issues
Contents

Page

Technical Issues and Options. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33

Controlling Stack Emissions From Incinerator Ships . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33

Reducing Transportation Risks Associated With Ocean Incineration . . . . . . . . . . . . . . . . . 37

Incorporating Technological Improvements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

Nontechnical Issues and Options. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40

Regulating Land-Based and Ocean Incineration Equitably . . . . . . . . . . . . . . . . . . . . . . . . . . 40

Involving the Public in Decisions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..,. 41

Viewing Ocean Incineration in a Broad Context . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43

The Effect of Ocean Incineration on the Development of Better Alternatives . . . . . . . . . . 43

Understanding 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

. . . . . . . . . . . . . . . . 46

on. . . . . . . . . . . . . . 48

Designating Sites for Ocean Incineration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~ . . . . . . . . . . . 49

Considering Applicants’ Compliance Records . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49

Determining 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 of

an ocean incineration program, several key regulatory and policy issues will need to be resolved to

provide an equitable, efficient, and environmentally

sound approach to managing the activity. Despite

debate over the significance or means of resolving

the outstanding issues, general agreement exists as

to what the issues are. This chapter examines some

of the issues that are key to the design of an ocean

incineration program. The discussion provides a

range of policy or regulatory options that might be

used to resolve these issues.

ditional or more extensive controls and approaches

that are oriented toward the same general end.

The chapter discusses technical issues, which primarily concern the incineration technology; nontechnical issues, which concern institutional or

social structures that affect regulation of ocean incineration; and issues, both technical and nontechnical, that influence how ocean incineration fits into

an overall waste management strategy. The chapter also discusses several additional issues that have

generated significant public concern.

For each issue, the discussion describes current

controls or approaches, 1 followed by a range of ad1 Discussions of EPAs approach generally refer to the approach set

out in EPA’s proposed Ocean Incineration Regulation (50 FR 8222,

Feb. 28, 1985), Many of the provisions discussed in this report are

expected to change in the process of finalizing the regulation, but the

changes cannot yet be identified and, therefore, cannot serve as a basis for discussion.

TECHNICAL ISSUES AND OPTIONS

Controlling Stack Emissions From

Incinerator Ships

Current Controls

EPA’s proposed regulation would approach this

issue indirectly, controlling waste composition and

incinerator performance, rather than limiting the

emissions themselves. The regulation would limit

the quantities of metals allowed in wastes to be incinerated, as a means of controlling particulate and

metal emissions. Two methods of monitoring incinerator performance would be used to control

emissions of unburned or partially burned waste.

First, trial burns would determine operating conditions that would achieve the required destruction

efficiency (DE) (see ch. 7), and all subsequent burns

would have to utilize these conditions. Second, incinerator operators would be required to monitor

combustion efficiency (CE) continuously and maintain a minimum level, which would serve as a partial surrogate for the DE requirement.

Under the proposed regulation, no limitations

or standards would be specified for particular components of the emissions themselves. Instead, the

regulations would require compliance with two

environmental performance standards. First, acidforming emissions (primarily hydrogen chloride

gas) would be limited to amounts that would not

change the alkalinity of the water by more than 10

percent. Second, emissions would be limited to

amounts that would not ‘ ‘unreasonably degrade or

endanger human health, welfare, or amenities, or

the marine environment, ecological systems or economic potentialities or recreational or commercial

shipping or boating or recreational use of beaches

or shorelines. Such amounts would generally be

33
34 ● Ocean Incineration: Its Role in Managing Hazardous Waste

determined by referring to appropriate marine

water quality criteria, where they exist.

Additional Controls

Numerous more stringent controls on ocean incinerator emissions have been proposed. The following discussion focuses on two types of additional

controls: those that are not currently imposed on

either land-based or ocean incinerators but that are

relevant to both; and those that are currently imposed on land-based incinerators but would not be

imposed on ocean incinerators under EPA’s proposed regulation.

Proposals Applicable to Incineration Both on

Land and At Sea. —Five proposals for additional

controls would be relevant to both land-based and

ocean incineration.

1) Redefine Destruction Efficiency To Provide

a Measure of Complete Destruction of All the Waste

Constituents That Are Present.—EPA would require demonstration of the ability to attain a minimum destruction efficiency for a preselected set

of parent compounds known as Principal Organic

Hazardous Constituents (POHCs). The compounds chosen as POHCs would be present in high

concentrations in the waste and/or difficult to destroy completely by burning. The definition of DE

would be based on two major assumptions: 1) that

if a compound disappeared, it must have been completely destroyed; and 2) that if the preselected compounds were abundant and were more difficult to

destroy than were all other components, the rest

of the waste would be destroyed with equal or

greater 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 only

the disappearance of the parent POHC and does

not take into account products of partial decomposition or products newly synthesized in the incineration process, the definition is limited in its

ability to aid in the assessment of total emissions

and subsequent assessments of environmental exposures (12).

Several alternative approaches to determining

DE have been proposed (12, 15). Some have been

used in actual testing of incinerator vessels, and

EPA is currently conducting research to evaluate

their validity and potential use (5). The alternative definitions are based on a total destruction efficiency, or TDE, derived by measuring the total

quantity of organic material released in emissions.

Several variants of this approach have been used,

including measuring emissions of organically bound

chlorine or of difficult-to-incinerate tracer compounds added to the waste prior to incineration.

The DE standard measures performance by

focusing on what incineration destroys and removes

from wastes. The standard does not regulate what

actually comes out of the incinerator. It provides

no measure of the absolute quantity of organic material released into the environment, EPA has considered adopting two other standards that would

measure actual emissions (14). One is a mass emission rate standard, which would regulate the quantity of organic emissions released per unit of time;

the other is a mass emission concentration standard, which would limit the quantity of emissions

per unit of volume. Although these standards provide measures that could be used directly to assess

exposure and risk, the only bases for setting the

standards would be technology or risk. Technology is already used as a basis for the DE standard;

risk would have to be derived on a facility-by-facility

basis, which would impose tremendous data, monitoring, and administrative burdens.

For these reasons, EPA opted for the uniform

performance-based DE standard. Particularly

harmful constituents, however, might warrant action to regulate emissions further by limiting the

rate at which wastes can be burned or by requiring a higher DE. Permits for incineration of wastes

containing polychlorinated biphenyls (PCBs), in

fact, have limits on PCB content or the rate at which

the wastes can be fed into the incinerator (48 FR

48986, Oct. 21, 1983).

2) Require Complete Analysis of the Chemical

Characteristics of the Emissions That Would Arise

Under a Variety of Operating Conditions. Based

on Such a Characterization, Emissions Standards

for Particular Components May Be Needed. —The

Science Advisory Board (SAB) found that “incinerators can be built and run under a set of optimal

conditions so that the DE for the selected POHCs

can meet specified criteria of 99.99 percent (for most

wastes) 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 even

periodic basis, however, the SAB found that it

would not adequately account for variability in incinerator performance, particularly for incinerator

upsets, which might be brief but could significantly

reduce the time-averaged DE.

Calculating DE during deliberately created upset conditions or monitoring DE continuously during operational burns, as well as trial burns, has

been proposed. Unfortunately, current analytical

methodologies are not rapid enough for DE to serve

as a means of monitoring incinerator performance.

EPA proposed relying on combustion efficiency as

the best available substitute for DE, although a

strong correlation between CE and DE has not been

established. The SAB called on EPA to develop a

revised DE that adequately accounts for the well

established variability in how incinerators perform.

The SAB also recommended that a complete

characterization of incinerator emissions be performed, analyzing the chemical composition of the

emissions produced under a variety of operating

conditions. Many observers have called for the

characterization and regulation of metal emissions,

based on anticipated environmental effects. This

proposal may be particularly important because,

under EPA’s proposed regulation, waste limitations

would control the amount of individual metals allowed in the waste, but would not control the

waste’s aggregate metal concentration (see proposal

5 below).

Both land-based and ocean incinerators could be

significant sources of nitrogen and sulfur oxides and

of other hazardous air pollutants. The EPA regulation, however, would not require control over or

even consistent monitoring for such components in

stack emissions. Both the Resource Conservation

and Recovery Act (RCRA) and the Clean Air Act

regulate land-based incinerators, but emissions

standards apply only to total particulate and acid

gases. For ocean incineration, acid-forming emissions are regulated through an environmental performance standard for seawater, but this standard

does not regulate any substances as hazardous air

pollutants.

3) Require Tests of the Short-Term and LongTerm Toxicity of Emissions. —The SAB called on

EPA to determine the toxicity of representative incinerator emissions in a manner that would address

both short- and long-term effects. The tests should

be performed on a representative number and

range of species and life stages. The tests should

also account for environmental mechanisms that

are capable of concentrating emission products

(e.g., by trapping organic constituents in the ocean

surface microlayer; see ch. 9).

4) Limit Emissions of Products of Incomplete

Combustion (PICS). —Data on the generation and

toxicity of PICS are scarce, although such highly

toxic compounds as dioxins and dibenzofurans have

been identified among the PICS created in hazardous waste incinerators. EPA’s proposed regulation

would not regulate PICS, partly because of the lack

of data on how operating conditions are correlated

with the formation of PICS. EPA has, however,

offered two possible approaches to controlling PICS

under future regulations (50 FR 8247, Feb. 28,

1985).

First, emissions limits could be established on a

PIC-by-PIC basis, reflecting the applicable water

quality criteria or marine aquatic life no-effect

levels. Water quality criteria, however, currently

do not exist for most PICS and would have to be

developed. Moreover, monitoring for PICS could

not be carried out during routine operations because of the complexity of analysis required.

A second approach would be to limit the total

quantity of unburned hydrocarbons allowed in

emissions. In effect, this approach would set an upper limit on PIC emissions, but individual PICS

would not be identified or limited.

5) Limit Metal Emissions. —The proposed

Ocean Incineration Regulation would specifically

limit the amount of each of 14 metals that could

be present in waste to be incinerated at sea (50 FR

8244, Feb. 28, 1985). Two types of limitations were

proposed, one on the wastes that are initially accepted for incineration and one on the final blended

waste fed to the incinerator.

Concentrations of each of the metals in wastes

accepted for incineration at sea would be limited

to 500 parts per million (ppm) per metal. The aggregate concentration of all metals in the waste,

however, would not be limited. Thus, a waste containing metals far exceeding 500 ppm could be le-
36 . Ocean Incineration: Its Role in Managing Hazardous Waste

gaily accepted for incineration. Critics also point

out that no scientific basis exists for setting the metal

limitations at 500 ppm, and that the limitations

should be metal-specific and risk-based. In practice, the actual concentrations of metals in wastes

that have been incinerated at sea have generally

been far below the 500 ppm level (see ch. 8), so

lowering this standard—at least for the more toxic

metals—might not significantly affect the range of

wastes that could be accepted for ocean incineration.

Because incinerator ships do not have scrubbers,

all metals in the waste are presumed to exit through

the stack directly into the environment. In light of

this, EPA proposed a second limitation, in this case

on the concentrations of metals in the final blended

waste that is fed to the incinerator. These concentrations would be limited to amounts such that the

resulting emissions would not exceed marine water

quality criteria, after accounting for initial atmospheric and oceanic dispersion.2 This limitation is

scientifically based, since marine water quality criteria are developed on the basis of metal-specific

toxicity data. Of the metals listed above, EPA has

determined that mercury, silver, and copper must

be limited below the 500 ppm level to meet marine water quality criteria (50 FR 51362, Dec. 16,

1985).

The proposed regulation would appear to provide special treatment for mercury and cadmium

because of their special treatment in international

(London Dumping Convention, or LDC) and domestic ocean dumping regulations. Emissions of

these two metals, however, actually would be subject to the same standards as would other metals;

that is, they would be limited “to that amount

which if directly dumped would not exceed their

applicable water quality criteria’ (emphasis added).

Thus, despite language apparently singling out

these two metals, the proposed regulation would

limit all 14 metals in the same manner.

Finally, in addition to the absolute amount, the

chemical form of a metal plays an important role

in determining the metal’s environmental fate and

effects (see ch. 7). The chemical forms, as well as

‘Marine water quality criteria have been developed for all 14 of

the metals specified by EPA.

quantities, of particular metals in incinerator emissions have not been fully determined. Undertaking such a characterization of the emissions

would be essential for justifying the lack of a requirement for scrubbers on incineration vessels.

Further regulation of metal emissions might well

be warranted, given EPA’s finding that most of the

human health risks associated with ocean incineration would be derived from metal emissions (1 1).

The potential need for stricter regulation of metal

emissions also applies to land-based incinerators,

where total particulate are regulated, but no monitoring or regulation of individual metals is required.

Proposals Extending Current Land-Based Incineration Requirements to Ocean Incineration. —Two proposals would extend to ocean incineration some requirements that currently apply

only to land-based incineration.

1) Require Air Pollution Control Equipment on

Incinerator Ships. —This is a major focus of the debate over ocean incineration, and reflects the major technical and regulatory difference between

land-based and ocean incineration. See chapter 1

for OTA’S analysis of this issue.

2) Require Secondary Chambers and/or Longer

Residence Times on Incinerator Ships. —EPA’s initial proposal for regulating land-based incinerators

under RCRA specified minimum operating conditions for residence time (how long the wastes must

reside in the incinerator) and temperature. In

promulgating its final regulations, however, EPA

opted for what it considered a ‘ ‘more flexible’ system based on performance standards. An exception to this approach is made for land-based incineration of PCBs regulated under the Toxic Substances

Control Act (TSCA), which specifies minimum

temperature and residence times.

EPA proposed an intermediate approach for regulating ocean incineration, to comply with international requirements under the LDC. Minimum

temperatures would be required for the wall and

flame of the incinerator, unless the trial burn established that DE and CE requirements could be met

at lower temperatures. A minimum residence time

(lower than that required under TSCA for landbased incineration of PCBs) would also be specified.
—

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

Critics of EPA’s proposed ocean incineration regulation have argued that, relative to land-based incineration, ocean incineration technology is less safe

because it employs a shorter residence time. Although not specifically required to do so, land-based

rotary kiln incinerators are generally designed to

include secondary chambers or afterburners, which

expose volatilized waste to a second flame to ensure complete combustion. This design keeps wastes

in the combustion zone longer, which is considered

necessary for incinerating solids and sludges.

Liquid wastes, however, are often injected

directly into the afterburner section of a rotary kiln,

which means their residence time is relatively short.

In addition, land-based liquid injection incinerators (like ocean-based incinerators) typically have

no afterburner section. On land, therefore, liquid

wastes generally are subject to shorter residence

times than are solid or sludge wastes. Given the

relative ease with which liquids are incinerated,

short residence times may be sufficient for destruction.

Finally, as noted by the SAB (12), liquid injection incinerators on land and at sea generally employ higher temperatures than do rotary kilns. Generally, an inverse relationship exists between the

residence time and the temperature required to attain a particular DE; that is, the higher the temperature, the shorter the time required to completely destroy the waste.

Thus, the important distinctions are not between

land-based and ocean incineration, but rather between liquid wastes and solid and sludge wastes,

and between liquid injection and rotary kiln technologies. A shorter residence time alone is not sufficient evidence of inadequate destruction of wastes.

Because residence time is primarily determined

by the design of the combustion chamber or chambers, only limited increases in residence time are

possible once a facility has been constructed. Therefore, the residence time of existing ocean incinerators could not be substantially lengthened.

Although considerable controversy over this issue has arisen in the debate over ocean incineration, EPA has maintained that relying on performance standards rather than design criteria ensures

sufficient waste destruction, while providing flexibility and accommodating a variety of designs.

Based on available information, this conclusion

seems warranted.

Reducing Transportation Risks

Associated With Ocean Incineration

Regulations governing hazardous waste transportation are scattered among numerous Federal

agencies, and additional requirements often exist

at the State and local levels. Although examining

in detail the adequacy of the regulatory framework

or coordination among various authorities exceeds

the scope of this study, certain issues specifically

related to ocean incineration can be identified and

addressed. 3

Current Controls

Transporting hazardous waste over land for the

purpose of incineration at sea could involve the use

of both highway and rail vehicles and would be subject to regulation primarily by the Department of

Transportation (DOT). EPA’s proposed ocean incineration regulation would not address land transportation activities. Instead, EPA argues, “controls

imposed by programs specially designed and experienced in the area of land transportation are best

able to provide protection against environmental

risks during that phase of ocean incineration activities” (50 FR 8225, Feb. 28, 1985).

Waste transfer activities at port facilities would

be subject to U.S. Coast Guard (USCG) regulations. EPA generally would defer to the USCG’S

special expertise and would not incorporate all

USCG requirements into the permitting process for

ocean incineration, although the USCG would have

authority to recommend such permit requirements.

EPA proposed that applicants for permits be required to prepare contingency plans detailing the

procedures to be followed if spills occurred; the

USCG would have review authority over the plans.

USCG regulations would also govern a ship’s

transit from the port facility to the incineration site.

The USCG has authority to invoke several measures to ensure safe transit, including:

● providing a USCG escort and shiprider,

3Another OTA assessment examines this issue in the context of transportation of hazardous materials in general (8).
3$ . Ocean /incineration: Its Role in Managing Hazardous Waste

●

●

●

restricting transit to daylight hours or particular weather conditions,

establishing a moving safety zone around the

vessel, and

requiring the vessel to broadcast a Notice to

Mariners to avoid its route.

Imposing such measures falls under the jurisdiction of the Captain of the Port (COTP) and typically occurs as part of the permitting process, based

on the COTP’s evaluation of the particular conditions of each port. For the recently denied research

burn in the North Atlantic, the COTP of Philadelphia incorporated all four measures into the research permit, which would have governed transit

from the harbor to the open ocean.

The USCG is currently developing a set of instructions specifically for ocean incineration, designating a full range of measures (including those

listed above) for COTPs to consider when determining what particular permits should require.4

Additional Controls

Two general approaches might address the problem of multiagency jurisdiction over ocean incineration activities.

Comprehensive Regulations. -Comprehensive

regulations covering all aspects of ocean incineration could be developed under one agency (presumably EPA). The proposed Ocean Incineration

Regulation obviously would not accomplish this bureaucratic feat, and EPA lacks the statutory authority to propose regulations that would. If the development of such regulations is desired, Congress

would need to provide the necessary authority under the Marine Protection, Research, and Sanctuaries Act (MPRSA) or another statute.

Improved Regulatory Coordination.—A second, alternative approach would leave jurisdictions

over distinct activities divided among various agencies, capitalizing on the USCG’s particular expertise and experience, but would improve interagency

coordination and would tailor regulations to the

unique features of ocean incineration. Several steps

in addition to those proposed by EPA would be necessary to accomplish this end.

‘Commander C. Huber, U.S. Coast Guard, personal communication, June 1986.

1) Cross-Reference Regulations. —At a minimum, EPA regulations should specifically cite those

regulations that, although promulgated and enforced by other agencies, would apply to ocean incineration.

2) Clarify Regulatory Requirements and Jurisdictions. — Regulatory requirements and agency

jurisdictions would have to be clarified, perhaps by

an Interagency Memorandum of Understanding,

which some observers have recommended. Others

believe, however, that because no actual conflicts

exist between agency authorities or regulations,

what would really be needed would be a clear guidance manual for agencies and the public. The manual would define agencies’ authorities and responsibilities, cross-reference all applicable regulations,

and state how the regulations applied to ocean incineration. 5

3) Develop Criteria for Selecting Ports.—To

govern or guide the selection of ports for ocean incineration activities, EPA should develop criteria

analogous to those specified under the proposed regulation for selecting ocean incineration sites. These

criteria should address the full range of factors that

bear on using or developing a port facility, including such diverse issues as marine, highway, and

rail traffic patterns; the nature and safety of access

routes and their surroundings; the resources, capabilities, and emergency preparedness of local authorities; and the environmental sensitivity and economic value of areas that might be affected, Because

so many topics would need to be considered, and

because the potential exists for conflict with local

governments that have authority over port development, the process of developing the criteria

should involve all relevant Federal, State, local, and

public interests.

Additional Regulatory Initiatives.—Both EPA

and USCG are developing regulatory programs

governing ocean incineration. Several specific

aspects of these programs relating to transportation risks might require or warrant further attention to effectively address major public concerns.

1) Designate Several Sites and Ports. —Designating several ocean sites and port facilities for ocean

incineration 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 reducing importation of wastes from other regions.

The existence of several sites could at least theoretically increase public acceptance of ocean incineration, by lessening the risk any single community

or region would have to bear, and by allowing

wastes to be disposed of close to where they are generated. The major public opposition to using the

Port of Philadelphia for a research burn in the

North Atlantic as an alternative to the previously

used Gulf Coast port and site, however, suggests

that designating several sites might actually increase

opposition by creating multiple ‘‘backyards.

2) Tailor Waste Handling and Transportation

Regulations Specifically to Ocean Incineration. —

The USCG is currently promulgating construction

and design standards that would be specific for incineration vessels. Other USCG regulations, including requirements for certifying and operating

waterfront facilities and for safely transferring bulk

liquid cargoes other than oil, are more general in

nature and may not be applicable to, or sufficiently

account for, special problems associated with ocean

incineration vessels and operations. G

Several technical or design features of the various existing and proposed ocean incineration technologies bear directly on transportation safety.

These include containerization versus bulk storage

and transfer, and self-propelled versus barge vessels (see ch. 6).

Incorporating Technological

Improvements

Current Approach

In adopting a performance-based approach to

regulating both ocean and land-based incineration,

EPA established performance standards that reflect

the capabilities of current incineration technologies

to destroy waste and the detection limits of current

sampling technologies. As EPA stated in its rationale for requiring a 99.99 percent destruction efficiency (a standard more stringent than that required

under international law), ‘‘there is extensive data

6The USCG is currently developing regulations that govern the handling and transfer of chemical substances; the regulations would be

analogous to those that already apply to oil (Commander C. Huber,

U.S. Coast Guard, personal communication, June 1986).

indicating that such destruction efficiencies are attainable and can be routinely measured in incinerators burning a wide range of organic wastes’ (50

FR 8245, Feb. 28, 1985). Moreover, EPA argued

that such an approach could both accommodate a

broad spectrum of incinerator designs and maintain a high uniform level of performance.

The various existing and proposed technologies

for ocean incineration differ in ways that could significantly affect the performance and safety of the

incineration process itself, and of associated activities. Chapter 6 describes and compares these technologies in more detail.

The existence of alternative technologies creates

a tension between two opposing approaches to regulatory policy. On the one hand, the regulatory

framework must strive to incorporate superior design features that would allow performance standards to be upgraded, ensuring that such standards

would not simply become the lowest common

denominator. On the other hand, specifying particular design features in regulations might discourage the development of better designs and

could render obsolete existing facilities that were

designed to comply with standards regarded as

sufficient at an earlier time. The latter phenomenon is typically addressed through ‘ ‘grandfathering’ or by applying standards to new sources only.

Many observers have argued that existing incinerator ships represent ‘ ‘first generation’ technology and should not be accorded the status of best

available technology. Other observers disagree, arguing that, in addition to meeting all regulatory

requirements, existing designs are ‘‘proven’ technologies, in contrast to newer designs, which are

either untested or lack sufficient operational experience.

Additional Approaches

EPA’s proposed Ocean Incineration Regulation

would not address the issue of how to incorporate

better design features or to upgrade the performance standards for incineration vessels. Although

many aspects of the problem extend well beyond

this single regulation, certain steps could be taken

to address its application to ocean incineration.7

‘Because none of these steps is required under RCRA, the}” would

represent a departure from the approach used for regulation of landbased incineration.
40 . Ocean Incineration: Its Role in Managing Hazardous Waste

Comparing Technologies. -Congress could require EPA to conduct a detailed comparison of the

various existing, proposed, and emerging ocean incineration technologies, with respect to such factors as performance, cost, and availability. This

evaluation should be ongoing or subject to periodic

updating, in order to identify promising new research and development efforts.

Reviewing Permits. —The periodic review of

permits for ocean incineration provides a natural

point at which to consider whether additional regulatory requirements should be introduced or

whether operating conditions or design features

should be changed. EPA could institute such an

evaluation as part of the permit review process.

Developing New Regulatory Approaches.—

Congress could require EPA to examine the possibility of developing best available technology or

new source performance standard approaches for

regulating ocean incineration. Such approaches

might provide means to increase the stringency of

performance standards as technology capable of

achieving them became available.

NONTECHNICAL ISSUES AND OPTIONS

Regulating Land-Based and Ocean

Incineration Equitably

Current Approach

Land-based incineration facilities are regulated

under RCRA (although incineration of PCBS is

covered under TSCA), whereas ocean incineration

vessels are regulated under the primary authority

of MPRSA. Existing or proposed regulatory requirements for these two types of facilities differ

in several ways, some of which are the subject of

considerable controversy (see below).

The desirability of having different requirements

for land-based and ocean incineration depends on

numerous nontechnical factors, and therefore technical analysis alone generally cannot justify maintaining or eliminating the differences. For example, the shiprider requirement applicable only to

ocean incineration may, in part, reflect the fact that

public surveillance of incinerators would be much

more difficult at sea than on land. This requirement therefore might be necessary to address the

‘‘out-of-sight, out-of-mind’ concerns of the public and the regulator.

Clearly, equitable regulation of land-based and

ocean incineration does not mean simply adopting

identical sets of regulatory requirements. The technical and nontechnical bases for any differential regulations, however, should be thoroughly scrutinized

and made as explicit and open to review as possible.

The issue of equitability raises larger questions

concerning the adequacy of current legislative authority to regulate ocean incineration. Because it

falls under MPRSA, ocean incineration is regulated

as a form of ocean dumping. Although certain

aspects of this activity (i. e., release of emissions

directly into the marine environment) do constitute a form of ocean dumping, the fundamental

purpose of the activity—waste destruction-might

not be adequately addressed through MPRSA’S

legislative authority.

Regulatory Differences.—Listed below are requirements that apply exclusively to or are more

stringent for one of the two technologies, Many of

these requirements are discussed in detail in other

sections of this report and are mentioned here only

for the sake of comparison. Extensive rationales

support many of the differences, so the more detailed discussions should be consulted for a full understanding of the issue.

Requirements That Apply Exclusively to or Are More

Stringent for Land-Based Incineration. —At least three

requirements apply only to land-based incineration

or apply to it more stringently than to ocean incineration.

1. Emissions standards are specified for particulates and hydrogen chloride gas for landbased incinerators; no emission standards are

specified for ocean incinerators, although environmental performance standards and mon-
Ch. 2—Shaping an Ocean Incineration Program: Key Policy Issues ● 41

2.

3.

itoring requirements that are not required of

land-based incineration would be required for

ocean incineration.

Air pollution control or particulate equipment

is required for land-based incinerators if the

emissions standards would otherwise be exceeded. Under TSCA, such equipment must

be present if PCBs are burned.

For land-based incineration of PCBs, TSCA

requires a minimum temperature of 1,2000 C

+ 1000 C for a 2 .O-second residence time, or

1,600° C + 100° C for a 1.5-second residence

time, with the temperature to be measured at

the wall or flame of the incinerator. No operating conditions are specified for non-PCB

wastes. For ocean incineration of all wastes,

EPA proposes to require a minimum l-second

residence time and a minimum temperature of

1,250° C measured at the flame and 1, 100° C

measured at the incinerator wall.

Requiwnwnts That Apply Only to Ocean Incineration. —

Several requirements apply to ocean incineration

but not to land-based incineration:

●

●

●

●

●

●

Waste analysis and operational monitoring

data for each ocean burn would have to be submitted to EPA. Monitoring data would have

to be recorded using an automatic tamperresistant or tamper-detectable device.

A limitation on metals content of wastes would

be specified for ocean incineration but not for

land-based incineration.

Environmental monitoring would have to be

conducted periodically during and following

ocean incineration burns but not land-based

incineration.

EPA would have to review and approve the

qualifications of ocean incineration company

personnel involved in monitoring and analyzing waste.

A full-time EPA shiprider, and possibly a

USCG shiprider as well,8 would be required

to 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 fully

anticipates requiring a shiprider to accompany the vessel during harbor and bay transit.

●

●

●

vessels and port facilities (yearly by USCG,

on demand by EPA) would be required.

Transfer of wastes to the vessel at dockside

would have to be supervised by the USCG.

Each applicant for an ocean incineration permit would have to assess and report to EPA

the potential effects of the applicant’s loading

and transportation activities on endangered

species. EPA would have to prepare a formal

endangered species assessment as part of the

site designation process.

As specified under MPRSA, each permit applicant would be required to demonstrate a

need to incinerate wastes at sea.

Involving the Public in Decisions

Perhaps the major obstacle to developing a program of ocean incineration is the high degree of

organized public opposition. 9 A full analysis of the

historical and current basis for the opposition goes

beyond the scope of this study; indeed, many of

the issues raised in the public debate have broad

application extending well beyond the confines of

ocean incineration or even hazardous waste management. The importance of such issues in determining policy for ocean incineration, however, cannot be overstated.

Current Approach

Although EPA’s fulfillment of the public hearing requirements set forth under MPRSA has provided for ample expression of public opinion, it has

not succeeded in abating opposition or assuring the

public of EPA’s ability to develop an environmentally sound program. Moreover, although public opposition to incineration was a major factor in

halting ocean incineration until regulations were

promulgated, it is questionable whether the means

that are available to EPA for ensuring public participation are capable of truly responding to public concerns.

.-- —

‘For an excellent discussion of the major areas of public concern

and approaches to addressing them, see the recent EPA Hearing

Officer’s Report (13) and the accompanying Summary of Public

Comments.
42 . Ocean Incineration: Its Role in Managing Hazardous Waste

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

Over 6,000 people attended a U.S, Environmental

Protection Agency public hearing held in Brownsville,

Texas, in 1983. The hearing, which concerned whether

a permit should be granted for Incineration of PCB- and

DDT-containing wastes in the Gulf of Mexico, was the

largest public hearing in EPA history and reflected

intense public concern about the technology.

Additional Approaches

measures for resolving specific issues of public

concern.

Increasing Public Participation.—Several approaches would increase public involvement in decisionmaking, which could decrease opposition to

ocean incineration:

●

●

●

●

provide for public participation, through citizen advisory panels, in the permitting process and in selecting ports and incineration sites;

develop national criteria or guidance for selecting ports in a manner that addresses public concerns and involves the public and local

interests;

develop a more explicit approach to involving

State and local concerns in the decisionmaking process; and

develop a broad waste management strategy

and educate the public as to how incineration

fits into it.

Resolving Specific Concerns.—Several approaches for resolving specific concerns warrant further

●

●

●

●

●

attention:

provide for adequate liability and public protection in the event of accidental spills or

darnages arising from incineration operations;

in particular, provide adequate mechanisms

for injured parties to recover damages;

designate several ports and incineration sites

to more equitably distribute the risks and burdens of ocean incineration;

reopen the designation process for the Gulf

Coast incineration site;

carry out more research before proceeding

with operational ocean incineration; and

consider an applicant’s compliance history in

deciding whether to grant a permit.

Two general approaches have been suggested for

addressing the issue of public opposition: first, mechanisms providing for greater or more meaningful

public participation in decisionmaking; and second,
Ch. 2—Shaping an Ocean Incineration Program: Key Policy Issues ● 43

VIEWING OCEAN INCINERATION IN A BROAD CONTEXT

The Effect of Ocean Incineration on the

Development of Better Alternatives

Current Approach

Many critics of ocean incineration have argued

that because ocean incineration would conceivably

provide a cheap management option for liquid organic wastes, companies would choose ocean incineration instead of investing in waste reduction

and recovery or better treatment technologies. 10

Proponents counter that ocean incineration would

fill a niche by providing the best treatment option

for wastes that do not, for economic or technical

reasons, offer great potential for recovery or reduction.

OTA’S analysis indicates that, for several reasons, ocean incineration would have a very limited

effect on overall incentives for developing superior

hazardous waste management practices:

● As the findings described in chapter 1 indicate,

in the near future, only modest increases are

expected in the use of recovery, recycling, and

new treatment technologies for liquid organic

hazardous wastes. These practices are expected

to be applied mostly to nonincinerable wastes

and would not be affected by the availability

of ocean incineration as an option (see ch. 3).

● Only a small fraction (less than 10 percent) of

all hazardous waste is suitable for ocean incineration, and the amount actually available

for burning at sea would probably be significantly smaller, because of geographic, regulatory, and economic constraints. Realistic

projections of the size of the market for ocean

incineration indicate a small fleet of ships handling a very small fraction of all hazardous

wastes.

● Predicting how future waste reduction activity would affect the ocean incineration market, and vice versa, is difficult because the necessary data are lacking and no meaningful way

exists to measure waste reduction. Enormous

potential obviously exists for such activity to

significantly decrease the quantities of wastes

IOThe inadequacy of liabi]ity provisions for waste generators that

choose 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 short

term, however, major institutional, economic,

and attitudinal obstacles to waste reduction remain. ”

Ocean incineration costs waste generators considerably more than do the other forms of

management and disposal used for most incinerable wastes today. This cost differential

might actually increase incentives for capital

investment in recovery and reduction options,

particularly when an economic return (even

a relatively long-term return) on the investment could be anticipated.

A portion of the ocean incineration market actually consists of wastes generated during the

purification or recovery of chemicals (e. g., distillation wastes). These wastes, which can result from preferred management practices such

as waste recovery, still require disposal or

treatment, and are prime candidates for incineration.

Additional Approaches

Although ocean incineration would be unlikely

to impede the development of better waste management practices in the current climate, Congress

and EPA might want to ensure, for example, that

incinerable wastes that were (or became) recoverable would be directed toward the best available

management practices. Several policy directives or

regulatory requirements that would specifically apply to users of ocean incineration might be considered that would make waste generators more accountable for properly managing their wastes.

Providing Accountability .—Precedent and a

potential model for instituting accountability might

already exist. The Ocean Dumping Regulations (40

CFR 227.14-227. 16) explicitly require that each applicant for a permit to dump waste in the ocean

must provide information on what processes generated the wastes, how it was previously disposed

of, what other alternatives have been explored, and

why the waste now needs to be dumped in the

ocean.

1 IAnother OTA assessment, to be released in fall of 1986, explores

these issues in detail (9).
44 ● Ocean Incineration: Its Role in Managing Hazardous Waste

Section 224 of the 1984 RCRA Amendments

provides a step in the same direction for hazardous waste generators that dispose of wastes by methods regulated under RCRA. Although the effectiveness of regulations implementing Section 224

remains to be seen, the section is intended: 1) to

require generators to develop waste reduction or

detoxification programs on a waste-specific basis,

and to report periodically on the progress of these

programs; and 2) to certify on manifests that the

treatment or disposal option to be used is ‘ ‘that

practicable method currently available to the generator which minimizes the present and future threat

to human health and the environment.

Applying such an approach to ocean incineration might be complicated by the fact that the permit applicants do not generate the waste but only

transport and dispose of wastes that generally would

come from numerous sources. Thus, evaluating

and justifying the need to incinerate the wastes

might be beyond the applicants’ capabilities. This

complication is one of the reasons that EPA’s proposed Ocean Incineration Regulation would not require permit applicants to adhere to this requirement of the Ocean Dumping Regulations.

Nevertheless, operators of ocean incineration vessels could be required to gather waste-specific information from generators and submit it as part

of their applications for permits. Such a requirement might, however, place the permit applicant

in the difficult position of having to obtain data from

potential clients and then wait for a determination

from EPA before accepting or refusing the clients’

wastes. Alternatively, waste generators seeking to

use ocean incineration could be required, through

regulatory provisions developed to address this

aspect of the 1984 RCRA Amendments, to justify

their need to use ocean incineration. Where appropriate, approval could be made contingent on compliance with a waste reduction schedule.

Directing Wastes to Better Alternatives. -Additional measures could include regulatory restrictions on the ocean incineration of wastes for which

recovery or recycling capacity existed or could be

developed. Economic approaches, such as imposing a tax on waste incinerated at sea, provide

another possible avenue for ensuring that incinerable wastes would be directed toward preferred

practices. 12

Other less direct options might include measures

to encourage the development and introduction of

superior technologies for incinerable wastes. For

example, Congress might consider providing direct

incentives for research and development efforts and

establishing a formal institutional structure for demonstrating new technologies. Such an approach

might be especially useful for managing particularly troublesome wastes, such as PCBs.

Understanding the Impacts of

Ocean Incineration Relative to

Those of Other Alternatives

Many observers maintain that ocean incineration’s possibilities and limitations in managing hazardous wastes have been inadequately defined and

insufficiently exposed to public scrutiny and debate.

This situation is one symptom of a much larger deficiency: the lack of a comprehensive national hazardous waste management strategy.

One of the major obstacles to developing such

a strategy is the scarcity of comparative data on the

potential effects and applications of available and

emerging technologies. In the course of this study,

OTA encountered major gaps in information about

basic aspects of the waste management problem that

greatly impede the development of sound policy.

Congressional attention to several general problem

areas might significantly strengthen our understanding of what a technology like ocean incineration can and cannot accomplish. Congress might

want to:

● provide for more comparative research into

waste management technologies by the Federal Government (e. g., by EPA and the National Oceanic and Atmospheric Administration), by industry (accomplished through

incentives), and by universities (supported by

Federal grants);

Izunless it were app]ied to all waste management practices, or at

least to those considered less environmentally sound than ocean incineration, 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 for

establishing and maintaining more comprehensive and accessible databases on waste generation and disposal, number and status of

management facilities, and

basic areas; and

OTHER

numerous other

ISSUES AND

In addition to the key policy issues discussed

above, several other policy issues have become major public concerns in the debate over ocean incineration. This section describes and analyzes each of

these issues and, wherever possible, highlights potential approaches to resolving them.

Demonstrating a Need for

Ocean Incineration

Current Approach

Under provisions of both the London Dumping

Convention and the Marine Protection, Research,

and Sanctuaries Act, before a permit can be granted

for the dumping of any waste at sea, the need for

such dumping must be established. Because it falls

under the definitions of ocean dumping used by

both the LDC and MPRSA, ocean incineration

would be subject to the requirement for a needs

assessment. 13 The Eighth Consultative Meeting of

Contracting Parties held in 1984 (cited in the

preamble to the proposed Ocean Incineration Regulation; 50 FR 8247, Feb. 28, 1985) interpreted

the need provision of the LDC to mean that:

. . . other means of disposal should be considered

in the light of a comparative assessment of human

risks; environmental costs; hazards (including accidents) associated with treatment, packaging,

transport, and disposal; economics (including

energy costs); and exclusion of future uses of disposal areas, for both sea disposal and the alternatives. If the foregoing analysis shows the land alternatives to be more practical, a license for sea

disposal should not be given.

IJThe requirement to establish a need for ocean incineration is a

unique feature of the Marine Protection, Research, and Sanctuaries

Act. Establishment of need is not required for land-based incineration or any other land-based waste disposal technology.

● ensure that current data-collection and monitoring efforts are designed, managed, and coordinated in a manner- that generates useful

and accessible information for use in decisionmaking.

PUBLIC CONCERNS

The requirement to establish need has been incorporated into the proposed Ocean Incineration

Regulation (Section 234.50) in a manner that EPA

claims to be generally consistent with the LDC

interpretation. Under the proposed regulation, need

would 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 demonstrated: ‘ ‘Need will be presumptively demonstrated if ocean incineration poses less or no greater

risks than practicable land-based alternatives’ (50

FR 8247, ‘Feb. 28, 1985).

EPA’s proposed approach to demonstrating need

is to prepare a generic needs assessment for ocean

incineration on a national scale, rather than on a

case-by-case basis. 14 The generic needs analysi s

would provide a rebuttable presumption of need

for individual permit applications, placing on those

who challenged permit applications the burden of

proving that no need existed. EPA presented two

rationales for such an approach:

1. The issue of ocean incineration is onlv a part

2

of a larger problem of hazardous waste management, which requires solutions and management technologies to be looked at from a

broad perspective far beyond the capabilities

of the permit applicants.

The permit applicants do not generate the

waste but only transport and dispose of waste

that generally comes from numerous sources.

Because applicants would lack the necessary

information, evaluating and justifying the

need to incinerate the wastes would be beyond

their capabilities.

l+EpA is apparently reconsidering its proposed generic needs approach in preparing its final Ocean Incineration Regulation, opting

for the permit-by-permit approach embodied in the Ocean Dumping

Regulations.
46 . Ocean Incineration: Its Role in Managing Hazardous Waste

Additional Approaches

EPA’s approach to defining need is emerging as

a major point of contention in the ocean incineration debate. Critics of the technology argue: 1) that

the burden of proof should lie with EPA to prove

that ocean incineration is as safe as, or safer than,

other available alternatives; 2) that need should be

evaluated on a permit-by-permit basis; and 3) that

the EPA’s presumptive definition would be inconsistent with the intent of the MPRSA and LDC.

The controversy over the need for ocean incineration is in many respects related to the general issue of accountability. Public concern has been widespread that ocean incineration would largely free

waste generators of accountability for wastes incinerated at sea. Accountability in this context

would have two components: first, accountability

for reducing wastes as much as possible (as initiated under the 1984 RCRA Amendments); and

second, accountability with respect to legal liability for releases of waste. Implementing a mechanism for ensuring that generators would be held

accountable would help to resolve the objections

that ocean incineration would: 1) undermine incentives for waste reduction; and 2) allow generators to dispose of their waste with little or no liability, because of the difficulty of tracing waste back

to its source or assigning liability to individual

generators.

Setting Liability Requirements

Current Approaches

Many of the problems concerning liability that

apply to ocean incineration reflect the much broader

crisis in environmental liability generally. The

growing difficulty in obtaining affordable commercial pollution liability insurance threatens all handlers of waste, hazardous and otherwise. Except as

it directly relates to land-based and ocean incineration facilities, however, an analysis of liability is

beyond the scope of this study.

At the outset, liability limits must be distinguished from financial responsibility requirements.

Liability limits, which are commonly set by statutes, represent specified maximum amounts of

money that parties can be legally required to pay

for damages. Financial responsibility requirements,

which can be set by statutes or regulations, are designed to assure that parties undertaking certain

activities have sufficient financial resources to meet

liabilities the parties might incur. Therefore, the

liability limit and the required level of financial

responsibility are commonly the same.

The MPRSA establishes no liability limits for

any of the activities it covers, including ocean incineration; nor does the Act explicitly authorize

EPA to impose a financial responsibility requirement through regulation. In the proposed Ocean

Incineration Regulation, however, EPA indicated

the clear need to impose such a requirement and

solicited comments on an appropriate level of financial responsibility to be required of companies

that seek to incinerate hazardous wastes at sea. EPA

suggested a range of $50 million to $500 million

(50 FR 8233, Feb. 28, 1985).

EPA’s authority to impose any such requirement

through its Ocean Incineration Regulation has been

questioned (7), particularly because certain other

statutes and regulations already apply to incineration vessels.

For purposes of comparison, the following discussion summarizes existing liability and financial

responsibility requirements that apply to land-based

and ocean incineration.

Land-Based Incineration.—Two Federal statutes invoke liability and financial responsibility requirements that apply to land-based hazardous

waste treatment, storage, and disposal facilities, including land-based incinerators. RCRA sets ‘ ‘sudden and accidental” liability limits and financial

responsibility requirements at $1 million per accident or $2 million annually. Limits for damages

and third-party claims due to ‘‘gradual pollution’

are higher: $3 million per incident or $6 million

annually. The latter limits, however, currently apply only to landfills, surface impoundments, and

land treatment facilities, not to incinerators. Further liability and financial responsibility requirements might be imposed on incinerators under

regulations developed in response to RCRA’s provisions for closure and corrective action, although

these requirements would probably be determined

on a facility-by-facility basis.

Superfund (formally known as the Comprehensive

Environmental Response, Compensation, and Lia-
Ch. 2—Shaping an Ocean Incineration Program: Key Policy Issues • 47

bility Act, or CERCLA) specifies a much higher

liability limit of $50 million plus the costs of cleanup

for some land-based hazardous waste treatment,

storage, and disposal facilities, including land-based

incinerators. (Corresponding regulations specifying levels of financial responsibility have not yet

been developed under CERCLA, however, so landbased incinerators do not have to demonstrate their

financial ability to meet the required level of liability. Given this, the applicable financial responsibility requirements are those specified under RCRA.)

Ocean Incineration.—EPA’s proposed regulation was noncommittal on the issue of financial

responsibility and solicited public comment on a

proposed range of $50 million to $500 million for

ocean incineration permitters.

Several existing statutory limitations, however,

apply to incineration vessels (7). The oldest is based

on maritime law, dating back to 1851, limiting the

legal liability of vessel owners to the value of the

vessel plus its cargo after the accident.

Congress has enacted two additional statutes that

address liability as it applies to ocean incineration

vessels.

Section 311 of the Clean Water Act. —This provision limits legal liability for pollution damages to

$150 per gross ton, which amounts to $300,000 to

$600,000 for existing incineration vessels. An

identical financial responsibility requirement is

specified.

Section 107 of the Current CERCLA.—This

Superfund provision specifies a liability limit of $5

million to cover both damages to natural resources

and the costs of responding to the release of a hazardous substance. The statute also imposes an identical financial responsibility requirement.

Thus, CERCLA’S $5 million liability limit and

financial responsibility requirement appear to represent the current limits applicable to ocean incineration vessels.

Additional Approaches

Recent amendments to CERCLA offered in both

Houses of Congress (and agreed on in conference)

would bring the liability limit for incineration vessels up to the level required of land-based incinerators, which is $50 million plus the cost of responding to the accident. In addition, the $50 million

limit would apply to damages resulting from faulty

incineration or other releases of waste, and would

extend liability to the generators and transporters

of the waste in addition to the vessel owners.

The amendments would also extend current financial responsibility requirements for land-based

incinerators to ocean incineration vessels, but the

exact amount of financial responsibility is not specified. Instead, the amendments provide EPA with

the discretion to set financial responsibility requirements, with the explicit expectation that these requirements should be commensurate with those for

other activities that have similar levels of risk.

If adopted, these amendments to CERCLA apparently would resolve the issue of whether EPA

has the statutory jurisdiction to require liability insurance in excess of the limitations established under statutory law, or to invoke strict liability requirements for ocean incineration vessels.

Remaining Questions

Marine insurance policies are also subject to several legal defenses. For example, such policies typically do not cover damages resulting from acts of

God. Most policies provide no coverage unless

negligence by the vessel’s owner or operator can

be proved. Nor does coverage generally extend to

damages resulting from the actual incineration

process itself. In other words, coverage applies to

damage arising from sudden and accidental events,

such as spills, but not to damages from gradual pollution, such as incinerator emissions. 15 How such

defenses and limitations would apply to releases

from an ocean incineration vessel is currently an

open question.

Another major remaining question concerns liability for damages to third parties. Critics have argued that existing law does not adequately provide

for private parties to recover damages they have

sustained from spills of hazardous substances. Prol~Damages arising from federally permitted releases are excluded

from coverage under CERCLA. This immediately raises the question of how to distinguish damage caused by permitted releases from

damage caused by nonpermitted releases.
48 . Ocean Incineration: Its Role in Managing Hazardous Waste

posed amendments to MPRSA would remove barriers to third-party suits, but they do not address

the acknowledged difficulty third parties encounter in collecting damages. 16 Prospects for collecting damages are particularly slim when no evidence

of direct physical damage can be offered, even

though indirect or reputational damage may have

been substantial. This issue is complicated by the

extreme uncertainty entailed in estimating damages

from hazardous waste spills.

Availability and Costs of Liability Insurance

A major factor influencing the insurance market for incineration vessels is their lack of operating experience in this country. In addition, insurance is much more difficult to obtain and more

expensive when coverage is desired for damages resulting from both the incineration function and the

transportation function the vessels serve.

A recent study prepared for EPA assessed the

market availability and potential costs of obtaining liability insurance for incineration vessels (l).

Based on interviews with insurance industry representatives, the study estimated that coverage of

$50 million would require a premium of about $5

million annually, or 10 percent of the liability limit.

In contrast, a policy that meets the CERCLAmandated $5 million liability limit would carry an

annual premium of $20,000. The higher premium

for incineration vessels could increase per-ton rates

by as much as 63 percent, according to the study,

and would make insurance costs the chief operating expense for ocean incineration. 17

Evaluating the Effect of Ocean

Incineration on Land-Based Incineration 18

The Land-Based Perspective

Land-based incineration companies have

strongly argued that ocean incineration is not

needed, because the market for incineration of or-

.—lbTheSe amendments, to Section 106 of MPRSA, Were adopted on

June 26, 1986, by the House-Senate conference on H.R. 2005, which

would reauthorize CERCLA (W. Stelle, House Committee on Merchant Marine and Fisheries, personal communication, July 10, 1986).

I TThese results have been disputed by some ocean incineration industry representatives. Based on their experience, these representatives argue that the costs and difficulty of obtaining liability insurance 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 sufficient

liquid waste incineration capacity already exists on

land.

Moreover, these companies believe that sludge

and solid wastes are best incinerated by using highenergy organic liquid wastes to provide the needed

fuel, and they have suggested that the market for

land-based incineration of sludges and solids, but

not liquids, will increase. The companies have expressed concern that ocean incineration might draw

off much of the available high-energy liquid waste,

because of the economies of scale that the large atsea incinerators would provide. If this occurred, the

land-based incinerator companies would have to

purchase raw fuel to burn sludges and solids, which

they argue would be less cost-effective and less environmentally sound.

Land-based incineration companies base their

views of future needs on the following analysis: Because liquid wastes are highly amenable to recovery or other treatment, the quantities of liquids

available for incineration will decline, with a concomitant increase in quantities of sludges and highly

viscous liquids which would result from the treatment and which could only be incinerated on land.

These companies do not believe that the 1984

RCRA land disposal restrictions will greatly increase liquid waste volumes available for incineration, because most of the organic wastes currently

landfilled are sludges and solids.19

The Ocean Perspective

On the other side of the issue, proponents of

ocean incineration predict that the gap between capacity and demand for liquid waste incineration

would continue growing if ocean incineration were

not permitted. The proponents cite EPA’s market

analysis (10), which suggests this gap may be as

high as sevenfold. This study is highly controversial, however, because of the myriad assumptions

on 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 incinerated. The use of these options also will be restricted under the 1984

RCRA Amendments, although at a slower pace than for landfills.
Ch. 2—Shaping an Ocean Incineration Program: Key Policy Issues ● 49

Ocean incineration companies believe that landbased incinerators are simply wary of the competition. High-energy liquid wastes form a very competitive market, in which land-based incineration

companies already compete with industrial boilers

and furnaces (e. g., cement kilns) as well as waste

recyclers. Proponents of ocean incineration argue

that land-based incinerators who want to continue

to use liquid wastes as fuel for co-incinerating solids

and sludges would only be able to obtain the liquid wastes by charging generators lower rates than

those charged by their competitors. If land-based

incinerators lost this market and had to resort to

buying raw fuel, the costs could and would be

passed on to the sludge and solid waste generators

in the form of higher incineration charges.

Finally, proponents of ocean incineration argue

that, in its absence, greater quantities of hazardous waste would be disposed of using land alternatives known to be unsafe, including illegal dumping, which would be far less acceptable than the

potential risks posed by ocean incineration.

Designating Sites for Ocean Incineration

The proposed Ocean Incineration Regulation

lists the Gulf of Mexico Incineration Site as the only

currently designated site for ocean incineration and

states that the site may be used for up to 10 years.

Many members of the public and several elected

officials, including the governors of two Gulf States,

have argued that the designation process for the

Gulf site should be reopened because conditions

have substantially changed since its initial designation in 1976.20 The changes include the discovery

of valuable new fisheries in the area and increased

ship traffic and navigational hazards, Questions

have also arisen about the adequacy of opportunities for public participation in the initial decision

and about whether EPA has complied with the Agency’s own proposed criteria for site designation.

Finally, the 10-year designation has been challenged as too long a period to account for changing conditions and to accommodate any findings

derived from environmental monitoring; an alternative proposal for 3-year designation with annual

review has been proposed (for example, see ref. 16).

‘“A petition callin~ for the withdrawal of designation of the Gulf

site has been submitted to EPA by Texas Rural Legal Aid (3).

EPA has countered that the site still meets its initial selection criteria, and that it would also have

to satisfy the new requirements for site designation

(carrying capacity and a monitoring plan) before

it could be used for operational burns.

The same issue has surfaced with respect to the

proposed North Atlantic Incineration Site. An environmental impact statement (EIS) was prepared on

the site in 1981, but changed conditions (including use of the adjacent 106-mile deepwater dumpsite for the dumping of sewage sludge) have led to

requests that the 1981 EIS be updated (13). Updating the EIS for the Gulf site would also be warranted, given that it was initially designated in 1976

(see ch. 11).

Considering Applicants’ Compliance

Records

Current Approaches

Many concerned citizens and elected officials

have suggested that an applicant’s prior compliance

record with Federal, State, or local environmental

laws be included as a criterion in EPA’s evaluation of applications for ocean incineration permits .21

Texas has included such a provision in the State’s

new (and as yet untested) hazardous waste management act (16). EPA has rejected such proposals

on the grounds that equitable criteria for such an

evaluation are impossible to develop. As an alternative, EPA has proposed a permit-by-permit determination of an applicant’s ability to meet all

permit requirements and the development of an enforcement strategy to guide the response to a violation of a permit.

Additional Approaches

This issue is especially troublesome, because of

its close link to the larger issue of public confidence

in EPA and ocean incineration companies to carry

out this program in the safest possible manner. At

a minimum, EPA should evaluate whether the

available means are adequate: 1 ) to ensure that applicants can (and do) meet all permit requirements,

2) to hold permitters fully liable for any damages

that might result, 3) to enforce all provisions of the

z 1 For a de[aj]ed dlSCuSS](ln of [his position and thc~ precedents for

its adoption, see ref. 4.
50I . Ocean Incineration: Its Role in Managing Hazardous Waste

regulations, and 4) to provide for sufficient penalties for violations. It is also essential that the results of such a review be communicated to the public in an open manner.

In addition, further attention should be given to

developing appropriate means of considering the

integrity and environmental compliance records of

applicants for ocean incineration permits (13). Although a workable solution to this problem would

be difficult to formulate, permit proceedings should

at least provide full disclosure of applicants’ records,

including opportunities for applicants to explain

relevant mitigating or changed circumstances. If,

in preparing its final regulations, EPA ultimately

decides to reject direct consideration of past compliance in evaluating permit applications, the rationale for the decision deserves more than the sort of

passing mention provided in the proposed Ocean

Incineration Regulation (50 FR 8248, Feb. 28,

1985).

Determining Appropriate Operating

Permit Length and Renewal Provisions

Current Approach

EPA’s proposed Ocean Incineration Regulation

would grant operating permits for ocean incineration for 10 years, subject to renewal after 5 years

(or more frequently at the request of the Assistant

Adminstrator). Renewals would require approval

of a new application and satisfactory completion

of a new trial burn. EPA argues that shorter permit terms would not provide sufficient economic

incentive for companies to enter the market or allow them to make sufficiently long-term commitments to waste generators (50 FR 8232, Feb. 28,

1985).

Additional Approaches

Although such concerns are legitimate, a permit

length of 10 years at the initiation of a new program appears excessive. The length of the term is

especially troublesome in light of the existing perm it terms under other environmental regulations:

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

● a 5-year term for discharge permits under the

Clean Water Act;

. a requirement under the London Dumping

Convention for a survey (including a trial

burn) to be conducted every 2 years; and

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

the well established land-based incineration

program under RCRA.

Two provisions of the proposed regulations

affecting permit renewal are also problematic. First,

the review process appears to be limited to successful completion of a trial burn, and would not provide for reconsideration of the many factors that

might have changed since initial granting of the permit: for example, the need for ocean incineration

of the particular wastes to be burned; the environmental characteristics of the incineration site with

respect to factors such as data obtained from monitoring, the presence of endangered species, or other

or increased use of the site; and needed or desired

changes in operating conditions, monitoring, or

sampling protocols. Nor would the review appear

to allow an opportunity to make more substantial

changes as needed to reflect advances in ocean incineration technology or the scientific understanding of incinerator emissions, environmental impacts, and so forth. Particularly if a 10-year permit

length were to be considered, a substantive review

would be essential.

Second, as currently formulated, the proposed

regulation would provide for continued operation

beyond the end of the permit term in the event of

a delay on the part of EPA in processing a permit

reapplication. This provision is difficult to justify,

given: 1) the small number of permits (and therefore, the relatively small administrative burden)

likely to be involved; and 2) the real need for the

criteria listed above to be reexamined prior to continued operation.
Ch. 2—Shaping an Ocean Incineration Program: Key Policy Issues • 51

1.

2.

3.

4.

5.

6.

7.

8.

9.

10.

CHAPTER 2

Clark, L. H., and Oppenheimer, R. H., Environmental Insurance Coverage for Ocean Incineration

Vessels, prepared for the U.S. Environmental Protection Agency, Office of Policy, Planning, and

Evaluation (Washington, DC: Aug. 10, 1985).

ICF Inc., “Survey of Selected Firms in the Commercial Hazardous Waste Management Industry:

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

Environmental Protection Agency, Office of Policy

Analysis (Washington, DC: Sept. 30, 1985), p. 2-5.

Inside EPA, “Environmentalists Fear EPA May Finesse Approval of Mexico Sea Incineration Site,

Inside EPA 6(2):2, July 12, 1985.

Oceanic Society, Joint Comments of Environmental

and Other Citizen Organizations in Response to the

U.S. Environmental Protection Agency’s Draft

Regulations 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 Subcommittee on Natural Resources, Agricultural Research

and Environment, House Committee on Science

and Technology, Hearing on ‘ ‘Ocean Incineration

of Hazardous Waste, ” June 13 and 25, 1985, No.

61 (Washington, DC: 1985).

U.S. Congress, Library of Congress, Congressional

Research Service, “Authority of EPA To Impose

Financial Responsibility Requirement as Condition

for Ocean Incineration Permits” (Washington, DC:

Aug. 8, 1985).

U.S. Congress, Office of Technology Assessment,

Transportation of Hazardous Materials, OTASET-304 (Washington, DC: U.S. Government

Printing Office, July 1986).

U.S. Congress, Office of Technology Assessment,

“Serious Reduction of Hazardous Waste for Pollution Prevention and Industrial Efficiency, ” in

press (Washington, DC: 1986).

U.S. Environmental Protection Agency, Office of

Policy, Planning and Evaluation, “Background ReREFERENCES

11

12.

13.

14.

15.

16

port III: Assessment of the Commercial Hazardous

Waste Incineration Market, ” Assessment of Incineration as a Treatment Method for Liquid Organic Hazardous Wastes (Washington, DC: March

1985).

U.S. Environmental Protection Agency, Office of

Policy, Planning and Evaluation, ‘ ‘Background Report IV and Appendices: Comparison of Risks

From Land-Based and Ocean-Based Incineration, ’

Assessment of Incineration as a Treatment Method

for Liquid Organic Hazardous Wastes (Washington, DC: March 1985), ch. 8.

U.S. Environmental Protection Agency, Science

Advisory Board, Report on the Incineration of Liquid Hazardous Wastes by the Environmental Effects, Transport and Fate Committee (Washington,

DC: April 1985), pp. 16, 18, 20.

U.S. Environmental Protection Agency, “Hearing

Officer’s Report on the Tentative Determination To

Issue the Incineration-At-Sea Research Permit HQ85-001” (Washington, DC: May 1, 1986),

U.S. Environmental Protection Agency, Office of

Solid Waste and Emergency Response, “Supporting Documentation for the RCRA Incinerator Regulations, 40 CFR 264, Subpart O—Incinerators,

prepared by PEER Consultants, October 1984,

NTIS No. PB-86-110293 (Springfield, VA: National Technical Information Service, August 1985),

p. 7-19,

U.S. Environmental Protection Agency, Incineration-At-Sea Regulation Development Task Force,

Office of Water Regulations, Criteria and Standards Division, “Summary of Public Comments on

the Proposed Ocean Incineration Regulation

(Washington, DC: September 1985).

White, M., Governor of Texas, Testimony Before

the U.S. Senate Subcommittee on Environmental

Pollution, Committee on Environment and Public

Works, Hearing on “Ocean Incineration of Hazardous Waste, ” June 19, 1985 (Washington, DC:

1985).
Chapter 3

Incinerable Hazardous Waste:

Characteristics and Inventory
Contents

Page

Characterizing Incinerable Waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 55

Waste Properties.. . ., . $ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 55

Types of Ocean-Incinerable Wastes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58

Quantifying Incinerable Waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59

Waste Inventory . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59

Projections of Future Waste Generation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66

Onsite Versus Offsite Management of Hazardous Wastes . . . . . . . . . . . . . . . . . . . . . . . . . . . 72

Capacity of and Demand for Offsite Treatment Facilities . . . . . . . . . . . . . . . . . . . . . . . . . . . 73

Future Use of and Demand for Incineration Capacity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 74

Other Factors Affecting Future Waste Generation and Management . . . . . . . . . . . . . . . . . 76

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

Box

Page

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

Tables

Table No. Page

1. Most Common and Most Abundant Chemical Constituents Found in

Incinerated Hazardous Wastestreams . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57

2. Major Categories of Ocean-Incinerable Hazardous Waste . . . . . . . . . . . . . . . . . . . . . . . . . . 59

3. Quantities of Incinerable Wastes Generated in the United States, 1983 . . . . . . . . . . . . . . . 65

4. Generation of Ocean-Incinerable and Total Hazardous Wastes,

by EPA Region, 1983 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68

5. Top 10 States for Generation of Ocean-Incincrable Hazardous Waste, 1983 . . . . . . . . . . 68

6. Hazardous Waste Generation in 1983 and 1990: Effect of Recycling and Recovery

on Waste Quantities Requiring Treatment or Disposal, Summary of Comparison . . . . . 70

7. 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 and

Extent of Waste Reduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72

Figures

Figure No. Page

1. Major Industries Generating Wastes Suitable for Ocean Incineration . . . . . . . . . . . . . . . . 67

2. 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 hazardous

waste that could be incinerated on land or at sea

must start by considering characteristics of both the

waste and the technologies for incineration. This

section identifies and discusses the most important

characteristics of incinerable wastes, relating them

to the requirements or restrictions of available incineration technologies.

Generally, only organic wastes or other wastes

with significant organic content are considered

appropriate for incineration, which excludes all inorganic materials. 1 Other important attributes of

waste include energy content, physical form, the

presence of hazardous constituents or properties,

and chlorine and metal content.

Energy Content

An important characteristic that influences a

waste’s suitability for incineration is energy content (usually expressed in British thermal units, or

Btu). Efficient thermal destruction of the organic

portion of a waste requires that the entire mixture

being incinerated have some minimum energy content. Therefore, many incinerable wastes must be

blended with, or burned in the presence of, auxiliary fuel or high-energy waste to ensure complete

destruction. Other incinerable organic wastes have

sufficient energy content to maintain their own

combustion, enhancing both the efficiency and costeffectiveness of incineration.

Many common wastes represent mixtures of organic and inorganic materials. The organic fraction of such wastes, no matter how small, is at least

technically incinerable. For example, the Environmental Protection Agency (EPA) recently used a

mobile incinerator to destroy dioxin-tainted soil in

Times Beach, Missouri. Four pounds of dioxin contained in 40 tons of soil were successfully destroyed

by using auxiliary fuel to heat the soil to a sufficient temperature (20). However, for more routine

operations, and particularly for commercial incineration, the cost of incinerating wastes with extremely

low organic content would probably be prohibitive.

Physical Form

Different incineration technologies have developed for handling the various physical forms (solid,

sludge, liquid, and gas) of hazardous organic wastes

(see ch. 5).

Incinerable wastes that are candidates for ocean

incineration generally fall into the category of liquid organic wastes. Only wastes in liquid form are

suitable for the liquid injection technology used by

all incineration vessels built or planned to date. Liquid injection technology has the advantage of large

capacity but can only handle wastes that can be

pumped and be introduced into the incinerator in

the form of small droplets.2

A significantly broader range of waste forms is

considered incinerable on land than at sea, because

land-based facilities can employ a broader range

of incineration technologies. Most commercial landbased incineration facilities use rotary kiln technology, which can incinerate organic solids and

sludges, as well as liquids (25). Some existing rotary kilns can even incinerate solid waste contained

in 55-gallon steel drums (l).

The presence of water in wastes can be either

an advantage or a disadvantage with respect to their

incinerability. Generally, aqueous (water-contain-

‘The term organic refers to chemical substances that possess a

molecular skeleton made of carbon and hydrogen and that generally

contain only a few other elements, such as nitrogen, oxygen, or chlorine. Inorganic materials are generally composed of or contain metals.

‘Certain solid or sludge wastes that can be suspended in liquid waste

to render them pumpable could also be incinerated at sea.

55
56 . Ocean Incineration: Its Role in Managing Hazardous Waste

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 amenable to incineration, because more energy is needed

to heat and evaporate the water. If an aqueous

waste also contains organic material with a very

high energy content, however, the presence of water

can actually prevent overheating and increase the

rate at which wastes can be incinerated.

Hazardous Constituents or Properties

The vast majority of incinerable liquid wastes are

subject to regulation as hazardous waste under the

Resource Conservation and Recovery Act (RCRA)

or certain State statutes. This designation may be

based either on the presence of particular toxic components or on a generic characteristic of the waste

(e.g., ignitability). In addition to incinerable wastes

classified as hazardous, a few nonhazardous liquid

wastestreams are amenable to incineration. For example, alcohol-based portions of some pharmaceutical and pesticide wastes are incinerable but not

classified as hazardous (l).

Liquid organic wastes are derived from a wide

variety of industrial processes and sources and,

therefore, can contain an enormous number of

chemical constituents. One profile undertaken by

EPA identified over 400 distinct hazardous wastestreams 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 under RCRA. Table 1 summarizes those constituents

that were most commonly found and those that

were incinerated in the greatest amounts.

A second EPA profile of existing hazardous waste

incinerators used RCRA hazardous waste codes (40

CFR 261, Subpart D) to classify wastes currently

being incinerated in land-based facilities. This study

(10) found that the most frequently reported wastes

were nonlisted ignitable (RCRA Code DOO1) with

high energy content and high concentrations of

hazardous constituents. The waste category representing the largest annual quantity of incinerated

waste, however, was spent nonhalogenated solvents

(F003). The next most common categories contained sufficient water to be considered aqueous

wastes. These included the following:

●

●

●

●

●

aqueous corrosives (DO02),

aqueous reactives (DO03),

aqueous ignitable (DOO1) with low energy

content and low concentrations of hazardous

constituents,

wastewater from acrylonitrile production

(KO11), and

hydrocyanic acid (P063).

Most of these aqueous wastes are considered

poorly suited for recycling and recovery and are

generated in quantities too large to be economically

shipped for offsite disposal. Therefore, the wastes

are generally managed—by using underground injection or, where possible, incineration—at the facilities where they were generated. Such wastes

would be unlikely candidates for ocean incineration.

Table 1 .—Most Common and Most Abundant

Chemical Constituents Found in

Incinerated Hazardous Wastestreams

Five constituents

Five most commonly incinerated in the

identified constituents greatest amounts

1. Toluene 1. Methanol

2. Methanol 2. Acetonitrile

3. Acetone 3. Toluene

4. Xylene 4. Ethanol

5. Methyl ethyl ketone 5. Amyl acetate

SOURCE: Mitre Corp., CornposWon of Hazardous Waste Streams Current/y

Incinerated, contract report prepared for the US. Environmental

Protection Agency, Office of Solid Waste (Washington, DC: April 1983),

Chlorine Content

Many liquid wastes considered especially amenable to ocean incineration contain relatively high

amounts of organically bound chlorine.

Energy content is inversely related to chlorine

content, which means that the heat value of wastes

decreases as chlorine content increases.

Thermal destruction of chlorinated wastes by incineration generates highly corrosive and toxic

hydrogen chloride gas. Land-based facilities are required to have air pollution control equipment (i. e.,

scrubbers) capable of removing and neutralizing

acid gases, if wastes with significant chlorine content are to be incinerated (47 FR 27520, June 24,

1982). The proposed Ocean Incineration Regulation (50 FR 8222, Feb. 28, 1985) does not require

the use of scrubbers on ocean incinerator vessels,

because of seawater’s natural capacity to neutralize hydrogen chloride gas, and because the vessels

operate far away from human populations. 3

Several factors act to place a practical limit on

the chlorine content of wastes that can be incinerated in land-based facilities, as discussed in chapter 1. These factors include:

●

●

●

limitations on the practical size and capacity

of scrubbers for removing hydrogen chloride

gas;

the increase in the quantity and corrosivity of

hydrogen chloride emissions as the chlorine

content of wastes increases, which can damage the incinerator or scrubber system; and

the generation of chlorine gas (1 3,28), which

is not efficiently removed by stack scrubbers

and could pose risks from direct inhalation by

nearby human populations.

For these and other reasons, the chlorine content of hazardous wastes can strongly influence the

range of available management options. Wastes of

intermediate chlorine content can in some cases be

burned in cement kilns and other industrial furnaces, where corrosive gases are directly used in

the production process. Although there appears to

be an enormous available capacity for burning such

wastes in these facilities, the reluctance of many fur-

~For a number of reasons, incineration of highly chlorinated wastes

at 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 relative lack of regulation and rigorous environmental

testing of the practice, and practical limits on

acceptable chlorine content, are obstacles to its

greater application (2,5,17). See chapter 4 for a

detailed discussion of the burning of hazardous

wastes in industrial boilers and furnaces.

Metal Content

In contrast to the organic component of hazardous wastes, metals are not destroyed by incineration. Metals present in waste fed to an incinerator

are either deposited in the ash residue left behind

in the chamber or emitted in stack gases. Most

metals that leave the incinerator stack are in the

form of particulate matter and can be captured by

stack scrubbers,4 Particulate and associated metals

are deposited in the sludge generated by the operation of the scrubber. Ash and sludge residues from

hazardous waste incineration are generally classi- (

fied as hazardous waste and must be handled accordingly.

Although metals are not destroyed by incineration, high temperatures can alter the physical and

chemical forms of metals, thereby affecting their

subsequent fate and behavior, For example, certain toxic metals (e. g., arsenic and selenium) are

volatilized (i. e., changed into gas form) during incineration and pass through particulate collection

devices (28). For this reason, wastes that contain

significant amounts of these toxic metals or that

have high overall metal content are not considered

appropriate for incineration.

Types of Ocean-Incinerable Wastes

Liquid organic wastes are derived from a wide

variety of industrial processes and sources. These

include activities or uses that: 1) contaminate materials so that they are no longer usable in the process (e. g., spent solvents); 2) produce wastes through

purification or recovery of desired products (e. g.,

distillation wastes resulting from solvent recovery

or chemical synthesis); 3) produce wastes through

‘Particulate matter may be composed of metals adsorbed onto dust

or soot particles, or actual small metallic fragments. Particulate matter can vary significantly in size, and small particles are captured much

less efficiently by air pollution control equipment than are large particles (l).

treatment or handling of other wastes (e. g., PCB

contamination of solvents used to clean electrical

transformers); or 4) result in products that do not

meet specifications and therefore must be discarded,

Four major categories of liquid hazardous wastes

are generally identified as primary candidates for

ocean incineration. These categories, their RCRA

classification designations, their primary uses, and

their industrial sources are listed in table 2. Special

materials or wastes, such as liquid PCBs, are also

candidates for ocean incineration. These wastes,

which are unique in many respects, are discussed

in box B. The four major liquid incinerable waste

categories are briefly described below (l).

Waste Oils

These result from the use of lubricants, greases,

and other petroleum specialty products. Waste oils

are used in a variety of ways because of their high

heat content and relative ease of reclamation. Waste

oil can be: 1) burned as fuel in boilers and furnaces;

2) used as auxiliary fuel for incineration; 3) rerefined for reuse in its original purpose; or 4) used

for dust suppression on roads (a declining practice

because of environmental concerns).

A well established and growing market for the

reuse of waste oils exists, along with a network for

the collection of waste industrial and commercial

transportation oils. Collection and reuse of waste

automotive oils from individuals is not yet an established practice but is on the rise. As indicated in

table 2 and discussed further in chapter 4, waste

oils are coming under RCRA regulation as hazardous waste. These regulations have the potential to affect the quantities of such wastes available

for incineration.

Nonhalogenated Solvents

Waste solvents are commonly generated as mixtures of solvents, including aromatic hydrocarbons,

ketones, alcohols, and esters. Many waste solvents

contain large amounts ( 10 to 50 percent) of water,

as well, although this is increasingly avoided

through process modifications. The wastes also typically contain significant amounts of suspended

solids, including organic and inorganic pigments

and heavy metals (lead, chromium, barium, copper, nickel).
Ch. 3—/ncinerable Hazardous Waste: Characteristics and Inventory ● 59

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

RCRA

Type of waste classification Primary uses Major sources

waste oils . . . . . . . . . . . . . . . . . a

Industrial lubricants Metal and service industries

Transportation oils

Nonhalogenated solvents . . . . DOO1, FO03-005 Painting, coating, cleaning operations Manufacturing

Halogenated solvents . . . . . . . FO01-O02 Cleaning and decreasing agents Manufacturing

Dry cleaning

Other 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 November

1965). Burning of waste fuel and used oil fuel in Industrial boilers and furnaces is currently exempted from regulation, although EPA plans to regulate this practice

under permit standards to be proposed in 1966.

SOURCE: Office of Technology Assessment

Nonhalogenated waste solvents are generally in

demand as fuel because of their high heat content

(greater than 10,000 Btu/lb). In addition, large

quantities of waste solvents are currently cleaned

through distillation for recycling or reuse.

Halogenated Solvents

Most halogenated5 solvents consist of chlorinecontaining compounds, with bromine- and fluorinecontaining compounds much less common. Waste

halogenated solvents are produced in the cleaning

and decreasing of metals, machinery, and garments, and hence commonly contain oils, greases,

dirt, and other solids. The dry cleaning industry

generates substantial quantities of waste perchloroethylene.

Halogenated solvents have a high initial economic value due to the expense of their production and, therefore, are commonly recovered

through distillation for reuse. Most halogenated solvents are not in demand as fuel, because they have

relatively low heat value (less than 5,000 Btu/lb).

In fact, their incineration often requires the use of

auxiliary fuel.

5 Halogens are a group of related chemical elements, which are

present in many organic chemical compounds. The group includes

fluorine, chlorine, bromine, and iodine.

Other Organic Liquids

A broad range of wastestreams with significant

organic content is generated by various industrial

processes used to manufacture or purify organic

chemicals. Typically each of the wastestreams is

homogeneous but may have a unique composition.

Many or most wastestreams created in chemical

production or purification are specifically listed as

hazardous wastes under RCRA, and are referred

to as “K” wastes. The wastestreams can contain

a very broad spectrum of hazardous constituents.

Organic, water, and halogen content, and thus heat

value, can also vary significantly.

Several techniques are available or being developed for separating the organic and aqueous fractions of these wastestreams, potentially allowing

greater or more economical use of incineration for

destroying the organic portion. Although organic

wastes mixed with water can be incinerated, the

energy requirements (and hence costs) of doing so

often increase dramatically as water content increases. However, for a waste whose organic portion has a very high energy content, the presence

of water can actually be used to advantage by reducing total heat output to avoid overheating of the

incinerator.

QUANTIFYING INCINERABLE WASTE

Waste Inventory

ample, many industrial wastewaters are composed

The absolute quantities of incinerable waste may of extremely dilute aqueous solutions of hazardous

not adequately reflect the degree of toxicity or haz- chemicals. In contrast, many incinerable wastes are

ard 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
62 . Ocean Incineration: Its Role in Managing Hazardous Waste
Ch. 3—Incinerab/e Hazardous Waste: Characteristics and Inventory ● 63

ardous wastes and, therefore, represent a much

larger fraction of the total toxicity attributable to

hazardous wastes than their absolute quantity indicates.

Total Hazardous Waste

Given that virtually all ocean-incinerable wastes

are classified as hazardous, the starting point for

estimating the quantity of such wastes is to examine the various inventories for hazardous waste generation. Unfortunately, no statistically reliable database exists to allow an accurate estimation of the

total generation of hazardous wastes. Studies vary

tremendously both in the definition of what constitutes hazardous waste and in methodologies for

data collection and analysis. In addition, all the

studies rely to some extent on sets of simplifying

assumptions and models. Although using such assumptions is probably essential for generating a

complete national profile, they represent another

major and inherent source of variability and uncertainty.

The most prominent (and most often cited) of

such studies is the so-called Westat mail survey,

which was completed for EPA’s Office of Solid

Waste in April 1984 (27). The Westat study estimated that 264 million metric tons (equivalent to

71 billion gallons) of hazardous waste were generated in the base year of 1981. This quantity is many

times larger than all previous estimates and is generally regarded to be far closer to the actual

quantity.

The Westat figure closely agrees with estimates

made by the Congressional Budget Office (21) for

the base year of 1983, using industrial output

models (see below), and by the Office of Technology Assessment (23) for the base year of 1981, using

data obtained from a survey of the States. This

agreement is somewhat surprising, in view of the

fact that the Westat survey was primarily designed

to determine numbers of waste generators and

treatment, storage, and disposal facilities, rather

than waste quantities.

Incinerable Hazardous Waste

Virtually all of the available national data on hazardous waste generation are aggregated by broad

industrial categories, rather than by specific waste

types. Consequently, the data are not useful in estimating the portion of hazardous waste that is incinerable. Moreover, even the basis for defining

a material as a waste is often far from clear. For

example, solvents are not always classified as waste

if they have the potential to be recovered. And

many States do not consider used oils as waste and

therefore do not require them to be recorded on

manifests, which means estimates of incinerable

quantities must be extrapolated from available data

on oil use and recovery (1).

Finally, many ill-defined technical, economic,

and regulatory limitations bound the universe of

incinerable wastes. These and other constraints

greatly hinder an accurate measure of how much

incinerable hazardous waste is generated annually.

This section discusses two studies that allow an

estimation of waste generation by waste type and

therefore help to bound estimates of the quantity

of incinerable waste. With respect to wastes suitable for ocean incineration, these studies suggest

that between 10 million and 21 million metric tons

(mmt) of liquid incinerable wastes are generated

on an annual basis in the United States.

A recent study by the Congressional Budget Office (CBO) (21) can be used to provide an upper

estimate of incinerable waste quantities. This study

estimates national generation of hazardous waste

in a manner that allows aggregation of the data under any of four classifications: 1) by Standard Industrial Classification (SIC) codes representing major industrial categories (e. g., chemicals and allied

products); 2) by waste type (e. g., halogenated liquids); 3) by method of treatment or disposal (e. g.,

deep-well injection); or 4) by State. Data derived

from EPA survey estimates (27) for a base year of

1983 are used to make projections for the year 1990.

The hazardous waste universe as defined by

CBO is significantly larger than that currently

regulated under RCRA. In particular, the CBO

definition includes waste oils, which are only now

being brought under RCRA regulation; PCBs,

which are regulated under the Toxic Substances

Control Act (TSCA); and industrial scrubber sludges,

air pollution control dusts, and certain other liquid hazardous wastestreams, which EPA is currently studying for possible future regulation under RCRA.
64 • Ocean Incineration: Its Role in Managing Hazardous Waste

Several additional features of the CBO study

warrant discussion, as they introduce some uncertainty into the resulting estimates of waste generation. Because comprehensive and statistically reliable raw data on which to base waste generation

estimates were generally lacking, CBO developed

a computer-based model of hazardous waste generation derived from data on industrial output for

70 industrial categories. 12 ThiS approach assume d

that specific industries generated particular types

of waste at measurable rates. These generation rates

were assumed to result from three factors: industrial output (measured by employment directly related to production, on an industry-by-industry basis), process technology, and production efficiency.

Estimates of future waste generation were then derived from projections of growth in industrial

employment. CBO found that statistics on employment growth were the only comprehensive and consistent set of industry-specific projections available.

Because such statistics only indirectly reflect waste

generation, however, a degree of uncertainty was

introduced into the resulting estimates (21).

In addition to attempting to account for changes

in waste generation resulting from changes in industrial output, CBO also estimated changes due

to the application of waste reduction, recycling, and

recovery practices. CBO’s projected estimates of

the levels of recycling and recovery that could be

expected by 1990 were based on information obtained directly through surveys of industrial waste

generators and the waste recovery industry. These

estimates were then applied to the waste generation estimates, which were derived using the CBO

model.

Estimating the future extent of waste reduction

is extremely difficult, given the current lack of data

and the absence of an accepted and appropriate

means of measuring waste reduction (24). For this

reason, CBO’s analysis did not consider the full

range of approaches that might be used to reduce

waste. CBO’s estimates, therefore, probably understate the potential for reduction. However, although an enormous amount of waste reduction is

possible, many obstacles remain (24).

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

Despite these potential shortcomings, the CBO

effort represents the only available source of comprehensive waste generation data that is aggregated

on the basis of specific waste types, which is essential for estimating quantities of incinerable wastes.

Given its limitations, the CBO data maybe best

used to derive an upper estimate of incinerable

waste generation. Waste generation data are first

aggregated by waste type to allow estimation of the

quantities of waste generated in those categories that

could be managed through incineration. These data

are then adjusted downward to account for the

levels of recycling, reuse, and recovery that currently take place in each waste category, as estimated by CBO. Finally, separate aggregation of

data for liquids versus solids and sludges provides

an estimate of quantities of waste that are oceanincinerable (liquids) and waste that could only be

incinerated on land (solids and sludges). Table 3

presents the estimates derived using such a procedure.

The numbers presented in table 3 should be

taken as an upper bound for the following reasons:

●

●

●

●

●

It is unlikely that all of the wastes in each category are physically or economically suitable

for incineration.

Current market factors dictate the use of less

expensive disposal practices (e. g., underground injection) even for clearly incinerable

wastes.

Other competing fuel uses, particularly for

wastes with high energy content, reduce quantities available for incineration.

Many incinerable wastes are extensively recovered, reused, or recycled (see column 2 in

table 3), and the application of such practices

is growing due to clear economic incentives.

Application of other treatment methods (e.g.,

chemical detoxification of PCBs) and waste reduction practices to some incinerable wastes

is likely to increase in the near future.

Even with these limitations, the CBO data indicate that large quantities of the hazardous waste

generated annually could be incinerated, either on

land or at sea. This upper estimate indicates that

as much as 47 mmt per year, or about one-fifth of

all hazardous wastes not currently recovered or

recycled, 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 after

Type of waste (mmt) RECYC/RECOVa RECYC/RECOVa (mmt)

Liquids:

Waste oils . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14.25 1 1 % 12.68

Halogenated solvents. . . . . . . . . . . . . . . . . . . . . . . . 3,48 70 1.04

Nonhalogenated solvents . . . . . . . . . . . . . . . . . . . . 12.13 70 3.64

Other organic liquids . . . . . . . . . . . . . . . . . . . . . . . . 3.44 2 3.37

Pesticides/herbicides . . . . . . . . . . . . . . . . . . . . . . . . 0.026 55 0.012

PUBS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 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

0.72

2.24

4.24

3.73

9.78

4.58

4.02

380/o

o

0

0

5

0

0

65

20.74

0.72

2.24

4.24

3.54

9.78

4.58

1.41

Total sludges/solids . . . . . . . . . . . . . . . . . . . . . . . 29.31 10% 26.51

Total incinerable wastes . . . . . . . . . . . . . . . . . . . 62.64 25% 47.25

Total hazardous wastes . . . . . . . . . . . . . . . . . . . . . . 265.60 6% 249.28

All 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 on

land or at sea. In contrast, only an estimated 2.7

mmt—slightly more than 1 percent of all hazardous waste generated in the United States and less

than 6 percent of all wastes that could have been

incinerated —were incinerated in 1983 (21).

Table 3 indicates that very different quantities

of the four major categories of ocean-incinerable

waste were generated. CBO estimated that waste

oils and nonhalogenated solvents were generated in

amounts about four times higher than were halogenated solvents and other organic liquids. After

accounting for current levels of recycling, however, waste oils were predominant, and waste halogenated solvents represented the smallest category.

A second study, conducted under contract to

OTA, provides a lower bound on the quantities of

incinerable hazardous wastes generated nationally

on an annual basis. Arthur D. Little, Inc. (1) has

developed estimates of liquid organic hazardous

wastes based primarily on data derived from biennial State hazardous waste reports to EPA for the

year 1983. These data were aggregated by RCRA

hazardous waste codes (40 CFR Part 261, Subpart

D) but also include additional wastes considered

hazardous under State regulations.

The ADL estimates provide a lower bound on

the quantities of incinerable hazardous waste, for

the following reasons:

●

●

The ADL inventory included only those

RCRA categories designating wastes that were

essentially 100 percent incinerable, including

—DOO1 (ignitable wastes),

—FOO1-FO02 (halogenated solvents), and

—FO03-FO05 (nonhalogenated solvents).

The inventory excluded several other categories that contain potentially significant quantities of incinerable wastes, because the incinerable fraction could not be estimated. Excluding

these categories undoubtedly means a significant underestimation of total incinerable waste

quantities. The categories include:

—DO02 (corrosive wastes),

—DO03 (reactive wastes),

—K wastes (wastes from specific sources),
66 . Ocean Incineration: Its Role in Managing Hazardous Waste

—P wastes (wastes containing acutely hazardous compounds), and

—U wastes (wastes containing toxic compounds).

● Certain wastes that were managed onsite were

specifically excluded from the State reports.

These include wastes burned as fuel in industrial boilers and wastes recycled at the facilities where they were generated. Many such

wastes are not required to be reported as waste

under existing regulations.

● Data that could be used to determine quantities of incinerable liquid wastes generated in

1983 were not available for six States.13

ADL’s lower bound estimate for the quantity of

incinerable liquid wastes in these categories (which

exclude waste oils) is 5.8 mmt annually. This can

be compared to the somewhat higher CBO estimate

of 8.1 mmt (see table 3).

The ADL analysis also included an examination

of the use and disposition of waste oils. Of the estimated 2.1 billion gallons annually used in the

United States, ADL estimated that about 1 billion

gallons are consumed in use, leaving 1.1 billion gallons currently divided between disposal and various forms of reuse (burning as fuel, reclamation,

asphalt conditioning, and dust control). This quantity is equivalent to about 4.2 mmt of waste oil annually, which is significantly lower than the 12.7

mmt of waste oil estimated by CBO. The reasons

for this large discrepancy are unclear. Both studies,

however, estimated that waste oils constitute just

over 40 percent of all liquid wastes generated.

In sum, ADL conservatively estimated that a

minimum of about 10 mmt of incinerable liquid

waste suitable for ocean incineration is generated

annually in the United States.

Industries Generating Incinerable Waste

Most incinerable waste is generated by a few major industries. CBO has estimated the amounts of

various waste types contributed by industries in

each of 12 SIC codes representing major industrial

classifications (U.S. Congress, Congressional BudlsThe 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 of

incinerable wastes.

get Office, unpublished data). For each of the four

major categories of incinerable liquids, figure 1

shows the industries that together contribute over

90 percent of the wastes. With respect to total hazardous waste generation, the list includes industries

that are major (chemicals and petroleum/coal) and

minor (wood preserving and motor freight transportation) contributors (21).

Geographical Distribution of

Waste Generation

For both total and ocean-incinerable hazardous

wastes, CBO’s data allows an estimation of generation rates for 1983 on a State-by-State basis. A

regional distribution profile for hazardous waste

generation can be developed by adding the estimates for the States comprising each EPA Region.

Table 4 presents such a regional profile, and table

5 lists the 10 States in which the most ocean-incinerable hazardous waste is generated. Figure 2 shows

the proportion of ocean-incinerable wastes generated by each State in the Nation.

As is apparent from figure 1, the great majority

of ocean-incinerable hazardous wastes is generated

by the petroleum and chemical industries. Figure

2 indicates, not surprisingly, that at least half is generated along either the Gulf Coast (primarily from

petroleum refining) or the Middle Atlantic Coast

(primarily from chemical industries) .14 These conclusions are consistent with a comparable analysis

performed for OTA using data submitted by the

States to EPA in their biennial reports (l).

Thus, a large portion of ocean-incinerable waste

would not have to be transported great distances

to reach potential ocean incineration port facilities.

Moreover, this geographical distribution is consistent with EPA’s designation of an ocean incineration site in the Gulf of Mexico, and its proposal

for a site located off the Middle Atlantic Coast.

Projections of Future Waste Generation

Projections of future generation of hazardous

waste and of liquid organic hazardous waste require

the use of assumptions that can drastically affect

the resulting estimates. One common approach to

i +According t. the CBO data, Texas done produces nearly onequarter of all such liquid wastes (see table 5).
Ch. 3—lncinerable Hazardous Waste: Characteristics and inventory . 67

Figure 1.—Major Industries Generating Wastes

Suitable for Ocean Incineration

WASTE OILS

Chemicals

Other (1 O/.)

(88”/0)

SOURCE: Office of Technology Assessment, based on U.S. Congress, Congressional Budget Office, Hazz?~ous Waste Marragernent: Recenr Changes

and Po/icy A/kwratives (Washington, DC: U.S. Government Printing

Office, 1985); and unpublished data.

formulating such projections, therefore, is to design a number of scenarios based on various reasonable sets of assumptions, in the hope of at least

bounding the problem. However, estimates derived

by such an approach carry a degree of uncertainty

that render their use in a policy setting problematic.

Given existing deficiencies in the data on which projections must be based, uncertainty is an inherent

problem that must be borne in mind when considering any projection of waste generation.

Such projections must also reflect recent changes

in the regulatory environment surrounding hazardous waste management. As a result, many additional data gaps and sources of uncertainty are introduced. For example, in adjusting estimates to

account for the effect of the land disposal restrictions contained in the 1984 RCRA Amendments

(22), assumptions are required about the schedule

and extent of their implementation and the anticipated responses of generators and handlers of affected wastes.

The Congressional Budget Office (21 ) has estimated the quantity of hazardous waste that will be

generated and that will require disposal or treatment in 1990. These projections, which are aggregated by waste type, can be compared with the

quantities generated in 1983. The projections assume that EPA will meet the land disposal deadlines specified in the 1984 RCRA Amendments,

which are scheduled to be largely implemented by

that time. 15

CBO’s projection model takes into account two

additional variables that could significantly influence the quantities of wastes requiring disposal or

treatment in 1990:

1. the extent and effect of waste recovery and

recycling activities undertaken by industry; 16

and

15CB0 indicates that this assumption is perhaps over]y optimistic

but that any other assumption would be arbitrary. To the extent that

the implementation schedule is delayed, use of undesirable land practices will continue, Moreover, many of the specified deadlines are contingent 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 which

to base such an analysis is unavailable.
68 ● Ocean Incineration: Its Role in Managing Hazardous Waste

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

EPA Total Percent Ocean-i ncinerable Percent

region 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 8.3

Iv Al, FL, GA, KY, MS, NC, SC, TN . . . . 39.11 14.7 3.16 9.5

v 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 35.4

VII 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 3.6

lx AZ, CA, Hl, NV. . . . . . . . . . . . . . . . . . . 18.51 7.0 3.41 10.3

x AK, ID, OR, WA . . . . . . . . . . . . . . . . . . 7.71 2.9 0.79 2.4

Totals. . . . . . . . . . . . . . . . . . . . . . . . . 265.60 mmt 33.22 mmt

SOURCE: 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 of

Ocean-Incinerable Hazardous Waste, 1983

Percent of all

Quantitv ocean-i ncinerable

State (mt/yr)-

hazardous waste

Texas . . . . . . . . . . . . . . . .

California. . . . . . . . . . . . .

Louisiana. . . . . . . . . . . . . 1 Pennsylvania. . . . . . . . . .

Illinois . . . . . . . . . . . . . . .

New Jersey . . . . . . . . . . .

Ohio . . . . . . . . . . . . . . . . .

Oklahoma . . . . . . . . . . . .

Indiana. . . . . . . . . . . . . . .

Michigan . . . . . . . . . . . . .

7,723,175

3,199,166

2,468,357

1,846,652

1,782,197

1,674,352

1,304,503

1,051,550

977,969

805,882

23.20/o

9.6

7.4

5.6

5.4

5.0

3.9

3.2

2.9

2.4

68.6%

SOURCE: Office of Technolow Assessment, baaed on U.S. Coww% cOuveSsional Budget Offlce~ Hazardou s Waste A4arqpment.’ Recent Changes

and Po/lcy A/tematkea (Washington, DC: U.S. Government Printing

Office, 19S5); and unpublished data.

2. changes in baseline waste generation due to

expected increases or decreases in the production activities of particular industries, in response to both general and industry-specific

economic factors.

Thus, for a given waste category, each of the

above factors contributes to any changes predicted

to occur between 1983 and 1990.

Expected changes in total hazardous waste generation and in individual waste categories are presented in tables 6 and 7. The summary in table 6

presents CBO’s data for the broad categories of incinerable wastes (liquids versus solids and sludges)

and nonincinerable wastes, and indicates how both

waste recycling/recovery and changes in waste output affect the projected net change in waste quantities. Table 7 presents a more detailed examination of CBO’s data aggregated by individual waste

type.

Two major trends are apparent from these data.

First, CBO predicts that waste recovery and recycling activities will only modestly decrease the quantities of potentially incinerable wastes. As shown

in column 8 of table 6, the greatest effect of waste

recovery and recycling will be on nonincinerable

wastes. These data predict that the decrease in

amounts of nonincinerable wastes due to increases

in waste recovery and recycling activities will be

almost 15 times greater than the decrease in incinerable liquids (44 mmt versus 3 mmt). A few particular waste types, such as metal-containing liquids, will account for a large portion of the decrease

in nonincinerable wastes (see table 7).

This trend becomes even more apparent when

the actual quantities of wastes expected to be recovered or recycled in 1990 are compared with the

figures for 1983 (table 6). For nonincinerable

wastes, almost 45 mmt is projected to be recovered

or recycled in 1990, whereas less than 1 mmt is estimated to have been recovered or recycled in 1983.

However, the projection for incinerable wastes is

about 20 mmt for 1990, only a modest increase over

the 15 mmt recovered or recycled in 1983.17

A second trend indicated by these data is that

the two factors discussed above—changes in waste

generation and the limited application of waste reI 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 column

2 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/ternatlves (Washlrtgton, DC: U.S. Government Printing Office 19S5), and unpublished data.

covery and recycling to incinerable wastes—will

both slightly alter the relative amounts of liquids

versus solids and sludges generated in 1990. The

CBO data (table 6, column 9) predict that the quantities of incinerable solids and sludges will slightly

increase between 1983 and 1990 (by about 1 mmt),

whereas the quantity of incinerable liquids will

slightly decrease in quantity (by about 3 mmt). Despite these changes, CBO projects that waste in both

categories will continue to be generated in quantities that greatly exceed our current incineration capacity for them.

Several other sources, including evaluations of

future hazardous waste management needs undertaken by a number of States, support the conclusions drawn from this analysis of the CBO data.

Two of the sources will be discussed here to lend

further support to these conclusions.

The Minnesota Waste Management Board (11)

projected that, because of economic growth, Minnesota’s generation of wastes in 14 representative

categories would increase substantially by the year

2000, even under the State’s “high waste reduction alternative. This scenario assumed that

wastes would be reduced as much as possible and

recycled whenever they had resource recovery potential. 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 applied to include recovery and recycling activities as well as source reduction.
Table 6.-Hazardous Waste Generation in 1983 and 1990: Effect of Recycling and Recovery on

Waste 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 on

Waste Quantities Requiring Treatment or Disposal, Comparison by individual Waste Type8

1983 1990 Percent change

Quantity after Quantity after in quantity after

Percent waste RECYC/RECOV Percent waste RECYC/RECOV RECYC/RECOV

Type of waste RECYC/RECOV (mmt) RECYC/RECOV (mmt) 1983-1990

Incinerable wastes:

Liquids:

Waste oils . . . . . . . . . . . . . . . . . . . . . . . . 11 ”/0 12.68 15 ”/0 11.84 –6.60/0

Halogenated solvents . . . . . . . . . . . . . . 70 1.04 80 0.76 –26.9

Nonhalogenated solvents . . . . . . . . . . . 70 3.64 80 2.37 –34.9

Other organic liquids. . . . . . . . . . . . . . . 2 3.37 25 2.82 – 16.3

Pesticides/herbicides . . . . . . . . . . . . . . 55 0.012 70 0.008 –33.3

PCBs . . . . . . . . . . . . . . . . . . . . . . . . . . . . 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 –5.6

o 2.24 0 2.48 + 10.7

0 4.24 25 3.08 –27.4

5 3.54 10 3.20 –9.6

o 9.78 0 11.56 + 18.2

0 4.58 0 5.23 + 14.2

65 1.41 70 1.38 –2.1

10 26.51 14 27.61 +4.2

25 47.25 31

2

2

0

0

0

0

0

5

0

0

0

19.36

7.24

82.26

14.50

0.56

28.06

5.46

7.34

21.12

0.72

15.41

70

75

20

10

15

5

0

15

10

5

5

<1 202.03 21

6 249.28 23

45.41

5.99

1.82

71.93

13.63

0.50

26.77

5.75

6.90

19.99

0.78

15.92

169.98

215.39

–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

– 13.7

asee 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 into

vides these projections for several categories. the foreseeable future.

The data from the Minnesota analysis support

the conclusions drawn by the CBO study:

● a net increase will occur in future quantities

of incinerable wastes, including liquids, even

after accounting for waste reduction;

● the application of waste reduction, recycling,

and recovery practices will be greater for nonincinerable wastes than for incinerable wastes;

and

The New Jersey Hazardous Waste Facilities

Siting Plan (5) estimated the effect of waste reduction on the quantities of various types of hazardous wastes that are sent offsite for treatment or disposal. Baseline quantities were projected for 1988,

and then adjusted to account for the anticipated extent of waste reduction. Table 8 shows the data for

several major categories of incinerable and nonincinerable hazardous waste.
72 ● Ocean Incineration: Its Role in Managing Hazardous Waste

Table 8.—Two State Estimates of Future Hazardous Waste Generation and Extent

of Waste Reduction (all quantities in thousands of metric tons)

Minnesota

Baseline Downward Net change

projection adjustment for in quantity

for 2000 waste reduction over 1982

lncinerable:

Solvents/organic liquids . . . . . 33 +7

Oils and greases . . . . . . . . . . . 75 –22 –3

Organic sludges/bottoms. . . . 8 0 +2

Nonincinerable:

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

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

New Jersey

Baseline Downward Net change over

projection adjustment for average quantity

for 1988 waste reduction for 1981 to 1983

incinerable:

Organic liquids . . . . . . . . . . . . 95 0 +35

Solvents . . . . . . . . . . . . . . . . . . 34 –4 +2

Oils . . . . . . . . . . . . . . . . . . . . . . 69 –3 +5

Nonincinerable:

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

All offsite waste . . . . . . . . . . . . . . . . . 418 –30 +41

SOURCES: 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 sent

offsite also supports the same general conclusions

as the CBO study: most waste reduction will be applied to nonincinerable wastes, and even after accounting for such activity, large and increasing

quantities of incinerable (as well as nonincinerable) waste will require treatment.

Onsite Versus Offsite Management of

Hazardous Wastes

Another important distinction to be made in discussing quantities of waste likely to require treatment or disposal is whether waste management

activities occur within the facility at which wastes

were generated (onsite), or at a separate, typically

commercial, facility (offsite). Each of these waste

management strategies poses its own special advantages, requirements, and risks. For example, offsite management introduces the added burdens of

transportation and recordkeeping, although inspection and enforcement are generally accomplished

more easily at offsite facilities.

Whether a waste generator decides to manage

its wastes onsite or offsite largely depends on the

size of the generator. Some generators can realize

economies of scale sufficient to make investment

in onsite facilities attractive, and others generate

wastes in quantities too large to make offsite transport practicable; small generators typically find it

more cost-effective to ship wastes to commercial facilities for treatment or disposal. The onsite versus

offsite distinction is especially relevant to ocean

incineration, which is by definition offsite.

The majority of all hazardous waste is disposed

or treated onsite, although available estimates vary

over a considerable range. The Westat survey (27)

and the CBO study (21) estimated that less than

5 percent of all hazardous waste was managed or

disposed of offsite. Interestingly, a number of State

or regional analyses found that a somewhat larger

proportion was managed offsite. For example, Minnesota’s data indicated that at least 15 percent of

its hazardous waste was managed offsite (1 1). Two

New Jersey studies reached disparate estimates:

One study (5) suggested that only a small percentage of all waste was sent offsite; lg the other (28) inlgrf Wastewater Were excluded from this calculation, an estimated

25 percent would be sent offsite.
Ch. 3—lncinerable Hazardous Waste: Characteristics and Inventory • 73

dicated that 26 percent of New Jersey’s hazardous

waste was sent for offsite disposal or treatment. A

recent study of hazardous waste management in

New England found that the region’s waste was

divided almost evenly between onsite and offsite

management (14).

Unfortunately, none of these data concerning

on/offsite distribution was aggregated by waste

type, which precludes a separate evaluation for

those wastes with potential for incineration at sea.

However, other data suggest that most liquid organic hazardous wastes are managed onsite. The

Westat survey (27) found that about 0.9 mmt of

liquid organic hazardous wastes was incinerated in

land-based facilities in 1981, and that 98 percent

of this activity took place onsite. And the EPA market analysis (26) found that at least 90 percent of

current incineration of liquid wastes took place in

private onsite facilities.

Current land-based incineration of all forms of

hazardous waste follows a similar distribution: In

1983, 210 to 250 onsite hazardous waste incinerators managed an estimated 2.4 mmt, and about 30

offsite incinerators managed about 0.4 mmt (2, 10,

19,21).

Considerable uncertainty surrounds projections

of onsite versus offsite waste management and,

more specifically, incineration. It is not known

whether, and to what extent, waste generators facing restrictions on land disposal options will choose

(or will be able) to develop additional onsite capacity

or will instead send more waste to commercial facilities. Clearly, the future market for ocean incineration will be influenced to a large degree by such

decisions.

Several studies have estimated potential shifts in

onsite versus offsite treatment and disposal. CBO

(21) projected that the quantity of all hazardous

waste sent offsite will roughly double from 1983 to

1990. The magnitude of this shift depends on

whether the 1984 RCRA restrictions on land disposal are implemented according to schedule; if delays occur, the increase in offsite treatment would

be more gradual. CBO indicated that the trend

toward offsite treatment would be particularly

strong for wastes that can be incinerated or chemically treated, and that existing capacity in these

technologies could be surpassed easily.

A considerably less dramatic shift is forecast by

the majority of respondents to an EPA survey of

selected commercial hazardous waste management

firms (8). According to these respondents, changes

in the level of offsite treatment and disposal would

be limited at most to a ‘ ‘small (perhaps 4 to 6 percent), short-term pulse, ‘‘ primarily because of facility closures under new RCRA restrictions .20 Furthermore, they expect that offsite shipment of

wastes will eventually decline as waste reduction

practices are implemented. A minority of respondents to the survey, however, predicted a larger increase of 10 percent or more in response to RCRA

restrictions and also argued that ‘‘generators have

already exhausted most of their options to reduce

waste volumes.

Capacity of and Demand for Offsite

Treatment Facilities

The shifting of waste from onsite to offsite treatment is only one of several factors that contribute

to the overall demand for commercial treatment facilities. Other factors include:

●

●

●

●

an increase in actual waste generation, because

of economic growth;

changes that result from new regulatory controls, such as more stringent regulations that

govern the burning of hazardous waste in

boilers, restrictions on the use of land disposal

practices, or increased implementation and enforcement of effluent guidelines;

closure of existing facilities that are unable to

comply with new regulations or unwilling to

incur the additional costs of compliance; and

cleanup of uncontrolled hazardous waste disposal Sites.

Several countervailing factors also may affect

overall demand:

. an increase in the capacity of existing facilities,

whether they are private or commercial;

ZOSOme obSeNerS have questioned the reliability of information obtained from existing commercial hazardous waste firms, arguing that

these firms have a strong self-interest in downplaying any future need

for additional facilities. Aside from this issue, whether such a survey

is representative of the industry is questionable; indeed, EPA cautions readers that ‘ ‘no statements can be made about the entire commercial hazardous waste management industry from this small sample” (8).
74 . Ocean Incineration: Its Role in Managing Hazardous Waste

increasing waste or volume reduction by

generators that are seeking to minimize the

amounts of waste requiring offsite treatment;

and

increasing use of mobile treatment facilities

that are designed to treat wastes at the site of

generation.

Each of these factors is very difficult or impossible to assess in any quantitative manner. Nevertheless, several States attempted to account for these

factors in studies of future demand for offsite treatment capacity. 21 Virtually all of these studies projected a substantial growth in the demand for offsite capacity into the foreseeable future, although

estimates of the magnitude of growth varied considerably.

The studies also support the corollary that a

shortfall between offsite treatment capacity and demand is expected if substantial growth in existing

capacity does not occur. 22 Given this, capacity could

be increased by: 1) developing new facilities, or

2) expanding capacity at existing facilities. Although

both of these avenues are being pursued, progress

has been very slow:

● The firms surveyed in the EPA study (8) have

generally abandoned plans to develop new facilities, because of local public opposition and

because operating permits cannot be obtained

without a minimum delay of several years.

● Some of these firms indicated plans to expand

their incineration and other treatment capacity

at existing facilities; however, they again cited

significant delays in obtaining permits as a major obstacle, and argued that “stretching out

existing capacity can only go so far. Eventually, new sites must be brought on-line. ”

● CBO (21) indicated that—at the current rate

of permitting for hazardous waste treatment,

zl~e= in~ude efforts undertaken in Missouri, New Jersey (5), New

York, North Carolina, and Pennsylvania. References and more

detailed analyses of these studies are presented in ref. 24.

22 For examp]e, the Minnesota Waste Management Board (11) concluded that ‘‘there is not sufficient capacity at the present time to treat

all of the hazardous wastes amenable to treatment in the United States.

As increasing emphasis is put on treatment as an alternative to disposal of hazardous wastes, there may be an overall shortage in treatment capacity. Another observer indicated that ‘‘little growth of available commercial incineration capacity may be expected over the short

term. A three- to five-year delay is possible before significant new capacity could be available” (17).

●

storage, and diposal facilities—7 to 10 years

would be needed to issue the final permits that

these facilities must have to continue operating. 23

In a survey of private (onsite) treatment facilities in New Jersey, facility owners expressed

very little interest in expanding capacity and/or

commercializing their operations to help meet

the projected shortfall in treatment capacity

(5).

This discussion illustrates that the magnitude of

the expected shortfall in offsite hazardous waste

treatment capacity is exceedingly difficult, if not

impossible, to estimate. Despite this, the demand

for such capacity clearly will increase. The next section addresses these same issues with a focus on projecting the use of and demand for incineration capacity.

Future Use of and Demand for

Incineration Capacity

Numerous studies have indicated that the actual

use of and demand for incineration technologies to

manage hazardous waste will increase significantly

(1 ,5,8,16,17,21 ,28). This trend is a reflection of the

ability of these technologies to destroy the organic

portion of wastes and significantly reduce waste

volume:

Thermal destruction systems have become recognized over the past decade as an increasingly

desirable alternative to the more traditional methods of disposing of hazardous wastes in landfills,

lagoons, and injection wells (17).

As one example of these studies, CBO (21) projected that incineration of hazardous wastes would

triple or quadruple (from 2.7 mmt in 1983 to 8.2

to 11.6 mmt in 1990). The higher estimate assumed

that no waste recycling and recovery beyond current levels would be undertaken; the lower estimate

assumed that waste recycling and recovery efforts

would achieve the level reflected in tables 6 and 7.

CBO also indicated that the increased use of incineration would be the single largest change in the

use of all hazardous waste management technolZ’)section z 1s of the 1984 RGRA Amendments requires that d] incineration 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 be

used to manage organic liquid, sludge, and solid

wastes.

The EPA survey of commercial hazardous waste

management firms (8) also revealed that increased

quantities of waste were being directed toward incineration, a phenomenon clearly attributed by the

respondents to the first effects of the new RCRA

restrictions on land disposal. At least for the portion of the commercial market represented by this

survey, waste quantities received for incineration

were increasing at a faster rate than incineration

capacity .24

The survey respondents argued that future increases in demand for incineration capacity would

be primarily for organic solids and sludges, and that

liquid capacity was sufficient and would probably

remain so. Unfortunately, no data were presented

that indicated the relative quantities of the different physical forms of incinerable waste that were

received .25

Attempts To Project the Future Market for

Ocean Incineration

As part of EPA’s ‘‘Assessment of Incineration

as a Treatment Method for Liquid Organic Hazardous Waste, Booz-Allen & Hamilton, Inc., conducted an analysis of the near-future commercial

market for incinerable liquid wastes. The study (26)

was intended to directly quantify the potential size

of the ocean incineration market. The analysis,

however, was complicated by a set of constraints

beyond those confronting the studies cited above.

Because the study focused on the commercial sector of the incineration industry, assumptions had

to be made regarding, for example, the relative

proportion of incinerable wastes to be managed onsite versus offsite, and the contribution of commercial land-based incineration and other facilities to

the overall market picture for incinerable liquid

wastes,

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

zsAs discussed Previously, incinerable liquids are often in demand

because of their fuel value, Receiving these wastes from generators

is clearly attractive to commercial incineration firms, because burning them reduces the need to use auxiliary fuel when burning solids

and sludges that have a lower energy content. Thus, separate discussions of liquid capacity and solids and sludge capacity do not appear

to be particularly meaningful.

The result was a study that has been criticized

as being statistically unreliable and as failing to account sufficiently for the use of technologies other

than incineration. EPA indicated that the study did

not (and was not intended to) fulfill the requirement for EPA to conduct a formal needs assessment

for ocean incineration, as specified under the Marine Protection, Research, and Sanctuaries Act.

Rather, the study was intended to serve as a general indicator of the size of the potential shortfall

in commercial liquid incineration capacity, in support of EPA’s contention that there maybe a need

for ocean incineration. (For a fuller discussion of

uncertainties inherent in the market study, see refs.

4,15,26,29).

Despite its flaws, EPA’s incineration market

assessment was generally consistent with virtually

all other available studies. The major finding predicted a significant and growing shortfall in incineration capacity as a result of: 1 ) increases in the

quantities of wastes generated and available for incineration, and 2) very slow development of capacity in incineration and other technologies for managing such wastes.

EPA’s market analysis (26) projected the potential demand for ocean incineration based on a quantification of the shortfall in future commercial incineration capacity for liquid wastes. 2G A range of

projections was derived under scenarios involving

implementation of one or more of the land disposal

restrictions embodied in the 1984 RCRA Amendments. Assuming full implementation of all of the

RCRA restrictions, a range was estimated for the

quantity of excess liquid waste that would be shifted

away from land disposal. Managing the quantity

of wastes at the midpoint of that range would require 33 incinerator ships with a capacity of 50,000

mt per ship per year (or 82 additional land-based

incinerators at 20,000 mt per year).

This midpoint projection would represent an increased demand for commercial liquid waste incineration capacity of 1.65 mmt annually. 27 As

would be expected, CBO’s estimate of the increase

ZGThis finding has been contested by land-based incineration companies (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 to

51 incinerator vessels, or 38 to 128 land-based incinerators. The extent of this range is one indicator of the degree of uncertainty accompanying such projections.
76 ● Ocean Incineration: Its Role in Managing Hazardous Waste

in total use of incineration (i. e., both commercial

and private facilities burning liquids, sludges, and

solids) was higher, by a factor of 3 to 5.28 Thus,

despite major differences in methodology and somewhat different estimates, these two studies were

roughly consistent; both supported the conclusion

that, in the near future, there will be increased demand for capacity to manage liquid incinerable

wastes.

EPA’s market analysis cast its results in terms

of a specific demand for liquid incineration capacity. A more neutral statement of the result, however, is that the capacity to manage incinerable

wastes is expected to fall short of demand. This

shortfall could (and likely will) be addressed in a

number of ways. For example, development of

ocean incineration capacity or expansion of landbased incineration capacity or both could help to

meet this demand. Alternatively, it could be partially met by other means now used for a portion

of these wastes—including chemical treatment,

recycling and recovery, and use as fuel in industrial boilers and furnaces. Finally, the quantities

of waste requiring treatment could be decreased

through increased application of waste reduction

practices. Accurately estimating the future use of

any of these technologies is highly complex, if not

impossible.

Thus, a future need for ocean incineration (or

land-based incineration, or any other hazardous

waste management technology) may never be unequivocally demonstrated or quantified from an

analytical standpoint. Nevertheless, given the generally acknowledged shortfall in our present and

future capacity to manage incinerable wastes, the

development of several options will likely be necessary.

Other Factors Affecting Future Waste

Generation and Management

The two most important variables with respect

to hazardous waste generation and management in

the near future appear to be: 1) the extent and

ZfICBO>S range Was 8.2 m 11.6 mmt annually. After accounting for

current use of incineration at 2.7 mmt annually, this would represent an increase of 5.5 to 8.9 mmt annually. Thus, compared to the

EPA 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 from

land disposal) as well as future changes in the

RCRA definition and classification of hazardous

wastes (e. g., for waste oils); and 2) the extent of

application of new and emerging waste reduction,

reuse, and recovery technologies and strategies.

In addition to banning some wastes from land

disposal, two other changes in RCRA resulting

from the 1984 amendments will increase the quantities of hazardous waste by bringing heretofore unregulated wastestreams or generators under RCRA

authority:

1,

2.

Exemptions for hazardous wastes or used oils

burned as fuel are being removed, and new

regulations governing their blending, burning, and recycling for reuse are mandated.

CBO (21) estimated that, in 1983, significantly more hazardous waste was burned in

RCRA-exempt industrial boilers and furnaces

than was incinerated (9.5 mmt versus 2.7

mmt). EPA estimated that 3.4 to 5.4 mmt of

hazardous waste and used oils are burned annually in industrial boilers (50 FR 1684, Jan.

11, 1985). See chapter 4 for a detailed discussion of this topic.

The waste level below which generators are

exempted from regulation has been reduced

from 1,000 to 100 kilograms per month, thereby greatly increasing the number of regulated

small generators; EPA (50 FR 31285, Aug.

1, 1985) estimated that the number of RCRAregulated generators would increase from the

current 14,000 to a total of 175,000, but that

these small generators account for only about

760,000 metric tons per year of hazardous

waste (much less than 1 percent of the national

total).

Conversely, new RCRA requirements for implementing waste reduction and detoxification programs and increasing industrial efforts aimed

toward waste reduction, recycling, and recovery

would be likely to moderate or reduce future hazardous waste generation. The full impact of such

measures depends on a variety of regulatory, institutional, and economic variables and is therefore

exceedingly difficult to predict.
Ch. 3—lncinerable Hazardous Waste: Characteristics and Inventory • 77

1.

2.

3.

4.

5.

6.

7.

8.

9.

10.

CHAPTER 3 REFERENCES

Arthur D. Little, Inc., Overview of Ocean Incineration, 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), pp. II-23, 111-1, 14, V-17.

Booz-Allen & Hamilton, Inc., “Review of Activities of Major Firms in the Commercial Hazardous Waste Management Industry: 1982 Update,

prepared for the U.S. Environmental Protection

Agency, Office of Policy Analysis (Bethesda, MD:

Aug. 15, 1983), p. 8.

Borrelli, P., ‘ ‘To Dredge, Or Not To Dredge, A

Hudson River Saga, ’ The Amicus Journal,

spring 1985, pp. 14-26.

Environmental Defense Fund, “Comments of the

Environmental Defense Fund on the EPA’s Proposed Ocean Incineration Regulations, June 29,

1985.

Environmental Resources Management, Inc.,

New Jersey Hazardous Waste Facilities Plan, prepared for New Jersey Waste Facilities Siting Commission (Trenton, NJ: March 1985), p. 170.

EPRI Journal, ‘ ‘Handling PCBS, ” EPRI Journal 10(8):26-27, October 1985.

Gossett, R. W., Brown, D. A., and Young, D. R.,

“Predicting the Bioaccumulation and Toxicity of

Organic Compounds, Coastal Water Research

Project Biennial Report for the Years 1981-1982

(Long Beach, CA: Southern California Coasta l

Water Research Project, 1982).

ICF, Inc., ‘ ‘Survey of Selected Firms in the Commercial Hazardous Waste Management Industry:

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

Environmental Protection Agency, Office of Policy Analysis (Washington, DC: Sept. 30, 1985).

international Maritime Organization, Inter-Governmental Conference on the Convention on the

Dumping of Wastes At Sea, Final Act of the Conference With Attachments Including the Convention on the Prevention of Marine Pollution by

Dumping of Wastes and Other Matter, London

Dumping Convention, Oct. 30 to Nov. 13, 1972

(London: 1982), Technical Guideline 4.1.2.

Keitz, E., Vogel, G., Holberger, R., et al., A Profile of Existing Hazardous Waste Incineration Facilities and Manufacturers in the United States,

EPA No. 600/2-84-052, prepared for the U.S. Environmental Protection Agency, Office of Research and Development (Washington, DC:

1984).

11.

12.

13.

14.

15.

16.

17.

18.

19.

20.

21.

22.

23.

Minnesota Waste Management Board, “Revised

Draft Hazardous Waste Management Plan’

(Crystal, MN: February 1984).

Mitre Corp., Composition of Hazardous Waste

Streams Currently Incinerated, contract report

prepared for the U.S. Environmental Protection

Agency, Office of Solid Waste (Washington, DC:

April 1983).

Nauke, M. K. , “Development of Internationa l

Controls for Incineration At Sea, ” in Wastes in

the Ocean, vol. 5, D.R. Kester, et al. (eds. ) (New

York: John Wiley & Sons, 1985), pp. 33-52.

New England Congressional Institute, Hazardous

Waste Generation and Management in New England (Washington, DC: February 1986).

Oceanic Society, Joint Comments of Environmental and Other Citizen Organizations in Response to the U.S. Environmental Protection

Agency’s Draft Regulations on Ocean Incineration (Washington, DC: June 28, 1985).

Office of Appropriate Technology, “Alternatives

to the Land Disposal of Hazardous Wastes, An

Assessment for California, Toxic Waste Assessment Group, Governor’s Office of Appropriate

Technology (Sacramento, CA: 1981).

Oppelt, E. T., ‘ ‘Hazardous Waste Destruction,

Environ. Sci. Technol. 20(4):312-318, 1986.

SEAMOcean, Inc., ‘ ‘Preliminary Assessment of

the Cost Implications of Multimedia Waste Management Decisions That Include an Ocean Option, final report prepared for National Oceanic

and Atmospheric Administration, Office of

Oceanic and Atmospheric Research (Wheaton,

MD: February, 1986).

Stephan, D. G., letter of transmittal to Office of

Technology Assessment dated May 22, 1985, accompanying Keitz, et al., 1984.

Tejada, Susan, “The Blue Goose Flies!” EPA

Journal, October 1985.

U.S. Congress, Congressional Budget Office,

Hazardous Waste Management: Recent Changes

and Policy Alternatives (Washington, DC: U.S.

Government Printing Office, 1985).

U.S. Congress, House of Representatives, Hazardous 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
78 ● Ocean Incineration: Its Role in Managing Hazardous Waste

24.

25.

26.

I

Hazardous Waste Control, OTA-M-196 (Washington, DC: U.S. Government Printing Office,

March 1983). 27.

U.S. Congress, Office of Technology Assessment,

‘ ‘Serious Reduction of Hazardous Waste for Pollution Prevention and Industrial Efficiency, ” in

press (Washington, DC: 1986).

U.S. Environmental Protection Agency, Office of

Policy, Planning and Evaluation, “Background

Report I: Description of Incineration Technol- 28.

ogy, Assessment of Incineration as a Treatment

Method for Liquid Organic Hazardous Wastes

(Washington, DC: March 1985).

U.S. Environmental Protection Agency, Office of

Policy, Planning and Evaluation, “Background

Report 111: Assessment of the Commercial Haz- 29.

ardous Waste Incineration Market, Assessment

of Incineration as a Treatment Method for Liq -

uid Organic Hazardous Wastes (Washington,

DC: March 1985).

Westat, Inc., National Survey of Hazardous

Waste Generators and Treatment, Storage and

Disposal Facilities Regulated Under RCRA in

1981, contract report prepared by S. Dietz, M.

Emmet, R. DiGaetano, et al., for the U.S. Environmental Protection Agency, Office of Solid

Waste (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. Environmental

Protection Agency, Office of Research and Development (Washington, DC: May 1985), pp. 52,

53, 87,

Zurer, P. S., ‘ ‘Incineration of Hazardous Wastes

At Sea—Going Nowhere Fast, ” Chem. Engr.

News, Dec. 9, 1985, pp. 24-42.
Chapter 4

Current and Emerging Management

and Disposal Technologies for

Incinerable Hazardous Wastes
Contents

Page

Incinerable Waste Quantities Currently Managed by Various

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

Current Use of Particular Technologies for Managing Incinerable Wastes . . . . . . . . . . . . . 82

Land Disposal., . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 82

Use of Incinerable Waste as Fuel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 84

Biological and Physical/Chemical Treatment .,.... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 85

Waste Recovery and Recycling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 85

Waste Reduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 86

New and Emerging Technologies for Incinerable Wastes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 87

Recovery Processes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 87

Thermal Detoxification Processes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 88

Chemical Detoxification Processes .....+ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 88

Chapter4 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 89
Chapter 4

Current and Emerging Management

and Disposal Technologies for

Incinerable Hazardous Wastes

Incinerable wastes are currently managed by a

broad array of methods; how extensively each

method is used depends on innumerable economic,

regulatory, and geographic factors. In addition, a

wide range of new technologies for managing hazardous wastes is being developed, and many apply directly to incinerable wastes. This chapter first

summarizes available data on the quantities of incinerable waste currently managed by particular

methods and examines each method in more detail

with respect to its potential for influencing the use

of ocean incineration. Then the chapter briefly describes several new technologies with respect to their

availability, capacity, and degree of applicability

to incinerable wastes.

The discussion specifically excludes the large

quantities of hazardous waste present in wastewaters that are directly and indirectly discharged

into surface waters. Such disposal practices are regulated under the Clean Water Act and are specifically exempted from Resource Conservation and

Recovery Act (RCRA) regulations applicable to

hazardous waste. Moreover, only a small portion

of incinerable liquid wastes is discharged into surface waters. Another OTA report (21) will examine these practices in detail.

INCINERABLE WASTE QUANTITIES CURRENTLY MANAGED BY

VARIOUS TREATMENT AND DISPOSAL METHODS

Several studies have estimated the quantities of

hazardous waste managed through treatment, disposal, and recycling or recovery (6,18,24). However, only one study—by the Congressional Budget Office—was aggregated by waste type; this

allowed separate estimates to be developed for the

various categories of incinerable hazardous waste,

which include waste oils, halogenated and nonhalogenated solvents, and other organic liquids (ref.

18, and unpublished data).

The CBO estimates for the overall disposition

of hazardous waste differed significantly in some

cases from those of the Environmental Protection

Agency (24). 1 The sources of data for both studies

contain uncertainties and systematic errors which

likely contribute to such differences. In addition,

the universe of hazardous wastes considered in the

‘C BO acknowledged this discrepancy and discussed differences in

the methodologies of the two studies in a paper (19) which accompanied its 1985 report (18).

two studies differs significantly: CBO adopted a definition that is much broader than the RCRA definition used by EPA. Finally, CBO assumed full

compliance with RCRA and Clean Water Act requirements in generating its estimates. Given these

sources of uncertainty, the following discussion will

provide a range of estimates, wherever possible, to

provide a qualitative picture of current management of hazardous waste that could be incinerated.

Available data indicate that large quantities of

waste that could be incinerated are currently being disposed of on land—in landfills, surface impoundments, or injection wells. Of liquids that

could be incinerated at sea, CBO estimates that

almost a third of oils and solvents and more than

80 percent of other organic liquids are disposed of

on land. For incinerable sludges and solids, reliance on land disposal is even higher: CBO estimates

that more than 80 percent of these wastes are landdisposed.

81
82 . Ocean Incineration: Its Role in Managing Hazardous Waste

The CBO data also indicate that most waste oils

(about 60 percent) and significant quantities of

waste solvents (5 to 10 percent) are burned in

RCRA-exempt industrial boilers, currently under

little or no regulation. These data are generally consistent with those from other sources (refs. 4 and

13; 50 FR 1684, Jan. 11, 1985).

The 1984 RCRA Amendments were designed

to significantly restrict the use of these options for

managing hazardous wastes, because of concerns

about adverse impacts to human health and the

environment. If the restrictions are implemented

according to schedule, they are likely to significantly

increase the quantities of waste. available for or

directed to incineration.

CBO’S data and other data indicate that significant quantities of incinerable wastes, particularly

liquids, are currently being recovered, reused, or

recycled. These practices are likely to be increasingly used in the future. As shown in table 6 (see

ch. 3), however, despite the anticipated levels of

recovery, reuse, and recyling, it is likely that most

incinerable hazardous wastes generated by 1990 will

continue to require some form of treatment or

disposal.

CURRENT USE OF PARTICULAR TECHNOLOGIES

FOR MANAGING INCINERABLE WASTES

Hazardous waste management technologies can

be organized into a generally accepted hierarchy

of methods ranging from least to most environmentally desirable or sound. This hierarchy can

best be represented by a hazardous waste management “pyramid,” with the following tiers:

dispersion in the environment;

isolation or containment;

stabilization of waste through physical or

chemical means;

destruction or treatment of wastes to reduce

toxicity;

recovery of waste for recycling or reuse of materials or energy; and

reduced generation of waste, with respect to

both volume and toxicity.

A particular technology may actually contain elements from more than one tier in the hierarchy.

For example, ocean incineration entails destruction

of most of the waste, dispersion of a small amount

of unburned wastes into the environment, and containment of any residuals by disposing of them in

landfills. This section briefly discusses technologies

(other than incineration) in light of the above hierarchy and indicates which technologies contain elements of more than one tier. Currently available

incineration technologies are discussed in chapter 5.

Land Disposal

Large quantities of incinerable hazardous wastes

are now disposed of on land. Land disposal includes

three primary methods: underground injection,

landfilling, and surface impoundment. Although

they are meant to isolate and contain wastes, all

three methods have often resulted in dispersion of

wastes, through leakage and migration of wastes

from the disposal site. In some cases, wastes are

stabilized prior to disposal in order to lessen the

risk or degree of dispersion.

If implemented according to schedule and congressional intent, the 1984 RCRA Amendments’

restrictions on land disposal would shift large quantities of hazardous waste, particularly incinerable

liquids, away from land disposal. Almost all of the

RCRA prohibitions, however, are contingent on

the availability of alternative capacity for managing banned wastes. If alternatives are unavailable,

temporary variances can be granted.

Underground Injection

The injection of hazardous wastes into deep wells

is the disposal technology used most often for such

wastes. 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 of

by underground injection (ref. 18; EPA, cited in

ref. 19). The 1984 RCRA amendments impose new

requirements on this practice, although they are less

stringent than those applicable to landfilling and

surface impoundment. The schedule for banning

the underground injection of hazardous waste is

more gradual and the burden of proof of adverse

impact may be somewhat more stringent.

Landfilling

CBO(18) estimated that over one-fifth of all hazardous wastes generated in 1983 was disposed of

in landfills. Increasingly stringent RCRA requirements are raising costs, however, and are expected

to lead to decreased usage. Minimum technology

standards embodied in the 1984 RCRA Amendments require the use of double liners, leachate collection systems, and groundwater monitoring capability. Landfilling of bulk liquid hazardous waste

is already prohibited, and prohibitions on landfilling of other hazardous wastes are being decided on

a legislatively mandated schedule.

Surface Impoundment

Surface impoundments, which include ponds,

pits, and lagoons, are used to store and treat, as

well as dispose of, many hazardous wastes. CBO

(18) estimated that almost one-fifth (50 mmt) of all

hazardous wastes generated in 1983 was placed in

surface impoundments. Treatment processes used

in surface impoundments include volatilization,

evaporation, aerobic or anaerobic digestion, and

coagulation and precipitation. Under the 1984

RCRA Amendments, the same minimum technol-
84 ● Ocean Incineration: Its Role in Managing Hazardous Waste

I

i

I

I

I

I

ogy standards applicable to landfills now apply to

surface impoundments, although the immediate

ban on bulk liquid hazardous waste does not apply.

Use of Incinerable Waste as Fuel

A variety of technologies use incinerable waste

as a fuel source. These technologies embody elements of the treatment/destruction and recovery

tiers in the waste management hierarchy. In addition, disposal of residuals from such processes may

involve isolation/containment or dispersion of wastes,

as well.

Technologies employing incinerable waste as fuel

compete directly with both land-based and ocean

incineration. A regulatory distinction exists, however, between thermal technologies whose primary

purpose is to use and capture the energy content

of raw fuel or hazardous waste, and typical incineration technologies, which are designed primarily

for the purpose of destroying wastes (46 FR 7666,

Jan. 23, 1981).2

Various types of boilers and furnaces, both industrial and nonindustrial, employ incinerable

waste as fuel to some extent. Nonindustrial boilers

are used largely for space heating in apartments,

office buildings, schools, and hospitals. Industrial

boilers are used for space heating and steam production by utilities or other industrial facilities.

Industrial furnaces include cement and lime

kilns, asphalt plants, and steel blast furnaces. Some

of these technologies use the chlorine as well as the

energy from hazardous wastes. For example, cement kilns use the acid gas formed from burning

chlorinated wastes to reduce the alkalinity of the

cement slag; the kiln itself acts essentially as a scrubber, and the quality of the cement product is actually improved in the process.

Profile of Existing Facilities Using

Incinerable Waste as Fuel

This section provides a profile of the number of

these facilities and the extent of their use in burning hazardous wastes as fuel.

A very large number of industrial boilers and furnaces are used in the United States. EPA estimates

‘Incineration technologies are discussed in ch. 5.

that about 43,000 industrial boilers and 600 industrial furnaces are currently in operation (4, 13). Of

these, about 1,300 boilers and 10 to 20 furnaces

burned some waste oil or hazardous waste-derived

fuel in 1983 (25). EPA estimated that 3.4 to 5.4

mmt of hazardous waste and used oils are burned

annually in industrial boilers (50 FR 1684, Jan. 11,

1985) and that about 0.35 mmt are burned annually in industrial furnaces (24). CBO (18) reported

a much higher estimate of 9.5 mmt for industrial

boilers and furnaces. In any case, significantly more

hazardous waste is burned in industrial boilers and

furnaces than is incinerated: 1.7 to 2.7 mmt

(18,24).

While industrial furnaces and boilers appear to

have enormous capacity for hazardous wastes, several factors limit their use. First, although these

practices were exempted from RCRA regulations,

the 1984 RCRA Amendments call for their regulation as hazardous waste facilities (see below). Second, these facilities have tended to burn only hazardous wastes that are relatively clean and have a

high energy content. Attempts to significantly expand their use would involve wastes that are less

attractive to facility operators, because they contain higher amounts of ash, water, or solids (13).

Indeed, the reluctance of many operators to use

such wastes for fuel is reflected in the small proportion of existing facilities that actually burn hazardous wastes (as indicated above).

A third factor limiting the use of these facilities

for hazardous wastes is the relative lack of rigorous environmental testing or appropriate pollution

control equipment. Very few industrial boilers are

equipped with scrubbers (12, 13), so that wastes with

significant chlorine or ash content could not be

burned; moreover, the corrosivity of the resulting

exhaust gases would damage the boilers.

A fourth factor limiting such use is the chlorine

content of wastes. Wastes of intermediate chlorine

content can be burned in cement kilns and other

industrial furnaces, where corrosive gases are

directly used in the production process. Burning

of chlorinated wastes in kilns, however, tends to

increase the release of particulate, necessitating

that facilities be upgraded prior to such use (12).

These and other factors limit the chlorine content

of 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 experienced regulatory problems when burning hazardous wastes and have been forced to stop accepting

certain or all such wastes. This has led to increasing quantities of waste being sent to commercial

incinerators (2).

Regulation

Some regulation of hazardous waste burning in

boilers and furnaces has already occurred, and more

is likely in the near future. Burning of hazardous

waste in nonindustrial (particularly residential) devices is now strictly regulated and for the most part

prohibited (50 FR 49164, Nov. 29, 1985). The 1984

RCRA Amendments prohibit burning of hazardous waste in cement kilns located in cities with populations exceeding 500,000 unless the facility complies with RCRA incineration standards (Section

204(b)(2)(c)).

For facilities producing fuels containing hazardous waste, notification and labeling requirements

and product standards were also mandated and are

currently being developed. In addition, exemptions

for hazardous wastes or used oils burned as fuel are

being removed, and new regulations governing

their blending and burning are mandated. Finally,

in 1986 EPA expects to issue permit standards that

would extend the current performance standards

and requirements applicable to land-based incinerators to all industrial boilers and furnaces (50 FR

49164, Nov. 29, 1985).

Biological and Physical/Chemical

Treatment 3

Many technologies for treating hazardous wastes

are applicable to incinerable wastes. Biological

methods include traditional aerobic and anaerobic

digestion, in which naturally occurring bacteria are

used to metabolize the organic constituents of the

waste. Aerobic processes generally can be used only

with relatively dilute wastestreams (liquids that contain low levels of solids), because high concentrations of waste components or metabolic products

are often toxic to bacteria. Anaerobic procedures

3Although incineration and other thermal processes are often classified as treatment technologies, this discussion is limited to nonthermal processes.

are less sensitive, and have been used to digest

sludges that contain significant amounts of solids.

Biologists have isolated naturally occurring bacteria that can degrade particular toxic or persistent chemical compounds (5,23). Particularly for

specialized and highly problematic wastes such as

PCBS, these and other emerging biological approaches may prove extremely useful and costeffective.

Traditional physical/chemical treatment entails

removing organic or metallic compounds from

aqueous wastes—by using coagulant, absorbents

such as activated carbon, or chemical reactions—

and then destroying or disposing of the contaminated residues. Newer methods applicable to incinerable waste include several related technologies

for dechlorination. Such processes chemically strip

off chlorine atoms from highly chlorinated organic

compounds, thereby greatly decreasing or eliminating their toxicity and persistence. Mobile units

have been developed specifically to detoxify PC Bcontaminated transformer fluids and PCB- or dioxin-contaminated soils.

Waste Recovery and Recycling

Current methods for recovering waste have been

applied primarily to waste solvents and oils. Solvent recovery is a well established industry, which

handles most of the waste solvents that are generated (18). Solvents are often sent offsite to be purified and returned to the generator for a fee. In

other cases, the recoverer resells solvents to new

customers.

Solvent recovery consists of several independent

processes, which result in sequentially cleaner material. Some loss of quality relative to virgin materials

accompanies all of these processes. Although this

can lower the demand for recovered solvents, markets currently exist for both partially and fully recovered solvents. The intended use determines the

extent of treatment; for example, use as fuel requires only minimal treatment, whereas reuse as

solvent may require substantial treatment and

expense.

The initial step in solvent recovery usually is to

remove suspended impurities by filtration and centrifugation. Separation and removal of water, or
86 • Ocean Incineration: Its Role in Managing Hazardous Waste

separation of different solvents present in a mixture, is accomplished through various forms of distillation. Each of these processes generates a residual, which must be disposed of or destroyed. For

example, distillation generates various still wastes,

which are candidates for incineration (on land or

at sea).

Waste oil recovery, which is used to a much

smaller extent than is solvent recovery, also entails

several processes that produce sequentially cleaner

material. Specifications based on intended reuse

have been established, and they largely dictate

the extent and nature of treatment. Reclaiming

waste oil entails removing suspended solids, water,

and degraded oil compounds. Reclaimed oils are

blended or reformulated, resulting in products that

can be resold for uses that do not require oil meeting the specifications for virgin material. Rerefining of reclaimed oil is accomplished through fractional distillation to generate a final product that

approaches original specifications.

In addition to the new RCRA requirements that

apply to the blending and burning of fuels containing hazardous waste, EPA has proposed listing used

oil as a hazardous waste under RCRA (50 FR

49258, Nov. 29, 1985) and has proposed regulations governing recycled oil (50 FR 49212, Nov.

29, 1985). The regulations would ban the use of

recycled oil for oiling roads and would extend to

recycled oil those regulations that govern other

recycled hazardous wastes.

A third method of waste recovery applicable to

many types of waste is liquid extraction. This technique is especially useful for recovering a dissolved

waste component that has economic value in its

pure form. For example, phenol can be recovered

in this manner from refinery and coke oven wastes.

A number of newer technologies, which have not

been widely employed in the United States, can directly recover or use the chlorine released when

chlorinated wastes are thermally destroyed. These

processes are discussed in the section on new and

emerging technologies.

Waste Reduction

Although the term waste reduction has a very

broad meaning in common usage, in its most precise connotation it refers to technologies and processes that reduce the actual generation of waste

(measured in terms of volume, or in terms of the

toxicity or degree of hazard per unit volume). A

technology like incineration reduces the toxicity and

volume of waste, but a true waste reduction technology or process is used before the wastes are actually generated (i. e., in order to prevent their generation). The term, therefore, also excludes waste

recovery technologies that reduce the quantity of

waste requiring treatment or disposal but that act

after the waste is generated.

Waste reduction technologies generally fall into

two categories. First, process modifications reduce

waste generation by, for example, internal recycling or more efficient use of feedstocks. These

measures are ‘typically process-specific, and the

modifications are often driven by direct economic

incentive. Even modifications that are not tied to

the process itself have often been used to reduce

waste (e. g., computer-based scheduling and inventory control in paint manufacturing) (l).

A second category of waste reduction technologies includes product or ingredient substitution,

in which toxic or polluting materials are replaced

by safer components. For example, water-based

inks or adhesives can sometimes be substituted for

those containing or made with organic solvents.

A full discussion of waste reduction far exceeds

the scope of this study. For additional information,

see references 3,9,14,15,16.4

4Another ongoing OTA assessment (20) examines in detail the potential for industrial waste reduction.
Ch. 4—Current and Emerging Management and Disposal Technologies for /ncinerab/e Hazardous Wastes . 87

NEW AND EMERGING TECHNOLOGIES

FOR INCINERABLE WASTES

A wide range of new technologies is being developed for the management of hazardous wastes.

Many of these technologies, including methods for

the recovery as well as detoxification (through treatment or destruction) of wastes, apply directly to incinerable wastes. A full analysis of the new technologies 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 few

promising technologies and, where data are available, discusses their status, capacity, and degree

of applicability to incinerable wastes.

Recovery Processes

Solvent Recovery—Thin Film Evaporation

This technology, in which waste solvent is fractionated by evaporation from a thin film applied

to a heated surface, provides an alternative to conventional solvent distillation. The technology’s primary advantages over conventional distillation are

a higher efficiency of recovery (greater than 95 percent), a smaller amount of residual material requiring disposal or destruction, and the ability to recover even highly viscous liquids.

A few commercial solvent recovery firms have

recently installed thin film evaporators (l), but data

on current or near-future capacity are not available.

Advanced Oil Recovery Processes

Application of advanced petroleum technology

to waste oil has resulted in a number of new methods for removing contaminants and fractionating

oil, thereby producing material that closely approximates original specifications. Several of these methods have recently been put into operation. The extent to which they would be applied to incinerable

wastes would partly depend on oil prices and the

relative cost of existing alternatives, including incineration.

Chlorine Recovery Processes

Several emerging technologies can use the chlorine that is released during the incineration of highly

chlorinated organic wastes (17). These technologies

fall into two major classes. First, certain processes

can recover chlorine liberated during incineration

in the form of concentrated hydrochloric acid.

These processes are generally applicable to a broad

range of chlorinated organic wastes, but they have

only been used on a small scale to date, probably

in part because they are not competitive with other

industrial sources of hydrochloric acid (10). Second, a group of related chlorination processes directly use liberated chlorine in additional chemical chlorination reactions. These technologies can

be applied, for example, to the production of chlorinated hydrocarbons such as trichloroethylene, but

the waste used in the process must be quite pure

and homogeneous. To date, only wastes generated

in the production of vinyl chloride and propylene

oxide have been used successfully in chlorination

recovery processes.

Both types of processes are limited by the market’s capacity to absorb their products. In addition,

the technologies have been used primarily in Europe and have not found significant application in

the United States. Current costs are several times

higher than those for ocean incineration of the same

wastes, although the return on recovered materials can sometimes alter the ratio. From an environmental perspective, these recovery processes offer the advantage of occurring in relatively closed

systems, thus greatly reducing the emissions associated with conventional incineration.

Supercritical Fluid Extraction

This process is an advanced form of liquid extraction, employing elevated temperature and pressure to extract particular organic compounds from

waste mixtures. The process entails higher capital

investment but lower operating costs than conventional distillation or solvent extraction. As with liquid extraction, supercritical fluid extraction is likely

to be most useful for treating aqueous wastes containing valuable or highly toxic components. It may

also be able to concentrate the organic portions of

wastes in order to render their subsequent incineration 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 technique in which wastes are rapidly heated to extremely high temperatures (about 4,000° F) and

destroyed. Its developer claims that the destruction

efficiencies the reactor achieves are much higher

than those required of, or achieved by, conventional

incinerators. The reactor was initially developed

to destroy organic contaminants in soils or carbon

absorbents, but it has recently been used for liquid wastes, as well.

The reactor’s throughput for solids is estimated

to be as high or higher than that of conventional

incineration, although for liquids the converse may

be true. Commercialization is underway.

Molten Salt

This technology destroys organic wastes and removes inorganic residuals from combustion gases

in a single step. Wastes are injected into a pool

or bath of molten sodium carbonate or calcium

carbonate maintained at a temperature of about

1,6500 F; the inorganic byproducts of combustion

(containing phosphorus, sulfur, halogens, or metals) react with the carbonate component of the bath

and are retained as inorganic salts. These products,

as well as ash, must be periodically removed from

the bath.

Molten salt baths are suitable for both liquid and

solid wastes (including highly halogenated wastestreams) with low ash content. Throughput of a

pilot-scale facility was estimated to be about 100

lbs/hr. No commercial units are currently employed, although they are available for purchase.

Molten Glass

A similar technology employing a molten glass

bath maintained at about 2,200° F has also been developed. Inorganic components other than halogens

are trapped and removed in a classified, and therefore highly stabilized, form. Scrubbers are necessary when this technology is used with halogenated

wastes.

5This discussion is drawn primarily from refs. 1 and 8.

Fluid Wall Reactor

In this process, wastes pass through a porous carbon cylinder heated to about 2,200° F. A mobile

unit has been developed for destroying dioxin-contaminated liquids and soils. Projected costs are comparable to those of offsite incineration.

Plasma Arc

Wastes are destroyed in this process by injection

into an electrically superheated ionized gas

(plasma). Temperatures employed are claimed to

be extremely high: 10,000° F or more. An afterburner is usually attached to ensure complete destruction. The method has been used on PCBs and

other highly chlorinated liquid wastes, and has demonstrated very high destruction efficiencies (higher

than 99.9999 percent). A unit currently being demonstrated has a waste throughput of 600 lbs/hr. A

commercial unit is expected to be available within

a few years. The costs, which are projected to be

5 to 10 times higher than conventional incineration, would probably limit the technology’s use to

highly toxic liquids.

Supercritical Water Reactor

In this process, elevated temperature and pressure enhance the rate and efficiency of thermal oxidation of aqueous wastes. Inorganic constituents

are either neutralized or precipitated, eliminating

the need for scrubbers on systems fed with chlorinated wastes. Destruction efficiencies of demonstration units have been somewhat lower than those

required of incinerators.

A reactor system now being developed would

treat liquids and sludges containing high levels of

inorganic and toxic constituents. The unit would

be equipped with heat recovery capability as well.

Throughput is expected to be between 1,000 and

2,000 gallons per day (300 to 600 lbs/hr). Commercialization is expected to occur within several

years.

Chemical Detoxification Processes

As a general rule, incinerable wastes are not good

candidates for chemical treatment. Particular wastes

such as PCBs and dioxins, which have been the focus 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 information

about chemical detoxification processes, see ref. 1.

Oxidative Ultraviolet Light Treatment

This process couples the oxidative capacity of

ozone or hydrogen peroxide with the ability of highenergy ultraviolet light to break chemical bonds.

Several techniques are being developed, but they

are likely to be quite expensive, especially for waste

with significant organic content, thus limiting their

ability to compete with incineration. The techniques

may, however, be useful for hard-to-treat wastes

such as PC B- and dioxin-containing solids.

Catalytic Dehalogenation6

Two dehalogenation processes are being developed. One would be applicable to liquids with low

‘Most halogenated chemicals contain chlorine rather than other halogens; the processes discussed below are, therefore, often referred to

by the term dechlorination.

organic halogen content, the other to pure halogenated compounds or liquids with highly concentrated halogenated compounds. The first process

would replace halogen (usually chlorine) atoms with

hydrogen, detoxifying the original compound or

rendering it less stable. The halogen gas generated

in the process would have to be treated in a scrubber device. In the second process, the original compound would be oxidized to carbon dioxide and

water, and the halogen would take the form of the

pure element (e. g., chlorine gas), which could be

recovered.

The feasibility of both processes has been established in pilot-scale units, but neither has yet been

employed commercially. Both systems are expected

to be suitable for use in mobile units, which could

be employed at cleanup sites, but would probably

be too small for major commercial operations.

CHAPTER 4 REFERENCES

1.

2.

3.

4.

5

Arthur D. Little, Inc., Overview of Ocean Incineration, 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 Activities of Major Firms in the Commercial Hazardous Waste Management Industry: 1982 Update,

prepared for the U.S. Environmental Protection

Agency, Office of Policy Analysis (Bethesda, MD:

Aug. 15, 1983), p. 8.

Campbell, M., and Glenn, W., Profit From Pollution Prevention (Toronto, Ontario: Pollution

Probe Foundation, 1982).

Castaldini, C., Willard, H. K., Wolbach, C. D.,

et al., A Technical Overview of the Concept of

Disposing of Hazardous Wastes in Industrial Boilers, EPA No. EPA-600/2-84-197, prepared for the

U.S. Environmental Protection Agency, Office of

Research and Development, Industrial Environmental Research Laboratory (Washington, DC:

December 1984).

Chemical and Engineering News, ‘‘New Findings

on PCBs, Other Pollutant Group, Chemical &

Engineering News 63(18): 10, May 6, 1985.

6.

7.

8.

9.

10.

11.

12

Chemical Manufacturers Association, Results of

the 1984 CMA Hazardous Waste Survey (Austin, TX: Engineering-Science, Inc., January

1986).

Dombrowski, C. H., “Land Ban Encourages Technological Advancements, World Wastes, March

1986, pp. 25-28.

Freeman, H., Innovative Thermal Hazardous

Waste Treatment Processes, EPA/600/2-85/049,

prepared for the U.S. Environmental Protection

Agency (Washington, DC: April 1985).

Huisingh, D., and Bailey, V. (eds. ), Making Pollution Prevention Pay (New York: Pergamon

Press, 1982).

Nauke, M. K., “Development of International

Controls for Incineration At Sea, ” in Wastes in

the Ocean, vol. 5, D.R. Kester, et al. (eds. ) (New

York: John Wiley & Sons, 1985), pp. 33-52.

Nell, K. E., Haas, C. N., Schmidt, C., et al., Recovery, Recycle and Reuse of Industrial Wastes,

James W. Patterson Industrial Waste Management Series (Chelsea, MI: Lewis Publishers, Inc.,

1985).

Office of Appropriate Technology, “Alternatives

to the Land Disposal of Hazardous Wastes, An
90 ● Ocean Incineration: Its Role in Managing Hazardous Waste

13.

14.

15.

16.

17.

18.

19.

20.

Assessment for California, Toxic Waste Assessment Group, Governor’s Office of Appropriate

Technology (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 Strategies for Controlling Toxic Contamination (Westport, CT: Quorum Books, 1984).

Royston, M. G., Pollution Prevention Pays (Oxford: Pergamon Press, 1979).

Sorokin, D.J., et al., Cutting Chemical Wastes

(New York: INFORM, 1985).

Sutter, H., “Trends in the Incineration of Chlorinated Hydrocarbons At Sea, Mull and Abfall

(Garbage and Waste), April 1984, pp. 89-93.

U.S. Congress, Congressional Budget Office,

Hazardous Waste Management: Recent Changes

and Policy Alternatives (Washington, DC: U.S.

Government Printing Office, 1985).

U.S. Congress, Congressional Budget Office,

“Empirical Analysis of U.S. Hazardous Waste

Generation, Management, and Regulatory Costs, ”

draft staff working paper (Washington, DC: October 1985).

U.S. Congress, Office of Technology Assessment,

‘‘Serious Reduction of Hazardous Waste for Pollution Prevention and Industrial Efficiency, ” in

press (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 of

Policy, Planning and Evaluation, “Background

Report II: Assessment of Emerging Alternative

Technologies, Assessment of Incineration as a

Treatment Method for Liquid Organic Hazardous Wastes (Washington, DC: March 1985).

Walton, G. C., and Dobbs, D., “Biodegradation

of Hazardous Materials in Spill Situations, Control of Hazardous Material Spills (Nashville, TN:

Vanderbilt University, 1980), pp. 23-45.

Westat, Inc., National Survey of Hazardous

Waste Generators and Treatment, Storage and

Disposal Facilities Regulated Under RCRA in

1981, contract report prepared by S. Dietz, M.

Emmet, R. DiGaetano, et al., for the U.S. Environmental Protection Agency, Office of Solid

Waste (Rockville, MD: April 20, 1984).

Westat, Inc., Used or Waste Oil and Waste Derived Fuel Material Burner Questionnaire for

1983, prepared for the U.S. Environmental Protection Agency (Rockville, MD: 1984).
Chapter 5

Current Land-Based Incineration

Technologies
Contents

Page

Traditional Incineration Technologies. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 93

Liquid Injection Incineration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 93

Rotary Kiln Incineration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 93

Hearth Incineration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 96

Fluidized Bed Incineration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 97

Other Incineration-Like Technologies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 98

Pyrolysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 98

Wet Air Oxidation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 98

Use of Air Pollution Control and Heat Recovery Equipment. . . . . . . . . . . . . . . . . . . . . . . . . . 98

Air Pollution Control Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 98

Energy Recovery Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 99

Profile of Existing Hazardous Waste Incinerators. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..100

Number of Incineration Facilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ................100

Location of Incineration Facilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ................101

Incinerator Capacities and Operating Characteristics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .101

Chapter5 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .......................104

Tables

Table No. Page

9. Two Estimates of the Number of Land-Based Incineration Units Operating

in the United States . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .100

10. Commercial Status of Land-Based Incineration Facilities, by EPA Region . ..........103

Figures

Figure No. Page

3. Liquid Injection Incineration Technology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 95

4. Rotary Kiln Incineration Technology. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 95

5. Fluidized Bed Incineration Technology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 97

6. Wet Air Oxidation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 99

7. A Regional Profile of Land-Based Hazardous Waste Incineration Facilities:

Number of Facilities Located in Each State and EPA Region . . . . . ..................102

8. A Profile of the Capacity of Land-Based Incinerators for Liquid Wastes . . . . . . . . . . ....103
Chapter 5

Current Land-Based Incineration

Technologies

A variety of technologies are used to thermally

destroy hazardous wastes. In its strictest sense, incineration means the high-temperature destruction

of wastes carried out in the presence of oxygen. For

practical purposes, however, certain other thermal

destruction technologies that destroy wastes using

little or no oxygen (i.e., pyrolysis and starved air

incineration) can be be grouped with incineration

technologies. 1 This section briefly describes the dis-

‘The destruction of hazardous wastes in boilers and furnaces (see

ch. 4) is a common practice that is only beginning to come under regulation; however, under current regulations (46 FR 7666, Jan. 23,

1981 ), these practices are distinguished from incineration because

wastes are burned in boilers and furnaces for the primary purpose

of recovering their energy content, not for the purpose of destroying

the wastes. EPA estimated that, in 1981, almost twice as much hazardous waste was burned in boilers and furnaces than was burned

in incinerators (4).

tinctive features of the various processes that thermally destroy hazardous wastes.

All waste incinerators have several common components: a waste feed system, a combustion air or

oxygen system, a combustion chamber, combustion monitoring systems, and (where required) an

air pollution control and ash removal system. The

actual applications of the various components vary

somewhat in different designs. The following brief

description of available incineration technologies

discusses each of these features.

TRADITIONAL INCINERATION TECHNOLOGIE S

Liquid Injection Incineration

Liquid injection incineration is, by far, the most

common incineration technology used on land (primarily onsite), and is the only technology being

used or considered for ocean incineration, As the

name implies, liquid injection incineration can accommodate only freely flowing (pumpable) liquid

or slurry wastes. When coupled with other types

of incinerator designs, this technology serves as a

secondary chamber (afterburner) for volatilized

constituents produced by the primary incinerator.

Liquid injection incinerators are designed with

almost no moving parts and are almost exclusively

single-chamber units. (Figure 3 depicts in schematic

form a typical liquid injection incinerator. ) Wastes

are typically injected into the combustion chamber after being atomized (i.e., broken up into very

fine droplets) by passage through a nozzle or rotating cup located in or near the burner. A forced air

draft system supplies the oxygen required for combustion and also provides turbulence to aid in mixing. The combustion chamber itself is typically a

refractory-lined (heat-resistant) cylinder, which can

be mounted either vertically or horizontally.

Combustion gases are vented directly to the

atmosphere, if they comply with air pollution regulations for incinerators. If halogenated wastes are

burned, scrubbers capable of removing acid gases

may be required. Incineration of liquids usually results only in very low particulate emissions and,

therefore, does not usually require particulate

removal equipment.

Rotary Kiln Incineration

Rotary kiln incineration is the technology most

commonly used by major commercial land-based

facilities and is the third most common incinerator design in the United States. Rotary kilns can

accommodate a wide range of solid and sludge

wastes, including dry flowable granular wastes, containerized wastes, nonpumpable slurries, and semisolids. Rotary kilns are generally equipped with sec93
94 . Ocean Incineration: Its Role in Managing Hazardous Waste

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 by

waste 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 higher

increase 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 gravity

tary kilns, coupled with liquid injection units to ac- feed of wastes. (Figure 4 is a schematic represencommodate liquid wastes. Rotary kiln technology tation of a typical rotary kiln incinerator. ) Solid and

is not currently applicable to at-sea operation, nor sludge wastes enter at its high end, and liquid

is it likely to be in the foreseeable future, because wastes or auxiliary fuel are introduced as needed

of 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 waste

SOURCE: 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 of

hazardous wastes—solids, sludges, and liquids—and

is the technology most frequently used

at commercial facilities.

kiln, where it can be removed for disposal. After

being volatilized and partially destroyed in the primary chamber, gases are directed to the secondary chamber to complete the destruction process.

Incinerating solid wastes creates appreciable ash

residues and particulate, so rotary kilns are typically equipped with stack scrubbers to clean flue

gases.

Hearth Incineration

Hearth incineration, which is the second most

common design in the United States, is employed

primarily to burn wastes onsite. Hearth incinerators 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 burn

solids and sludges at the site of generation. This

particular facility has been equipped with liquid

injection equipment to allow the incineration

of liquid hazardous wastes as well.

form, but they can also be equipped with liquid injection capability.

Wastes are introduced onto a platform (hearth)

in the bottom of the combustion chamber. Both

fixed- and multiple-hearth designs are in use.

Multiple-hearth designs, in which wastes are conveyed from chamber to chamber, are especially useful for burning complex wastes that need to be exposed to high temperatures for long periods.

Incineration in fixed hearth units can occur under

conditions of excess air or starved air (pyrolytic)

conditions. Pyrolytic systems are generally accompanied by excess-air afterburners.

Although air flow over the waste mass can be

controlled to limit the amount of particulate matter in the exhaust gases, scrubbers are often necessary to comply with air pollution regulations.
Ch. 5—Current Land-Based Incineration Technologies ● 97

Fluidized Bed Incineration

Fluidized bed incineration uses a layer of small

particles (e. g., sand) suspended in an upward flowing stream of air. (Figure 5 schematically illustrates

a fluidized bed incinerator. ) The particles behave

much like a fluid (hence, the name). Wastes (and

auxiliary fuel, if needed) are mixed into the suspended bed and combusted. Fluidized bed incinerators were developed primarily to accommodate

highly viscous liquids and sludges not easily burned

in more conventional types of incinerators.

Combustion gases from this type of incineration

typically contain high levels of particulate and,

therefore, must be scrubbed before release to the

atmosphere.

Photo credit: GA Technologies, Inc.

Fluidized bed incinerators can destroy liquids and

sludges that are not easily handled by more

conventional incinerator technologies,

Figure 5.— Fluidized Bed Incineration Technology

/

Particulate

Solid feed removal

Waste feed pump

\

recycle Tramp

material

Recycled bed

 material return

 Bed material

Bed

makeup

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, and

in operation. These include fume incinerators (typi- combination systems (e. g., a hearth connected to

cally with liquid waste incineration capability) for a liquid injection unit).

burning gaseous wastes, incinerators for destroyOTHER INCINERATION-LIKE TECHNOLOGIE S

In addition to the traditional incineration technologies, two incineration-like technologies for destroying wastes are currently in use.

Pyrolysis

Pyrolysis refers to technologies that accomplish

thermal destruction in an oxygen-deficient atmosphere. Pyrolysis equipment is similar to conventional incineration technologies, with the obvious

exception that it lacks a system for introducing air

into the combustion chamber. Organic waste compounds are volatilized and partially decomposed by

thermal reactions alone. Gases from the pyrolytic

chamber then pass into a conventional chamber

where they are combusted in the presence of excess air. One advantage of pyrolytic technologies

is that emissions of particulate tend to be lower

than do those from more traditional incinerators

(8).

Three pyrolysis

the United States,

(l).

units are currently operating in

and several others are planned

Wet Air Oxidation

Wet air oxidation is a thermal destruction technology that oxidizes organic contaminants in water.

The water modifies oxidation reactions so that they

can occur at relatively low temperatures (3500 to

650° F). Air is bubbled through the liquid phase,

and the reactor vessel is maintained at a pressure

high enough to prevent excessive evaporation (8).

Wet air oxidation is primarily applicable to aqueous waste contaminated with dissolved or suspended organic material. The organic content of

wastes suitable for wet air oxidation is generally too

low to make traditional incineration economical,

but sufficiently high to sustain the reaction temperatures needed for oxidation. The technology has

been used successfully to treat a variety of aqueous wastes contaminated with nonhalogenated organic compounds, but it has been much less successful with halogenated compounds. Moreover, a

secondary process is typically needed, because detoxification is incomplete (40 to 95 percent).

Figure 6 depicts a typical wet air oxidation system. Several units are currently operating in the

United States.

USE OF AIR POLLUTION CONTROL AN D

HEAT RECOVERY EQUIPMEN T

Equipment serving either of two additional functions can be (or is required to be) added to the basic

systems described above. Such equipment includes

devices to control the emission of air pollutants and

devices to recover and use a portion of the energy

released through incineration. 2

‘This discussion is drawn primarily from refs. 1 and 3; these sources

should be consulted for additional information,

Air Pollution Control Equipment

Air pollution control equipment is often required

for land-based incinerators, particularly if wastes

with significant ash or halogen content are to be

incinerated. Such equipment consists of two components. The first is a quench chamber or heat exchanger to cool the gases leaving the combustion

chamber. The cooling is necessary for efficient operation 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 pressure

feed feed pump

I

Compressed

air

Heat exchanger

2

Reactor

* Off-gas

~ Oxidized

& 1 a liquor

Cooler Pressure

Cooling

Separator

control

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 of

Technology Assessment (Cambridge, MA: May 1986).

The second component includes one or more

scrubbers for actually cleaning the gases. Major

commercial incineration facilities typically remove

particulate by using wet or dry electrostatic precipitators, venturi scrubbers, or, less commonly, fabric filters. Removal of gaseous pollutants, including corrosive acid gases, usually requires a wet

scrubber, which neutralizes gases through contact

with an alkaline liquid reagent. Operation of a wet

scrubber requires installation of a mist eliminator

downstream, to separate the flue gases from water

droplets containing contaminants. (For a fuller discussion of scrubbers, see app. B in ref. 6.)

Both particulate and gaseous pollutant removal

systems generate waste sludges that, along with ash

residues, are typically handled as hazardous wastes

and disposed of in hazardous waste landfills.

Energy Recovery Equipment

Energy recovery equipment is not required under current regulations but is sometimes installed

on hazardous waste incinerators if it is deemed economically feasible and advantageous. Such equipment generally can only be installed upstream from

air pollution control equipment, that is, prior to

removal of corrosive gases or particulate. Incineration of wastes generating these products may damage or interfere with the operation of energy recovery equipment and, therefore, often precludes

its use. Certain modifications have recently been

introduced to partially alleviate these design restrictions.

Energy is generally recovered through the production of steam, which can be used to generate

electricity, to drive machinery, or to provide heat.

Alternatively, energy can be used to heat the air

fed to the incinerator, thereby increasing combustion efficiency and reducing the need for auxiliary

fuel.

Typical energy recovery equipment consists of

watertube or firetube boilers capable of recovering

60 to 80 percent of the heat content of combustion

gases.
100 ● Ocean Incineration: Its Role in Managing Hazardous Waste

PROFILE OF EXISTING HAZARDOUS WASTE INCINERATOR S

This section, which is drawn largely from EPA

documents, summarizes available information on

the number, capacity, and characteristics of existing land-based hazardous waste incinerators. OTA

has found that these data are incomplete and only

provide rough estimates, even of seemingly straightforward statistics, such as the number of permitted

hazardous waste incineration facilities currently

operating in the United States. No reliable national

database containing such information currently exists. Moreover, the number and permit status of

incineration facilities is constantly changing, as permits are processed or facilities open or shut down

in response to various regulatory or economic,

factors.

Despite these deficiencies, data derived from several sources can be used to develop a profile of existing facilities.

Number of Incineration Facilities

EPA has estimated that about 240 to 275 operating hazardous waste incineration facilities exist

in the United States.3 This estimate emerged from

several independent studies, including those based I

‘This estimate excludes industrial boilers and furnaces, which are

not considered incinerators under current regulations. These facilities

,

are numerous in the United States, and they currently account for

the destmction of substantially more hazardous waste than do incinerators (see ch. 4).

on the Westat national survey (10), interviews with

incineration manufacturers, a survey of RCRA

Part A permit applicants listed in the EPA Hazardous Waste Data Management System, and data

from EPA Regional Office permit files.

As of July 1982, EPA had identified 271 hazardous waste incineration facilities using 352 operational incineration units (3). Based on 1985 permit data, however, this estimate was revised

downward, to about 240 facilities using about 310

incineration units (5). The reduction in part

reflected the fact that some facilities ceased operations instead of securing final Part B RCRA

permits.4

Table 9 presents two estimates of the number of

incinerators of each design that were in use in 1981

(3). One estimate (shown in column A) was derived

from interviews with incinerator manufacturers regarding the number and type of units sold in the

United States. The other (column B) was extrapolated from partial data obtained from applications

for RCRA Part A permits. These estimates generally agree regarding liquid injection and hearth in-

*Complicating matters further, OTA recently obtained a computer

printout from the Hazardous Waste Data Management System of incinerator facilities that had submitted permit applications as of May

1986. This source listed a total of 274 incineration facilities with pending applications, but it did not provide any information concerning

incinerator design or commercial status. In this discussion, the data

from this source will be used as the most current available data.

Table 9.—Two Estimates of the Number of Land-Based incineration Units

Operating in the United States

Estimate Aa

Estimate Bb

Number Percent Number Percent

of units of total of units of total

Liquid injection . . . . . . . . . . . . . . . . . . . . . 219 650/o 213 61 ‘/0

Hearth (total) . . . . . . . . . . . . . . . . . . . . . . . 70 21 75 21

Hearth (with liquid capacity). . . . . . . . — — (44) –

Hearth (solids only) . . . . . . . . . . . . . . . – — (31) –

Rotary kiln (total) . . . . . . . . . . . . . . . . . . . 37 11 17

Rotary kiln (with liquid capacity) . . . . – — (15) 5

Rotary kiln (solids only) . . . . . . . . . . . . — (2) –

Fluidized bed. . . . . . . . . . . . . . . . . . . . . . . 9 3 5 1

Other 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 h4anufacturera in the Un/ted States, EPA No. S00/2-84452, prepared for the U.S. Environmental Protection Agency, Office

of Research and Development (VWahington, DC: 19S4).
Ch 5—Current Land-Based Incineration Technologies • 101

cinerators but differ significantly regarding rotary

kilns. (Note that these estimates were derived from

1981 data; the total number of units has changed

since 1981, but revised data for the distribution

among different designs are not available. )

The data from Estimate B in table 9 indicate that

almost 80 percent of hazardous waste incinerators

have some capacity for burning liquid wastes.

Data on the use and nature of air pollution control equipment on land-based incinerators are

scant. Based on data obtained from applicants for

RCRA Part A permits, EPA (3) estimated that

about 45 percent of existing incinerators have some

form of air pollution control equipment. About 37

percent of existing units use some type of scrubber. Large incinerators and those employing higher

temperatures and longer residence times were more

likely to have air pollution control equipment.

EPA (3) also found that only about 22 percent

of existing incinerators used energy recovery

equipment. Energy recovery equipment is more

commonly found on incinerators burning liquids,

on larger incinerators, and on incinerators operating on a continuous basis.

Only six incineration facilities are currently permitted to incinerate PCBs, as provided under the

Toxic Substances Control Act. See box B in chapter 3 for a more detailed discussion of PCB incineration.

Location of Incineration Facilities

This section considers both the regional distribution and the commercial status (i.e., onsite versus

offsite) of existing incineration facilities. For the 274

facilities for which data were available, figure 7 indicates the number of facilities located in each State

and EPA Region. Table 10 presents the commercial status of the 227 facilities whose status was indicated in reference 3.

Several conclusions can be drawn from these data

on regional distribution. First, as was true for incinerable waste generation, the distribution of hazardous waste incinerators is concentrated in particular States and regions. (For example, as shown

in figure 7, EPA Regions V and VI each contain

about one-fifth of all facilities. Texas alone accounts

for almost one-eighth of all facilities. ) Second, the

Northwestern United States, in general, contains

few incineration facilities, and EPA Region VIII

contains no commercial facilities. Finally, the great

majority (80 percent) of existing hazardous waste

incinerators are private facilities located onsite. No

correlation is apparent between onsite or offsite incineration and regional distribution.

EPA also examined the sources of waste burned

by the incinerators covered in its survey. Of the

respondents, 77 percent identified waste they incinerated as having been generated onsite. Of the

23 percent that reported handling waste generated

offsite, 90 percent were commercial incinerators (3).

Incinerator Capacities and Operating

Characteristics

Existing incinerators have been further characterized with respect to their capacity for liquid and

solid wastes and the temperatures and residence

times attained under typical operating conditions.

Capacity

For 180 of the incinerators surveyed by EPA (3),

capacity for liquid wastes was specified. Figure 8

shows the range of capacities.

According to these data, the capacities of twothirds of existing incinerators for liquid wastes are

below 300 gal/hr (2,500 lbs/hr). The median capacity for liquid wastes is 150 gal/hr (1 ,250 lbs/hr).

Similar data for incinerators burning solid wastes

revealed a median capacity of less than 80 gal/hr

(650 lbs/hr), or about half of the median for liquids. Assuming that the facilities were operated at

an average of 55 percent capacity, as estimated by

EPA (9), the median capacities would translate into

annual throughputs of about 1,400 metric tons for

solid wastes and 3,000 metric tons for liquids.

These data can be compared to the burning rate

for liquid wastes incinerated at sea. Each of the incinerators on the Vulcanus ships has a capacity of

about 1,650 gal/hr, or about 11 times the median

for land-based incinerators. The Apollo ships are

designed to have an even greater capacity, about

2,750 gal/hr per incinerator (7). Only 2 percent of

all land-based incinerators have a reported capacity greater than 2,000 gal/hr, and about 4 percent

have capacity greater than 1,000 gal/hr.
102 • Ocean Incineration: Its Role in Managing Hazardous Waste

Figure 7.—A Regional Profile of Land-Based Hazardous Waste

Located in Each State and EPA Region

Incineration Facilities:

(Total of 274 facilities)

Number of Facilities

2 (DE )

10 (MD)

I

SOURCE: 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 in

use today have annual throughputs of about 20,000

to 35,000 metric tons of mixed wastes,5 whereas

existing ocean incineration vessels could each burn

50,000 to 100,000 metric tons of liquid wastes annually (refs. 2,9; and data from incineration vessel owners).

Combustion Zone Temperature and

Residence Time

According to EPA (3), the average combustion

zone temperature in those incinerators for which

5

If these incinerators were to burn only liquid wastes, the capacity

would be considerably higher.

data were available was 1,820 + 2250 F (993 +

1070 C). For liquid injection incinerators, the average was slightly higher, 1,857 + 224° F (1 ,014 +

1070 C). In both cases, the median temperature

was about 1,8000 F. Liquid injection incinerators

generally operate at higher temperatures than do

rotary kilns, because the former do not require as

much excess air to atomize and combust liquid

wastes.

With respect to residence time, EPA data indicate that about half of the incinerators for which

data were provided had residence times of 2 seconds

or longer, and only about 15 percent had residence

times under 1 second, Liquid injection incinerators had a similar distribution.
Chapter 6

Ocean Incineration Technology
Contents

Page

Existing and Planned Vessels . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... , ..107

Wastestream Characteristics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .........................109

Infrastructure and Logistical Support Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .......109

No-Infrastructure System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .......................109

Existing Infrastructure System . . . . . . . . . . . . . . . . . . . . . ., . . . . . . . . . . . . . . . . . . . ........109

Integrated System. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..........................,..109

Technical Comparison of Designs for Ocean Incineration. . . . .....................,.,.110

Containerization Versus Bulk Storage and Transfer . . . . . . ..........................110

Self-Propelled Versus Barge Vessels . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..............113

Seawater Scrubbers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ............................114

Combustion Chambers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..................,......115

Burner Types . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..., .. ....115

Chapter6 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .......................116

Table

Table No. Page

11. Characteristics of Existing and Proposed Incineration Ships . ......................108
Chapter 6

Ocean Incineration Technology

EXISTING AND PLANNED VESSEL S

Ocean incineration technology has been used on cinerate only liquid organic wastestreams. Table

a much smaller scale than has land-based inciner- 11 summarizes relevant data for all existing, underation or any other major technology for managing construction, and planned incineration vessels. Of

hazardous wastes. Two incineration vessels are cur- these, the only foreign-owned vessel is the German

rently operating, primarily in Europe; 1 two more

are fully or partially built but not yet employed;

and plans for constructing others have been offered

by several companies. The combined waste handling capacity of all of these vessels could accommodate only a small portion of the hazardous waste

generated in the United States.

Vesta, which operates in the North Sea.

Although all of these vessels share features intended to respond to the unique needs and constraints of ocean incineration, they differ in several important respects. This chapter examines

ocean 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 also

used or proposed for ocean incineration. All exist- compares and contrasts the various existing and

ing or planned ocean incineration vessels use liq- proposed technologies for ocean incineration. For

uid 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 us

technologies, 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 below

deck deck

Completed

Incinerator ship

type II

2

Vertical

Air nozzle

12 tanks below

deck

1,300

5,500

9.9 —

Oceangoing barge Small supply ship

and tug type I type II

4 1

Horizontal Horizontal

Operating in

Europe

Rotary cup

9 tanks below

deck

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 vessels

be 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 Liquid

Organ/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

WASTESTREAM CHARACTERISTIC S

Typical liquid hazardous wastestreams are complex mixtures of many chemical compounds. For

ocean incineration in particular, most shiploads are

expected to consist of heterogeneous mixtures derived from several or many sources and processes.

Wastestreams are usually characterized with respect

to a number of parameters. The viscosity of the

waste must be sufficiently low to allow it to be

pumped and introduced into the incinerator in

small droplets. The heating value (i. e., energy content) of the waste feed must be sufficiently high to

heat incoming waste to its ignition temperature, to

provide the energy needed for oxidation, and to

maintain combustion. The heating value of a waste

generally decreases as water content increases and

as the proportion (percent by weight) of chlorine

present in organic compounds increases. Therefore,

liquid wastes are usually blended to produce optimum values for energy content, chlorine and water

content, and viscosity. Virtually all wastes, even

relatively homogeneous ones, require some blending before incineration to ensure proper consistency

and flow.

INFRASTRUCTURE AND LOGISTICAL SUPPORT SYSTEM S

The various ocean incineration vessels differ in

how much they rely on waste preparation, storage,

handling, and transfer facilities on shore. Three

general categories of logistical systems have been

identified (7,8).

No-Infrastructure System

Under this system, waste handlers make minimal use of fixed facilities. Wastes accumulate where

they are generated or handled, stored in truck or

rail tanks or in portable containers. When full, the

tanks or containers are transported to existing port

transfer facilities not dedicated solely to ocean incineration operations. Wastes are pumped or are lifted

in containers onto the vessel. Any blending of

wastes from different sources occurs only on board,

as they are fed to the incinerator. Wastes from

different storage tanks are fed sequentially or simultaneously, to provide the best burning mixture.

SeaBurn, Inc., and Environmental Oceanic

Services Corp. plan to use a variant of this design.

They would use the sealed 5,000-gallon stainless

steel intermodal containers (see discussion of containerization below) to transport wastes from their

sources to the the vessel, avoiding the need for any

dockside handling of uncontainerized wastes.

Existing Infrastructure System

Under this system, waste handlers use port facilities not dedicated solely to ocean incineration.

Blending, preparation, and storage functions are

carried out at existing, centralized facilities that are

entirely separate from the port facility.

Waste Management, Inc., plans to employ such

a system (or to develop an integrated system; see

below) to support Vulcanus operations in the Gulf.

Under the existing system, liquid wastes would be

transported from generators to its testing, blending, and storage facility at Emelle, Alabama.

Blended wastes would be loaded onto trucks for

transport to dockside, and then pumped directly

from the trucks to the vessel.

Integrated System

Under this system, waste handlers use specialized port facilities designed primarily for ocean incineration. The facility receives wastes directly from

generators and maintains onsite testing, blending,

and storage capability for both containerized and

tanked wastes.

At-Sea Incineration, Inc., proposed using such

an integrated port facility to support operation of

its Apollo vessels. Waste Management, Inc., is considering developing such a facility, in lieu of or in

addition to its existing facility at Emelle, Alabama.
110 . Ocean Incineration: Its Role in Managing Hazardous Waste

TECHNICAL COMPARISON OF DESIGNS FO R

OCEAN INCINERATIO N

One major theme of the debate over ocean incineration 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 vessels

differ in several respects that directly bear on the

nature and potential safety of their operations. The

Environmental Protection Agency has not yet thoroughly evaluated the various designs; such an

evaluation must be undertaken if the BAT question is to be resolved.

Given its limited mandate in this study, OTA

has not attempted to develop a comprehensive comparative evaluation. Rather, the following discusi

sion identifies particular design and performance

features that would probably be central issues in

such a comparison. By reference to table 11, the

specific vessels to which this discussion applies can

be identified.

Containerization Versus Bulk Storage

and Transfer

The most obvious difference between existing

I and proposed designs for ocean incineration systems is how cargo is handled and transferred. Two

companies have proposed systems based on a containership concept that would employ 5,000-gallon

stainless steel intermodal tank containers. Intermodal (IM) containers are increasingly used for all

types of cargo throughout the world. An estimated

20,000 IM tank containers designed specifically to

carry liquid commodities are in use worldwide (3).

As the name implies, IM containers can be transported via rail, truck, barge, and ship. Standardized twistlock mechanisms on containers and on vehicle chassis are designed to ensure that containers

are adequately secured during transport.

In specifically applying the containership concept to ocean incineration, waste generators or handlers would fill and seal tank containers and would

transport them by truck or rail to port facilities for

loading onto barges or ships. No blending or other

handling of waste would occur at the ports. IM tank

containers would be mounted on or above deck and

their wastes individually pumped to a feed tank

directly connected to the incinerator. Following

cleaning, tank containers would be returned to

generators for further use.

The containership concept differs from existing

ocean incineration systems, which use more conventional tank trucks and tank farms for land transportation and storage, and large bulk tanks (about

100,000 gallons each) to hold waste onboard the

vessels. As described above, waste blending and

transfer facilities on land are an essential link in

such systems.

The relative advantages and disadvantages of

these two approaches need to be evaluated for all

phases of incineration operations, beginning with

waste generators and ending with handling during

and after shipboard incineration. Advantages and

disadvantages of IM containers are discussed below, for each of several phases of incinerator operation: land transportation, handling, and transfer;

marine transportation; and waste incineration.

First, however, the reader must recognize several

assumptions that apply to this analysis.

In the following discussion of advantages and disadvantages, the intermodal approach is implicitly

compared with the more conventional bulk handling system used by all existing incineration vessels. It is important to recognize that particular features of an individual company’s operation may

greatly affect the extent to which these advantages

or disadvantages are applicable. The discussion is

therefore oriented towards a ‘ ‘generic’ operation,

and wherever possible, relevant information specific to a particular operation is also presented.

In addition, both the bulk and intermodal tank

approaches to handling hazardous cargoes are already widely used. The U.S. Coast Guard believes

that both approaches can be, and are being, carried out safely under appropriate regulation. The

Coast Guard has further indicated that solutions

are available to the problems that are identified below, and can be addressed through proper regulation, thereby rendering both approaches fully viable.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 are

advantageous or that may require additional regulation in order to ensure safe operation.

Land Transportation, Handling, and Transfer

Advantages:

● Tank containers are sealed at the site of generation and before any transportation, so that

wastes do not need to be transferred later on

land or at the port.

● The intermodal nature provides for flexibility in transport, because IM tank containers

can travel to port facilities by truck, rail, or

barge. -

● No special facilities are required at the port,

and individual IM tank containers can be

stored still attached to their chassis while awaiting the arrival of the incineration vessel,

facilitating their movement in the event of an

emergency.

●

●

●

The IM tank container is encased in a rigid

metal protective frame that substantially reduces the risk of breaching the tank in the

event of a rail, highway, or terminal accident.

A large and growing international network for

handling and transporting IM containers is

available.

Wastes from different generators are not

mixed or blended before they are incinerated,

allowing the identity and source of a waste to

be traced in the event of a spill.

Disadvantages. —Although there appear to be

several clear advantages with respect to the IM tank

container itself, transport of these containers, particularly by truck, poses several problems. 3 These

problems are related primarily to the fact that there

—.-. -— —..-

is an insufficient number of chassis designed to

3Another OTA assessment (9) examines hazardous materials transportation in detail and evaluates the relative safety, performance, and

regulation of intermodal and other bulk liquid containers. Much of

the discussion of land transportation using IM tank containers presented here is drawn from that analysis.
112 ● Ocean Incineration: Its Role in Managing Hazardous Waste

transport IM tank containers in a manner that maximizes over-the-road stability and complies with

bridge laws that limit the vehicle weight per axle

and

●

●

●

per wheelbase.

The chassis most commonly used today that

is designed specifically to carry IM containers

is 20 feet in length and equipped with corner

twistlocks; however, for most liquids, a fully

loaded IM tank container mounted on such

a chassis violates bridge laws in most States.

The option of partially filling the tank is not

viable, since it can lead to sloshing of the liquid contents and instability on the road. Use

of a 40-foot chassis with the IM tank container

centrally mounted using twistlocks solves these

problems; however, the number of such chassis

(estimated to be only about 400 in the entire

United States) is far less than the number of

IM tank containers currently in use.

The size, shape, and height of IM tank containers are such that, even when mounted legally on the standard 20- or 40-foot chassis,

they can be inherently unstable: the high center of gravity greatly increases the potential for

roll-over. A specially designed IM chassis

called a “low boy’ addresses this concern, and

is widely used in Europe, but fewer than 100

of these chassis (40-foot, center-mount, and

low boy) are in use in the United States.

Although the number of standard 20-foot chassis possessing twistlock mechanisms is sufficient to accommodate the IM tank containers

currently in use in the United States, their use

on the highway violates bridge laws in many

States. This situation commonly results in the

transport of IM tank containers on flatbed

trucks, ‘‘secured’ by wrapping with chains.

This practice is entirely legal under current

Department of Transportation regulations,

even though it has been denounced by some

trucking industry representatives and has resulted in a number of accidents involving hazardous materials (for example, see ref. 2).

These problems appear to have a straightforward

technical solution: required use of 40-foot low boy

chassis for over-the-road transport of loaded IM

tank containers. Indeed, SeaBurn, Inc., has indicated that it plans to use the 40-foot low boy chassis. SeaBurn intends to have a sufficient number

of these chassis manufactured to support its operation, and to dedicate these chassis exclusively to

such use in order to preclude unauthorized methods of handling its IM tank containers.

Marine Transportation

The containership concept appears to offer several advantages over bulk transport in the marine

transportation phase of ocean incineration. The advantages include the following:

●

●

●

The relatively small volume of waste in each

container should limit the size of a spill in the

event of an accident. Many individual tank

containers would have to rupture to approach

the size of a release that could be expected from

the rupture of one large bulk cargo tank.

Because individual IM tank containers could

be relatively easily salvaged, they would facilitate the retrieval of waste lost overboard.

IM tank containers would be stowed above

deck, and hence above water line. In addition,

an on-deck spill collection system will be utilized, These features would facilitate inspection and leak detection and would reduce the

likelihood that leaks would contaminate bilge

water or the marine environment. The greater

ventilation above deck would reduce the possibility of explosions caused by buildup of reactive gases.

Waste Incineration

In contrast to the advantages of using IM tank

containers with respect to marine transportation,

their use may pose significant disadvantages relative to bulk storage when considering the incineration operation itself. These disadvantages are all

related to the large number of individual tanks involved:

● Because wastes are not blended before being

loaded onto the vessel, a potentially enormous

burden of waste analysis maybe involved. Under the proposed Ocean Incineration Regulation, separate sampling and analysis will be

required for each of the many individual tanks,

before they are accepted by the permittee and

again before they are incinerated. Verification

by EPA that only permissible wastes are accepted for ocean incineration will become

equally burdensome.
Ch. 6—Ocean /incineration Technologies ● 113

● The potential exists for incompatible wastes

to come into contact when tank containers are

switched. Accurate information regarding the

contents of each container and constant control over the sequence in which tank containers

are connected for pumping to the incinerator

will be essential, to a much greater degree than

would be required of the bulk storage approach.

● The reduction in the need for waste handling

on land offered by the IM mode is reversed

during the incineration operation itself. Frequent container switching (on the order of

every few hours) will be required, increasing

the potential for spills or exposure of the crew

to waste materials.

● Whether and how the frequent switching of

containers would affect incinerator performance or necessitate greater surveillance has not

been adequately investigated. For example,

ensuring consistency in waste destruction efficiency when switching from a high-energy

waste to a low-energy waste would probably

require adjustments in waste feed rate, use of

auxiliary fuel, air flow, and other parameters.

Despite the clear differences between the bulk

and containerized modes with regard to handling

and incineration, the proposed Ocean Incineration

Regulation contains no provisions specifically addressing containerized wastes. Provisions governing tank containers have been developed internationally and are incorporated into the London

Dumping Convention’s Technical Guidelines for

Ocean Incineration.

Again, it is important to acknowledge that technical and regulatory solutions exist, or can be

developed, to address the potential problems associated with both the bulk and containerized approaches, and to provide for their use to full advantage. The above discussion is intended to highlight

areas where further attention may well be needed,

rather than to detract from the merits of either approach. Based on OTA’s limited analysis of the

containership concept in relation to bulk transport,

further study will be necessary to determine whether

either approach provides a clearly superior technology for waste handling.

Self-Propelled Versus Barge Vessels

One company has proposed using an oceangoing barge-tug combination for ocean incineration. A total of one hundred and forty-four 5,000 -

gallon IM tank containers and up to four incinerators would be mounted on the barge. Such a vessel would have a shallow draft, which would allow

it access to virtually any port facility.

Concerns have been raised about the relative

safety and maneuverability of a barge system. Unfortunately, data that can be used to evaluate the

safety of the type of ocean-going barge proposed

for use in ocean incineration are largely unavailable. The U.S. Coast Guard maintains a database

that records all reported hazardous materials spills

to U.S. waters (10). Data for 1982 and 1983 indicate an accident rate for tank barges double that

for tank ships. These data include barges of all types

used to carry oil or hazardous substances, however,

including those operating on rivers or other inland

waters. Indeed, with respect to both the number

of accidents and the quantities of material released,

the vast majority involved oil released to inland

waters. For spills involving hazardous substances

rather than oil, the number of releases was twofold higher for tank barges, but the quantities released were actually slightly higher for tank ships.

Several features of the ocean incineration barge

proposed by SeaBurn, Inc., should greatly reduce

the risk of a release of waste in the event of an accident, 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 requirements applicable to ocean incineration vessels.4 According to SeaBurn, Inc., no other such

barges currently exist in the world’s fleet. Second,

the proposed barge is ocean-going and has a ship’s

bow, unlike the barges involved in the vast majority

of reported accidents. Given these and other features, SeaBurn, Inc., argues that its barge will be

in a safety class all its own. 5

‘Coast Guard regulations for chemical carriers specify three levels

of cargo containment systems, Type I affording the highest degree

of containment. See 46 CFR 172 for a description of these construction requirements.

‘V. G. Grey, President, SeaBurn, Inc. , personal communication,

May 16, 1986.
114 ● Ocean Incineration: Its Role in Managing Hazardous Waste

As proposed, the SeaBurn barge would be towed

behind an ocean-going tug, a feature which somewhat reduces its maneuverability relative to existing ocean incineration vessels possessing bow

thrusters. However, the U.S. Coast Guard indicates that a barge-tug system can be operated safely,

even in confined areas, particularly when accompanied by the other navigational controls (e. g., a

moving safety zone) that are to be applied to ocean

incineration vessels. G

Despite the factors discussed above, regulations

governing construction, inspection, and other

aspects of an ocean incineration system employing

a towed barge should be carefully examined to ensure that the requirements are adequate and commensurate with those applicable to self-propelled

systems.

Seawater Scrubbers

Existing ocean incineration systems are designed

to vent combustion gases directly upwards into the

atmosphere, which raises concerns about the potential for subsequent adverse impacts on the marine environment and at least the nearest shorelines.

As an alternative, two companies have proposed

a system in which combustion gases would pass

through a scrubber-like device prior to discharge.

A deluge of seawater would physically wash the exhaust stream. In contrast to a true scrubber, however, the seawater scrubber would immediately discharge the untreated scrubbing effluent into the

ocean. Thus, the scrubber would alter the location

and nature, but not the quantity, of the discharge

to the marine environment.

A seawater scrubber would alter incinerator

emissions in two major respects, by affecting both

the partitioning and the temperature of emissions.

Each of these differences offers potential advantages

and disadvantages (see below).

Although a seawater scrubber would greatly affect the nature of incinerator emissions, data are

currently insufficient for determining whether the

addition of seawater scrubbers to ocean incineration vessels would provide any improvement over

the technology presently employed. Further study

sThese comments were received through the review of a draft of

this report by the U.S. Coast Guard.

may provide a basis for such a determination in

the future.

Partitioning of Emissions

A seawater scrubber would divide emission components into two parts: those discharged in the

scrubbing effluent; and those not removed through

scrubbing and therefore emitted to the atmosphere.

Acidic gases (typically hydrogen chloride) would

be expected to be mostly neutralized during the

wash, because of the natural buffering capacity of

seawater. Any residual acid would be rapidly neutralized after the effluent was discharged to the

ocean. In addition, during the scrubbing, some of

the particulate and organic components of the emissions would become dissolved or become suspended

in the effluent.

A seawater scrubber would significantly reduce

the quantity of contaminants emitted to the atmosphere, but would discharge contaminants into the

ocean at much higher concentrations than those resulting from contact of an unscrubbed plume with

the ocean surface (12).

Plans call for the scrubbing effluent to be discharged directly into the wake of the vessel to maximize mixing and dispersion of trace contaminants.

Being warmer than ambient seawater, however, the

scrubbing effluent would tend to remain at, or rise

to, the surface (12). The potential for these concentrated and heated discharges to affect surfacedwelling organisms (including the so-called microlayer; see ch. 9) has not been examined.

In contrast, emissions from vessels not employing seawater scrubbers would disperse and settle

out over the ocean surface, affecting a larger area,

but introducing contaminants at lower concentrations.

Temperature of Emissions

Seawater scrubbers would also quench (i.e., cool)

exhaust gases, reducing their exit temperature from

about 2,5000 F to below 3000 F. This would have

two practical effects on incinerator emissions. First,

the plume would be less buoyant and would, therefore, not rise as far above the ocean surface. This

effect would tend to decrease the time required for

the plume to settle on the ocean surface, thereby

decreasing the size of the affected area, but also in-
Ch. 6—Ocean Incineration Technologies ● 115

creasing concentrations at the surface. As indicated

previously, this increase in the concentration of incineration products would be expected to exert relatively greater effects on surface organisms residing

in the smaller affected area.

Second, because sampling of stack gases is complicated by the high exit temperatures as well as

by the corrosivity typical of ocean incineration emissions, a scrubber might help to simplify emissions

monitoring and reduce damage to sampling devices. On the other hand, sampling of emissions

for particulate (see ch. 7) could become more difficult or impossible, because particulate might be

washed out of the plume before they could be sampled. Significant quantities of unburned wastes or

products of incomplete combustion (PICs) can be

bound to such particulate after exhaust gases hav’e

cooled or condensed ( 1). In the absence of corrective measures, this effect could significantly compromise the reliability of sampling for the purposes

of calculating a destruction efficiency.

Clearly, further research into the advantages and

disadvantages of seawater scrubbers will be necessary to determine whether they represent best available technology. As discussed in chapter 1, based

on available information, there appears to be little

need for scrubbers on ocean incineration vessels if

proper controls are placed over waste content and

operating conditions.

Combustion Chambers

Existing and proposed technologies also differ

with respect to the design and orientation of the

combustion chamber itself. Existing vessels carry

vertically mounted single-chamber incinerators,

whereas two proposed designs would use horizontally mounted two-chamber units.

Proponents of the horizontal orientation argue

that it is the only design that could accommodate

a seawater scrubber and two combustion chambers,

and that the design would also help to reduce plume

altitude. Passage of wastes through two combustion chambers should at least theoretically increase

residence time and enhance destruction efficiency.

However, confirmation of these claims must await

the development and testing of such an incineration vessel. Moreover, because two chambers are

not considered necessary to achieve high destruction efficiencies of liquid wastes in land-based incinerators (see ch. 2), requiring their use in ocean

incineration appears premature. Although EPA’s

reliance on performance rather than design standards does not negate the need for further investigation into combustion chamber design, it represents a reasonable regulatory approach at the

present time.

Burner Types

Incinerator burners serve several important functions, including atomization (i. e., fine droplet formation) of wastes. The degree of atomization can

be an important determinant of overall destruction

efficiency because it affects the mixing rate of waste

and air in the combustion zone. The ocean incineration vessels that are currently operating employ

a traditional European-designed burner that

atomizes incoming waste using a mechanical device (rotary CUP or vortex). Those vessels recently

built or planned for construction in the United

States would use a U.S.-designed spray nozzle injection system for atomization. According to EPA,

most land-based incinerators in the United States

also employ the spray nozzle design (11 ).

Although the mechanical design for atomizing

wastes is allowed by EPA, considerable controtersy

exists over the adequacy of its performance. Critics

argue that the use of rotary cup burners is being

discontinued or even prohibited because of’ insufficient atomization and excessive .sensitivity to operating conditions like waste feed rate and vibration

(see refs. 4 and 5, and other references therein).

Proponents argue that studies specifically designed

to assess the performance and degree of atomization

of mechanical burners have found them comparable

to other designs ( 1), and that the very short flame

length generated by mechanical burners yields high

combustion efficiencies (6).

According to EPA, insufficient data exist to

correlate burner design with incinerator performance. Because burner design is only one of many

factors (e. g., operating conditions, combustion

chamber geometry) that affect incinerator performance, EPA has chosen to rely on performance rather

than design standards in formulating both landbased and ocean incineration regulations (1 1).

Thus, although further study of this issue is warranted, no consensus currently exists as to the best

available technology for atomizing waste.
116 Ž Ocean Incineration: Its Role in Managing Hazardous Waste

1.

2.

3.

4.

5.

I

6.

7.

I

CHAPTER 6 REFERENCE S

Ackerman, D. G., et al., The Capability of Ocean

Incineration—A Critical Review and Rebuttal of

the Kleppinger Report (Redondo Beach, CA:

TRW Energy and Environmental Division, 1983).

Douglas, J., and Grothaus, D., “Trucker Dies in

Fiery 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 Incineration of Hazardous Waste: A Critique (Washington, DC: EWK Consultants, Inc., 1983).

Kleppinger, E. W., and Bond, D. H., Ocean Incineration of Hazardous Waste: A Revisit to the

Controversy (Washington, DC: EWK Consultants,

Inc., 1985).

Lankes, W., “Incineration 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.

Marcus, H. S., and Daniel, C. T., Logistical Systems To Support Ocean Incineration of Liquid

Hazardous Wastes, prepared for U.S. Department

of Transportation, Maritime Administration, Office of Maritime Technology, Maritime Administration Research & Development (Washington,

DC: August 1982).

8<

9.

10.

11.

12.

Marcus, H. S., and Glucksman, M. A., Planning

a Port Interface for an Ocean Incineration System,

prepared for the U.S. Department of Transportation, Maritime Administration (Springfield, VA:

National Technical Information Service, August

1985).

U.S. Congress, Office of Technology Assessment,

Transportation of Hazardous Materials, OTASET-304 (Washington, DC: U.S. Government

Printing Office, July 1986).

U.S. Department of Transportation, U.S. Coast

Guard, Polluting Incidents In and Around U.S.

Waters, Calendar Years 1982 and 1983, Commandant Instruction M16450.2F (Washington, DC:

1983).

U.S. Environmental Protection Agency, Office of

Policy, Planning and Evaluation, “Background

Report I: Description of Incineration Technology, ”

Assessment of Incineration as a Treatment Method

for Liquid Organic Hazardous Wastes (Washington, DC: March 1985).

U.S. Environmental Protection Agency, Science

Advisory Board, Report on the Incineration of Liquid Hazardous Wastes by the Environmental Effects, Transport and Fate Committee (Washington,

DC: April 1985), p. 21.
Chapter 7

Comparison of Land-Based and

Ocean Incineration Technologies
Contents

Page

Composition of Incineration Products . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. ....119

Plume Gases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...119

Residual Parent Compounds and Products of Incomplete Combustion (PICs) . ........119

Metals and Particulate. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1’20

Solid Residues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ............121

Comparison of ’Technical and Regulatory Requirements. . . . . . . . . . . . . . . . . . . . . . ........122

Waste Analysis and Waste Limitations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..122

Performance Standards . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .......123

Operating Conditions . . . . . . . . . . . . . . . . . . , . 125

Air Pollution Control Technology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..............127

Sampling and Monitoring Requirements and Procedures . . . . . . . . . . . . . . . . . . . . . .. ...128

.Additional Provisions Not Required of Land-Based Incineration . . . . . . . . . . . . . ..129

Chapter 7 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..129

Table

Table No. Page

12. Performance Standards Applicable to Land-Based and Ocean Incineration. . . .124
Chapter 7

Comparison of Land-Based and

Ocean Incineration Technologies

Although liquid organic wastes are currently This chapter describes the nature of the combusmanaged in various ways, ocean incineration’s pri- tion products arising from both land-based and

mary competition and closest analog is land-based ocean incineration and compares and contrasts their

incineration. Therefore, it is important to compare respective technical and regulatory requirements.

and contrast their technical features, the nature and

extent of their regulation, and their relative risks

of environmental release and adverse impacts.

COMPOSITION OF INCINERATION PRODUCT S

The products resulting from incineration of hazardous waste, whether on land or at sea, can result from complete or partial thermal oxidation of

waste components. The products can be grouped

as follows: plume gases, residual parent compounds, products of incomplete combustion (PICs),

metals and particulate, and solid residues. A brief

description of each category is provided below.

Plume Gases

Total combustion of simple, nonhalogenated

chemicals generates carbon dioxide and water as

end products. If combustion is incomplete, carbon

monoxide is also formed, and its level in emissions

indicates the degree of incomplete combustion. Incineration of halogenated compounds generates acid

gases (e. g., hydrogen chloride) and much smaller

amounts of chlorine gas, in addition to carbon dioxide and water. The incineration of liquid wastes

containing sulfur or nitrogen can produce a variety of sulfur oxides and nitrogen oxides.

Except for acid-forming emissions (dominated

by hydrogen chloride), the Environmental Protection Agency (EPA) has not promulgated or proposed regulations limiting emissions of stack gases

from hazardous waste incinerators. Relative to

larger combustion sources like powerplants, the incinerators probably are a relatively minor source

for most of these pollutants. For certain wastes or

in certain geographic settings, however, hazardous

waste incineration may contribute significantly to

the risks posed by hazardous air pollutants.

Residual Parent Compounds and Products

of Incomplete Combustion (PICs)

Parent compounds refer to those present in the

original waste, a small fraction of which pass

through the incinerator intact. PICs include both

partially destroyed compounds and new chemical

compounds not originally present in the wastes.

PICs, which all types of combustion processes generate to some degree, include a wide range of compounds that are apparently synthesized during or

immediately after combustion through chemical reactions or the recombining of molecular fragments.

PICs often bear little or no resemblance to the

parent compounds from which they were derived;

nor does the presence of a particular PIC necessarily correlate with the presence of a particular

waste component. Very little is understood about

how PICs are formed. They have been detected in

the emissions from burning a wide range of materials, both hazardous and nonhazardous (e. g., municipal garbage, wood). The generation of PIGs

might be correlated with the level of oxygen present

during incineration and with the completeness of

combustion.

Both dioxin and dibenzofuran compounds,

known to be highly toxic to humans and in the envi119
120 ● Ocean Incineration: /ts Role in Managing Hazardous Waste

I

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ronment, have been identified among PICs produced from incinerating various materials, including municipal garbage. Our understanding of the

public health significance of these emissions, or even

their major sources, is far from complete.

The quantities of both residual parent compounds and PICs present in incinerator emissions

vary with operating conditions, such as residence

time, turbulence, and temperature. An EPA study

of land-based hazardous waste incinerators (13)

found that the concentrations of PICs in the stack

gases were typically as high as the concentrations

of parent compounds, but that both were rarely

above 0.01 percent of the concentration of the parent compounds in the original waste. EPA’s Science Advisory Board’s analysis of available studies

characterizing emissions from land-based incinerators, however, led the Board to conclude that:

It is apparent that even with the uncertainties

related to sampling efficiencies and inadequate

chemical analyses, as much as 1 percent of the

mass of the waste feed could exit an incinerator

as compounds other than carbon dioxide, carbon

monoxide, water, and hydrochloric acid. (16)

Under such conditions, a total destruction efficiency (DE) of only 99 percent would be achieved,

even though a much higher DE would probably be

measured under EPA’s current definition (see discussion of DE in ch. 2).

With respect to ocean incineration, EPA was unable to detect any dioxins or dibenzofurans in stack

emissions from the Vulcanus ships burning poly -

chlorinated biphenyls (PCBs) or the defoliant Agent

Orange. Questions have arisen, however, about the

adequacy of sampling and analytic methodology

employed during those monitoring efforts (see refs.

3, 16; also see discussion of past U.S. burns in

ch. 11).

EPA is currently devoting considerable effort to

characterizing the PICs that result from hazardous waste incineration, and the Agency considers

it a research priority. PICs are currently unregulated, although EPA proposed regulations under

the Resource Conservation and Recovery Act

(RCRA) in 1981 (46 FR 7684, Jan. 23, 1981). The

proposed Ocean Incineration Regulation would not

include any specific limits on the emissions of PICs,

pending further study, but EPA is considering two

approaches to their possible future regulation (see

ch. 2, and proposed Ocean Incineration Regulation, 50 FR 8247, Feb. 28, 1985).

Metals and Particulate

These incineration products are the largely noncombustible, inorganic (mineral) remainder from

the combustion of waste. In addition, substantial

amounts of particulate matter are sometimes derived from the refractory firebrick lining of the combustion chamber, itself. How much of these products are generated depends on the type of waste

incinerated; for example, the quantity of particulate from incineration of liquid wastes is generally significantly less than from incineration of solid

wastes.

Because metals are not destroyed by incineration, those present in the waste feed are either deposited in ash residues or are emitted from the combustion chamber. Metals can be emitted in either

a particulate (solid) or a volatilized (gaseous) state.

Control strategies and environmental behavior vary

considerably for these two forms and from metal

to metal.

Incineration can

of metals in several

discussed below.

alter the form and properties

important respects, which are

Volatilization

The high temperatures typically employed in

hazardous waste incinerators can volatilize heavy

metals that are present in the waste; the degree of

volatilization varies with the incinerator’s operating conditions, and from metal to metal. Mercury,

cadmium, and lead are generally considered most

problematic because they are easily volatilized and

are harmful if inhaled by humans. Although few

data are available for hazardous waste incineration,

one study examined the release of metals from incineration of sewage sludge at 1,6000 F in a facility possessing air pollution control equipment (6).

At least 20 percent of the lead and cadmium, and

essentially all of the mercury, were emitted because

of the scrubber’s low efficiency at removing volatilized metals.
Ch. 7—Comparison of Land-Based and Ocean Incineration Technologies . 121

Volubility

Incineration can also alter the chemical form and

volubility of metals found in wastes, thereby altering the metals’ potential availability and routes of

exposure to organisms or humans. For example,

incineration might change a water-insoluble form

of cadmium in an organic wastestream to a more

soluble form; when the resultant ash is disposed of

in a landfill, the cadmium would be more likely to

leach into nearby groundwater. Incineration increases the water volubility of cadmium and copper and decreases the water volubility of chromium,

nickel, and lead (4).

Bioavailability 1

Incineration can alter the bioavailability of certain metals. The ability of living organisms to absorb and detoxify a particular metal greatly depends

on the metal’s chemical form. Because metal chemistry can be greatly altered by high temperature,

the potential for incineration to increase or decrease

the bioavailability of a metal must be considered.

Although this problem has been insufficiently studied, some data indicate that incineration increases

the bioavailability of arsenic and chromium (4).

Although emissions standards for specific metals

do not exist, for either land-based or ocean incineration, EPA has limited the total allowable quantity of particulate material from land-based incinerators, which should lower emissions of those metals

bound to particulate matter. For ocean incineration, EPA has proposed limiting the individual concentrations of particular metals in waste accepted

for incineration and, furthermore, the concentrations of metals in the final blended waste, as a

means of reducing the quantity of emitted metals

(see next section). Many observers, however, have

called for further characterization and regulation

of actual metal emissions, based on their potential

contribution to the risk posed by hazardous air pollutants (see chs. 2 and 9).

‘A bioavailable metal is one that can be taken up by a living organism

and incorporated into its makeup or metabolic processes. Only certain metals, and only certain chemical forms of metals, are taken up,

and the bioavailability of a particular metal also varies from one organism to another.

Solid Residues

These products include ash left behind in the

combustion chamber and wastes generated when

air pollution control equipment (e. g., scrubber

sludges) is used.

Ash

The quantity and composition of ash resulting

from incineration varies widely and primarily depends on the waste itself. For example, incineration generates substantially greater amounts of ash

from solid wastes than from liquid wastes. Operating conditions can also influence the quantities

of residuals. Ocean incineration typically produces

very little or no ash, although periodic cleaning of

the combustion chamber is necessary to remove

slag.

Sludges and Dusts

Land-based incinerators that employ air pollution control equipment generate additional waste,

including sludges and effluents (from the use of wet

scrubbers) and dusts (from the use of dry scrubbers and other collection devices). The quantity of

these additional wastes, which can be substantial

(see ch. 8), depends on what waste is incinerated.

The existing regulations governing land-based

incinerators (40 CFR 261 .3(c)2) and those proposed

for ocean incineration (50 FR 8268, Section 234.56(j),

Feb. 28, 1985) define ash and pollution control

residues as hazardous wastes and specify that they

be handled as such. Under RCRA, however, a variance can be granted if the residue is shown to be

nonhazardous (Sections 264.351 and 261 .3(d)).

Residues can also be delisted on a case-by-case basis

by the EPA Administrator, under a provision of

the 1984 RCRA Amendments.

The latter procedure may be used to delist

residues from incineration of dioxin-contaminated

materials generated by a mobile incinerator operating in Times Beach, Missouri (5). It may also

be used to reclassify such residues as hazardous,

rather than acutely hazardous (the designation

given to all dioxin-contaminated materials). EPA

sees such a step, which would significantly ease residue disposal requirements, as necessary to encourage incineration of dioxin wastes, but the reasoning is based on a controversial model of dioxin

toxicity (7).
722 . Ocean Incineration: Its Role in Managing Hazardous Waste

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,

COMPARISON OF TECHNICAL AN D

REGULATORY REQUIREMENT S

This section summarizes and compares the various regulatory provisions that impose technical requirements on the use of land-based and ocean incineration. For land-based incineration, references

are generally to EPA’s Incinerator Standards for

Owners and Operators of Hazardous Waste Management Facilities (46 FR 7666-7683, Jan. 23,

1981) and subsequent amendments (47 FR 27516-

27535, June 24, 1982), developed under the statutory authority of RCRA. For ocean incineration,

references are to the proposed Ocean Incineration

Regulation (50 FR 8222-8288, Feb. 28, 1985),

which was developed under the statutory authority of the Marine Protection, Research, and Sanctuaries Act (MPRSA).

Waste Analysis and Waste Limitations

An operating permit for either land-based or

ocean incineration must specify what range of

wastes an incineration facility has demonstrated its

capability to satisfactorily treat. This range of wastes

must be specifically tested in a trial burn. In specifying the wastes, the permit may limit waste composition, if necessary to meet performance or emissions standards. Some limitations are specific to a

particular facility, whereas others apply to all incinerators.

Regulations for both land-based and ocean incineration require facility operators to perform periodic waste analyses in order to identify constituents to which performance standards apply (see

below) and to ensure compliance with the terms of

operating permits. The stringency of this requirement, however, differs considerably. For ocean incineration, a waste analysis would be required before each voyage; for land-based incineration, an

analysis is required only when requested by EPA.

Wastes to be incinerated on land must be characterized with respect to the following:

●

●

●

●

heat value,

viscosity,

physical form, and

identification and approximate quantification

of RCRA-hazardous organic constituents.

The waste description required for ocean incineration is somewhat more extensive than that for landbased incineration. In addition to those listed above,

the following waste properties or components must

be identified:

•

●

●

●

●

●

moisture, solid, and ash content;

specific gravity (density);

presence of polychlorinated terphenyls;

main inorganic constituents;

halogens, sulfur, and nitrogen constituents;

and

other organic compounds not listed as hazardous under RCRA.

Limitations on chlorine content are commonly

written into operating permits for land-based incinerators, in order to meet emissions standards or

to stay within the operating limits of scrubbers.

Solid or metal content may be similarly limited.

If PCBs are to be incinerated, maximum concentrations of PCBs in the waste are specified for both

land-based and ocean incineration.

Under the proposed Ocean Incineration Regulation, two additional kinds of waste limitations

would be specified. First, EPA would specifically

limit how much of each of the following 14 metals

could be present in waste accepted for incineration

at sea:

aluminum iron silver

arsenic lead thallium

cadmium mercury tin

chromium nickel zinc

copper selenium

Concentrations would be limited to a maximum

of 500 parts per million (ppm) per metal. No limits

on the aggregate quantity of metals in the waste

or in the emissions would be specified.

Second, certain metals (and potentially other substances) would be limited by a proposed environmental performance standard (see next section).

Under the standard, concentrations of particular

waste constituents in the final blended waste to be

incinerated would be limited to amounts that would

prevent the resulting mixture of incinerator emissions and seawater from exceeding marine water
Ch. 7–Comparison of Land-Based and Ocean Incineration Technologies ● 123

quality criteria.2 EPA has determined that limits

for mercury, silver, and copper would have to be

below 500 ppm to meet marine water quality criteria (50 FR 51362, Dec. 16, 1985).

Both technical and regulatory distinctions between land-based and ocean incineration account

for the differences in waste limitations and requirements for waste analysis. Limitations on chlorine

content are not considered necessary for ocean incineration, because of natural seawater’s ability to

neutralize hydrochloric acid gas. This phenomenon is also the reason EPA would not require incineration vessels to carry air pollution control

equipment. Because the lack of scrubbers would allow the emission of essentially all metals present

in the waste, however, the metal content of wastes

incinerated at sea would be strictly controlled.

The waste analysis requirements are more stringent for ocean incineration than for land-based incineration, partly because the two activities are regulated under entirely different statutes. Ocean

incineration falls under the definition of ocean

dumping specified in MPRSA. In general, international and domestic regulation of ocean dumping has strictly controlled the types of waste that

could be dumped and has, therefore, mandated extensive waste analysis as a condition for obtaining

permits.

Performance Standards

EPA’s approach to regulating land-based and

ocean incineration has relied primarily on standards for incinerator performance rather than standards governing incinerator design. Thus, any facility that possessed a combination of design

features capable of meeting minimum performance

standards would be eligible for an operating permit. This capability has typically been demonstrated by trial burns carried out prior to the granting of operating permits. For ocean incineration,

EPA has proposed a combination of incinerator performance and environmental performance stand-

‘w’here there are no critera, the mixture could not exceed a marine aquatic life no-effect level or a toxicity threshold defined as 1 percent of an ambient marine water concentration shown to be acutely

toxic to appropriate sensitive marine organisms (in a bioassay carried out in accordance with EPA-approved procedures). Marine water

quality criteria have been developed for each of the 14 metals specified by EPA,

ards. The latter are proposed as alternatives to the

land-based incinerator performance standards governing hydrogen chloride and particulate emissions.

Table 12 summarizes incinerator and environmental performance standards applicable to landbased and ocean incineration facilities. Each of

these standards is defined and discussed below.

Combustion Efficiency (CE)

This measure of incinerator performance indicates the overall efficiency of the combustion process

and can be monitored on a continuous basis. CE

is represented by the relationship between the concentrations of carbon dioxide (CO2) and carbon

monoxide (CO) in the incinerator exhaust:

CE = [C O2 - [co ] x 100

[C02 ]

The CE standard is more stringent for ocean than

for land-based incineration in two respects: the

standard applies to all wastes, not only PCBs; and

it is numerically higher (see table 12). The higher

value is required because regulations promulgated

under MPRSA must equal or exceed international

regulations developed under the London Dumping

Convention, which specifies a minimum CE of

99.95 *0.05 percent for all wastes.

Destruction Efficiency (DE) or Destruction

and Removal Efficiency (DRE)

These measures of incinerator performance indicate the extent to which particular compounds

that were present in the waste feed are absent from

emissions. DE and DRE must be calculated

separately for each designated compound and, because the chemical analysis is complex and timeconsuming, cannot be determined on a continuous basis. Consequently, the usefulness of DE and

DRE in monitoring incinerator performance is

limited.

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 particular

compound in the waste feed and IWout] is the concentration of the same compound in the emissions

vented to the atmosphere.
—.

124 . Ocean Incineration: Its Role in Managing Hazardous Waste

t

I

I

I

I

,

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, Planning

and 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) and

subsequent 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 that

any removal of compounds accomplished by air pollution control equipment is included in the calculation of DRE, because DRE is measured after the

devices have acted on emissions. Because air pollution control equipment is generally poor at removing organic constituents (2, 13, 15), however,

DE and DRE are often functionally equivalent.

The waste destruction standard would be identical for land-based and ocean incineration (see table

12). Thus, despite their lack of scrubbers, incinerator vessels would have to achieve an emission rate

for organic materials no higher than that allowed

for land-based facilities.

Hydrogen Chloride (HC1) Emissions

Incineration of chlorinated wastes generates

highly corrosive HCl gas. On land, if the rate of

HCl production exceeds 1.8 kg/hr (4 lbs/hr), scrubbers must be employed to limit emissions to less

than that amount or to remove 99 percent of the

total, whichever results in the larger emission. EPA

regards 99 percent removal as achievable using current technology.

For a land-based incinerator operating at median

capacity (1 ,250 lbs/hr), any waste whose chlorine

content was greater than 0.3 percent could be expected to exceed the HCl emission limitation of 4

lbs/hr and, hence, would require a scrubber. Once

equipped with a scrubber that achieves 99 percent

HCl removal, the same facility could incinerate

waste with a chlorine content of up to about 30 percent without emitting more than 4 lbs/hr of HCl.

Incineration of waste with a chlorine content

greater than 30 percent would be legal as long as

99 percent of the HCl were removed, but other

practical constraints (e. g., corrosion, scrubber capacity, formation of chlorine gas) limit chlorine content to a maximum of about 35 percent.

For ocean incineration, EPA has proposed an

environmental performance standard that would

limit emissions to an amount that would result in

no more than a 10 percent change in alkalinity of

seawater in the release zone, measured 4 hours after release. EPA has calculated that this standard

would be met even for incineration of pure carbon

tetrachloride, whose chlorine content is over 90 percent, at the very high feed rate of 25 metric tons

per hour, Given the significantly lower chlorine

content and feed rates that would realistically be

employed, it is highly unlikely that this environmental performance standard would ever be exceeded.

Particulate Emissions

The existing particulate standard for land-based

incinerators is 180 mg per dry standard cubic meter, measured after correction to 50 percent excess

air. The correction is designed to prevent operators 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 actually controlling particulate.

The rationale for controlling particulate is twofold: First, particulate matter itself can be hazardous, because it can include toxic metals, which are

not destroyed during incineration; and second,

other hazardous constituents, including unburned

or partially burned organic compounds, can adsorb

to particulate matter. Although the chemical analysis used to calculate DRE accounts for unburned

parent compounds bound to particulate matter, the

DRE standard does not in any way measure or limit

partial combustion products (e. g., PICs) or metals.

The particulate standard applicable to land-based

hazardous waste incinerators is identical to that required of municipal incinerators under the Clean

Air Act’s New Source Performance Standards (12).

For ocean incineration, EPA has proposed an

environmental performance standard for metals instead of establishing a direct particulate emissions

standard. The proposed environmental standard

would limit incinerator emissions so that:

. . . the effect of the emissions would not unreasonably degrade or endanger human health, welfare, or amenities, or the marine environment,

ecological systems, or economic potentialities or

recreational or commercial shipping or boating or

recreational use of beaches or shorelines (Section

234.48(b) of EPA’s proposed Ocean Incineration

Regulation, 50 FR 8266, Feb. 28, 1985).

EPA has interpreted this rather vague language

to mean that concentrations of particular constituents in wastes to be incinerated would be limited

to amounts that would prevent the resulting mixture of incinerator emissions and seawater from exceeding marine water quality criteria.3

This standard would theoretically apply to any

substance present in incinerator emissions. In practice, however, criteria and toxicity thresholds have

been developed for few chemicals, and this standard would primarily be used to limit metal concentrations allowed in wastes incinerated at sea. Because liquid wastes suitable for ocean incineration

typically generate low levels of particulate, EPA

considers the proposed limitations to be a justifia3See footnote 2.

ble alternative to requiring particulate control devices on incinerator vessels.

Although the environmental performance standard appears to address harmful metal emissions,

whether it can adequately control emissions of PICs

associated with particulate is controversial. EPA

argues that at the high temperatures employed in

ocean incineration, essentially all organic compounds would be in a volatilized state and not adsorbed to particulate matter. Thus, particulate

removal equipment would not help to reduce PIC

emissions (l). However, some observers argue that

certain organic compounds, including PCBs, dioxins, and dibenzofurans, can to some extent associate with particulate matter even at high temperatures. In addition, these observers maintain, other

mechanisms exist for including organic matter in

the particulate fraction of incinerator emissions

(9,10).

Further research will probably be essential for

resolving this controversy. EPA’s proposed research

strategy for ocean incineration would include tests

designed to address the issue (14).

Operating Conditions

Operating permits for both land-based and ocean

incineration facilities specify sets of operating conditions that were demonstrated in trial burns to be

capable of achieving the performance standards discussed above. A set of conditions is determined for

each waste feed expected to be burned. Periodic

waste analyses must be performed to demonstrate

that wastes actually incinerated are within the range

for which a permit is written.

Land-Based Incineration

For land-based incinerators, each set of operating conditions includes limits on at least the following parameters:

●

●

●

●

the carbon monoxide level in the exhaust stack

gas (indicates combustion efficiency, completeness, or upset);

waste feed rate;

combustion zone temperature, with location

of sensor specified;

appropriate indicator of combustion gas ve-
126 • Ocean Incineration: Its Role in Managing Hazardous Waste

locity (indicator of residence time in the combustion zone); and

. air pollution control device operating conditions.

In addition to these waste feed-specific conditions,

several operating requirements are uniformly applied to all land-based incinerators:

●

●

●

during startup and shutdown, hazardous

wastes cannot be fed to incinerators unless they

are operating under specified conditions;

combustion zones must be completely sealed

and maintained under negative pressure in order to control fugitive emissions; and

automatic shutoff systems must be employed

to halt waste feed when operating conditions

deviate from specified limits.

Incineration of PCBs requires separate approval

from the Assistant Administrator of the Office of

Pesticides and Toxic Substances, in compliance I

with 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-based

incineration facility.

Other operating conditions are allowed if they

can be demonstrated to achieve the required DRE.

Ocean Incineration

The proposed Ocean Incineration Regulation

would also use a trial burn to determine appropriate sets of operating conditions and waste feeds. For

certain wastes specified in London Dumping Convention (LDC) regulations, if a contracting party

to the Convention “has doubts as to the thermal

destructibility of the wastes, ” then a separate test

burn would have to be conducted to ensure that

all standards could be met. Because of the anticipated difficulty in achieving their complete thermal destruction, the following wastes would receive

special attention:

● polychlorinated biphenyls (PCBs);

• polychlorinated terphenyls (PCTs);

● tetrachlorodibenzo-p-dioxin (TCDD);

● benzene hexachloride (BHC); and

● dichlorodiphenyl trichloroethane (DDT).

EPA considers available data sufficient to document

the ability of incinerators to destroy PCBs, BHC,

and DDT to the level specified by the LDC (50 FR

8228, Feb. 28, 1985). Because a 99.9999 percent

standard applies to PCBs and TCDD and data are

lacking for PCTs, however, test burns would be

mandated for these three substances.

Operating permits for incineration vessels would

have to specify allowable limits for at least two operating conditions:

gases, and

. waste feed rate t. the incinerator.

The proposed regulation specifically sets limits

on 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 in

the combustion gases; and

residence time in the combustion zone of at

least 1.0 second.

all of these except residence time, alternate

values could be substituted in the operating permit, if other conditions were demonstrated in a trial

burn to be capable of achieving the performance

standards.
Ch. 7—Comparison of Land-Based and Ocean Incineration Technologies • 127

The proposed regulation also specifies a set of

general operating requirements that would apply

to all vessels at all times:

●

●

●

●

no black smoke or flame may extend above

the stack plane;

between startup and shutdown, hazardous

waste could not be fed to incinerators unless

they were operating under specified conditions;

automatic shutoff systems would have to be

employed to halt waste feed when operating

conditions deviated from specified limits; and

all residues would have to be incinerated at

sea or transported back to land for proper

disposal.

This comparison of requirements for operating

conditions shows that the proposed Ocean Incineration Regulation generally tends to specify values

for more operating parameters and leaves less to

the judgment of individual permit writers than do

the regulations governing land-based facilities.

Air Pollution Control Technology

Effect of Scrubbers on Emissions From

Hazardous Waste Incinerators

Currently available air pollution control equipment generally controls emissions of particulate

and acidic gases very effectively but removes organic compounds (parent compounds and PICs),

certain metals (e. g., mercury), and nitrogen oxides

very poorly.

An EPA study of land-based incinerators found

that, for various wastestreams, scrubbers had little or no detectable effect on the levels of unburned

waste (parent compounds) present in emissions

(13). Based on these and other data, air pollution

control devices cannot be expected to remove residual parent compounds or PICs from incinerator exhausts or to provide an extra margin of safety

in the event of operation upset (2, 15).

Although scrubbers effectively control emissions

of particulate metal oxides and gaseous sulfur oxides, controlling volatilized metals and nitrogen oxides is exceedingly difficult, particularly for hazardous waste incinerators, This is because: 1) wet

scrubbers are ineffective at removing them; and 2)

other control measures often entail decreasing the

operating temperature, which must be maintained

to ensure complete combustion of hazardous wastes.

Land-Based Incineration

Scrubbers are required for land-based incinerators that burn wastes whose chlorine or particulate

content would otherwise cause emissions standards

to be exceeded. EPA estimates that about 45 percent of land-based incinerators currently operating,

including the large commercial incinerators, carry

some sort of air pollution control equipment (8).

Scrubber technology, especially for removing particulates, is well-developed but expensive.

Land-based incinerators regulated under RCRA

(or TSCA for PCBs) are also subject to controls

on scrubber waste disposal. Scrubber operation

generates very large amounts of scrubber water (see

ch. 8), which is itself classified as a hazardous waste.

Several methods, all subject to RCRA regulation,

are used for treating this residual. The methods include impoundment, deepwell injection, treatment,

and landfilling. Treatment generates two products:

a sludge, which is generally disposed of in a hazardous waste landfill; and an effluent, which can

be legally discharged to surface waters or into sewer

systems if the effluent meets the requirements of

the Clean Water Act,

Ocean Incineration

Proposed domestic regulations, as well as existing international regulations, do not require the use

of any air pollution control equipment on incineration vessels. Separate rationales are offered for the

two major categories of incinerator emissions: acid

gases and particulate. EPA argues that acid gases

emitted from the stack would be effectively neutralized on contact with seawater because of its natural buffering capacity. As an additional control,

the proposed Ocean Incineration Regulation would

impose an environmental performance standard for

acid gas -emissions (see previous section).

EPA also considers that burning only liquid

wastes at sea would generate very low levels of particulates and that controls over metal content in

waste would further limit harmful metal emissions.

Limitations on metal content of wastes burned at

sea would be based on EPA’s interpretation of the

London Dumping Convention’s guidelines with

reference to water quality criteria.
128 • Ocean Incineration: Its Role in Managing Hazardous Waste

Two companies, SeaBurn, Inc., and Environmental Oceanic Services, Inc., have proposed plans

for incineration vessels that would be equipped with

seawater scrubbers, but their purpose would only

be to dilute the plume and direct it more quickly

into the ocean. The scrubbers, therefore, would not

generate any scrubber residuals (see ch. 6).

Sampling and Monitoring Requirements

and Procedures

Three levels of monitoring are generally discussed with regard to incineration: monitoring of

trial burns; routine monitoring of emissions and

incinerator operating conditions; and ambient monitoring of surrounding air, water, and biota. Each

of these is discussed below for land-based and ocean

incineration.

Land-Based Incineration

Sampling and analysis procedures for incinerator emissions are specified in Federal regulations

and EPA manuals. For the trial burn, actual locations for sampling and monitoring devices are indicated, and data collected are used to determine

performance of the incinerator by providing for the

following:

●

●

●

●

●

●

●

quantitative analysis of waste feed, stack emissions, scrubber water, and ash and other

residues;

computation of DE or DRE;

acid gas removal efficiency;

quantification of particulate emissions;

measurement of average, maximum, and minimum combustion temperature;

continuous measurement of carbon monoxide

concentration in the stack gases; and

identification of the sources of fugitive

emissions.4

Operating permits for routine incineration

specify waste analysis and monitoring requirements. A waste analysis plan is required and must

provide for periodic verification of the chemical and

physical composition limits specified in the permit.

RCRA requires that temperature, carbon monoxide, waste feed rate, and combustion gas velocity

‘Fugitive emissions are small, sporadic losses of waste from sources

like leaking valves, vents, and seals.

be continuously monitored during operational

burning and that an automatic waste feed shutoff

system be continuously operated, as well. Waste

feed shutoff is triggered by deviation from permit

limits in any of several operating parameters, as

determined by the continuous monitoring devices.

Sampling and analysis of waste feed or emissions

must be conducted on request by the EPA Regional

Administrator. All sampling and monitoring data

must be recorded.

RCRA does not require ambient monitoring for

land-based incinerators, although some individual

States might have such requirements under the

Clean Air Act. EPA offers three reasons for not

mandating ambient monitoring: the Agency believes that if stack emissions are within regulatory

limits, no adverse effects will occur; accurate and

reliable ambient monitoring would not be feasible

because concentrations are extremely low; and

other industrial activities contribute similar or identical emissions, which would impede attempts to

assign sources to emissions or their effects.

Ocean Incineration

For trial burns, proposed Federal regulations

specify sampling and analysis procedures for parent compounds. Routine operations would require

continuous monitoring, which would have to be

recorded in sealed tamper-resistant devices, of the

following parameters:

●

●

●

●

●

●

incinerator wall and flame temperatures;

oxygen, carbon dioxide, and carbon monoxide concentrations in the combustion gases;

waste and auxiliary fuel feed rates to the incinerator;

air flow to the combustion chamber;

status of the flame (to monitor continuous

combustion); and

amount of waste incinerated.

An automatic waste feed shutoff system would have

to be operated continuously and be triggered by

deviations from specified limits for: minimum wall

temperature and minimum oxygen and maximum

carbon monoxide in combustion gases; flame-outs;

or failure in continuous monitoring devices.

Tests of ballast waters, tank washings, pumproom bilge waters, and wash waters from decontamination operations would have to be performed
Ch. 7—Comparison of Land-Based and Ocean Incineration Technologies ● 129

and recorded to ensure compliance with permit requirements.

Vessel operators would be required to monitor

ambient air, water, and biota, using approved

methods under the direction of EPA. The monitoring would be conducted periodically or at the

request of the permit program managers. Costs

would be borne by individual vessel operators.

EPA would have authority to review and approve

the qualifications of all personnel involved in collecting and analyzing samples for monitoring emissions and the ambient environment.

As was the case for operational requirements,

proposed sampling and monitoring requirements

are generally more detailed and stringent for ocean

incineration than for land-based incineration.

Additional Provisions Not Required of

Land-Based Incineration

The proposed Ocean Incineration Regulation

contains several requirements that do not have

counterparts in RCRA regulations governing landbased incineration. These requirements include the

following:

. all data from waste analyses and monitoring

would have to be submitted to EPA;

●

●

●

●

●

●

operators would have to meet additional requirements regarding the collection and

reporting of monitoring data. The requirements would specify, for example, the frequency of recording and the use of tamperresistant devices;

a full-time EPA shiprider would be required

on each voyage, and the U.S. Coast Guard

could require an additional shiprider;

facilities and records would be inspected yearly

by the U.S. Coast Guard and on request by

EPA;

permit applicants would have to assess the effects of their activities on endangered or threatened species, and EPA would have to conduct

and periodically update its own endangered

species assessment, under the authority of the

Endangered Species Act;

the activity would have to be consistent with

the Coastal Zone Management Act; and

operators must demonstrate the need for ocean

incineration (see ch. 2).

Although many of these requirements address concerns arising from the fact that ocean incineration

takes place far from land, together they reinforce

the conclusion that the proposed Ocean Incineration Regulation would be considerably more explicit and stringent than the corresponding regulations for land-based incineration.

CHAPTER 7 REFERENCE S

1. Ackerman, D. G., et al., The Capability of Ocean

Incineration—A Critical Review and Rebuttal of

the Kleppinger Report (Redondo Beach, CA: TRW

Energy and Environmental Division, 1983).

2. Arthur D. Little, Inc., Overview of Ocean Incineration, 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).

3. Bond, D. H., ‘ ‘At-Sea Incineration of Hazardous

Wastes, ” Environ. Sci. Technol. 18(5): 148A-152A,

1984.

4. Booz-Allen & Hamilton, Inc., “An Overview of the

Contaminants of Concern in the Disposal and Utilization of Municipal Sewage Sludge, Revised Draft,

prepared for the U.S. Environmental Protection

Agency, Sludge Task Force (Bethesda, MD: Feb.

11, 1983).

5. Environment Reporter, “Wastes From Burning Dioxin in Mobile Unit Would Be Excluded From List

Under Proposal, ’ Environment Reporter, June 14,

1985, p. 276.

6. Gerstle, R. W., and Albrinck, D. N., “Atmospheric

Emissions of Metals From Sewage Sludge Incineration, ”J. Air Pollut. Control Assoc. 32(11):1119-

1122, November 1982.

7. Inside EPA, ‘ ‘EPA May Weaken Regulation of

Dioxin-Containing Incinerator Wastes, Inside

EPA 6(31):2, Aug. 2, 1985.

8. Keitz, E., Vogel, G., Holberger, R., et al., A Profile of Existing Hazardous Waste Incineration Facilities and Manufacturers in the United States,

EPA No. 600/2-84-052, prepared for the U.S. Environmental Protection Agency, Office of Research

and 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 (Washington, DC: EWK Consultants, Inc., 1983).

Kleppinger, E. W., and Bond, D. H., Ocean Incineration of Hazardous Waste: A Revisit to the

Controversy (Washington, DC: EWK Consultants,

Inc., 1985).

League of Women Voters of Texas Education

Fund, “Independent Observations on Ocean Incineration, A League Member’s Experiences on

Vulcanus II Voyage, November 4-9, 1983, ” prepared by D.B. Sheridan (Austin, TX: League of

Women Voters of Texas Education Fund, 1983).

Pahl, D., ‘ ‘EPA’s Program for Establishing Standards of Performance for New Stationary Sources of

Air Pollution, ” J. Air Pollut. Control Assoc.

33(5):468-482, May 1983.

Trenholm, A., German, P., and Jungclaus, G.,

Performance Evaluation of Full-Scale Hazardous

Waste Incinerators, EPA/600/S2-84, contract report

14.

15.

16.

17.

prepared for the U.S. Environmental Protection

Agency (Washington, DC: May 1984).

U.S. Environmental Protection Agency, Office of

Water, Incineration-At-Sea Research Strategy

(Washington, DC: Feb. 19, 1985).

U.S. Environmental Protection Agency, Office of

Policy, Planning and Evaluation, “Background Report I: Description of Incineration Technology, ”

Assessment of Incineration as a Treatment Method

for Liquid Organic Hazardous Wastes (Washington, DC: March 1985), p. 30.

U.S. Environmental Protection Agency, Science

Advisory Board, Report on the Incineration of Liquid Hazardous Wastes by the Environmental Effects, Transport and Fate Committee (Washington,

DC: April 1985), pp. 20, 23.

Zurer, P. S., ‘‘Incineration of Hazardous Wastes at

Sea—Going Nowhere Fast, ” Chem. Engr. News,

Dec. 9, 1985, pp. 24-42.
Chapter 8

Environmental Releases From

Ocean Incineration
Contents

Page

Data Limitations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... , . . . . .......133

Types of Environmental Releases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ........133

Marine Spills . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ........................134

Incinerator Upset . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .142

Fugitive Emissions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..........143

Normal 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 . ...................136

14. Annual Tonnages of Hazardous Materials and Crude Petroleum Passing Through

Various U.S. Ports in 1984 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ., .........,..141

15. Average Annual Tonnages of Petroleum Products and Chemicals in Mobile Bay .. ...142

16. Shipments of Petroleum and Hazardous Substances in the Gulf of Mexico,

Fiscal Year 1983 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ....142

17. Average Expected Annual Releases From Storage and Transfer Operations. . ........144

18. Estimated Inputs of PCBs to Various Marine Waters . . . . . . . . . . ...................146

19. Maximum Concentrations of Three Metals Allowed in Wastes

To Be Incinerated At Sea . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .....................147

20. Comparison of Inputs of Seven Metals to the Gulf of Mexico From Incineration

and Land-Based Sources. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . . . . . . . .148

21. Metal Concentrations Resulting From Ocean Incineration Under Three Different

Scenarios for Mixing of Emissions in Seawater . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...150

22. Comparison of Metal Inputs From Ocean Incineration to Background Metal

Concentrations in the Uppe r60 Meters of the Open Ocean . ......................150

23. Summary of Annual Incineration Releases for Two Model Wastestreams . . . . ........153

Figures

Figure No. Page

9. Step-by-Step Flowchart for Land-Based and Ocean Incineration. . . . ................135

10. Spill Rates for the Vulcanus II in Mobile and Delaware Bays . ....................137

11. Comparative Size Scale of an Incineration Vessel (the Apollo I)

and Other Typical Commercial Ships . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .139
Chapter 8

Environmental Releases From

Ocean Incineration

Incineration is a technology primarily intended

to destroy hazardous wastes. However, as with any

hazardous waste technology, each phase of operation has at least the potential to release waste or

waste products into the environment.

A full quantitative analysis of the magnitude and

probability of releases from incineration is not possible, primarily because insufficient data exist on

which to base such an analysis. This chapter first

comments on these data limitations and then describes the nature of releases associated with ocean

incineration. It then presents and analyzes available data on the probability of such releases occurring, and compares these risks with those from similar activities (i. e., land-based incineration, marine

transportation of hazardous materials, and additional sources of marine pollution).

The chapter ends with a summary and comparative discussion of the total releases expected from

land-based and ocean incineration. This summary

ties together the large amount of information presented in the chapter and provides an overview that

may suffice for readers who do not wish to explore

the subject in detail.

DATA LIMITATION S

Any discussion of risks arising from land-based

and ocean incineration is greatly hampered by a

lack of data on many key aspects. This chapter often

refers to such data gaps, particularly those cited by

EPA’s Science Advisory Board. Significantly, our

understanding of risks from both land-based and

ocean incineration is comparably constrained by

this lack of needed data. Indeed, many of these data

gaps apply to many or all other hazardous waste

management technologies as well.

Without sufficient data, a very large degree of

uncertainty taints all of the risk calculations and

some of the overall conclusions, as well. At the same

time, given the truism that no method for managing hazardous wastes is risk-free, the most important information is that which provides for a comparative assessment of risks. Although this task is

difficult and by no means free of uncertainties, an

evaluation of relative risk can be developed now

and subsequently refined as the information base

improves.

For ocean incineration, data with which to assess the potential for both accidental and routine

releases are particularly scant, in part because of

the relative lack of experience with this technology

(at least in the United States). This necessitates a

reliance on indirect historical data for such releases

(i.e., data collected for related activities such as hazardous materials transportation). In addition, the

lack of experience has provided only limited opportunities to collect data on routine releases occurring under a wide range of operating conditions.

‘OTA has examined the risks involved

ardous materials, including waste (19).

TYPES OF ENVIRONMENTAL RELEASE S

Environmental release of waste from incinera- result from normal or routine

in transporta( ;on of hazoperations, when,

tion operations can occur as a result of accidents, for example, small fractions of unburned waste are

such as vessel or truck collisions, leaking tanks, or emitted from incinerator stacks or waste or residupsets in incinerator operation. Releases can also ual ashes are handled. A full analysis of the envi133
134 . Ocean Incineration: Its Role

ronmental effects of land-based and ocean incineration will ultimately require that both kinds of

releases be characterized and quantified.

Several important distinctions can be drawn between these two types of events.

Accidental releases are not predictable with respect to time or place, although historical data can

be used to develop estimates of their probability of

occurrence. For events that occur relatively often,

as do, for example, vehicle accidents, historical data

can provide accurate risk estimates. However, for

rare events such as ship grounding, or for events

arising from unique aspects of a new technology,

historical data either are nonexistent or produce

much less reliable estimates.

Both the frequency and the magnitude of accidental releases are subject to influence by regulatory and technical factors. For example, use of

containerized systems for transporting wastes can

decrease the quantity of wastes released in the event

of accidents, and restrictions on vessel transit during storm conditions should reduce the likelihood

of accidents.

Routine releases are easier to predict and quantify. Although the magnitude of routine releases can I

be minimized through technological design and

i careful practice, some release is inevitable from essentially any system.

Routine releases resulting from incineration can

involve either the waste itself or products generated as a result of the incineration. Accidental releases virtually always involve loss of the original

waste itself.

This section describes the various types of environmental releases and, wherever appropriate,

draws distinctions between land and ocean basing.

The types of releases considered include the following: accidental releases from spills and incinerator

upsets; and routine releases from fugitive emissions,

normal stack emissions, and air pollution control

device effluents.

Available data are discussed from two perspectives: First, the additional activities and risks specifically associated with ocean incineration are highlighted; and second, these risks are compared to

risks associated with related activities, to provide

a broad context in which to view ocean incineration.

Marine Spills z

Typically, handling and transport of hazardous

waste to be incinerated involves many similar or

identical steps for both land-based and ocean incineration. Figure 9 presents a schematic representation of such steps for land-based and ocean incineration. The potential for a spill to occur must

be evaluated at each of these steps. For ocean incineration, an extra transfer and transport step is

required to bring wastes to dockside, load them onto

the vessel, and transport them to the incineration

site. This factor tends to increase the risk of accidental release of wastes. (As discussed in ch. 6, implementation of the containership concept, in which

wastes would be transferred directly from source

to vessel in sealed containers, might substantially

reduce this risk during handling on land and during vessel loading; increased handling of containers

on board could increase the risk of a spill during

the voyage. )

Table 13 summarizes steps in the waste flow

where accidents can occur, and indicates the cause

and type of, release in each case.

With respect to additional transportation and

handling risks applicable to ocean incineration,

EPA estimated the probability of release for a ship

with characteristics similar to the Vulcanus II, operating in two locations: 1) out of Mobile Bay in Alabama and incinerating at the designated Gulf of

Mexico Incineration Site (app. C in ref. 22); and

2) out of Philadelphia and Delaware Bay and incinerating at the proposed North Atlantic Incineration Site (8). These analyses were based on consideration of historical safety and engineering data

for the maritime bulk chemical industry. Specifically, bulk chemical transport data for tank ships

of comparable size operating worldwide between

1969 and 1982 formed the basis of the analysis. The

data were adjusted to account for the following special circumstances and the somewhat stricter design and operational requirements applicable to incinerator ships:

• relative ease of maneuvering and use of sophisticated navigational equipment;

‘In this discussion, the term spill refers to a release caused by the

breaching 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
136 ● Ocean Incineration: Its Role in Managing Hazardous Waste

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, bulk

Bulk liquids . . . . . . . . . . . . . .Overfilling, line break Spill on land Land/ocean, bulk

Containers ., . . . . . . . . . . . . . Mishandling Spill on land Land/ocean, containerized

Road or rail transit . . . . . . . . . .Vehicle accident, tank or Spill on land Land/ocean, bulk/containerized

valve leak Fire

Storage:

At dockside . . . . . . . . . . . . . .Tank or container failure Spill on land Ocean

At incinerator . . . . . . . . . . . .Tank or container failure Spill on land Land

Vessel loading. . . . . . . . . . . . . .Overfilling, line break Spill on land, water, Ocean, bulk

or ship

Vessel transit . . . . . . . . . . . . . .Collision or grounding Spill to water or Ocean, bulk

on ship

Incineration . . . . . . . . . . . . . . . . Upset or malfunction Increased emissions Land/ocean, bulk/containerized

Bulk 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 ballast 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); and

routes to be used.

The probability of an accident occurring during

various segments of the transit was separately

assessed for four locations: the pier or harbor, Mobile or Delaware Bay, the coastal zone, and the

burn site. Four types of accidents were separately

addressed as well: collisions (ship/ship); rammings

(ship/nonship); grounding; and nonimpact events

(e. g., explosions, fires, structural failures, capsizing).3 In addition, accident data were adjusted to

account for the fact that not all accidents result in

actual release of waste.

The resulting estimates are of two sorts: first, estimates of the probability of a spill (i. e., spill rate)

of any size occurring at a given location or from

a given type of accident; and second, a probability

‘Adjustments of the data were made where appropriate to account

for conditions specific to a location and an accident type. For example, probabilities for vessel grounding in Delaware Bay were adjusted

upward based on the higher rate of grounding in this region relative

to that experienced worldwide; probabilities for grounding in the Gulf

of Mexico were adjusted downward to account for soft bottom conditions. No adjustments of data for nonimpact accidents were made,

due to lack of sufficient information.

distribution that predicts the frequency of spills of

various sizes.

Estimation of Spill Rates

For a Vulcanus H-type ship, EPA’s estimated

spill rates for the Gulf of Mexico and for Delaware

Bay are presented in figure 10. The total spill rates

are the sum of those for the four locations or the

four types of accidents. These data suggest that

about half of all spills in both locations can be expected to occur at dockside or in the harbor or bay.

Nonimpact casualties (e. g., explosions, fires, structural failures, capsizing) are predicted to account

for almost half of all spills in the Gulf of Mexico,

but less than a third of those in Delaware Bay. Spills

due to grounding are over four times more likely

in Delaware Bay than in the Gulf, largely because

of differences in bottom conditions. Based on historical accident rates, a major fraction of spills in

the pier/harbor area are expected to take place while

the vessel is moored, rather than during transit.

Based on these data, EPA predicts that the overall spill rate for all accident types and locations

would be 6 per 100,000 voyages for the Gulf of

Mexico and 9 per 100,000 voyages for Delaware

Bay. As can be seen from figure 10, most of the

difference in these two estimates is because of the

higher probability of grounding in the Delaware

Bay, due to harder bottom conditions.

These estimated spill rates for the Vulcanus II

are seven- to ten-fold lower than the historical spill
Ch. 8—Environmental Releases From Ocean Incineration • 137

Figure 10.—Spill Rates for the Vulcanus // in Mobile

and Delaware Bays

A. Spill Rates by Location

6

5

Pier/ Bay Coastal Burn Total

harbor area zone

Mobile Bay

Collisions Grounding Rammings Nonimpact Total

Accident type

Mobile Bay I!?,l T. Delaware Bay

SOURCES: MolWa Bay: U.S. Environmental Protection Agency, Office of Policy, Planning

and Evaluation, “Background Report IV: Comparison of Risks From LandBased and Ocean-Baeed Incineration,” Assessment of Incfneratlon as a Treatment Method for L/qu/d Organic Hazardous Wastes (Washington, DC: March

19S5); Delaware Bay: Engineering Computer Optecnomics, Inc., “Analysis of

the Risk of a Spill During a Single Voyage of the Vu/carrus // From the Port

of Philadelphia to the Incineration Site in the Atlantic Ocean, ” prepared for

the U.S. Environmental Protection Agency (Annapolis, MD: Apr. 30, 1980).
138 . Ocean Incineration: Its Role in Managing Hazardous Waste

rate for all tank ships of comparable size operating

worldwide between 1969 and 1982 (61 per 100,000

voyages). Such a result is expected because of the

adjustments made to account for the special safety

features of incineration vessels and their operation.

Using EPA’s assumption of an average of 14

voyages per ship per year, these spill rates indicate

that one accident could be expected to occur every

800 years (Delaware Bay) to 1,200 years (Gulf of

Mexico). These estimates are per ship; thus, if three

ships were in operation, one spill would be expected

every 270 to 400 years on average.

EPA’s spill rate estimates are subject to a number of limitations. For example, spill rates only represent a Vulcanus II-type vessel operating in specific regions, and cannot be expected to apply to

other vessel designs or locations. In addition, spills

of hazardous material go unreported to a significant degree. No upward adjustment was made to

account for the number of unreported accidents and

spills. Such an adjustment would affect the absolute probability of a spill for the Vulcanus II, but

not its safety relative to that of all tank ships operating worldwide. 4

EPA’s spill rate estimates are highly sensitive to

the magnitude, reliability, and appropriateness of

adjustments made to historical spill data. For example, if it is assumed that only a quarter of all

marine spills are reported, then the actual spill frequency would be increased by a factor of 4. The

resulting spill rates would now be 1 per 200 to 300

years (again per ship). If three ships were operating, a spill could be expected every 67 to 100 years;

if a larger fleet of 30 ships were employed, a spill

could be expected every 7 to 10 years.

Conversely, the downward adjustments made to

historical spill data might be too conservative. For

example, nonimpact accidents may well be affected

by design and operational features that are employed (e.g., double-hull construction; sophisticated

firefighting equipment). These factors were excluded from EPA’s analysis due to a lack of quan4A number of other criticisms of the EPA analysis have been raised

(6), based primarily on U.S. Coast Guard data on polluting incidents

in and around U.S. waters (20). However, most of these data are not

relevant 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) the

incidents involved sources other than vessels; or 3) the vessels involved

were of significantly less safe design (e. g., river barges).

titative information. Their consideration would result in actual spill rates that would be even smaller

than EPA has estimated.

The factors listed above represent only some of

the many inherent sources of uncertainty that affect the reliability of spill rate estimates. Even if

only small uncertainties accompanied each of the

individual factors that influenced the calculation of

a spill rate, the combined uncertainties could lead

to a highly questionable result. For this reason, the

absolute magnitude of such risk estimates must be

used with great caution.

Comparing the relative risks for activities that

are subject to the same or similar uncertainties,

however, can still be informative. Thus, a major

conclusion that is clearly supported by EPA’s spill

rate analysis is that the operation of incineration

vessels should result in a significantly lower pership rate of spills than the rate for tank ships in

general.

Estimation of Spill Size

EPA rejected use of direct historical data on spill

size for tank ships, because such data are skewed

toward conventional single-hull tankers whose average tank size is comparable to the entire cargo of

the Vulcanus II. Instead, historical data on the extent of damage caused by accidents were used to

estimate the probability of occurrence of each of

the following categories of events leading to cargo

loss:

. involvement of a single cargo tank—80 percent of spill events,

. involvement of two adjacent tanks—15 percent of spill events, and

. involvement of three or more tanks—5 percent of spill events.

In each case, it was assumed that the entire contents of a tank involved in an accident were lost.

Because the Vulcanus II is designed to remain afloat

even after the loss of two of its tanks, cargo losses

from events involving damage to one or two tanks

would 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) was

assumed. These assumptions are quite conservative because of the unlikelihood that all the con-
Ch. 8—Environmental Releases From Ocean Incineration • 139

Figure 11.–Comparative Size Scale of an Incineration Vessel (the Apollo l) and Other Typical Commercial Ships

.

Staten Island Ferry (Avg.)

Length 300 feet

Gross Tonnage 2,576 tons

At-Sea Incineration's Apollo I

Length 369 feet

Gross 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 spill

from an incineration vessel would result in the release of 19 percent of the total cargo, which would

correspond to about 150,000 gallons in the case of

the Vulcanus II.

Unfortunately, essentially no data are available

for vessels of comparable size and possessing the

design and operational features of incineration vessels. Moreover, because historical data collected

over only a few years may by chance include or exclude the very rare event that generates a very large

spill, their reliability is highly questionable. These

and the other limitations discussed above clearly

illustrate the problems associated with using historical data to estimate the average magnitude of

a low-probability, high-consequence event such as

a marine spill.

Whatever its absolute magnitude or uncertainty,

the average expected spill size from an incineration vessel can logically be assumed to be significantly smaller than that resulting from a typical

tanker accident, where both tank and total cargo

size tend to be much larger (see fig. 11).

Estimates of spill rate and size are certain to vary

between vessels, port locations, and burn sites.

Thus, an analysis based on any one operation is

of limited applicability to others, whereas a generic

analysis tends to obscure the potential for significant variation. This fact underscores the need for

comparing various vessel designs and operation

plans as an integral part of assessing the safety of

ocean incineration (see ch. 6).

Comparison of Releases From Transportation

on Land and At Sea

EPA estimated the magnitude of releases that

would be expected to occur as a result of accidental

spills during land and ocean transportation (21,22).

Based on this comparison, EPA suggested that the

ocean transportation phase would contribute about

20 percent of releases of waste caused by spills. Releases caused by spills during land transportation

are estimated to be more than three times higher

than releases caused by spills during ocean transportation. Releases caused by spills during transfer and storage operations would be slightly lower

than releases caused by spills during ocean transpor-
140 ● Ocean Incineration: Its Role in Managing Hazardous Waste

tation. Because spill releases from land transportation, transfer, and storage are estimated to be identical for land-based and ocean incineration, EPA

suggested that the total expected release due to spills

for ocean incineration would be about 20 percent

higher than that for land-based incineration.

Even if accurate, however, such estimates do not

adequately reflect the relative environmental consequences of releases. To do so would require consideration of such factors as the ease of cleaning up

spills, the transport and fate of spilled material, the

nature of exposure to organisms and humans, and

the actual health effects of the substances present

in the waste. Compared to estimation of spill rate

and size, far more uncertainty and absence of data

accompany the estimation of these additional factors, which are considered in chapter 9.

Comparison of Marine Transportation of

Hazardous Waste and Nonwaste Materials

Available data indicate that, with respect to number of transits, quantities and types of material carried, and expected releases, ocean incineration entails a very small incremental increase in risk over

that routinely borne in the marine transport of hazardous materials. Even if a fleet of 30 vessels were

employed, marine transport of hazardous materials would increase by about one-tenth of 1

percent; quantities of material spilled in the marine environment would increase by an even

smaller fraction.

A discussion of the risks of accidental releases of

wastes while at sea or dockside should consider both

the types and quantities of hazardous non waste materials (e. g., petroleum products, raw chemical

feedstocks) that are handled and transported by

similar means and routes on a routine basis.

Types of Material Carried.—Critics of ocean incineration argue that transport of hazardous waste

poses a greater risk than transport of hazardous

nonwaste materials for two reasons: first, that waste

materials are more toxic or concentrated; and second, that incineration vessels would carry complex

mixtures of different substances, whereas tank ships

carry pure substances, which are easier to clean up

if spilled.

Typical liquid cargoes carried by tank ships include crude oil, petroleum products, petrochemicals, liquefied gases, and nonpetroleum-based

chemicals. Thus all of the major categories of oceanincinerable wastes are represented among materials routinely transported in raw form. In addition,

many tank ships are designed and authorized to

carry numerous substances in various combinations, for example, petroleum products and nonpetroleum-based chemicals. These materials, however, are segregated in separate tanks, reducing the

likelihood that a mixture of substances would be

released in a tank ship spill.

With respect to toxicity and concentration, the

majority of waste suitable for incineration at sea

is derived from industrial processes that use a wide

variety of chemicals in pure form. The composition of waste generated by a given industrial process, therefore, tends to reflect rather closely the composition of the feedstocks initially used.

However, industrial processes can alter the composition of subsequent waste products in at least

three respects. First, contaminants can be introduced; for example, solvents used for cleaning and

decreasing may contain dirt, grease and oil, and

metals not originally present in the feedstocks. Second, water content can be increased, diluting the

original material. Third, different substances can

indeed become mixed in the process that generates

the waste.

Thus, contamination or mixing can render

wastes resulting from industrial processes more

complex than the nonwaste materials from which

they were derived; at the same time, the concentrations of particular toxic constituents may well

be less than those of the raw materials. Because

environmental toxicity is a function of both concentration and composition, any generalization

about relative toxicities of wastes and raw materials is impossible; rather, analysis on a case-by-case

basis is required.

Much public attention has focused on the transport of PCBs, which are no longer routinely

produced or transported for industrial or other commercial purposes. Although PCBs are a small fraction of ocean-incinerable wastes, they are among

the most environmentally persistent of all toxic materials transported at sea, and have considerable

potential to be accumulated by exposed organisms

and introduced into the food chain. For this reason, special regulatory attention is warranted for

PCBs. (See box B in ch. 3.)
Ch. 8—Environmental Releases From Ocean Incineration • 141

Quantities of Material Carried.-EPA has estimated that the amount of hazardous waste that

would be transported by the six existing or planned

incinerator ships would be 0.03 percent of the total volume of hazardous substances handled by

U.S. ports in 1983 (50 FR 8226, Feb. 28, 1985).

This calculation was based on U.S. Army Corps

of Engineers data reporting a total of 1.38 billion

metric tons5 of hazardous materials passing through

U.S. ports in 1983.

Table 14 provides a summary of U.S. Army

Corps of Engineers data on the annual tonnages

of hazardous materials and petroleum passing

through various U.S. ports in 1984, These amounts

are compared to the quantities that would be carried by 1 or 30 incineration vessels similar in size

to the Vulcanus ships or the significantly larger

Apollo ships.

Gulf of Mexico and Mobile Bay. —EPA has examined data on shipments of petroleum and haz5The quantity cited by EPA is 8.70 billion barrels of hazardous substances; this is roughly equivalent to 1.38 billion metric tons.

ardous substances in Mobile Bay and the Gulf of

Mexico. The data distinguish between crude petroleum, petroleum products, and hazardous chemicals. Table 15 presents data for shipments in and

out of Mobile Bay between the years 1977 and

1981. Table 16 presents similar data for the Gulf

of Mexico in 1983 and indicates the total number

of shipments made.

The data in tables 15 and 16 provide the basis

for the following conclusions:

● Each incineration vessel with an annual capacity of 65,000 metric tons operating full time

out of Mobile Bay would increase total carriage 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 the

Gulf 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 transits annual] y, the number of hazardous material shipments in the Gulf of Mexico would

Table 14.—Annual Tonnages of Hazardous Materials and Crude Petroleum

Passing Through Various U.S. Ports in 1984

Quantity Transported in 1984

(millions of metric tons)

Hazardous Crude Quantity normalized to

Location 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 1,723

Delaware River/Bay . . . . . . . . . . . . . . . . . . . . . . . 26 46 72 1,108

Port of Mobile, AL . . . . . . . . . . . . . . . . . . . . . . . . 3 3 6 92

Port of Lake Charles, LA . . . . . . . . . . . . . . . . . . 20 7 27 415

Houston Ship Channel, TX. . . . . . . . . . . . . . . . . 46 11 57 877

San Francisco Bay, CA. . . . . . . . . . . . . . . . . . . . 25 26 51 785

Annual quantityc

One incineration vessel

Vulcanus . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 0.065 1

Apollo . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 0.100 1.5

30 incineration vessels

Vulcanus . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2.0 30

Apollo . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3.0 46

alncjudes the following commodhjes:

Sodium hydroxjde Basjc chemicals Jet fuel

Crude tar, ojls, gas Pajnts Kerosene

Dyes, pigments Gum, wood chemjcals Distillate fuel oii

Alcohols Insecticides, disinfectants Residual fuel oil

Benzene and toiuene Miscellaneous chemjcais Lubricating oil and grease

Sulfuric 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 Waterborne

Commerce 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 Calendar

Year 1984.
142 . Ocean Incineration: Its Role in Managing Hazardous Waste

I

I

Table 15.—Average Annual Tonnages of Petroleum

Products and Chemicals in Mobile Bay

(thousands of metric tons)

Commodity Tonnagea

Crude petroleum . . . . . . . . . . . . . . . . . . . . . . . . . 3,848

Gasoline, jet fuel, kerosene, fuel oil,

and solvents . . . . . . . . . . . . . . . . . . . . , . . . . . . 4,018

Benzene, toluene, and basic chemicals. . . . . . 155

Total. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7,821

aAnnual averagea for the period 1977~1.

SOURCE: U.S. Environmental ProtectIon Agency, Office of Policy, Planning and

Evaluation, “Background Report IV: Comparison of Risks From LandSased and Ocean-Baaed Incineration, ” Assessment of Inclneratlon as

a Treatment Method for L/quid Organic Hazardous Wastes (VVashington, DC: 19S5).

Table 16.—Shipments of Petroleum and Hazardous

Substances in the Gulf of Mexico, Fiscal Year 1983

Volume of

shipments Number of

Commodity (mmt) shipments

Petroleum. . . . . . . . . . . . . . . . . . 270 44,917

Hazardous substances. . . . . . . 274 14,978

Total . . . . . . . . . . . . . . . . . . . . 544 59,895

SOURCE: U.S. Environmental Protection Agency, Office of Policy, Planning and

Evaluation, “Background Report IV: Comparison of Risks From LandBaaed and Ocean-Baaed Incineration,” Assessment of Irrcineratlon as

a Treatment Method for Liquid Organic Hazardous Wastes (Washington, DC: 19S5).

increase by about 0.09 percent, or less than 1

per 1,000. If petroleum were included, the increase would be 0.02 percent, or 2 per 10,000.

EPA argues that stricter design and operational

requirements applicable to incineration vessels

would decrease actual releases of hazardous material to the environment even further. Design factors include the smaller tank and total cargo size,

double hull, greater maneuverability, and shallower

draft of incineration vessels. Operational requirements include weather restrictions and U.S. Coast

Guard controls on vessel transit. If such factors are

taken into account, EPA expects releases from each

incinerator ship operating in the Gulf to be less

than 0.002 percent (or one fifty-thousandth) of

those from routine transport of petroleum and hazardous material in the Gulf.

set would be limited because of the requirement for

automatic shutoff of waste to the incinerator in the

event of a malfunction. Nevertheless, during this

time waste could be expected to enter—and exit—

the incinerator under conditions that deviated from

permit requirements. A significant amount of combustion would continue to occur because of the remaining heat in the combustion chamber, although

the degree of combustion would almost certainly

be lower than the efficiency standard.

The amount of additional release would depend

on both the length of the upset and the destruction

efficiency attained under upset conditions. To illustrate the magnitude of the expected additional

release, a worst-case scenario might involve a 10-

second delay in waste feed shutoff (see ref. 23; the

proposed Ocean Incineration Regulation would allow only 4 seconds). Assuming that during this 10

seconds the destruction efficiency (DE) fell (in the

worst case) to 90 percent, the quantity of unburned

waste released would be equivalent to 2.8 hours of

operation at a DE of 99.99 percent, or 280 hours

at a DE of 99.9999 percent. G

For a PCB burn requiring a DE of 99.9999 percent, about 10 such upsets during a 12-day (288-

hour) burn would reduce the average DE by a factor of 10, to 99.999 percent. If a DE of only 99.99

percent were required (i.e., for incineration of nonPCB wastes), about 1,000 such upsets would be

needed to reduce the DE by a factor of 10, to 99.9

percent.

This calculation highlights the fact that the higher

the desired DE is, the more sensitive the system

is to temporary incinerator upsets. Unfortunately,

data are not available on the expected frequency

of upsets associated with either land-based or ocean

incineration. Nor does evidence exist showing that

ocean and land-based incineration technologies experience different frequencies of upset. This issue

of variation in operating conditions during extended

incineration is one area identified by EPA’s SciIncinerator Upset

A second category of accidental release involves

any malfunction of the incinerator that results in

the release of undestroyed or partially destroyed

waste. The expected duration of an incinerator uP-

. .

‘A reduction in DE from 99.99 percent to 90 percent would increase

the rate of emissions a thousand-fold; if the lower DE lasted for 10

seconds, the amount of emissions would be equivalent to that normally 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 equivalent

to that normally released in 10 seconds X 100,000 = 1,000,000 seconds = 280 hours.
Ch. 8—Environmental Releases From Ocean Incineration • 143

ence Advisory Board (23) as warranting further

study and attention. 7

Fugitive Emissions

Fugitive emissions, which are commonly associated with the transfer and storage phases of incinerator operation, are typically small, slow, or

sporadic releases of waste from a variety of sources,

including leaking seals, pumps, pipes, valves, and

storage tank vents. Unlike spills, most fugitive emissions are released to the atmosphere through volatilization; only rarely are fugitive emissions of a

nature or magnitude that would lead to the contamination of marine waters. Such releases can be

7The Science Advisory Board has suggested that operation on rolling and pitching seas may conceivable affect operating conditions. Opponents contend that there would necessarily be an inherent reduction in the performance of a moving incinerator, while proponents

argue that such effects would be negligible and draw an anology to

the fuel injection system of a sports car.

largely controlled through design modifications and

good operating practices.

With respect to estimating magnitude, some fugitive emissions (e. g., small, intermittent pump or

valve leaks) are probabilistic (random) in nature.

Others (e.g., breathing losses from storage tanks

and working losses during the filling and emptying of tanks) are continuous, at least during a particular activity. EPA has estimated fugitive emissions for an ocean incineration operation using an

integrated port facility of the type that Chemical

Waste Management, Inc., had proposed to build

at Chickasaw, Alabama. The calculation assumed

that one of the following two wastestreams was incinerated: an annual throughput of 56,000 metric

tons of waste containing 35 percent PCBs, or 68,000

metric tons of waste containing 50 percent ethylene dichloride (EDC).8

8Fugitive emissions from these wastestreams would probably be composed largely of volatile waste components, rather than PCB or EDC

themselves (app. B in ref. 22).
144 . Ocean Incineration: Its Role in Managing Hazardous Waste

Under this scenario, EPA calculated that the release of either waste through fugitive emissions

would be about 0.7 metric tons annually, or about

one-thousandth of 1 percent (0.001 percent) of the

total amount of waste handled (22). In each case,

storage tanks, not waste transfer and handling, were

the major source of emissions, accounting for over

80 percent of the total release.

EPA also estimated fugitive emissions from an

ocean incineration system using an intermediate

waste storage facility of considerably older design

(Chemical Waste Management’s facility in Emelle,

Alabama). EPA found that fugitive emissions could

be expected to increase because of two factors: first,

the extra transfers of waste to and from the Emelle

facility; and second, the less airtight design of the

I Emelle storage tanks. Total fugitive emissions under this scenario would be 4.9 and 5.5 metric tons

annually for the PCB and EDC wastes, respectively

(app. B in ref. 22). These levels would be seven

to eight times higher than those resulting from the

I more modern, single-step operation in an integrated

port facility like the one that was proposed for

Chickasaw.

Fugitive emissions calculated under each of these

scenarios represent the largest of all sources of releases for the handling and transfer phases of ocean

incineration. Table 17 compares the various sources

of releases for three systems: ocean incineration

using a modern integrated port facility (e. g., the

one planned for Chickasaw); an equivalent landbased incineration system; and ocean incineration

using an older intermediate storage facility requirTable 17.—Average Expected Annual Releases From

Storage and Transfer Operations (metric tons per year)

Planned Existing

Chickasaw Emelle Land-based

Release source facility facility equivalent

Truck unloading/

loading (spills). . . . 0.03 0.1 0.03

Transfer/storage

(spills) . . . . . . . . . . . 0.5 0.4 0.5

Fugitive emissions . . 0.7 5.2 0.6

Total . . . . . . . . . . . . 1.2 5.7 1.1

aAn annu~ w~te throughput of 59,000 metric tons iS assumed.

SOURCE: U.S. Environmental Protection Agency, Office of Policy, Planning and

Evaluation, “Background Report IV: Comparison of Risks From LandBased and Ocean-Baaed Incineration: Appendix B,” Assessment of

Incineration as a Treatment Method for Liquid Organic Hazardous

Wastes (Washington, DC: 19S5).

ing a two-step transfer procedure (e. g., the existing facility at Emelle). Total expected releases range

from 0.002 percent (Chickasaw and land-based) to

0.01 percent (Emelle) of waste throughput.

Comparison to Land-Based Incineration

Using an approach similar to the one outlined

above, EPA has estimated the amount of fugitive

emissions that could be expected from the additional

waste storage and handling that ocean incineration

would entail. This analysis indicated that, after

accounting for all phases of operation, releases due

to fugitive emissions would be about 15 percent

higher for ocean incineration than for land incineration (22).

Comparison to Other Sources of

Fugitive Emissions

Data to compare levels of fugitive emissions from

ocean incineration to levels from other sources are

generally lacking. Numerous other sources exist at

U.S. ports, given the very large quantities of hazardous materials handled by such ports. For example, in the Port of Mobile, about 30 waterfront facilities are currently licensed to handle or store

hazardous substances (22). In addition, there are,

of course, thousands of other facilities located

throughout the United States that handle such substances.

Normal Stack Emissions

Because incineration cannot completely destroy

wastes, stack emissions have at least the potential

to contain harmful levels of hazardous substances

and to convey them to the environment. These substances 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 quantities of each of these classes of emissions that could

be expected to be released to the environment

through ocean incineration.
Ch. 8—Environmental Releases From Ocean Incineration . 145

Unburned Waste

This category of wastes is defined (in a regulatory sense) through the selection of a few compounds considered to be representative of the entire waste. The selection is based on one of two

criteria: the compounds are present in the waste

in high concentration or are judged to be particularly difficult to destroy through incineration. These

compounds are termed principal organic hazardous constituents, or POHCs. The regulatory

advantage of such a system is that destruction efficiency need only be measured for a small set of

POHCs, because their destruction to a particular

level is assumed to indicate equal or greater destruction of all the unmeasured components of the waste.

Potential shortcomings of this definition are discussed at length in chapter 2.

If the assumptions behind the definitions of

POHCs and DE are accepted, and if the desired

DE is actually achieved, then the quantity of unburned waste released through stack emissions can

be calculated in a straightforward manner. The

quantity is simply the product of the unburned fraction of the waste ([100— DE]+ 100) and the total

quantity of waste burned. Thus, if an incineration

vessel burned 50,000 metric tons of a waste containing 35 percent PCBs in a given year, and if the

burns met the DE standard of 99.9999 percent, the

quantity of unburned PCBs released would be:

100 - 99.9999 x 50,000 x 0.35 = 0.0175 metric tons, or

100 17.5 kilograms

(38.5 pounds) annually

The magnitude of such releases would be extremely sensitive to changes in the DE. For example, if a DE of only 99.99 percent were achieved,

almost 2 metric tons of PCBs would exit the stack

annually.

The unburned waste emitted by an incineration

vessel would be released over a rather large area,

because of the movement of the ship during incineration and the dispersion of the plume after release.

This material would be further dispersed upon entry into the sea, due to currents and wave action,

although there is potential for concentration of emissions in the surface microlayer (see ch. 9).

The significance of releases of unburned waste

to the environment is unresolved. One approach

commonly used for evaluating significance is to

compare expected releases from ocean incineration

with releases from other sources. Ocean incinerator emissions are typically released to the atmosphere (unless a seawater scrubber is employed), but

they generally settle over the ocean surface, so the

contributions of other sources to both the atmosphere and marine waters are germane. Available

data for each of these environments are discussed

below, using the example of PCBs.

Releases to the Atmosphere.—In the Gulf of

Mexico, ambient (i.e., background) concentrations

of PCBs in the atmosphere have ranged between

0.05 and 0.5 nanograms per cubic meter (ng/m3

)

(app. I in ref. 22). This atmospheric concentration

is estimated to result in 7 to 70 grams of PCBs being annually deposited onto each square kilometer of the Gulf’s surface (g/km2 per year). Using

this rate of deposition, EPA has estimated that each

year between 10 and 100 metric tons of PCBs enter

the waters of the Gulf from the atmosphere (app.

I in ref. 22).

Using this range as a measure of the background

flux of PCBs entering the waters of the Gulf from

the atmosphere permits an estimation of the increase that could be expected to occur because of

ocean incineration. The area of the ocean surface

affected by the incinerator plume is estimated to

be about 90,000 square kilometers (app. I in ref.

22). Assuming a throughput of 50,000 mt of 35 percent PCBs and a DE of 99.9999 percent, the estimated flux of unburned PCBs from ocean incineration would be about 0.2 g/km2 per year. g This

would yield an increase above background flux of

0.3 to 3 percent over the affected area.

Averaged over the entire Gu]f these data indicate that each incineration vessel operating at a DE

of 99.9999 percent would cause a 0.02 to 0.2 percent increase in the quantity of PCBs entering the

water from the atmosphere. At the upper end of

this range, an increase in the number of vessels

operating in the Gulf or a decrease in the DE

achieved could result in a significant increase above

background.

917.5 kglyr + 90,000 km2 = 0.2 g/km2 per year,
146 ● Ocean Incineration: Its Role in Managing Hazardous Waste

Releases Directly Entering Marine Waters.—

PCBs also enter marine waters from a variety of

other sources, including waste discharges, dumping, and rivers. For comparative purposes, table

18 lists several estimates of direct PCB inputs to

various marine waters from various sources.

The data indicate that ocean incineration employed on a modest scale would cause an incremental increase in the total input of PCBs to marine waters. Clearly, the relative magnitude and

significance of such an increase would also vary with

respect to location. For example, in contrast to most

of the inputs from sources shown in table 18, the

emissions from ocean incineration would be expected to enter marine waters at considerable distances from the coast. At these deep ocean sites,

the emissions could represent a greater fractional

input of PCBs, but would be dispersed over a much

larger volume and have less adverse impact on marine life or humans. Unfortunately, few data are

available with which to assess the absolute significance of the consequences of the incremental increase in PCBs that would be caused by ocean incineration (see ch. 9 for a discussion of one study).

Table 18.—Estimated Inputs of PCBs

to Various Marine Waters

Affected waters: Annual PCB

source loading (kg/yr)

New York Bight:a

Sewage sludge dumping . . . . . . . . . . . 800-2,000

Dredge materials dumping . . . . . . . . . 3,500

POTW discharges . . . . . . . . . . . . . . . . . 200-1,000

Upstream sources. . . . . . . . . . . . . . . . . 3,100

Southern California Bight:b

Sewage . . . . . . . . . . . . . . . . . . . . . . . . . . 2,000

One incineration vessel

at 99.9999% DEC 

. . . . . . . . . . . . . . . . . . 18

One incineration vessel

at 99.99% DEC 

. . . . . . . . . . . . . . . . . . . . 1,800

aJ< o’~nnor, J. Klo@ and T. Knelp, “Sources, Sinks and Dletrtbutlon of orgmic

Contamlnant$ In the New York Bight Ecosystem,” Ecological Stress and the

New 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 Hearing

Before the Subcommittee on Fisheries and Wildlife Conservation and the

Environment and the Subcommittee on Oceanography of the Houee Committee

on Merchant Martne and Fisheries, 9Sth Cong., Ist sese., Dec. 7, 19S3, Serial

No. 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 both

land-based and ocean incineration. Indeed, EPA’s

Science Advisory Board has identified the lack of

data on the formation of PICs as a major gap in

our understanding of incineration, one that precludes an accurate assessment of the full extent of

exposure and the impacts of incinerator emissions.

Emissions of PICs were studied in each of the

previous U.S. ocean burns, and in a number of

land-based incineration trials. Many questions remain regarding the adequacy of sampling and analysis undertaken during the trials, especially with

respect to identifying and detecting PICs. The most

glaring shortcoming, which was common to virtually all such measurements, was that only a small

fraction of all compounds in the emissions (both

parent compounds and PICs) was actually identified and individually measured (app. E in ref. 22).

Thus, the fraction of emissions that is actually

PICs, as opposed to residual parent compounds,

is unknown.

This factor alone can lead to underestimation of

PIC emissions by several orders of magnitude. For

example, in past burns the sum of the amounts of

individually identified and measured PICs typically

accounted for about 1 percent of the total unburned

hydrocarbons present in emissions (app. E in ref. 22).

Moreover, in most past trial burns, measurements were attempted for only a few PICs. In the

ocean incineration trials involving PCBs, for example, analysis was performed for only a single

PIC: tetrachlorodibenzo-p-dioxin (TCDD).

Other sources of uncertainty in estimating PIC

emission rates from existing data include the following (app. E in ref. 22):

●

●

●

●

●

inconsistency in definitions of what constitutes

a PIC;

variations in sampling procedures and detection limits for PICs;

inconsistency in lists of compounds for which

sampling and analyses were undertaken;

variations in waste feed, which is thought to

be a partial determinant of PIC composition;

and

variations in incinerator type and operating

conditions.
Ch. 8—Environmental Releases From Ocean Incineration ● 147

What is needed is a systematic examination of

PICs to provide a consistent and comparative set

of data for evaluating both land-based and ocean

incineration. Currently, both the quality and quantity of existing data are insufficient to provide the

basis for any sound scientific conclusions.

Toxic Metals

Because ocean incinerators would be expected

to burn only liquid wastes with low solids content,

metal emissions would be directly proportional to

the quantity of metals present in the waste feed.

Essentially all metals present in the waste would

exit the stack during the course of the burn.

EPA has proposed placing a regulatory limit on

allowable concentrations of metals in wastes accepted for incineration at sea (see ch. 7). Each of

14 specified metals would be limited to no more

than 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 these

metals would be released through incineration.

In addition, the proposed Ocean Incineration

Regulation would further limit the concentrations

of certain of these metals in the final blended waste

to be incinerated. This further limitation would be

accomplished through compliance with an environmental performance standard based on water quality criteria for each metal (see ch. 7). EPA has calculated the maximum quantity of particular metals

that could be emitted without exceeding applicable

water quality criteria, using a model for plume

dispersal and surface water mixing. For 3 of the

14 specified metals, the model requires a waste

concentration of less than 500 ppm. Allowable concentrations of these three metals, along with resultant annual emissions (again assuming an annual throughput of 50,000 metric tons), are shown

in table 19 (50 FR 51363, Dec. 16, 1985).

Because EPA would not limit the aggregate

quantity of metals allowable in waste to be incinerated at sea, each individual metal could theoretically be present up to its individual limit, This

would place a maximum theoretical limit on total

emissions for all 14 metals, calculated as follows:

1.1 mt (silver) + 0.5 mt (mercury) + 17.5 mt (copper) + 275 mt (11 other metals at 25 mt each) =

294 metric tons/year.

Table 19.—Maximum Concentrations of Three Metals

Allowed in Wastes To Be Incinerated At Sea

Allowable

concentrations Expected emissions

Metal (parts per million) (metric tons/year)

Silver . . . . . . . . 21.3 1.1

Mercury . . . . . . 9 0.5

Copper . . . . . . . 350 17.5

aAsaumes 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 metal

emissions, because no waste would be likely to contain all 14 metals at concentrations even approaching the maximum levels indicated above. The few

available data that quantify the metal content of

wastes likely to be incinerated at sea indicate that

the concentration of individual metals in liquid organic wastes is typically one to three orders of magnitude lower than the 500 ppm standard (3). The

metal content of wastes actually incinerated at sea

in Europe and the United States is comparably low

(1 ,9, 14).10 Nevertheless, in the following comparisons, emissions of metals at the theoretical maxim urn are used as a means of considering worstcase conditions.

Comparison With Other Releases of Metals

to Marine Waters. —Metal emissions expected

from ocean incineration may be compared with inputs of metals into marine waters from other

sources.

Coastal Waters. —Resources for the Future (16)

developed a database that estimates marine discharges of seven different metals (arsenic, cadmium, chromium, copper, lead, mercury, and zinc)

from land-based sources. Table 20 indicates their

estimate of the total amount of these metals discharged annually to the Gulf of Mexico. These inputs can be compared to the theoretical maximum

input of the same seven metals that would result

from the operation of an incineration vessel.

The data indicate that land-based sources annually deposit about 5,600 metric tons of these seven

metals in the Gulf of Mexico. In contrast, based

on the proposed limits for ocean incineration, the

1OThe PCB waste that Chemical Waste Management, Inc. (4), proposed to incinerate in the recently canceled EPA research burn contained four metals at detectable levels: chromium (35 ppm), lead (61

ppm), nickel (16 ppm), and zinc (61 ppm).
148 . Ocean Incineration: Its Role in Managing Hazardous Waste

Table 20.—Comparison of Inputs of Seven Metals to the Gulf of Mexico

From Incineration and Land-Based Sources (metric tons)

Maximum percent

Annual land-based Maximum annual increase due

Metal loading to Gulfa

incinerator emissionb

to incineration

Mercury. . . . . . . . . . . . . . . . . 27 0.5 1.9

Copper . . . . . . . . . . . . . . . . . 628 17.5 2.8

Cadmium . . . . . . . . . . . . . . . 645 25.0 3.9

Arsenic . . . . . . . . . . . . . . . . . 757 25.0 3.3

Lead. . . . . . . . . . . . . . . . . . . . 828 25.0 3.0

Chromium . . . . . . . . . . . . . . . 1,317 25.0 1.9

Zinc . . . . . . . . . . . . . . . . . . . . 1,405 25.0 1.8

Total . . . . . . . . . . . . . . . . . 5,607 143.0 2.6

SOURCES: 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 emissions

would be 143 metric tons per ship per year.11 Thus,

even if incinerated wastes contained the maximum

allowable amounts of these metals, each incineration vessel operating in the Gulf would increase the

input of these seven metals by about 2.6 percent.

Adding estimates for a number of metals obscures the fact that significant variation commonly

exists in the amount of various metals in wastes.

This is true for both incinerable wastes and the

other sources of metal inputs discussed above. The I

, variation takes on greater significance in light of

the fact that metals differ significantly with respect

to human and environmental toxicity.

To illustrate this variation, table 20 indicates the

quantities of individual metals contributed by landbased sources and (in the worst case) by operation

of an incineration vessel. The data indicate that

mercury and zinc are discharged in the smallest and

largest amounts, respectively, from land-based

sources; inputs of zinc into the Gulf are more than

50 times greater than inputs of mercury.

Also shown in table 20 is the maximum percent

increase in inputs of each of the seven metals that

would result from the operation of an incineration

vessel. Interestingly, despite the fiftyfold difference

in the actual quantity of mercury and zinc entering the Gulf, the predicted relative increases in the

inputs of these two metals resulting from incineration are almost identical (1.9 percent for mercury

versus 1.8 percent for zinc). This similarity is due

1117.5 mt (copper) + 0.5 mt (mercury) + 125 mt (5 X 25 mt for

the other five metals) = 143 mt per ship per year.

to the fact that the proposed limitation on incinerator emissions specified for zinc is fiftyfold higher

than that proposed for mercury.

Finally, the data in table 20 indicate that, even

in the worst case, the incremental increase in metal

inputs caused by incineration would be small for

all seven metals, ranging between 1.8 percent (zinc)

and 3.9 percent (cadmium).

Other available data on toxic metal inputs to

coastal marine waters include estimates for six metals in the New York Bight (13) and eight metals

in the Southern California Bight (24). The sources

considered in these studies included municipal and

industrial wastewaters, atmospheric deposition, and

storm runoff. These data indicate annual metal inputs of about 3,500 metric tons (in the Southern

California Bight) and 24,500 metric tons (in the

New York Bight). Using maximum emissions limits

calculated for these metals, one incinerator ship

could theoretically contribute about 4 percent

(Southern California) and 0.5 percent (New York)

of the respective metal burdens already entering

these marine waters.12

Open Ocean Waters. —Currently some 300,000

metric tons of acid and alkaline wastes are directly

dumped into the ocean each year (7). This practice is expected to continue for the foreseeable future. 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 distances from the coast. At these ocean sites, they might be a greater

fraction of total inputs, but also could be expected to disperse over

a much larger volume and to cause less adverse impact on marine

life or humans.
Ch. 8—Environmental Releases From Ocean Incineration ● 149

(cadmium, chromium, copper, lead, and zinc) present in this waste is estimated to be about 630 metric tons (7). Relative to the maximum theoretical

limit on incinerator emissions for these five metals

(1 17.5 metric tons annually), the amount dumped

directly into the ocean is about five times greater

than the amount an incinerator vessel would emit

in the worst case.

As a final comparison, metal emissions from

ocean incineration can be compared to the quantity of metals present in sewage sludge that is

dumped in the ocean. An estimate for the concentrations of the five predominant metals (cadmium,

chromium, copper, nickel, and zinc) present in

New York City’s sewage sludge was developed for

the City’s Department of Environmental Protection (ref. 12, cited in ref. 17).13 The ocean dumping of New York City’s sewage sludge is estimated

to contribute approximately 540 metric tons annually of these five metals, or almost five times the

maximum theoretical quantity of these same metals

that one incinerator ship could emit in a year.

Because New York City’s sewage sludge represents only about half of the total amount currently

dumped in the ocean (1 1), this source of metals to

the marine environment is even larger than the

above comparison indicates.

Comparison With Land-Based Incineration.

—Land-based incinerators that would otherwise exceed the particulate standard specified under the

Resource Conservation and Recovery Act (RCRA)

(see ch. 7) are required to be equipped with stack

scrubbers designed to control particulate emissions,

Because most metals are strongly bound to particulate matter, scrubbers should significantly reduce

metal emissions from hazardous waste incineration.

EPA (22) compared expected emissions of metals from land-based and ocean incineration, using

a model liquid wastestream containing 100 ppm of

each 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 are

assumed to be removed at 90 percent efficiency.

Using these assumptions, EPA predicts that total

metal emissions from land-based incineration of this

model wastestream would be one-fifth of those from

ocean incineration.

EPA’s estimates of the scrubbers’ removal efficiencies might be too high for the incineration of

liquid wastes, because resulting particulate would

fall at the low end of the particulate size range and

would be removed at a lower efficiency than average (2). Nonetheless, incineration of waste at sea

would clearly result in greater emissions of metals

than incineration of the same waste on land at facilities equipped with scrubbers.

Comparison With Background Metal Concentrations in the Open Ocean.—EPA used an

atmospheric plume/ocean transport model to estimate the rate at which metals would be deposited

and how large an area would be affected by emissions from ocean incineration. For the model (4-

metal) wastestream described in the previous example, the total amounts of each of the four metals deposited per unit area were calculated. The

subsequent mixing of metals in seawater was explored under three scenarios and the resulting metal

concentrations were calculated. Table 21 presents

these scenarios and concentrations (app. I in ref.

22).

Some limited field data provide estimates of background metal concentrations in the open ocean.

Background concentrations were calculated for the

upper 60 meters, allowing a direct comparison to

the estimated input from ocean incineration under

Scenario 3. Table 22 presents the results of this

comparison (App. I in ref. 22).

These data indicate that, for mixing to 60

meters, 14 three of the four metals would be well below background. Only cadmium could be expected

to 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 dumped

at a site in the New York Bight. Under current regulations to be completely in effect by the end of 1987, all of this sludge, as well as that

from two newly constructed treatment plants in New York City, is

to be dumped at the 106-mile Sewage Sludge Dump Site, located immediately 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 as

comprising the upper 20 meters of surface water; this represents an

estimate of the depth of the surface thermocline, above which the initial mixing would be expected to occur. Initial mixing would be defined as “dispersion or diffusion of incinerator emissions into the receiving water which occurs within four hours after release from the

incinerator” (50 FR 8258, Feb. 28, 1985).
150 . Ocean Incineration: Its Role in Managing Hazardous Waste

Table 21.—Metal Concentrations Resulting From

Ocean Incineration, Under Three Different Scenarios

for Mixing of Emissions in Seawater

Resulting

concentration a

Scenario 1:

All metals are deposited within the

surface microlayer, represented by

the upper 0.1 millimeter of the ocean

surface in the affected area . . . . . . . . . . 320,000 pptb

Scenario 2:

All metals are evenly mixed in the

upper 1 meter of the affected area . . . . 32 ppt

Scenario 3:

All metals are evenly mixed in

the upper 60 metersc of the

affected area . . . . . . . . . . . . . . . . . . . . . . . 0.53 ppt

aA99urnes that four metals (arsenic, cadmium, chromium, and niCkeO are Present

in 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 20

meters of surface water this represents an estimate of the depth of the surface

thermocline, above which the Initial mixing would be expected to occur.

SOURCE: U.S. Environmental Protection Agency, Office of Policy, Planning and

Evaluation, “Background Report IV: Comparison of Risks From LandBased and Ocean-Based Incineration: Appendix l,” Assessment of

Incineration as a Treatment Method for Liquid Organic Hazardous

Wastes (Washington, DC: 19S5).

under this scenario. Even if metals from emissions

were confined to the upper 1 meter of water, only

cadmium could be expected to exceed its backt ground level; in this case, however, the cadmium

level would be about 100 times its background concentration.

In contrast, if all emissions were somehow entirely confined to the microlayer, all four metals

would far exceed background levels. This would

be true despite the fact that background levels of

metals measured in the surface microlayer exceed

those measured in surface waters by a factor of anywhere from 1 to 50 (app. I in ref. 22). The significance of the microlayer is an area of considerable

controversy, and is discussed in chapter 9.

Acid Gases

Because ocean incineration is not expected to employ scrubbers to remove acid gases, the level of

acid emissions can be calculated directly from the

chlorine (or other halogen) content of the waste

feed. Almost all of the organic chlorine content of

wastes would be converted through incineration to

hydrogen chloride (HCl) gas, with much smaller

amounts 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 of

highly chlorinated wastes at sea might exceed the

proposed environmental performance standard for

HCl (see ch. 7), EPA (50 FR 8245, Feb. 28, 1985)

developed a worst-case scenario by assuming the

following:

●

●

●

pure carbon tetrachloride, 92 percent chlorine

content, is incinerated at a rate of 25 metric

tons per hour;

all chlorine exits as HCl at a rate of 23.7 metric tons per hour; and

all HCl is deposited within 100 meters of the

ship and mixed to a depth of 20 meters (the

estimated depth of the thermocline defining

the 4-hour mixing zone), which makes the total

volume of the mixing zone 22 billion liters.

Under these extreme conditions, EPA estimated,

the resulting decrease in alkalinity of seawater in

the mixing zone would be only about 1.3 percent,

Table 22.—Comparison of Metal Inputs From Ocean Incineration to

Background Metal Concentrations in the Upper 60 Metersa of the Open Ocean

Upper 60 meters Upper 60 meters Ratio of background

Metal b

background level (ppt)c Scenario 3 level (ppt) to Scenario 3

Arsenic . . . . . . . . . 1,100 0.53 2,075

Cadmium . . . . . . . 0.3 0.53 0.57

Chromium. . . . . . . 268 0,53 506

Nickel . . . . . . . . . . 146 0.53 275

aEPA’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: timparison of Risks From Land-Based and Ocean-Baaed Inclneratlon: Appendix l,” Assessment of /incineration as a Treatment Method for Liquid Organic Hazardous Wastes (Washington, DC: 19S5).
Ch. 8—Environmental Releases From Ocean Incineration ● 151

Photo credit: Fred Ward @ 1985 National Geographic Society

The Vulcanus // incinerator ship, now owned by

Chemical Waste Management, Inc., operating in the

North Sea. The plume from the ship is composed

mostly of steam and hydrochloric acid.

well below the 10 percent change allowed by the

proposed standard.

This scenario has been challenged on the basis

that it ignores potential impacts that could occur

at the higher concentrations of acid that would exist before initial mixing was achieved (i. e., before

4 hours had elapsed). In particular, regions of the

surface microlayer that came in direct contact with

the incinerator plume might well be exposed to very

high (though transient) HCl concentrations. In that

event, a large proportion of the organisms in this

area could be impaired or possibly killed.

However, given the intermittent nature of ocean

incineration, the relatively small size of the affected

area, and the high renewal rate of the surface

microlayer resulting from new growth and replenishment from adjacent areas, the long-term net loss

of biomass would probably be small or non-existent.

A more extensive discussion of the nature and significance of the surface microlayer is presented in

chapter 9.

Acid wastes are currently directly dumped into

the ocean at two sites in the North Atlantic Ocean

(7), The rate of dumping of this waste and the size

of the dumping area are such that the concentration of acid entering surface waters greatly exceeds

that expected from an incineration vessel, by a factor of about 250 (9). In some cases, transient (1

to 4 hours) perturbations in the alkalinity of seawater have been observed following the dumping

of acid waste, although no significant effects on marine life have been observed. In contrast, extensive monitoring of past ocean incineration burns

has not detected any change in seawater alkalinity

(see ch. 11).

Air Pollution Control Device Effluents

This waste, which is generated in very large

quantities by land-based incinerators equipped with

scrubbers, contains all of the particulate, metals,

and acid gases removed from incinerator emissions.

EPA (app. Fin ref. 22) calculated the following annual composition and quantity of scrubber effluent

from a land-based incinerator burning 50,000 metric tons of PCB waste annually and complying with

all RCRA standards (waste metal content was assumed to be 100 ppm each of arsenic, cadmium,

chromium, and nickel):

● total quantity— 1.34 million metric tons (more

than 99 percent wastewater);

. chlorine content—9,30() metric tons (O. 7 percent of the total), mostly dissolved salts; and

. ~et~ content—4. 5 metric tons each of cad-
152 . Ocean Incineration: Its Role in Managing Hazardous Waste

mium, chromium, and nickel and 2.5 metric charged under a Clean Water Act permit as nontons of arsenic. hazardous waste. Sludges generated through treatScrubber effluents are typically neutralized, ment are normally considered hazardous under

RCRA, and must be disposed of as such. treated to remove particulate matter, and disSUMMARY AND COMPARISON OF TOTAL RELEASES FRO M

LAND-BASED AND OCEAN INCINERATIO N

This section summarizes and compares estimates

of the total amounts of waste released by land-based

incineration and by ocean incineration. The comparison highlights major differences between these

technologies with regard to their potential to cause

exposure and adverse impacts.

I

The EPA incineration study (21) attempted to

quantify releases from each phase of operations for

both land-based and ocean incineration. The study

evaluated the incineration of two different wastes-

.— --—- - — nfi m -- — * – :-.: — — . – –A – .- -—: . I . r -: -. urcdms: a PCB-contaminating waste typlcaJ 01 exisling stockpiles; and an ethylene dichloride (EDC)

waste representing a common (though simplified)

industrial chlorinated wastestream. Table 23

presents estimates of how much of each of these

wastes would be released during various phases of

incineration operations. For a full discussion of the

derivation of these estimates and the assumptions

and uncertainties involved, the reader should consult the EPA study.

The absence of reliable data, particularly for PIC

emissions, and the need to invoke numerous assumptions that are difficult to verify, cast considerable doubt on the estimates and greatly limits

their use for setting policy. In particular, the absolute quantities probably do not accurately reflect

releases from any actual operation.

The following discussion uses the data presented

in table 23 for comparative purposes only, to identify substantial differences between the releases expected from land-based and ocean incineration.

Within the limits of accuracy of EPA’s release

estimates, land-based and ocean incineration appear to pose comparable hazards with respect to

the overall quantities of wastes and waste products

released into the environment. However, the nature and location of the releases also play major

roles in determining the potential for humans and

the environment to be exposed to or harmed by the

releases. By highlighting these differences, chapter 9 compares risks to humans and the environment posed by land-based and ocean incineration.

As an aside, data presented on the last line of

table 23 underscores the general advantage of incineration (on land or at sea) over land disposal as

a means of managing hazardous waste. Expressed

as a percentage of total throughput, releases of

waste from incineration are minute, indicating the

tremendous potential for incineration to reduce

both the quantity and degree of hazard associated

with these wastes.

Ocean incineration can be expected to release

somewhat greater quantities of waste and waste

products to the environment than land-based incineration. Increased releases are expected from

several phases of ocean incineration operations.

Transfer and Storage.—Ocean incineration

would entail at least one extra step, namely the

transfer of wastes to the vessel itself. This additional

activity would slightly increase the expected quantity of fugitive emissions and the likelihood of a spill

occurring.

Ocean Transportation.—Ocean transportation

of hazardous waste, which would obviously occur

only for incineration that took place at sea, would

increase the risk of waste being released through

spillage. Assigning an annual average quantity to

such an event is highly problematic, because it does

not adequately reflect either the probability of a spill

occurring or the size of the spill. Available data

strongly suggest that a marine spill from an ocean

incineration vessel represents a very low-probability

event; however, it is equally clear that the consequences of such an event could be catastrophic (see

ch. 9).
Ch. 8—Environmental Releases From Ocean Incineration ● 153

Table 23.—Summary of Annual Incineration Releases for Two Model Wastestreams

PCB wastes EDC wastes

Assumptions:

Concentration of PCB or EDC . . . . . . . . . . . . . . . . . . . . . . 350/0 50 ”/0

Metal content (As, Cd, Cr, Ni) . . . . . . . . . . . . . . . . . . . . . . 100 ppm each 100 ppm each

Annual throughput. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50,000 mt 68,500 mt

Destruction efficiency. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 99.99990/0 99.99 ”/0

Use of modern transfer facility . . . . . . . . . . . . . . . . . . . . . Yes Yes

Ocean Land Ocean Land

Estimated reieases (mt/yr)a:

Land transportation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2.1

Transfer and storage . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1.2

Ocean transportation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 0.6

Subtotal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3.9

Normal stack emissions:

Unburned wastes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 0.1

PICs b . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . <<0.1

Metals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22.4

Stack subtotal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22,5

Scrubber effluent metals . . . . . . . . . . . . . . . . . . . . . . . . . . —

Total releases (mt/yr). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26.4

(as percent of throughput) . . . . . . . . . . . . . . . . . . . . . . . 0.053

2.1

1.1

—

3.2

0.1

<<0.1

4.5

4.6

17.9

25.7

0.051

2.7

1.2

0.8

4.7

6.8

20.6

27.4

54.8

—

59.5

0.087

2.7

1.1

—

3.8

6.8

0.6

5.5

12.9

21.9

38.6

0.056

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; actual

releases 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 mate s of 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 Treatment

Method for Liquid Organic Hazardous Wastes (Washington, DC: 1985).

For these reasons, comparing the risks of spills

from incineration vessels to the risks of spills from

marine transportation of hazardous substances in

general is more appropriate than comparing them

to transportation risks from land-based incineration. This more appropriate comparison is presented earlier in this chapter.

As expected, table 23 indicates a somewhat larger

(20 percent) release from transporting and handling

waste for ocean incineration than for land-based

incineration, primarily because of the additional

marine transportation that would be involved. The

slightly larger releases expected for the EDC waste

relative to PCBs is due mostly to the higher assumed throughput.

Incineration. —For both land-based and ocean

incineration, and for both types of wastestreams,

the incineration process itself would be the major

source of expected releases. Each of the three major categories comprising total incinerator emissions

is discussed below.

Unburned Waste. —More unburned EDC waste

than PCBs would be released because a lower destruction efficiency and a higher annual throughput apply to the EDC waste. Under the assumptions employed, no differences in quantities of

undestroyed waste released from land-based and

ocean incineration are expected.

PICs. —All of the estimates for PIGs are based

on extremely limited field data, and cannot serve

as the basis for sound generalizations. Thus, EPA’s

estimates that much higher PIC emissions would

be expected from ocean incineration of EDC waste

than from land-based incineration, and from burning EDC waste than from burning PCBs, cannot

be considered reliable (see previous section on

PICs). The only possibly valid generalization is that

achievement of a higher DE should logically lead

to lower PIC emissions. However, even this straightforward prediction must await further field verification for both land-based and ocean incineration.

Metals. —The quantity of metals resulting from

burning the same type of waste is not expected to

differ between land-based and ocean incineration.

However, the use of air pollution control equipment on some land-based incinerators (which rep-
I

I

154 ● Ocean /incineration: Its Role in Managing Hazardous Waste

resents a major regulatory distinction between these

technologies) is expected to alter the final disposition of such metal emissions. For both the PCB and

EDC wastestreams, the sum of metals present in

stack releases and scrubber effluents from landbased incineration would be equal to the stack releases of metals from ocean incineration.

The data in table 23 suggest that metals account

for the great majority of releases from land-based

and ocean incineration. These estimates, however,

depend entirely on the assumptions made about

metal content, which appear to have been substantially overestimated (see previous section on estimating releases of metals).

As is the case with PIC emissions, our present

understanding of metal emissions, both qualitative

and quantitative, is far from adequate for both landbased and ocean incineration. This major data gap

limits our ability to accurately assess the potential

for exposure to and harm from incineration of hazardous wastes.

CHAPTER 8 REFERENCES

1.

2.

3.

i

4.

5.

Ackerman, D. G., and Venezia, R. A., “Research

on At-Sea Incineration in the United States, in

VVastes 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 Incineration, 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).

Castaldini, C., Willard, H, K., Wolbach, C. D., et

al., A Technical Overview of the Concept of Disposing of Hazardous Wastes in Industrial Boilers,

EPA No. EPA-600/2-84-197, prepared for the U.S.

Environmental Protection Agency, Office of Research and Development, Industrial Environmental

Research Laboratory (Washington, DC: December

1984).

Chemical Waste Management, Inc., “Application

for a Research Permit To Incinerate Hazardous

Waste At Sea: Exhibit B“ (Oak Brook, IL: May

24, 1985).

Connor, M., “Statement on Incineration of Hazardous Waste At Sea, Hearing Before the Subcommittee on Fisheries and Wildlife Conservation

and the Environment and the Subcommittee on

Oceanography of the House Committee on Merchant 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 of

Public Interest Advocacy, “Comments of the Department of the Public Advocate on EPA’s Proposed

Ocean Incineration Regulations” (Trenton, NJ:

June 28, 1985).

7. EG&G Washington Analytical Services Center,

Inc., Oceanographic Services, Industrial Waste Dis8,

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 (Waltham, MA: February 1986).

Engineering Computer Optecnomics, Inc., “Analysis of the Risk of a Spill During a Single Voyage

of the Vulcanus 11 From the Port of Philadelphia

to the Incineration Site in the Atlantic Ocean, prepared for the U.S. Environmental Protection

Agency (Annapolis, MD: Apr. 30, 1986).

Fay, R. R., and Wastler, T. A., “Ocean Incineration: Contaminant Loading and Monitoring, ” in

Wastes 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 Education

Fund, “Independent Observations on Ocean Incineration, A League Member’s Experiences on

Vulcanus 11 Voyage, November 4-9, 1983, ” prepared by D.B. Sheridan (Austin, TX: 1983).

Leschine, T. M., and Broadus, J. M., “Economic

and Operational Considerations of Offshore Disposal of Sewage Sludge, ‘‘ in Wastes in the Ocean,

vol. 5, D.R. Kester, et al. (eds. ) (New York: John

Wiley & Sons, 1985), pp. 287-315.

Metcalf & Eddy of New York, Inc., and Lawler,

Matusky & Skelly Engineers, “Industrial Pretreatment Program for the City of New York Department of Environmental Protection, Task 4: Determination of Technical Information Required For

the Development of an Updated Industrial Waste

Ordinance” (New York: Metcalf & Eddy of New

York, 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-
Ch. 8—Environmental Releases From Ocean Incineration ● 155

trols for Incineration At Sea, in Wastes in the

Ocean, 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 in

the New York Bight Ecosystem, Ecological Stress

and the New York Bight, G. Mayer (cd. ) (Charleston, SC: Estuarine Research Federation, 1982), pp.

631-653.

16. Resources for the Future, Renewable Resources Division, PoZlutant Discharges to Surface Waters for

Coastal Regions, prepared for the U.S. Congress,

Office of Technology Assessment (Washington,

DC: February 1986).

17. Science Applications International Corp., “Assessment of Ocean Waste Disposal Case Studies, prepared for the U.S. Congress, Office of Technology

Assessment (McLean, VA: Science Applications International Corp., Oct. 3, 1985).

18. U.S. Army Corps of Engineers, Waterborne Commerce Statistics Center, Waterborne Commerce of

the United States (New Orleans, LA: 1984).

19. U.S. Congress, Office of Technology Assessment,

Transportation of Hazardous Materials, OTASET-304 (Washington, DC: U.S. Government

Printing Office, July 1986).

20. U.S. Department of Transportation, U.S. Coast

Guard, Polluting Incidents In and Around U.S.

Waters, Calendar Years 1982 and 1983, Commandant Instruction M16450.2F (Washington, DC:

1983).

21. U.S. Environmental Protection Agency, Office of

Policy, Planning and Evaluation, ‘ ‘Summary and

Conclusions, Assessment of Incineration as a

Treatment Method for Liquid Organic Hazardous

Wastes (Washington, DC: March 1985).

22. U.S. Environmental Protection Agency, Office of

Policy, Planning and Evaluation, “Background Report IV and Appendices: Comparison of Risks

From Land-Based and Ocean-Based Incineration, ”

Assessment of Incineration as a Treatment Method

for Liquid Organic Hazardous Wastes (Washington, DC: March 1985).

23. U.S. Environmental Protection Agency, Science

Advisory Board, Report on the Incineration of Liquid Hazardous Wastes by the Environmental Effects, Transport and Fate Committee (Washington,

DC: April 1985).

24. Young, D. R., Moore, M. D., Alexander, G. V., et

al., Trace Elements in Seafood Org-anisms Around

Southern California Municipal Wastewater OutfalZs, Publication No. 60 (Sacramento, CA: California State Water Resources Control Board, 1978).

25. Zurer, P. S., ‘ ‘Incineration of Hazardous Wastes At

Sea—Going Nowhere Fast, ” Chem. Engr. News,

Dec. 9, 1985, pp. 24-42.
Chapter 9

Comparison of Risks Posed by

Land-Based and Ocean Incineration
Contents

Page

Risks of Human Exposure and Impact. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ., . .........159

Risks of Environmental Exposure and Impact . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 161

Impacts From Routine Emissions . . . . . . . . . . . . . . . . . . . . . . ......................,..161

Impacts From Accidental Spills . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...............162

The Role of the Surface Microlayer . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. ...165

Additional Factors Relevant to a Comparison of Land-Based and Ocean Incineration ....166

Onsite Versus Offsite Incineration, . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ............166

Cost to Generators . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .....................167

Ease of Monitoring and Surveillance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .,.,........,168

Degree and Nature of Public Participation ....,, . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...168

Chapter 9 References. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ........169

Table

Table No. Page

24. Major Areas of Concern Identified by EPA in Its Ocean Incineration

Research Strategy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..........164
Chapter 9

Comparison of Risks Posed by

Land-Based and Ocean Incineration

Each of the several types of releases from landbased and ocean incineration has the potential to

adversely affect exposed humans or organisms in

marine and terrestrial environments. This chapter explores the key differences between land-based

and ocean incineration technologies in terms of the

relative risks they pose to human health and to the

environment. The chapter also discusses the controversial topic of the surface microlayer’s role and

the potential for ocean incineration to adversely affect it.

An extensive literature describes the potential for

the various aspects of incineration to adversely affect humans and the environment. A full analysis

of this literature is well beyond the scope of this

study. Moreover, such information rarely provides

significant insight into the comparative aspects of

risks posed by land-based and ocean incineration,

partly because many risks cannot be quantified at

all, and partly because the fundamentally different nature of the risks often precludes comparison.

For example, no accepted methodology exists for

comparing a risk to human health with a risk to

the marine environment. Yet the comparative aspects of risk are the most relevant in the policy setting that surrounds the issue of ocean incineration.

Because of such limitations, the discussion is restricted primarily to two subjects: the primary types

of risks posed by incineration technologies; and the

differences between land-based and ocean incineration that bear on the risks each poses to human

and environmental health. Where direct comparison of risks is possible, available data are discussed

accordingly.

RISKS OF HUMAN EXPOSURE AND IMPACT

One of the major conclusions of EPA’s incineration study was that ocean incineration would pose

a substantially lower risk of human exposure and

health effects than land-based incineration poses.

This conclusion was reached by estimating direct

exposures and the resulting incremental cancer risks

associated with each of the several types of stack

releases (POHCs, PICs, and metals).

The analysis, however, has several shortcomings:

●

•

●

it only evaluated cancer risks, ignoring the potential for other health effects; in addition, the

accuracy of the cancer risk estimates is questionable;

it considered in detail only direct exposure to

emissions via inhalation and did not sufficiently assess other routes of exposure (e. g.,

ingestion of seafood or terrestrial food crops

contaminated through bioaccumulation of

emission products);

it analyzed risks for a hypothetical ‘‘most exposed individual, and not for the population

●

as a whole; although the level of risk would

certainly be greater for the former, relative

risks could differ if assessed for the population

as a whole; and

it considered only routine stack releases as

sources of exposure and excluded spills, fugitive emissions, and releases due to incinerator upset.

Many exclusions were necessitated by the lack

of data required to quantify the risks. For example, data on health effects other than cancer are generally lacking for many of the substances present

in stack emissions. Similarly, estimation of risk to

an entire population would require a quantification of exposure to various sectors of the population, which would be exceedingly difficult (and controversial) to perform.

Despite these shortcomings, however, the general conclusion that ocean incineration poses substantially less risk to human health than does landbased incineration appears both logical and reason159
160 . Ocean Incineration: Its Role in Managing Hazardous Waste

able, if judged from within the limits of our current level of understanding. Several lines of reasoning support this conclusion.

The major releases from incineration are from

the incineration process itself, and incineration at

sea is much further removed from human populations than is land-based incineration.

The general population would be exposed to substantially fewer releases from ocean incineration

than from land-based incineration. The two processes would release roughly comparable quantities

of material, and several plausible or demonstrated

routes could expose humans to waste products released even in the open ocean. Such factors as

atmospheric and ocean dilution volumes, the relative human dietary intake of marine versus terrestrial food products, and distance, however, would

lessen the exposure from ocean incineration.

EPA’s estimates assign the major portion of incremental cancer risk to metal emissions, which are

predicted to be higher for ocean incineration because scrubbers would not be required on incineration vessels. Nonetheless, the risks to human

health 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 not

equipped with scrubbers would release metals

in the same uncontrolled fashion as ocean incinerators, but because land-based incineration occurs closer to humans, it would produce

a higher exposure.

● Regulations governing land-based incineration

do not specify limitations on metal content of

wastes, as would the proposed regulation for

ocean incineration.

● Although land-based incineration regulations

control particulate (but not metals per se) and

require scrubbers for wastes that would otherwise exceed the standard, the removal efficiency of scrubbers for metals is probably lower

than assumed by EPA, particularly for the liquid wastes relevant to this discussion. Incineration of liquids generates only low levels of

smaller than average particulate, and scrubbers operate less efficiently at low particulate

density and on small particulate (l).

● Although toxic metals removed by scrubbers

are deposited in scrubber effluents and sludges,

EPA’s study did not assess the considerable

potential for human exposure to these wastes,

for example, via groundwater for landfilled

sludges, and drinking water for discharged effluent.

One recent study modeled the exposure of humans to emissions of PCBs, through both direct and

indirect pathways, and concluded that exposure

would be considerably lower from ocean incineration than from land-based incineration (9). For

land-based incineration, the study evaluated human exposure to PCBs that could result from inhalation, drinking water, and diet (terrestrially

grown food); for ocean incineration, it evaluated

human exposure that could result from a seafood

diet (fish and shellfish). In considering dietary exposures to PCBs, the study compared average exposures from land-based incineration with worstcase exposures from ocean incineration (i. e., individuals were assumed to receive all seafood from

the ocean incineration site).

The study concluded that dietary exposures to

PCBs would still be 20 times higher from landbased incineration. Predicted exposures from inhalation were two orders of magnitude higher for

land-based incineration, and predicted exposures

from drinking water were comparable to those expected from ingestion of seafood.

Because of a lack of information, the study did

not model exposures that would result from the concentration of emissions in the ocean surface

microlayer (see later section in this chapter). If the

microlayer is an important contributor to the marine food chain, the relative magnitude of dietary

exposures could be altered significantly.

One possible major exception to the generalization that ocean incineration would pose no greater

risk to human health than land-based incineration

poses is the unlikely event of a catastrophic spill,

particularly one occurring close to shore. Estimating the extent of health risk from direct and indirect

human exposure to spilled waste materials is fraught

with difficulties. However, such risks would probably, under some circumstances, be much greater

for 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 expected

to be much greater at sea than on land.

Despite many years of operating experience, the

actual impact of land-based incineration has been

very difficult to study and ascertain. In part, this

is because of a general lack of understanding of two

issues identified by EPA’s Science Advisory Board

(16)—the transport and fate of incineration products in terrestrial ecosystems and the use of monitoring strategies and technologies that are less than

state-of-the-art. Environmental monitoring is complex on land, however, because similar emissions

can arise from other land-based sources of pollution, greatly complicating attempts to assign exposure or impacts to land-based incinerators or even

to study the transport and fate of incinerator

emissions.

RISKS OF ENVIRONMENTAL EXPOSURE AND IMPACT

Comparing the environmental consequences of

land-based and ocean incineration is much more

difficult (if not impossible) than comparing their

risks to human health, because marine and terrestrial environments and the potential impacts involved are so fundamentally different. Even when

data allowing risks to be quantified are available,

no accepted means exist for comparing the risks

faced by different organisms or environments.

Because of these difficulties, the discussion in this

section is limited to a description of the nature and

expected extent of environmental risks posed by

ocean incineration, and a sketch of aspects or resources unique to marine environments that might

be affected by ocean incineration. Potential adverse

effects of routine emissions and of accidental spills

are discussed separately.

Impacts From Routine Emissions

The first area affected by incinerator emissions

would be the ocean surface contacted by the incinerator plume. Particular attention has been focused

on the so-called surface microlayer, represented

by the skin or uppermost fraction of a millimeter

of the ocean. This micro-environment has been

shown to contain high concentrations of both living

organisms and contaminants, relative to the water

immediately below the surface. Information concerning the nature and ecological significance of the

microlayer habitat is only beginning to emerge.

With respect to ocean incineration’s potential effect on it, EPA’s Science Advisory Board (16) has

identified the surface microlayer as a priority for

further study and testing, partly because of its probable key role in the food chain of the ocean. The

current state of knowledge regarding this habitat

is discussed later in this chapter.

Various types of marine organisms have the

potential to be affected by incinerator emissions.

Plankton, which are microscopic organisms present

in immense numbers in the water column, could

suffer both short- and long-term damage from various components of incinerator emissions. During

past U.S. burns, attempts were made to sample

plankton and to look for short-term effects caused

by changes in chlorine content, alkalinity, and the

introduction of trace amounts of organochlorine

compounds and metals. In addition, physiological

indicators of plankton health (chlorophyll and

adenosine triphosphate content) were also monitored. Although no effects were detected for any

of these parameters, the number and size of samples analyzed may have been too small to detect

changes. Moreover, an adequate method of measuring long-term effects has not been developed, so

they cannot currently be assessed.

Fish and other swimming organisms near the

settling plume might be affected briefly by the

changes described above. These effects would be

expected to be limited both temporally and spatially

because of the mobility of affected organisms and

the relatively rapid neutralization or dilution of the

residual constituents to background levels.

Somewhat longer term effects can be studied by

using certain physiological measures of stress caused

by exposure to toxic pollutants. Laboratory and

field experiments conducted during one of the past

U.S. ocean burns, in fact, detected such a stress

response (ref. 11; also see discussion of past U.S.

burns inch. 11). Activation of an enzyme-detoxifi-
162 . Ocean Incineration: Its Role in Managing Hazardous Waste

cation system was detected in fish taken from the

exposure zone, and similar results were obtained

in parallel laboratory tests involving direct exposure

of fish to raw (unburned) waste material. In the

laboratory studies, enzyme levels decreased to normal levels when fish were returned to clean water,

indicating that the response was a transient one.

These experiments provided the first direct evidence for an environmental effect attributable to

ocean incineration. Because the response was transient and the duration and scale of the experiment

were limited, the full significance of these results

cannot yet be determined. EPA plans to study this

phenomenon further as part of the Agency’s Ocean

Incineration Research Strategy (14).

Longer term or more subtle impacts (e. g., effects on reproduction or growth) are much more

difficult to study, especially in the field, and have

not been examined during past ocean burns. EPA’s

Research Strategy includes limited efforts to examine such effects.

Bottom-dwelling organisms could be affected

by contaminants adsorbed to particles that eventually became incorporated into bottom sediments,

Because water at existing or proposed incineration

, sites is deep, such effects would probably be minimal, exceedingly difficult to detect, and long term

in nature.

Prior to settling or dispersion of the incinerator

plume, there is potential for adverse impact on

migratory and open-ocean species of birds. Both

the Gulf incineration site and the proposed North

Atlantic site lie in known migratory routes. The

routes are extremely broad, and the incineration

sites cover only a small fraction of their width.

These facts, together with the intermittent nature

of incineration activities and the typically high altitude of migratory paths, should limit the extent

of this type of impact. However, migrating birds

often seek out ships or other platforms for resting;

indeed, some reports suggest that birds may be attracted to incineration vessels, particularly at night

when the glow of the furnaces is visible for considerable distances. Whether birds would avoid the

incinerator plume itself is not known (6,18).

The potential for adverse impact to marine

mammals and turtles has also generated considerable debate. The proposed Ocean Incineration

Regulation would require an endangered species

assessment to be conducted and periodically updated, in compliance with the Endangered Species

Act.

Several endangered or threatened species have

been identified in the vicinity of existing or proposed burn sites. This issue has recently been raised

in the context of EPA’s designation process for the

North Atlantic Incineration Site. An Environmental

Impact Statement (EIS) on the site completed in

1981 concluded that the site lay in migratory routes

for certain marine animals (13). New information

from the National Marine Fisheries Service

(NMFS), however, indicated that the site also lay

within a high-use area for several marine mammals,

including the endangered sperm whale (2).

Based on EPA’s updated assessment of the site

from the perspective of endangered species (17),

NMFS granted conditional approval to using the

site for a research burn (7). Final designation of

the North Atlantic Incineration Site will require a

more formal biological opinion fully addressing this

controversial issue.

Impacts From Accidental Spills

The most severe environmental impacts associated with ocean incineration would be those resulting from an accidental spill of hazardous wastes.

There is a general consensus that, under most circumstances, spilled material would be impractical

or impossible to clean up, especially as distance

from the loading dock increases. Although a spill

is considered an unlikely event, the severity of its

consequences and the difficulty of cleanup warrant

a comprehensive evaluation of the risk involved.

Unfortunately, few data are available for assessing the magnitude of the damage that would result from a major spill of hazardous wastes in marine waters. Innumerable determinants of fate and

effects must be understood in order to undertake

such an analysis. These include the following:

● the nature of the waste: factors such as density and volubility would determine the waste’s

subsequent 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 mixtures of different wastes would be complex and

hard to predict;

the properties of individual constituents: factors like toxicity, persistence, and potential for

bioaccumulation would dictate subsequent exposure and impact;

the location and characteristics of the spill site

(harbor, coastline, open ocean): water depth

and bottom terrain; currents, tides and other

determinants of dispersal rate; the presence

and value of resources; nature and extent of

biological activity; and ecological sensitivity

would all influence the magnitude of impacts

from the spill; and

the potential for cleanup or recovery: the distance from shore and the expense and availability of appropriate technologies would affect response to a spill.

For most hazardous materials, a significant spill

in almost any location would result in considerable

immediate destruction of biomass and loss of most

organisms in and around the spill. Acute effects

could result from physical impacts (e. g., smothering of bottom-dwelling organisms, or coating of

birds’ wings) as well as from the immediate toxic

effects of caustic or other highly reactive substances.

Chronic effects would be more widespread and

long-lasting, particularly for toxic and persistent

chlorinated hydrocarbons, which are among the

most likely candidates for ocean incineration.

The following discussion of the possible effects

of spills focuses on two PCB wastes—one heavier

than water (sinking) and one lighter than water

(floating)-and on two possible spill locations—

either an open-ocean setting, such as the burn site

itself, or an enclosed harbor or bay, such as Mobile. Many of the effects described would be likely

to occur only in a worst-case situation. 1 Effects from

materials that differ from PCBs in toxicity or persistence would be more or less severe and long-

-lasting.

1 Note that PC, 13s are only one of many wastes that could be incinerated 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.arge

quantities of chlorinated hydrocarbon nonwasfe materials are routinely

transported by sea (see ch. 8),

A spill of sinking material in the deep water of

the incineration site would probably pose the least

hazard, but would also be most difficult to clean

up. Acute effects on plankton or other organisms

would largely be limited to those caught in the waste

mass itself as it descended toward the bottom, Currents and waste volubility, among other factors,

could serve to further disperse waste as it passed

through the water column, thereby increasing the

area of immediate impact. The bottom-dwelling

community would be immediately and most heavily

affected in this scenario. In the worst case, a significant portion of the organisms in the affected

zone could be eliminated, and long-term contamination of bottom sediments could severely limit

recolonization. Chronic effects would be most likely

for surviving bottom-dwelling organisms, although

remobilization of contaminated sediments by bottom currents, bioturbation, or other means could

increase the size of the affected area.

A floating waste spilled at the incineration site

would probably spread over a broad area relatively

rapidly. Damage would be greatest for the surface

microlayer and for organisms living in or frequenting water near the surface. A significant portion

of such organisms would experience acutely toxic

or even lethal effects, whereas organisms with less

exposure could be expected to show chronic effects

from more gradual accumulation.

Compared to a spill in the open ocean, the consequences of a spill in a confined and shallow area,

such as a harbor or bay, would probably be more

severe. Planktonic effects from the high concentrations of PCBs could be expected. Because PCBs

tend to adsorb strongly to organic matter, organisms like shrimp larvae, which feed on organic matter, could suffer serious acute and chronic effects.

In the worst case, a sinking waste would kill most

or all bottom-dwelling organisms. Greater opportunities for resuspension of contaminated sediments

exist in shallow waters, so continued release of waste

materials to the water column could be expected.

A floating waste spilled close to land would probably be the most likely to afford opportunities for

partial cleanup. But it could also harm not only marine organisms, but humans and other shore life

(e. g., birds, shellfish beds, and wetlands), as well.

Volatilization of waste constituents from the sur-
164 . Ocean Incineration: Its Role in Managing Hazardous Waste

face slick could pose direct inhalation risks to nearby

residents. Many or most marine commercial and

recreational activities in the region would be affected immediately and possibly for the long term.

The potential effects of a PCB spill in the Delaware River and Estuary were recently assessed in

relation to a proposed research burn in the North

Atlantic Ocean (10). For a spill of about 800 metric tons2 of waste containing 10 to 30 percent PCBs,

three scenarios were modeled: 1) an upstream spill

at or near the loading dock in Philadelphia, 2) a

midstream spill near Wilmington, and 3) a spill at

the midpoint of the Delaware Estuary. Conservative assumptions regarding the dispersion and fate

of PCBs were used to generate a ‘ ‘worst-case’

prediction.

For the first two scenarios, the results indicated

that during the first several hours at a given location, water quality criteria and aquatic toxicity

levels would be exceeded and most fish would probably be killed. Predicted long-term concentrations

in the river water or sediments would be much

lower, probably below those that have been demonstrated to cause any ecological effects. For the

third scenario—an estuarine spill-a kill also would

occur during the first several hours, affecting fish,

plankton, and invertebrates, and in the worst case

involving the entire estuary. Long-term effects resulting from sediment contamination could include

accumulation of measurable quantities of PCBs in

shellfish such as oysters.

Most of the effects discussed above are difficult

or impossible to quantify. Much of the criticism of

ocean incineration identifies and focuses on the

many sources of uncertainty inherent in determining actual risk. Indeed, uncertainty is a clear theme

throughout this entire discussion of risks.

Both EPA and its Science Advisory Board recognize that much more information is needed to

evaluate the full extent of risks posed by ocean incineration. Both have identified unresolved issues

and areas that need further research. The SAB (16)

noted the following topics as needing more attention:

. understanding the role of the microlayer in the

‘Equivalent to one-fourth of the capacity of the Vukanus ZI, corresponding to the loss of the entire contents of two of its eight cargo

tanks.

●

●

●

●

marine food web and the nature of its apparent high biological activity and ability to trap

contaminants;

field-testing of the numerous models used by

EPA in estimating impacts;

better understanding the routes of exposure,

food chains, and community structures in marine environments;

determining toxicities and bioaccumulation

potential of wastes and waste products in marine settings; and

developing better means of assessing long-term —

and sublethal effects on marine organisms,

communities, and ecosystems.

EPA has developed a research strategy for ocean

incineration (14), which specifically addresses many

of the remaining areas of uncertainty, and outlines

additional research plans in both laboratory and

field settings. Table 24 lists the major areas of concern identified in EPA’s research strategy.

The SAB emphasized that uncertainty was by

no means the exclusive domain of ocean incineration, and that many of the areas the Board identified also applied to land-based incineration and

even to other common combustion processes. The

discussions in previous chapters concerning risks

associated with land-based hazardous waste disposal

and with marine transportation of hazardous maTable 24.–Major Areas of Concern Identified by EPA

in its Ocean incineration Research Strategy

1. Composition of emissions

A. Development of appropriate sampling and analysis

methods

B, Determination of the composition of emissions

from an at-sea PCB research burn

Il. Exposure assessment

A. Incineration research site selection

B. Environmental baseline sampling

C. Environmental sampling during research burn

D. Worst-case exposure scenarios

E. Laboratory transport testing

F. Transport model development, atmospheric and

aquatic

G. Transport model validation

Ill. Biological effects assessment

A. Acute and chronic toxicity

B. Bioconcentration

C. Genotoxicity

D. Effects on the surface microlayer

IV. Comparative environmental risk/hazard assessment

SOURCE: U.S. Environmental Protection Agency, Office of Water, /m3rreratiorrAt-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 comparative assessment of risks and to view any single

activity such as ocean incineration in as broad a

context 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, one

that has properties distinct from the sea immediately below and the air immediately above. Yet the

microlayer also appears to play a vital, but only

poorly understood, role as an interface and medium

of transfer between sea and air.

The dimensions and composition of the surface

microlayer have not been thoroughly defined. Although it is most commonly visualized as a surface

slick, which may be patchy, it is present even when

it is not visible. Its thickness, which is mostly defined operationally through sampling procedures,

ranges from less than one-tenth of a millimeter to

several centimeters. Many studies have demonstrated that the microlayer can be enriched in a variety of materials, including organic matter, metals, toxic organic chemicals, and active populations

of organisms (1 2). The organisms include a wide

range of bacteria, minute animals or plants (the surface subset of plankton), and the eggs and larvae

of many different fish and crustaceans. Certain species are entirely unique to the microlayer (8).

The enrichment of various materials in the

microlayer can result in concentrations that are anywhere from 2 to 10,000 times higher than those

found just a few centimeters below the surface (8).

However, the level of enrichment varies with time

of day, season, weather conditions, location, and

the particular substance or organism being considered. This variability greatly complicates the study

and definition of the microlayer.

3This discussion is based on information from papers presented at

an EPA-sponsored workshop on the Sea-Surface Microlayer, held in

Arlie, VA, on Dec. 18 and 19, 1985.

Various mechanisms for depositing and removing materials and organisms from the microlayer

have been identified. These include wave and

whitecap formation, surface interaction of gas bubbles, the natural buoyancy of eggs and larvae, the

hydrophobic (water-repelling) nature of some organic materials, surface flows and currents, and

wind action. The combined effect of these mechanisms is a steady turnover, in which loss and

replenishment of essentially all components of the

microlayer occurs continuously. For example, various organic compounds and metals can remain in

the microlayer anywhere from a few seconds to

many hours (3). Mixing by surface flows, wave action, or other means drives surface material downward to underlying waters, which is now recognized

as an important transport mechanism for materials deposited on the ocean surface (19).

The ecological significance of the living portion

of the microlayer is poorly understood. The enrichment of organic matter in the microlayer provides

a food source for the minute plants and animals

that reside there and accounts for their high densities in the microlayer. These surface organisms, in

turn, may play an important role in the marine food

web, because they provide a basic food source for

the plankton that live in immediately underlying

waters (8). These questions are currently under intense study, which should rapidly increase our understanding of the microlayer’s role in marine communities.

The microlayer also appears to serve as an essential, if temporary, habitat for the embryonic life

stages of many fish and crustaceans, including

many commercially important species (e. g., shrimp

in the Gulf of Mexico).

The surface microlayer’s apparently vital roles

and its ability to become enriched in toxic organic

compounds and metals raise legitimate concerns

over whether accidental spills and emissions from

ocean incineration would cause significant environmental damage. Unfortunately, an evaluation of

possible consequences must await further study, including the development of an adequate methodology to sample and monitor the surface microlayer.
166 ● Ocean Incineration: Its Role in Managing Hazardous Waste

ADDITIONAL FACTORS RELEVANT TO A COMPARISON OF

LAND-BASED AND OCEAN INCINERATION

This section presents several additional points of

comparison and contrast relevant to a consideration of hazardous waste incineration technologies.

These issues have been raised repeatedly in the debate over ocean incineration and are particularly

germane to determination of policy. The following discussion does not attempt to resolve these issues, but it presents common arguments that illustrate the range of existing opinion.

Onsite Versus Offsite Incineration

Ocean incineration is, by definition, an offsite

activity, in which the manager of wastes is distinct

from the generator of wastes. Virtually all current

commercial land-based incineration also occurs offsite, whereas private incineration typically entails

a generator processing wastes in a facility located

at the site of generation.

Two concerns are raised about offsite incineration, and indeed, about all offsite hazardous waste

management activity. The first is that offsite management generates additional risks (because of extra transportation and handling requirements) that

could be avoided by management at the site of generation. The second concern stems from the fact

that the party who actually disposes of or treats

waste offsite is different from the party who generated it. Some observers believe that the generator’s

accountability for the generation and subsequent

handling of waste is substantially weakened, which

necessitates elaborate regulatory mechanisms for

tracking wastes from ‘‘cradle to grave. Furthermore, because the waste managers are paid for rendering their service, these observers fear that profit

becomes a primary determinant of how carefully

and safely wastes are handled. Addressing this concern 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 would

otherwise be needed.

Many other observers argue, however, that the

development of large, offsite management capability is desirable because it centralizes hazardous

waste management activities. According to this

argument, centralization takes advantage of economies of scale and eases the tremendous regulatory

burden of permitting, monitoring, and ensuring the

regulatory compliance of many smaller facilities.

Moreover, given the number of waste generators

that cannot afford to manage their own wastes or

use the best technological means available, commercial facilities in the business of managing wastes

may be in a better position to do so safely and in

compliance with regulatory requirements.

Both arguments have been legitimately raised in

the debate over the relative merits of land-based

and ocean incineration. Such a debate bears as well

on the larger issue of the roles and responsibilities

of the public and private sectors in solving complex societal problems such as hazardous waste

management,

Cost to Generators

A related issue involves how much generators

would have to pay for ocean incineration, relative

to the price of commercial land-based incineration.

Many critics of ocean incineration argue that it is

an inexpensive option that would be used in place

of more expensive but environmentally sounder

practices. The major reason cited for the low cost

of ocean incineration, relative to land-based incineration, is the absence of a requirement for costly air

pollution control equipment.

Many widely varying estimates of the cost of

ocean incineration have been offered (4,5, 15). The

reliability of any of these estimates is questionable,

however, because the many variables involved are

difficult or impossible to determine in advance.

Some of the variables include:

●

●

size of the market for incineration of liquid

wastes;

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 (competitive pricing);

regulatory requirements, such as liability insurance levels and monitoring and analysis requirements;

port and incineration site locations; and

nature and cost of required port facility development.

In light of such hard-to-predict factors, estimated

prices cover a broad range. For example, the following price ranges (expressed in 1983 dollars per

metric ton), averaged for several waste types, have

been estimated for land-based and ocean incineration and (for purposes of comparison) for landfilling (5):

Landfilling . . . . . . . . . . . . . $ 55 to $240

Land-based incineration . . $360 to $500

Ocean incineration ., . . . . $200 to $40 0

Other studies exhibit wide ranges and variations

in price estimates, but virtually all support several

generalizations:

●

●

●

Incineration, whether on land or at sea, is consistently more expensive than traditional land

disposal alternatives. Indeed, cost is cited as

the primary reason for generators’ minimal

use of incineration to date.

The gap between costs for disposal and incineration is expected to narrow as restrictions

on land disposal are implemented and in response to generators’ growing concerns about

their long-term liability for wastes.

On an average, ocean incineration is predicted

to cost waste generators somewhat less than

land-based incineration, although price ranges

are likely to overlap substantially. Despite arguments that ocean incineration’s lower costs

would stem from the lack of a requirement for

expensive air pollution control equipment, two

operating factors are likely to be equally or

more determinative:

1.

2.

ocean incineration’s annual throughput

would be higher, enhancing income-generating potential; and

ocean incineration would concentrate on a

high-value waste market, predominantly on

wastes with high chlorine and energy contents and on easy-to-burn liquid wastes,
168 • Ocean Incineration: Its Role in Managing Hazardous Waste

rather than on a mixture liquids, solids, and

sludges.

Whatever ocean incineration’s eventual price, it

probably will for the foreseeable future lie between

the low costs of land disposal and the much higher

costs of the new and emerging technologies discussed in chapter 4.

Ease of Monitoring and Surveillance

The fact that ocean incineration occurs far from

shore has provoked two reasonable but opposing

lines of argument by participants in the ocean incineration debate. Proponents point to the fact that

the residual quantities of wastes or waste products

released during incineration are far less likely to

harm humans if the incineration occurs far from

human populations. Opponents, however, consider

ocean incineration an ‘‘out-of-site, out-of-mind’

solution to the hazardous waste problem. Indeed,

monitoring and enforcement probably would be

more troublesome for an activity that occurs beyond the horizon. In the absence of compensatory

measures, the government’s (and perhaps equally

important, the public’s) ability to monitor the activity and to detect regulatory violations could be expected to decrease with distance from shore.

In response to such concerns, EPA has proposed

several special regulatory provisions to be required

only of ocean incineration. These include requirements for a full-time EPA shiprider on each voyage, use of tamper-proof or tamper-detectable

recording devices for all automatic monitoring data,

submission of all monitoring and waste analysis

data to EPA after each voyage, and, on request,

inspections of facilities and records. Not surprisingly, the adequacy of such measures is also the

subject of considerable controversy.

Interestingly, a similar line of argument has been

applied to private (onsite) incineration and other

noncommercial hazardous waste management facilities. Concerns have been raised about the ease

with which the government or the public could

monitor such operations or could gain access to private information that was in the public interest.

These concerns have arisen, for example, in debates over the siting of such facilities.

Degree and Nature of Public

Participation

The high degree of public participation (and in

general, opposition) in the debate over ocean incineration is somewhat surprising, in light of the

commonly heard concern that the ocean has little

political representation (“fish don’t vote”) and is

‘ ‘in no one’s backyard. This level of participation partly reflects the fact that designating specific

ports and sites for ocean incineration does have

clear local and regional consequences. The debate

has broadened beyond these concerns, however,

and has taken on national dimensions; indeed, a

broad-based ‘‘ocean constituency’ has developed.

One result of this phenomenon is that the role of

ocean incineration is increasingly being viewed in

a broad context, as only one component in the debate over the shaping of a national hazardous waste

management strategy.

In contrast, land-based incineration remains a

chiefly local concern. Although public concern and

opposition to the siting of land-based incinerators

is often equally intense, broader issues are less likely

to be raised in the process.

The government and the various interest groups

working toward solutions to hazardous waste problems have an obligation to recognize and consider

the interrelationships between these issues of local

and national concern in order to raise the level and

scope of the debate.
Ch. 9—Comparison of Risks Posed by Land-Based and Ocean Incineration ● 169

CHAPTER 9 REFERENCES

1.

2.

3.

4.

5.

6.

7<

8.

9.

10.

Arthur D. Little, Inc., Overview of Ocean incineration, 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).

Bigford, T. E., letter dated Mar. 20, 1985, from

Thomas E. Bigford, Chief of the Habitat Conservation Branch, National Marine Fisheries Service,

to David P. Redford, Marine Permits and Monitoring Branch, U.S. Environmental Protection

Agency.

Carlson, D.J., ‘‘Organic Chemistry of the Sea Surface Microlayer, ” paper presented at the SeaSurface Microlayer Workshop, Arlie, VA, Dec. 18,

1985.

Chemical Week, “Waste Disposal by Burning At

Sea, ” Chemiczd Week, Apr. 11, 1979, p. 44.

Emison, J., “Review of Incineration At Sea, ” EPA

Memorandum, July 15, 1983.

GESAMP (Joint Group of Experts on the Scientific

Aspects of Marine Pollution), “Scientific Criteria

for the Selection of Waste Disposal Sites At Sea, ’

No. 16 in Reports and Studies of the InterGovernmental Maritime Consultative Organization

(London: 1982).

Gordon, W. G., letter dated Sept. 10, 1985, from

William G. Gordon, Assistant Administrator for

Fisheries, National Marine Fisheries Service, to

Tudor Davies, Director of the OffIce of Marine and

Estuarine Protection, U.S. Environmental Protection Agency.

Hardy, J. T., ‘‘Phytoneuston: Plants of the SeaSurface Microlayer, ” paper presented at the SeaSurface Microlayer Workshop, Arlie, VA, Dec. 18,

1985.

Holton, G. A., Travis, C, C., and Etnier, E. L., “A

Comparison of Human Exposures to PCB Emissions From Oceanic and Terrestrial Incineration,

Hazardous Waste and Hazardous Materials

2(4):453-471, 1985.

ICF Technology, Inc., “Potential Effects to the

Delaware River and Estuary Resulting From a

Hypothetical 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 Organochlorine

Wastes by At-Sea Incineration, Ocean Dumping

of Industrial Wastes, B.H. Ketchum, et al. (eds. )

(New York: Plenum Publishing Corp., 1981), pp.

295-314.

Meyers, P. A., ‘‘Processes Contributing to the Concentration of Polychlorinated Biphenyls at the SeaSurface Microlayer, ” paper presented at the SeaSurface Microlayer Workshop, Arlie, VA, Dec. 18,

1985.

U.S. Environmental Protection Agency, Office of

Water Regulations, Criteria and Standards Division, Environmental Protection Agency Final Environmentzd Impact Statement (EIS) for North Atlantic Incineration Site Designation (Washington,

DC: Nov. 25, 1981).

U.S. Environmental Protection Agency, Office of

Water, Incineration-At-Sea Research Strategy

(Washington, DC: Feb. 19, 1985).

U.S. Environmental Protection Agency, Office of

Policy, Planning and Evaluation, “Summary and

Conclusions, Assessment of Incineration as a

Treatment Method for Liquid Organic Hazardous

Wastes (Washington, DC: March 1985).

U.S. Environmental Protection Agency, Science

Advisory Board, Report on the Incineration of Liquid Hazardous Wastes by the Environmental Effects Transport and Fate Committee (Washington,

DC: April 1985).

U.S. Environmental Protection Agency, Marine

Operations Division of the OffIce of Marine and Estuarine Protection, Assessment of the Impact of Incineration of Chemical Wastes in the Proposed

North Atlantic Incineration Site on Endangered and

Threatened Species (Washington, DC: July 9,

1985).

Wastler, T. A., Offutt, C. K., Fitzsimmons, C. K.,

et al., DisposaJ of Organochlorine Wastes, EPA430/9-75-014, contract report prepared for the U.S.

Environmental Protection Agency (Washington,

DC: July 1975).

Weller, R. A., “Mixing Down From the Microlayer: The Role of Three-Dimensional Flows, ” paper presented at the Sea-Surface Microlayer Workshop, Arlie, VA, Dec. 18, 1985.
Chapter 10

Overview of Federal Laws and

Regulations 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, Page

25. Summary of Federal Regulatory Framework for Incineration . .....................173
Chapter 10

Overview of Federal Laws and

Regulations Governing Incineration

Land-based and ocean incineration are regulated incineration. Table 25 provides a summary of statunder different primary statutes and regulations. utes applicable to land-based or ocean incineration

Various additional statutes cover activities (e. g., or both, along with a description of the regulated

land transportation) related to both technologies. activities. Many of the specific details of existing

This chapter provides an overview of the statutory requirements and provisions are reviewed earlier

and regulatory framework for land-based and ocean in other chapters.

Table 25.—Summary of Federal Regulatory Framework for Incineration

Activities

Statute/reguIation Agency Ocean incineration Land-based incineration

Resource Conservation

and Recovery Act . . . . . . . . . . . . . . U.S. Environmental

Protection Agency

(EPA)

Marine Protection, Research,

and Sanctuaries Act . . . . . . . . . . . . EPA

Coast Guard

Toxic Substances Control Act . . . . . EPA

Coastal Zone Management Act. . . . . States

Hazardous Materials

Transportation 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 . . . . . . . . . . . . . . . . . EPA

Coast Guard

Comprehensive Environmental

Response, Compensation, and

Liability Act (Superfund). . . . . . . . . EPA

Coast Guard

Waste storage

Waste content

Land transportation

Residuals disposal

Ocean incineration

Incineration of PCBs

Activities affecting land or

water use in the coastal

zone

Hazardous waste

transportation by truck or

rail

Transportation by water

Design, construction,

certification, operation of

incinerator vessels

Vessel movement through

ports; waste storage,

transfer at waterfront

Compatibility of designated

sites with protection of

wildlife

Cleanup of spills in territorial

waters

National Contingency Plan,

cleanup of spills

Waste storage

Waste content

Land transportation

Land-based incineration

Residuals disposal

—

Incineration of PCBs

Activities affecting land or

water use in the coastal

zone

Hazardous waste

transportation by

or rail

—

—

—

—

truck

Cleanup of spills in inland

waters

National Contingency Plan,

cleanup of spills

SOURCE: Office of Technology Assessment

173
174 ● Ocean Incineration: Its Role in Managing Hazardous Waste

LAND-BASED INCINERATION

Although hazardous waste incineration has been

widely used by industry for some time, explicit regulation of the practice was only recently initiated.

The 1976 Resource Conservation and Recovery

Act (RCRA) provided a mandate to regulate hazardous waste incineration on land, because operations fell under the definition of treatment, storage,

and disposal facilities for hazardous waste. Regulations finalized in 1981 (46 FR 7666, Jan. 23,

1981) and amended in 1982 (47 FR 27520, June

24, 1982) established standards for land-based incineration and required that all land-based incineration facilities obtain RCRA operating permits.

These regulations specified the basic requirements

for land-based incinerator design, performance, permitting, waste analysis, monitoring, and reporting.

Because it is covered under RCRA, hazardous

waste incineration on land is effectively exempted

from coverage under the Clean Air Act (CAA).

Municipal waste incinerators, however, are covered under the CAA. New source performance

standards for municipal facilities were promulgated

in 1981 but include only a single standard for particulate emissions. A numerically identical standard has been incorporated into the RCRA regulations governing land-based hazardous waste

incineration.

The Toxic Substances Control Act, passed in

the same year as RCRA, banned the manufacture

of PCBs and was followed by regulations governing their treatment and disposal, including the use

of incineration (see box B in ch. 3). Under RCRA,

an application to incinerate PCBs requires special

approval by the EPA Administrator before authorization can be incorporated into a RCRA (for landbased incineration) or MPRSA (for ocean incineration) permit. Currently, only six incinerators are

permitted to incinerate PCBs. These are owned and

operated by ENSCO (Arkansas); Rollins Environmental Services (Texas); SCA Chemical Services,

Photo credit: GA Technologies, Inc.

A transportable fluidized bed incinerator that was

recently granted a permit for PCB incineration.

owned by Waste Management, Inc. (Illinois);

Pyrotech (Tennessee); General Electric (Massachusetts); and EPA (a mobile unit currently stationed

in New Jersey). In addition, GA Technologies

(California) recently received a permit for a transportable incinerator which, when completed, can

be used anywhere in the country for PCB incineration.
Ch. 10—Overview of Federal Laws and Regulations Governing Incineration ● 175

OCEAN INCINERATION

Primary statutory authority for regulating ocean

incineration resides in the Marine Protection, Research, and Sanctuaries Act (MPRSA). Although

EPA initially claimed that its jurisdiction under

MPRSA did not extend to ocean incineration,l the

Agency became persuaded of its authority because

of rising concern that failure to regulate ocean incineration might frustrate the purposes of MPRSA.

In 1974, ocean incineration without a Federal

permit was prohibited. Initial permits were issued

using general administrative and technical criteria

from the Ocean Dumping Regulations (40 CFR

220). Also relied on were the London Dumping

Convention’s regulations and technical guidelines,

including a set of standards for destruction and

combustion efficiency, operating conditions, and

monitoring parameters (see ch. 12).

The Ocean Dumping Regulations include extensive criteria for use in evaluating permit applications to dispose of waste by ocean dumping. These

include criteria for evaluating environmental

damages; the need for ocean dumping; and the impact of dumping on esthetic, recreational, and economic values and on other uses of the ocean.

Because the Ocean Dumping Regulations do not

specifically address ocean incineration, EPA has re-

‘The basis of EPAs quandary was whether Congress intended

MPRSA to cover air pollutants emitted at sea.

cently begun developing an Ocean Incineration

Regulation. The proposed regulation, which was

issued by EPA’s Office of Water (50 FR 8222, Feb.

28, 1985), specifies application procedures for research, trial, and operational permits as well as requirements governing incinerator operation, waste

specifications, site designation, and operational and

environmental monitoring. Specific provisions of

the proposed Regulation are discussed throughout

this report.

During the public comment period, five public

hearings and several public meetings were held

around the country. In September 1985, EPA released a summary of the approximately 4,500 comments received during these sessions (l).

Activities of the London Dumping Convention

(LDC) are germane to domestic policy on ocean

incineration, as the United States is a signatory to

the convention. All U.S. regulations regarding

ocean dumping and ocean incineration must be

consistent with those of the LDC, and MPRSA

serves as the primary statutory instrument for

adherence to the LDC. (See ch. 12 for more information on the LDC. )

Amendments to MPRSA also authorize research

and monitoring for ocean incineration and for

ocean dumping activities in general, to be carried

out by EPA, the National Oceanic and Atmospheric Administration, and the U.S. Coast Guard.

STATUTES GOVERNING RELATED ACTIVITIES

For wastes managed using ocean or land-based

incineration, the incineration process itself is the

last step, except for disposal of incineration residuals, in the ‘‘cradle-to-grave’ management of hazardous wastes. For operations on land and at sea,

various Federal authorities are involved at different stages; Table 25 summarizes the statutes, agencies, and jurisdictions for all incineration support

activities.

Various responsibilities also fall on State and local

jurisdictions. These include hazardous waste facility

siting, enforcement authority, and emergency response.

Designating Ocean Incineration Sites

The proposed Ocean Incineration Regulation

contains detailed procedures for the formal designation of sites for ocean incineration (50 FR 8271,

Feb. 28, 1985). EPA proposes using the same siteseleciion criteria for ocean incineration as those

specified in the Ocean Dumping Regulations, with

three additions:

1. the effect of incinerator emissions on endangered species in or near the site must be examined;

2. the site’s carrying capacity must be calcu-
176 ● Ocean Incineration: Its Role in Managing Hazardous Waste

3.

lated and any requirements that are necessary and the most prevalent organic compounds exto ensure that it is not exceeded must be in- pected to be incinerated.

corporate into individual permits; and Although burns occurring under research or a plan to monitor the environmental effects emergency permits could occur at undesignated of 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 forfor designation, EPA would prepare an environ- mal rulemaking process. Use of designated sites

mental 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 through

required by EPA policy. As part of this assessment, evaluation of data obtained from the mandatory

the carrying capacity and loading rates at the site environmental monitoring plan specified for each

would be calculated for acid emissions, 14 metals, site.

CHAPTER 10 REFERENCES

1. U.S. Environmental Protection Agency, Incinera- ards Division, ‘‘Summary of Public Comments on

tion-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 of

Shell Chemical Organochlorine Wastes in the Gulf of

Agent Orange Wastes in the South Pacific . . . . . . .

PCB Wastes in the Gulf of Mexico . . . . . . . . . . . . . .

Organochlorine Wastes in the North Sea Using the

Canceled Burns. . . . . . . .

Adequacy of Past

Past Incidents .

Site Designation .

Gulf Site . . . . .

Burns in

. . . . . . . .

. . . . . . . .

. . . . . . . .

North Atlantic Site. . . . .

Other Possible Sites . . . .

Recent EPA Efforts . . . . . .

. . . . . . . . . . . . . . . . . . . . . . .

. .

. .

Page

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 179

Mexico: First Series . ...........179

Mexico: Second Series. . ........179

. . . . . . .

,. ....!

Vulcan us

. . . . . . . . .

. . . . . . . . . . . . . . . . . . . . . . . 181

181

~~ : : : : : : : : : : : : : : : : : : ; : : 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 Agency

tory of ocean incineration in the United States. Past (EPA) activities, including the recently denied proburns, the designation of sites for ocean incinera- posal for a PCB research burn, are discussed.

PAST BURNS

Four sets of research or interim burns occurred

under EPA’s authority between 1974 and 1982. All

four used the Vulcanus I and included varying

degrees of monitoring and analysis of stack emissions and the marine environment. In addition,

EPA monitored a test of the Vulcanus II in the

North Sea in 1983. This section describes each of

these burns and discusses the reported results. Table 26 presents a summary of these five sets of

burns, indicating locations, types of waste incinerated, destruction efficiencies, and other reported

results. In each case, a primary reference is indicated for additional information.

Shell Chemical Organochlorine Wastes

in the Gulf of Mexico: First Series

Use of ocean incineration was first proposed in

the United States in 1974, when Shell Chemical

Co. sought permission to use the Dutch-owned vessel Vulcanus I to incinerate liquid organochlorine

wastes. This type of waste had previously been

dumped in the Gulf of Mexico, until EPA halted

the practice in 1973. The waste proposed for incineration was a mixture of chlorinated hydrocarbons derived from production of vinyl chloride and

other chemicals. The chlorine content of the waste

was 63 percent.

In October 1974, EPA granted Shell a research

permit to incinerate one shipload (4,200 metric

tons, or mt) of the waste at a site 190 miles from

land in the Gulf of Mexico. Because several problems arose during the monitoring of this burn, a

second research permit for another shipload was

granted, and a second burn took place in December

1974. The generally favorable results led EPA to

grant a special interim permit for the incineration

of two remaining shiploads of waste, which were

burned in late December 1974 and early January

1975.

EPA reported that destruction efficiencies for this

set of burns averaged 99.95 percent, measured on

the basis of total organic carbon. No separate measurement of individual principal organic hazardous

constituents (POHCs) or products of incomplete

combustion (PICs) was undertaken. Seawater samples taken from the area of contact between the incinerator plume and the ocean surface were analyzed for organochlorines, pH, chlorine content,

and trace metals. EPA was unable to detect any

changes over background levels.

Shell Chemical Organochlorine Wastes in

the Gulf of Mexico: Second Series

In 1977, Shell obtained a special permit to conduct another set of burns in the Gulf of Mexico,

and again used the Vulcanus I to incinerate four

shiploads, or about 16,000 mt, of organochlorine

wastes. EPA conducted extensive testing of the first

of these burns. Trace amounts of known waste constituents (POHCs) were detected in the stack gas

samples; these measurements were used to calculate the POHC-specific destruction efficiencies reported in table 26. The analysis of emissions found

very low amounts of other compounds, which had

not been identified in the waste, and which may

have been PICs.

EPA reported that the DE for total hydrocarbons

ranged from 99.991 to 99.997 percent. The DE for

the major waste constituent, trichloropropane,

ranged from 99.92 to 99.98 percent.

The environmental monitoring of these burns revealed the first evidence of an environmental effect from ocean incineration. Fish in towed cages

179
180 ● Ocean Incineration: Its Role in Managing Hazardous Waste
Ch. 11—History of U.S. Ocean Incineration ● 181

were exposed to surface water in the area of contact between the incineration plume and the ocean

surface. Assays were then conducted on three enzyme systems that increase in activity in response

to physiological stress induced by the presence of

pollutants. One enzyme system (Cytochrome P450) showed a significant increase in activity.

When the exposed fish were placed in clean water

for several days in the laboratory, the activities of

all three systems were found to be normal. Although

EPA interpreted the temporary nature of the effect optimistically, detection of such an effect illustrates the need for caution and further monitoring

and research of ocean incineration activities. This

would be particularly important if incineration at

particular sites became frequent or routine, because

longer term exposures to marine organisms might

result.

Agent Orange Wastes in the

South Pacific

Another set of burns employing the Vulcanus I

occurred later in 1977, in the South Pacific about

120 miles west of Johnston Atoll. The waste incinerated was the herbicide Agent Orange, which came

from an Air Force stockpile of many separate drums

remaining from production that occurred during

the Vietnam War. The waste consisted of roughly

equal amounts of 2,4-D and 2,4,5-T (see table 26

for full chemical names), contaminated with the

highly toxic dioxin TCDD at a level that ranged

from O to 47 milligrams per kilogram (mg/kg) and

averaged 1.9 mg/kg. Total chlorine content was

about 30 percent.

A total of about 10,400 mt of Agent Orange was

incinerated in three separate burns. An initial burn

of 3,520 mt took place under an EPA research permit. Favorable monitoring results led EPA to authorize incineration of the remaining stock, about

6,880 mt in two shiploads, under a special permit.

Destruction efficiencies were reported in several

forms by EPA. For all three burns, the DE for the

two main components of Agent Orange, 2,4-D and

2,4,5-T, and for total chlorinated hydrocarbons,

exceeded 99.999 percent. In fact, none of these substances was detected at all in the emissions. The

minimum DE of 99.999 percent was reported, even

though the actual DE might have been higher, because the detection limits of the sampling and analytical instruments employed did not allow measurement of a higher DE. Destruction efficiencies

for total hydrocarbons ranged from 99.982 percent

to 99.992 percent.

Emissions were also analyzed for the presence

of TCDD (dioxin), which was found only in samples from the second trial; its detection in these samples may have been caused, however, by interference from other substances. Because TCDD was

below the limit of detection in burns 1 and 3, the

reported DEs again represent minimum values:

99,99 percent for burn 1 and 99.96 percent for burn

3. A DE of 99.88 percent was calculated for the

second burn.

Only limited environmental monitoring was conducted during the Agent Orange burn. Plankton

samples at the site collected before and after the

first burn showed no consistent differences in numbers or species composition, No other tests were

performed on marine organisms.

PCB Wastes in the Gulf of Mexico

An additional set of burns occurred in the Gulf

of Mexico, beginning in late 1981/early 1982 and

completed later in 1982. Both sets of burns were

carried out under research permits. In the first

burn, about 3,500 mt of PCB-containing waste was

incinerated aboard the Vulcanus I (which by then

had been acquired by Chemical Waste Management, Inc., of Oakbrook, Illinois). EPA monitored

the burn, but later indicated that the data collected

were ‘ ‘inconclusive because of major problems

with sampling and analysis. This test in particular

is cited by critics of ocean incineration as evidence

of the unreliability, if not total unacceptability, of

incineration at sea.

The Vulcan us I was also used for a second burn

of about 3,500 mt of PCB wastes conducted in August 1982. The waste composition included 27.5

percent PCBs, 7 percent chlorobenzenes, and trace

amounts (estimated at 0.0000048 percent) of highly

toxic tetrachlorodibenzofurans (TCDF). None of

the emissions samples analyzed showed any trace

of these components, which means that the reported

DEs again represent minimum values. These DEs

are as follows:

● PCBs . . . . . . . . . , . . . >99.99989 percent
182 ● Ocean Incineration: Its Role in Managing Hazardous Waste

● Chlorobenzenes . . . . >99.99993 percent

● TCDF . . . . . . . . . . . . >99.96 percent.

Both waste and emissions were analyzed for the

presence of TCDD, none of which was detected in

any samples. The plume itself was also sampled for

PCBs and other organochlorine compounds, and

none was detected. However, some nonchlorinated

compounds were detected in the plume, and EPA

suggested that they either were PICs or arose from

the vessel’s propulsion engines.

Marine sampling and monitoring was conducted

during the second burn, and no detectable increase

in PCBs was found in water samples or organisms.

Nor did any physiological indicators of exposurerelated stress exceed normal levels.

Organochlorine Wastes in the North Sea

Using the Vulcanus II

With EPA in attendance, the newly built Vulcanus II was tested in February 1983, burning

waste from vinyl chloride production at the designated incineration site in the North Sea. The waste

consisted almost entirely of four compounds: trichloroethane (39 percent), chloroform (26 percent),

carbon tetrachloride (20 percent), and dichloroethanes (15 percent). The waste’s total chlorine content was 84 percent; in addition, two of the waste’s

components (chloroform and carbon tetrachloride)

are ranked by EPA as among the most difficult

compounds to destroy thermally, because of their

high chlorine content. Thus, this waste provided

an unusually difficult test of the incinerator.

The reported DEs were high, ranging from

99.998 percent for carbon tetrachloride to more

than 99.999995 percent for trichloroethane.

Canceled Burns

In October 1983, EPA proposed issuing two 3-

year special permits and one 6-month research permit to Chemical Waste Management, Inc., to incinerate 300,000 mt of PCB-containing waste and

900 mt of DDT-containing waste in the Gulf of

Mexico. EPA based its tentative approval on the

successful 1982 PCB burn (using Vulcanus I) and

the 1983 European organochlorine burn (using

Vulcanus II).

Major public opposition mounted, culminating

in a public hearing in Brownsville, Texas, on November 21, 1983, attended by more than 6,400 people, the largest public hearing in EPA history. In

May 1984, EPA denied the permits and announced

that no further operating permits would be issued

until the Agency had promulgated specific ocean

incineration regulations and completed several ongoing studies.

In December 1985, EPA published its tentative

determination to issue a research permit to Chemical Waste Management, Inc., for incineration at

sea using the Vulcanus II (50 FR 51360, Dec. 16,

1985). EPA initially solicited the research permit

as part of its Ocean Incineration Research Strategy (26).1 The permit would have authorized the

incineration of one shipload (about 700,000 gallons)

of a waste consisting of 10 to 30 percent PCBs in

fuel oil. The waste was to have been loaded at the

Port of Philadelphia, transported through Delaware

Bay, and incinerated at the North Atlantic Incineration Site. In its application, Chemical Waste Management indicated that the waste it planned to burn

would actually contain 12 percent PCBs, and would

be transported by rail from its storage facility in

Emelle, Alabama (8).

The Coastal Zone Management Act, which is administered at the Federal level by the National

Oceanic and Atmospheric Administration (NOAA),

grants States the right to review Federal activities

affecting their coastal zones for consistency with

State management plans. As part of its application

procedure, Chemical Waste Management, Inc.

sought coastal zone management (CZM) consistency determinations from three coastal States: Delaware, New Jersey, and Pennsylvania. These States

were consulted because the Vulcan us II would pass

through their coastal waters en route to the incineration site. Pennsylvania granted approval without

conditions 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, Tacoma

Boat, filed Chapter 11 bankruptcy proceedings in the fall of 1985.

This move, brought on partly by delays in the finalization of EPA’s

regulations, forced ASI to default on $68 million in guaranteed loans

granted earlier by the U.S. Maritime Administration for construction of its two incineration vessels ( 14). The loan was paid in full by

the Maritime Administration. The uncertain financial status of ASI

led EPA to hold its permit application in abeyance pending resolution of the situation (50 FR 51361, Dec. 16, 1985).
Ch. 11-History of U.S. Ocean Incineration • 183

also reached a determination of CZM consistency

but limited transit to daylight hours and required

prior notification of the ship’s movement (13). In

addition, Delaware was considering suing EPA to

require the agency to prepare a separate Environmental Impact Statement on the transit route (13).

New Jersey originally placed several conditions

on its finding of CZM consistency. These included

prohibiting transit during the summer, extending

the moving safety zone, modifying Coast Guard

contingency plans for managing a spill, allowing

60 days for the State to verify waste composition,

and requiring State approval of the level of liability coverage. In the course of litigation, however,

New Jersey withdrew its conditions regarding the

moving safety zone and contingency plans, and

modified its waste analysis requirement.

In early 1986, the State of Maryland appealed

to NOAA for the right to make a CZM consistency

determination, claiming that the proposed test burn

could adversely affect the States coastal zone.

Maryland argued that, although the vessel would

not pass through Maryland waters, those waters

could nevertheless be adversely affected by the activity. In February, NOAA ruled in favor of Maryland, despite strong opposition from EPA. Maryland was granted 6 months to conduct its review

and reach a consistency determination (letter cited

in ref. 1 1).

In response to the NOAA decision and the strict

conditions imposed by New Jersey, Chemical

Waste Management filed suit in March against

NOAA and EPA (15). The suit contended that

Maryland was not entitled to conduct a consistency

review for an activity that would occur outside of

its coastal zone. In addition, Chemical Waste Management contended that the Marine Protection, Research, and Sanctuaries Act preempts New Jersey

from imposing conditions.

Prior to any decision in the suit, the State of

Maryland and Chemical Waste Management reached

a settlement in which Maryland withdrew its request to conduct a CZM consistency review of this

research permit but retained its right to pursue such

a review in the future (16).

Following the announcement of its tentative determination to grant a research permit to Chemical Waste Management, EPA held a series of public

hearings in Philadelphia; Red Bank, New Jersey;

Wilmington, Delaware; and Ocean City, Maryland. Through the course of these hearings, strong

public opposition again surfaced, focusing particularly on the land and nearshore marine transportation risks. These concerns led to the issuance of

a Hearing Officer’s report (31) that called for the

resolution of several major issues of public concern

before proceeding with the burn.

In May 1986, EPA announced its decision to

deny the research permit, and to grant no permits,

research or otherwise, until finalization of its Ocean

Incineration Regulation (51 FR 20344, June 4,

1986). In its decision, EPA argued that the nature

of the issues raised in considering the research permit could be more appropriately addressed through

the regulatory development process.2

As a result of EPA’s decision, the suit brought

by Chemical Waste Management was dismissed

without a ruling on the circumstances under which

permit applicants are required to demonstrate

CZM consistency or the rights of States to place

conditions on their finding of CZM consistency

(11).

2The PCB wastes that were to have been incinerated under the research permit are now expected to be transported to Chicago for incineration in Chemical Waste Management land-based incinerator,

ADEQUACY OF PAST BURNS IN DEMONSTRATING THE SAFETY

OF OCEAN INCINERATION

All of the burns discussed above took place under only 99.9 percent. Therefore, all but one of the reEPA regulations that incorporated the technical re- ported DEs met the required standard. (The exquirement of the London Dumping Convention ception was the reported DE for TCDD in the secmandating a minimum destruction efficiency of ond burn of Agent Orange, which appears to have
184 • Ocean Incineration: Its Role in Managing Hazardous Waste

been anomalous and may have resulted from interference by chemically related compounds. )

In 1981, EPA adopted rules requiring land-based

hazardous waste incinerators to achieve a 99.99 percent DE. In addition, the Toxic Substances Control Act requires a minimum 99.9999 percent DE

for PCBs. EPA has proposed that the same values

be adopted in the regulations governing ocean incineration. The ability of ocean incineration to

achieve this DE has not yet been demonstrated.

Past test burn data for PCBs was derived from analysis of samples that were not large enough to definitively establish that the Vulcanus I is capable of

meeting a 99.9999 percent DE. However, EPA believes that this DE was achieved in the burn and

is achievable using ocean incineration (28).

No consensus exists with regard to the adequacy

and accuracy of EPA’s past efforts to monitor ocean

incineration. Based on its monitoring of incinerator performance and the environment during past

ocean incineration activities, EPA reported that it

had been unable to detect any increase in background levels of waste constituents in ambient air,

water, or marine organisms. Many members of the

public and EPA’s own Science Advisory Board

(SAB), however, have expressed concerns about

these conclusions and the methods and adequacy

of EPA’s monitoring efforts. (For further critical

discussion of these past efforts, see refs. 6,7,18,

19,29).

In response to these concerns, EPA has called

for additional test burns before operating permits

are issued. The test burns would be intended to provide more accurate assessments of the performance,

levels of emissions, and environmental consequences of ocean incineration. In addition, the proposed regulations governing ocean incineration contain provisions for comprehensive environmental

monitoring, which would be conducted by EPA

with the participation of permitters.

Past Incidents

Several small spills and contamination of the vessel occurred during three of the sets of burns described in this chapter.

During the incineration of Agent Orange in the

Pacific (l), several small spills of herbicide occurred,

caused by accidental breakage of a sampling bottle; sloshing of liquid through a tank hatch, as a result of rough seas; and overfilling of a tank during

rinsing. One or more of these spills was apparently

tracked by personnel, leading to the contamination

of other areas of the vessel. This contamination was

detected during routine monitoring of the vessel

performed as a precautionary measure.

There have also been reports of a more serious

release of waste from this burn, caused by the intentional discharge of bilge water, which was apparently contaminated with Agent Orange, into a lagoon at Johnston Atoll (12,22). Sampling of lagoon

water in the immediate vicinity of the bilge water

discharges revealed concentrations of herbicide that

significantly exceeded water quality criteria. Reported concentrations were as high as 3 to 5 parts

per million, and the total release of herbicide was

estimated to have been about 270 pounds (12). In

addition, a visible orange cloud in the water was

noted, although the captain of the Vulcanus I maintained that the color was caused, not by herbicide,

but by rust (22).

Several small spills on deck were reported during the first of the PCB burns that took place in

the Gulf of Mexico in 1981-82 (2,25), Some contamination of other parts of the vessel (the burner

room, pumproom, and a gangway) was also reported, identified during routine monitoring of the

vessel.

During the Agent Orange burns (1) and the 1977

organochlorine burns in the Gulf of Mexico (9),

several ‘ ‘impingements’ of the incinerator plume

onto the deck of the vessel were reported. These

were attributable to momentary flameouts caused

by water in the waste being incinerated or to high

wind velocities and erratic wind direction, and in

some cases resulted in brief exposure of crew members to emissions. Based on consideration of the circumstances surrounding these incidents, steps were

taken to avoid or reduce their subsequent

occurrence.

Several other incidents have been reported or alleged to have occurred during ocean burns that

occurred in Europe. These are discussed in reference 20.

Certain provisions of EPA’s proposed Ocean Incineration 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, in

and tank washings would have to be tested for the combination with the prevailing wind speed, would

presence of waste constituents and, if contaminated, yield a combined effective wind speed over the veseither incinerated at sea or disposed of in an ap- sel of 3 knots or more, to ensure that the plume

proved land-based facility (50 FR 8236, Feb. 28, remained aft of the vessel and would not come into

1985). 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, and

Sanctuaries Act, incineration sites must be designated by EPA, and operational permits for ocean

incineration may only be granted for designated

sites. The site designation process falls under formal rulemaking procedural requirements mandating public hearings. In addition, an Environmental

Impact Statement (EIS) must be prepared for each

site.

The following discussion highlights the status of

designation activities for ocean incineration sites.

Gulf Site

Currently, only one site has been designated for

ocean incineration. The final EIS for the Gulf of

Mexico Incineration Site was issued in 1976 (23).

This site lies in the middle of the Gulf, about 190

miles from land, and occupies an area of 4,900

square kilometers (see figure 12). The site is beyond the edge of the continental shelf, in waters

ranging 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 in

1982 (47 FR 17817, Apr. 26, 1982). The 1982 rule

designated the Gulf Site for ‘‘continued use. The

proposed Ocean Incineration Regulation would

limit designation of the Gulf Site to a period of 10

years, assuming that the additional proposed requirements for site designation were met (see ch.

10). Some members of the public and elected officials have called for the designation process for the

Gulf Site to be reopened, based on new information and developments since 1976 (see ch. 2).

North Atlantic Site

In 1981, a final EIS for the North Atlantic Incineration Site was released (24). This site, which

has not been formally designated, lies about 140

miles east of the coasts of Delaware and Maryland

and covers 4,250 square kilometers (see figure 12).

The site lies beyond the continental shelf on the continental rise, in waters ranging in depth from 2,400

to 2,900 meters. Due north and adjacent to the proposed incineration site is the 106-mile Ocean Waste

Disposal Site, which is expected to be used for

dumping industrial acid and alkaline wastes as well

as municipal sludge for the foreseeable future.

Since the development of the 1981 EIS, the National Marine Fisheries Service (NMFS) has found

that the proposed North Atlantic Incineration Site

lies in a “high use” area for several species of endangered or threatened marine mammals (see ch.

9). In response to this finding, EPA reevaluated

the site and concluded that endangered species

would not be affected by incineration there (30).

NMFS has concurred with this conclusion with respect to limited use of the site for research burns.

However, NMFS must develop a formal biological opinion for consideration prior to EPA’s final

designation of the site.

Other Possible Sites

EPA-sponsored studies have tentatively examined areas off the coasts of California and Florida

as possible future sites for ocean incineration. However, no steps in the actual site designation process have taken place to date.
186 ● Ocean Incineration: Its Role in Managing Hazardous Waste

Figure 12.-Location of the Designated (Gulf of Mexico)

and Proposed (North Atlantic) incineration Sites

Designated

incineration

site

SOURCE: Office of Technology Assessment.

RECENT EPA EFFORTS

In conjunction with the development and issu- human and environmental health and compared

ance of its proposed Ocean Incineration Regula- and contrasted the current level of understanding

tion, 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 hazardous chemicals, and that the report’s intent was

In April 1985, EPA’s SAB released its “Report to ‘‘strengthen already existing incineration proon the Incineration of Liquid Hazardous Wastes grams rather than to discontinue what is already

by the Environmental Effects, Transport, and Fate in place, the SAB identified several major areas

Committee” (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 available, which meant that the potential for environmental or human exposure and impact could not

be assessed. The study challenged EPA’s measurement of destruction efficiency, which addresses only

a few selected compounds, as a basis for evaluating the total performance of incinerators. It recommended that EPA undertake a complete characterization of emissions, including products of

incomplete combustion (PICs).

The report stressed that the uncertainties the

SAB had identified applied equally to land-based

and ocean incineration and, in many cases, to other

common combustion processes, such as the burning of fossil fuels. The report also argued that, because it destroys waste, incineration is preferable

to current methods of disposal, such as landfilling

and deep-well injection.

Incineration Study

EPA’s Office of Policy, Planning and Evaluation (OPPE) (27) published an “Assessment of Incineration as a Treatment Method for Liquid Organic Hazardous Wastes” in March 1985. The

study compared and evaluated land-based and

ocean incineration with respect to technology, regulation, commercial market potential, relative environmental and health risks, and public concerns.

The major conclusions are the following:

. incineration, whether at sea or on land, is a

valuable and environmentally sound treatment

option for destroying liquid hazardous wastes,

particularly when compared to land disposal

options now available;

● there is no clear preference for land-based or

ocean incineration in terms of risks to human

health and the environment; and

● future demand for hazardous waste incineration will significantly exceed capacity as other

disposal alternatives are increasingly restricted.

Ocean Incineration Research Strategy

EPA’s Office of Water published an Ocean Incineration Research Strategy (26) detailing the

means by which EPA intends to address the areas

of uncertainty identified in the SAB and OPPE

reports, in previous research burns, and in comments received from the public. The strategy calls

for several research burns, both on land and at sea.

Initial dockside burns with diesel fuel would allow

development and testing of methodology; subsequent burns of hazardous waste would be designed

to gather data on incinerator performance, the

quantity and composition of emissions, and environmental effects.

Proposed Research Burn

As described earlier in this chapter, EPA proposed to issue a research permit for incineration

at sea as part of its research strategy (50 FR 51360,

Dec. 16, 1985). The burn was planned to be continuous for 19 days, during which EPA would conduct extensive sampling and monitoring of all

aspects of operation. The following specific tests

were planned:

●

●

●

●

●

●

determination of flow characteristics and combustion efficiency at all points in the stack;

sampling and analysis of emissions to allow

measurement of: 1) semi-volatile trace organic

compounds, including PCBs, for calculation

of destruction efficiency; 2) volatile organic

compounds; 3) particulate; and 4) total chlorinated organic compounds;

collection of samples for toxicity testing;

actual toxicity bioassays on five marine plant

and animal species, testing for acute toxic effects and chronic effects on growth and reproduction;

plume sampling and modeling; and

collection and analysis of samples of air, water,

and indigenous organisms for determining the

presence of, or effects from, incinerationderived substances.

The Usefulness of Research Burns:

Opportunities and Limitations

Recent EPA developments are likely to considerably delay issuance of the final Ocean Incineration

Regulation and any subsequent research burns.

Clearly, ocean research burns are necessary to resolve some of the technical questions about ocean

incineration. In addition, if a decision were made

to proceed with ocean incineration, information

from research burns could aid in modifying the regulatory program, if necessary.
188 . Ocean Incineration: Its Role in Managing Hazardous Waste

Nonetheless, there are limits to the usefulness of

the data that could be obtained from ocean research

burns. Foremost among these is the fact that the

data would not resolve the basic issue of whether

to proceed with the ocean incineration program.

Technical analysis is only one of many factors influencing such a decision.

Moreover, one or even a series of research burns

would still leave many technical questions unresolved. For example, the recently denied EPA research burn would have used a waste composed of

relatively homogeneous PCBs in fuel oil (8). This

waste was chosen because toxicity characteristics

and detection methods for PCBs are well studied,

and because EPA wanted to have as little interference from other chemicals as possible. Typical

ocean incineration wastestreams, however, would

be more likely to contain complex mixtures of many

chemicals, which limits the applicability of results

from this test burn to “real” situations. Conversely,

choosing a heterogeneous wastestream for the research burn would have introduced a different but

comparable set of constraints.

Finally, to be most useful, ocean incineration

research must be coupled to research on other alternatives. A proper comparative analysis would

require research on both land-based and ocean technologies. EPA does have an ongoing research program on land-based incineration, and EPA’s ocean

incineration research strategy contains a land-based

incinerator component—primarily to allow testing

of the protocols for sampling, analysis, and toxicity tests to be used during an ocean research burn.

CHAPTER 11 REFERENCES

1. Ackerman, D. G., Fisher, H.J., Johnson, R.J., et

al., At-Sea Incineration of Herbicide Orange Onboard the M\T Vulcanus, EPA Technology Series

No. EPA-600/2-78-186, prepared for the U.S. Environmental Protection Agency, Industrial Environmental Research Laboratory, Office of Research

and Development (Washington, DC: April 1978).

2. Ackerman, D. G., ‘‘Observations During the First

PCB Research Burn, ” and Attachments, Communication 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-Containing

Wastes Onboard the M\T Vulcanus, EPA-600/

7-83-024, prepared for the U.S. Environmental

Protection Agency (Research Triangle Park, NC:

1983).

4. Ackerman, D. G., Beimer, R. G., and McGaughey,

J. F., Incineration of Volatile Organic Compounds

by the M\T Vulcanus 11, prepared for Chemical

Waste Management, Inc., Oak Brook, IL (Redondo Beach, CA: TRW Energy and Environmental

Division, 1983).

5. Ackerman, D. G., and Venezia, R. A., “Research

on At-Sea Incineration in the United States, in

Wastes 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 Hazardous

Wastes: An Update, ” Environ. Sci. Technol.

19(6):486-487, 1985.

8. Chemical Waste Management, Inc., “Application

for a Research Permit To Incinerate Hazardous

Waste At Sea: Exhibit B“ (Oak Brook, IL: May

24, 1985).

9. Clausen, J. F., Fisher, H.J., Johnson, R.J., et al.,

At-Sea Incineration of Organochlorine Wastes Onboard the M\T Vulcanus, EPA Technology Series

No. EPA-600/2-77-196, prepared for the U.S. Environmental Protection Agency, Industrial Environmental Research Laboratory, Office of Research

and Development (Washington, DC: 1977).

10. Environment Reporter, “NOAA Decision Allowing Maryland Review May Delay Ocean Test Burn

Until Mid-1987, ” Environment Reporter 16(42):

1878, Feb. 14, 1986.

11. Environment Reporter, “Federal Court Defers to

EPA Review in Waste Incineration Permit Dispute, ” Environment Reporter 17(9):264, June 27,

1986.

12. Graffeo, A. P., and Thomas, T., “Ocean Disposal

of Agent Orange—Land-Based Environmental

Monitoring at Johnston Island, ” paper presented

at the Third International Ocean Disposal Symposium, 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, ” Inside

EPA 6(41):2, Oct. 11, 1985.

Inside EPA, “EPA Okays At-Sea Research Burns,

But Pool of Applicants Dwindles, ” Inside EPA

6(48):5, Nov. 29, 1985.

Inside EPA, “EPA, NOAA Sued for Allowing

Maryland Incineration-At-Sea Review Rights, ’ inside EPA 7(12):8, Mar. 21, 1986.

Inside EPA, “Justice Asks Court To Dismiss Industry Incineration-At-Sea Suit, ’ Inside EPA

7(18):3-4, May 2, 1986.

Kamlet, K. S., ‘‘Ocean Disposal of Organochlorine

Wastes by At-Sea Incineration, ” Ocean Dumping

of 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 Incineration of Hazardous Waste: A Critique (Washington, DC: EWK Consultants, Inc. , 1983).

Kleppinger, E. W., and Bond, D. H., Ocean incineration of Hazardous Waste: A Revisit to the

Controversy (Washington, DC: EWK Consultants,

Inc., 1985).

Lentz, S. A., Testimony Before the Subcommittee

on Oceanography, House Committee on Merchant

Marine and Fisheries, U.S. Congress, Hearing on

‘ ‘Incineration of Hazardous Waste At Sea, ” Nov.

11 and Dec. 3, 1985, Serial No. 99-25 (Washington, DC: 1986).

Metzger, J. F., and Ackerman, D. G., “A Summary

of Events, Communications, and Technical Data

Related to the At-Sea Incineration of PCBContaining Wastes Onboard the M/T Vulcanus,

20 December, 1981-4 January, 1982, ” prepared

for the U.S. Environmental Protection Agency,

March 1983.

Smith, G., ‘‘The Burning Question, San Francisco Chronicle, This World, May 12, 1985, pp.

7-9.

U.S. Environmental Protection Agency, Office of

Water and Hazardous Materials, Division of Oil

and Special Materials Control, Final Environmental

Impact Statement of Designation of a Site in the

Gulf 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 of

Water Regulations, Criteria and Standards Division, Environmental Protection Agency Find Environmental Impact Statement (EIS) for North AtJantic Incineration Site Designation (Washington,

DC: Nov. 25, 1981).

U.S. Environmental Protection Agency, ‘ ‘Preliminary Report, Research Permit for Incineration At

Sea of PCB Wastes, HQ 81-002, Results of Test

Burn on M/T Vulcanus, ” May 20, 1982, p. 57.

U.S. Environmental Protection Agency, Office of

Water, Incineration-At-Sea Research Strategy

(Washington, DC: Feb. 19, 1985).

U.S. Environmental Protection Agency, Office of

Policy, Planning and Evaluation, “Summary and

Conclusions, Assessment of Incineration as a

Treatment Method for Liquid Organic Hazardous

Wastes (Washington, DC: March 1985).

U.S. Environmental Protection Agency, Office of

Policy, Planning and Evaluation, “Background Report I: Description of Incineration Technology, ”

Assessment of Incineration as a Treatment Method

for Liquid Organic Hazardous Wastes (Washington, DC: March 1985).

U.S. Environmental Protection Agency, Science

Advisory Board, Report on the Incineration of Liquid Hazardous Wastes by the Environmental Effects, Transport and Fate Committee (Washington,

DC: April 1985).

U.S. Environmental Protection Agency, Marine

Operations Division of the Ofilce of Marine and Estuarine Protection, Assessment of the Impact of Incineration of Chemical Wastes in the Proposed

North Atlantic Incineration Site on Endangered and

Threatened Species (Washington, DC: July 9,

1985).

U.S. Environmental Protection Agency, “Hearing

Officer’s Report on the Tentative Determination To

Issue the Incineration-At-Sea Research Permit HQ85-001” (Washington, DC: May 1, 1986).

Wastler, T. A., Offutt, C. K., Fitzsimmons, C. K.,

et al., Disposal of Organ ochlorine Wastes, EPA430/9-75-014, contract report prepared for the U.S.

Environmental Protection Agency (Washington,

DC: July 1975).
Chapter 12

The Regulation and Use of

Ocean Incineration by Other Nations
Contents

Page

Historical Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..........................193

International Bodies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .....................194

London Dumping Convention . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .................194

Oslo Commission . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .194

Commission of the European Communities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ........195

European Parliament . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...............-......195

Use of Ocean Incineration by Other Nations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ......195

Incineration Vessels . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ........................195

Quantities of Waste Incinerated . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ................195

Number of Voyages . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ............................197

Characteristics of Waste Incinerated .,... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .......197

Profiles of Individual

Major Conclusions

Belgium . . . . . . . . .

Canada . . . . . . . . . .

Denmark . . . . . . . .

Finland . . . . . . . . . .

France . . . . . . . . . .

Nations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...............198

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 198

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...... . . . . . . . . . . . . . 198

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..... 199

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 199

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 199

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 199

Federal Republic of Germany . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .................200

The Netherlands . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..........................200

Norway . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .......201

Sweden . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ........................-....201

Switzerland . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...201

United Kingdom . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .............................201

Chapter 12 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... ...202

Tables

Table No.

27. Incineration Vessels Employed in Europe, 1969 to

Page

Present . .......................19 6

28. Type of Waste Incinerated and Country of Origin, 1982 . . . . . . . . . . . . . . . . . . . . . . . . . .197

Figure

Figure No. Page

13. Quantities of Waste Annually Incinerated At Sea, 1969-84 . . . . . . . . . . . . . . . . . . ......196
Chapter 12

The Regulation and Use of

Ocean Incineration by Other Nations

This chapter provides overviews of the past,

present, and future use of ocean incineration by

nations other than the United States. The first section provides a brief history of international use and

regulation of ocean incineration. The second section discusses the various international and regional

conventions and other deliberative bodies that have

addressed the use of ocean incineration and describes several important recent actions. The third

section presents a summary of data on the past and

present use of ocean incineration by other nations.

The fourth and final section briefly discusses the

policies and practices of 11 individual nations, based

on information from several sources, including a

survey of foreign embassies conducted by OTA.

HISTORICAL BACKGROUND

Commercial use of ocean incineration by other

nations dates back to 1969, when the first incineration vessel, a modified chemical tanker named

Mathias I, was launched under the flag of the Federal Republic of Germany. Development of ocean

incineration for the purpose of incinerating organochlorine wastes was initially motivated by five

factors (12):

1.

2.

3.

4.

5.

the many problems encountered on land in

operating and maintaining scrubbers in the

presence of the corrosive gases produced by

incinerating organochlorine wastes;

the ability of seawater to neutralize the gases,

thereby negating the need for scrubbers;

additional problems arising from treating and

disposing scrubbing effluents and sludges;

the advantage of a centralized, large-scale system for collecting and incinerating organohalogen wastes, which could potentially be

better controlled and monitored, as well as

more economical, than other alternatives; and

unacceptable impacts from ocean dumping of

certain organochlorine wastes, such as tars

arising from the production of ethylene dichloride.

Consideration of these factors led to an increase in

the European market for ocean incineration and

the launching of two additional ships, the Mathias

II and the Vulcanus I, in the early 1970s. All three

ships operated exclusively in the North Sea.

Also at this time, international concern was increasing over environmental impacts of ocean disposal of wastes in general. These concerns led to

the development of the worldwide London Dumping Convention (LDC) and the regional Oslo Convention, both established in 1972. Although these

conventions did not initially address ocean incineration, proposals to begin incineration in the Mediterranean Sea prompted two developments. First,

the Barcelona Convention, established in 1976,

decided to prohibit incineration in the Mediterranean Sea (12). Second, the LDC and the Oslo

Commission began developing special provisions

and codes of practice to govern the use of incineration at sea. Groups of experts convened by both

conventions developed sets of technical guidelines

for incorporation into the conventions. The guidelines covered the following topics:

●

●

●

●

●

●

control and approval of incinerator system design and specifications,

control over the nature of wastes to be incinerated at sea,

criteria for the selection of incineration sites,

control over vessel design and operation,

requirements for monitoring and the use of

recording devices, and

reporting requirements and procedures for incineration activities.

The next section examines the approaches and

recent activities of these and other international

bodies with regard to ocean incineration.

193
194 . Ocean Incineration: Its Role in Managing Hazardous Waste

INTERNATIONAL BODIES

London Dumping Convention

The LDC considers incineration at sea as legally

constituting ocean dumping and has developed extensive procedural and operational requirements,

which are contained in Annexes to the Convention

(8). Under the LDC, incineration at sea is viewed

as an interim method of waste management, as

reflected in LDC Regulation 2.2:

Contracting parties shall first consider the practical availability of alternative land-based methods of treatment, disposal or elimination, or of

treatment to render the wastes or other matter less

harmful, before issuing a permit for incineration

at sea in accordance with these Regulations. Incineration at sea shall in no way be interpreted

as discouraging progress towards environmentally

better solutions including the development of new

techniques.

At a meeting of the LDC’s Scientific Group on

Dumping (SGD) in 1985, a working group on

ocean incineration was convened to identify and

discuss several unresolved questions regarding the

performance of and monitoring capabilities for incineration at sea (7). These issues include the following:

● the relationship between destruction and combustion efficiencies over a broad range of operating conditions;

• the ability to sample incinerator stack gases

in a mannner that is representative of the entire emission;

• the ability to accurately sample particulate

matter in stack emissions; and

● the nature and significance of newly synthesized compounds (products of incomplete combustion, or PICs) in stack emissions.

A group of experts jointly drawn from the LDC

and the Oslo Commission is to undertake further

discussion of these issues at an intersessional meeting in 1986 or 1987. This discussion was to be based

in part on new information provided by the U.S.

PCB research burn (10); given its cancellation, the

timing of formal international consideration of these

questions is not clear.

The International Maritime Organization

(IMO) is designated under the LDC to serve as Secretariat. The IMO, therefore, is responsible for

collecting data from Contracting Parties on ocean

incineration activities, including the number and

status of permits, as well as the quantities and types

of wastes authorized for incineration at sea. The

most recent of these data (for activities in 1982) are

discussed later in this chapter.

0slo Commission

Rule 2.3 of the Oslo Commission Rules, adopted

in 1981, stipulates that ‘‘the Commission will meet

before the 1st of January 1990 to establish a final

date for the termination of incineration at sea’ in

the North Sea, which comprises the Oslo Convention area (15). The 1990 date was formulated at

a time when few controls existed over the use of

ocean incineration. Since that time, international

(LDC and Oslo Commission) and national regulations have been developed to cover most aspects

of this technology, leading some Oslo Commission

nations to see the need to terminate use of ocean

incineration in the near future as less pressing; other

members, however, remain committed to its termination by 1990 (see profiles of individual nations

later in this chapter).

At the Commission’s 11th meeting, held June

11-13, 1985, The Netherlands presented the results

of a survey of member nations, which was undertaken to gauge the availability of alternative means

of disposing wastes currently incinerated at sea (1 7).

The survey provided an initial step toward assessing the practicality of fulfilling the language of Rule

2.3. Responses to The Netherlands survey were received from all but two members (France and

Spain). Its conclusions are as follows:

●

●

There is a potential shortfall in the capacity

of land-based incinerators and other landbased treatment methods to dispose of the

wastes currently being incinerated at sea.

Spare capacity on land is considered far from

sufficient 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 in

such capacity is expected in the near future.

● It is expected that by 1990 wastes will remain

for incineration at sea.

In 1987, at its 13th meeting, the Oslo Commission expects to draft a policy statement on the termination of incineration at sea, contingent on the

availability of adequate capacity in acceptable landbased alternatives (16).

The Commission’s Standing Advisory Committee for Scientific Advice (SACSA) examined data

regarding the location of the current North Sea

incineration site, and concluded that ‘ ‘there is no

better compromise between meteorological and

logistical requirements (shorter approach to the incineration site resulting in higher cargo safety).

This finding was endorsed by the commission at

its 11th meeting in 1985 (16).

Commission of the European

Communities

This commission exists under the auspices of the

European Economic Community (EEC). In July

1985, the commission submitted to its Council of

Ministers a proposal for a council directive on the

dumping of waste at sea (2). Ocean incineration

is explicitly included in the definition of ‘‘dumping at sea. The intent of the directive would be

to reduce and terminate all dumping at sea by EEC

Member States as soon as possible. Under the direc-

‘‘temporary’ disposal option to be used ‘ ‘only if

there are no practical alternative methods of landbased treatment, as determined on a case-by-case

basis.

EEC Member States would be required to submit to the commission by January 1, 1990, information required for setting a final date for terminating incineration at sea. The council would be

required to act on the information within 6 months

of that date.

If adopted, the directive would prohibit the granting of any new special permits for incineration after January 1, 1988. Permits already in effect could

be renewed until January 1, 1990, for up to 5 years,

but Member States would be required to decrease

the quantities of waste incinerated at sea each year

by 10 percent.

European Parliament

The European Parliament also exists under the

auspices of the EEC. A Parliament report (4) issued by the Committee on the Environment, Public

Health, and Consumer Protection in December

1983 identified ocean incineration as a contributor to pollution of the North Sea through the release of ash, hydrogen chloride gas, and small quantities of unburned waste to the atmosphere. The

report suggested that ocean incineration be relocated to a less sensitive location in the Atlantic

Ocean.

tive, ocean incineration ‘would be

USE OF OCEA N

regarded as a

INCINERATION BY OTHER NATIONS

This section presents available data on European

incineration vessels, the number of voyages they

have made, and the quantities and types of European wastes that have been incinerated at sea.

ated exclusively in the North Sea. All but the Matthias III, which was only used for a brief time, are

much smaller than typical tank ships.

Quantities of Waste Incinerated

Incineration Vessels

A total of six vessels have been built and employed to incinerate European wastes at sea. Table 27 provides a summary of the most important

features of these six vessels, including dates of operation. All but one vessel (the Vulcan us I) have operQuantities of wastes managed by ocean incineration steadily increased from 1969, when incineration began in the North Sea, until about 1979,

when quantities stabilized at the present level of

about 100,000 metric tons annually (fig. 13). The

great majority of all waste has been incinerated in
196 • Ocean Incineration: Its Role in Managing Hazardous Waste

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-present

Site of operation . . . . . . . . . . . . Exclusively in the North Sea North Sea North Sea North Sea

United States

Pacific

Australia

Number of incinerators . . . . . . 1 1 1 2 3 1

Total cargo (ret). . . . . . . . . . . . . 550 1,200 15,000 3,500 3,200 1,400

Total gross tons . . . . . . . . . . . . 438 999 12,636 3,100 3,100 999

SOURCE: 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, State

of 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*

u Gulf 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, Draft

Report 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 burned

by the Vulcanus I in the Gulf of Mexico (Shell

wastes and PCBs), in the Pacific Ocean (Agent

Orange), and in one burn near Australia. Figure

13 presents the estimated quantities burned between

1969 and 1984.

Many different European countries, as well as

Australia and Japan, have used ocean incineration.

Each member nation must report annually to the

LDC, providing data on the quantities of waste sent

for incineration at sea. Table 28 presents the most

recent available compilation of such data, covering the year 1982.

These data indicate that 14 LDC nations in addition to the United States incinerated wastes at sea

in 1982. Actual quantities sent for incineration varied significantly, ranging from 200 metric tons

(Spain) to 53,000 metric tons (Germany). Most

wastes are sent for loading at Antwerp, Belgium,

although other ports have also been used (e. g., Rotterdam in The Netherlands and Le Havre in

France); in addition, permits have been granted for

exporting wastes from nations such as Finland.

Four vessels were used to incinerate wastes in the

North Sea in 1982. Of the 94,000 mt of waste actually incinerated in the North Sea in 1982, the folTable 28.—Type of Waste Incinerated and

Country of Origin, 1982

Country Type of waste

Australia . . . . . . . . .Vinyl chloride and PCB

wastes

Austria . . . . . . . . . . . Organohalogen wastes

Belgium . . . . . . . . . . Organohalogen wastes

Finland . . . . . . . . . .Organohalogen wastes

France . . . . . . . . . . . Organohalogen wastes

Germany . . . . . . . . . Organohalogen wastes

Italy . . . . . . . . . . . . .Organohalogen wastes

Japan . . . . . . . . . . . . Oily sludges

The Netherlands . . Organohalogen wastes

Norway . . . . . . . . . . Organohalogen wastes

Spain . . . . . . . . . . , . Organohalogen wastes

Sweden . . . . . . . . . . Organohalogen wastes

Switzerland . . . . . . . Organohalogen wastes

United Kingdom . . .Organohalogen and

organophosphorous

wastes

Quantitya

4,820

490

10,643

2,750

6,582

52,751

3,431

1,488

9,396

8,000

210

6,420

3,711

6,194

Total . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 116,886a

aThe5e are quantities for which permits were granted; in some caSes, the amount

of waste actually incinerated in 1982 was smaller,

SOURCE: International Maritime Organization, “Consideration of Report on

Dumping, Draft Report of Permits Issued in 1982,” Document

LDC/SG.8/lNF.3, prepared for 8th Meeting of Scientific Group on

Dumping (London: Dec. 20, 1984).

lowing proportions were incinerated by each vessel: Matthias II, 29 percent; Vulcanus I, 25 percent;

Vesta, 42 percent, and the newly commissioned

Vulcanus II, 4 percent.

Number of Voyages

EPA formulated estimates of the number of

voyages, as well as quantities of waste incinerated,

by the two Vulcanus ships and the Vesta from their

launch dates through 1983 (app. C in ref. 19).

These data indicate that the ships made 322 voyages

and incinerated more than 650,000 mt of waste.

Comparable data were not available for the three

Matthias vessels.

The total number of incineration voyages is likely

to be substantially higher, because almost twice as

much waste was incinerated at sea by all six vessels over the period 1969-84 (see figure 13).

Characteristics of Waste Incinerated

The vast majority of waste incinerated in the

North Sea is organochlorine waste. Of the 100,000

mt incinerated in the North Sea in 1981, about 80

percent consisted of organochlorines (6). Many of

these wastes have appreciable chlorine content, estimated to average between 60 and 70 percent (1 1).

The waste burned during testing of the Vulcanus

II in 1983 (see ch. 11) was derived from vinyl chloride production in Norway and had a chlorine content of 84 percent. Chemical Waste Management,

Inc., estimated that 65 percent of the waste incinerated by the Vulcanus ships in the North Sea had

chlorine contents greater than 35 percent (l).

Few data are available characterizing European

wastes with respect to metal content; the available

analyses, however, indicate that metals are typically in the parts per million range (12). The Oslo

Commission (17) has estimated that approximately

90 percent of the emissions of heavy metals from

incineration at sea originate from wastes with chlorine content less than 45 percent. Wastes with high

metal content (and low chlorine content) are increasingly being diverted to land-based incineration (3).

With respect to emissions of heavy metals, the

Oslo Commission (17) estimates that the total con-
I@ ● Ocean Incineration: Its Role in Managing Hazardous Waste

tribution of ocean incineration to the Dutch part

of the North Sea (encompassing the incineration

site) represents less than 0.3 percent of the total input of metals. The German Hydrographic Institute has compared such emissions to the average

input of metals entering the North Sea via the

Rhine River (cited in ref. 3). The contribution from

the Rhine River is estimated to be 1,000 to 10,000

times higher than that from ocean incineration

emissions, for each of six toxic metals.

No PCBs have been incinerated at sea in Europe; LDC regulations list PCBs as a waste about

which there is doubt regarding its thermal destructability. However, The Netherlands has announced

plans to conduct a research burn using PCBs in late

1986 or 1987. The loss of land-based incineration

capacity (located in England and France) previously

used for PCBs by The Netherlands necessitated

reconsideration of the at-sea incineration option

(10,18).

PROFILES OF INDIVIDUAL NATIONS

This section describes the policies and practices

of 11 individual nations regarding the use of ocean

incineration for managing hazardous wastes. All

11 are signatories to the LDC, and all but two

(Canada and Denmark) have used ocean incineration.

Sources for the information presented in this section, unless otherwise noted, include The First Decade, a report of the Oslo and Paris Conventions

published in 1984 (ref. 14), and letters from foreign embassies received in response to an OTA request for information on practices and policies regarding ocean incineration.

Major Conclusions

The data presented below, as well as that contained in the survey of Oslo Commission members

described above, provide the basis for two major

conclusions regarding the use of ocean incineration

by other nations:

1.

2.

The major constraint blocking termination of

ocean incineration is the lack of sufficient landbased capacity for treating organochlorine

wastes.

A broad range of opinion and position regarding future use of ocean incineration exists

among European nations. For example, the

United Kingdom holds a quite favorable view,

whereas Denmark argues for termination as

soon as possible. Other nations, such as The

Netherlands and the Federal Republic of Germany, are attempting to reduce their reliance

on ocean incineration but regard it as a necessary option for the foreseeable future due

to lack of land-based capacity.

Belgium

Belgium estimates that it generates about 100,000

mt of hazardous waste each year, an unreported

fraction of which is incinerated on land. About

10,000 mt of hazardous waste generated in Belgium

was incinerated at sea in 1982.

Belgium regards incineration at sea to be “an

acceptable solution whenever difficult technical

and/or economic problems arise regarding incineration on land. For Belgium, ocean incineration

is ‘‘a fairly attractive method as the burners and

furnaces can be relatively simplified and it is not

necessary to provide for the neutralization of the

combustion gases due to the buffering capacity of

seawater. The method’s main drawback is that at

sea it is more difficult to efficiently control the effectiveness of the incineration process and the way

in which these operations are carried out.

Antwerp, Belgium, has served as the major port

for incineration vessels operating in the North Sea.

Currently, the loading and transit of incineration

vessels occur two or three times each month. Because this activity involves the burning of wastes

from numerous European countries, importation

and storage of hazardous wastes at Antwerp is routine. For example, in 1982, Antwerp received about

70,000 mt of hazardous waste destined for incineration in the North Sea. This waste originated in

seven 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 for

highly chlorinated wastes is limited to a few private onsite destruction facilities. Thus, chlorinated

wastes for which no other alternative exists will continue to be sent for incineration at sea. Belgium

has experienced little change in the amount of

wastes incinerated at sea over the past decade and

anticipates little change for the next 5 years. A new

publicly owned incineration plant, scheduled for

completion 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 hazardous

wastes. Canada anticipates having only small

quantities of waste suitable for ocean incineration,

has not incinerated any wastes at sea, and has no

immediate plans to do so. However, a general application from Chemical Waste Management, Inc.,

has prompted

ogy, based in

LDC data.

a further evaluation of the technollarge part on a review of relevant

Denmark

Denmark is engaged in a substantial hazardous

waste management program administered by public

authorities, with land-based incineration representing the primary method of treatment or disposal.

Of the 40,000 mt of chemical waste received at the

central treatment facility (known as Kommunekemi) in 1980, 80 to 90 percent is treated by incineration. Total incineration capacity of the facility

is about 90,000 mt annually.

No permits for ocean incineration have been issued by the Danish Minister for the Environment.

Although Denmark regards thermal destruction to

be a “useful and acceptable disposal method, ”

especially for organohalogen wastes, it believes that

‘‘incineration at sea presents great problems in connection with the control of destruction and combustion efficiency. ” In addition, Denmark expresses concern about the large areas of the North

Sea that are unavailable for other uses because of

ocean incineration, and concern about the potential for the technology to aggravate regional problems with acid rain.

The Danish Government, which has been the

most vocal and consistent opponent of ocean incineration in the European community, continues

to press for an end to the practice, particularly in

the North Sea.

Finland

Finland estimates that it produced about 500,000

mt of hazardous waste in 1975. The majority of

Finland’s oily wastes and about half of its solvent

wastes are burned, mostly in land-based incinerators. Finland currently lacks sufficient incineration

capacity for PCBS and certain other chlorinated

wastes, and hence exports these wastes to the

United Kingdom for destruction in a land-based

incinerator (1 7).

Finland has recently constructed (at Riihimki)

a centralized hazardous waste treatment facility,

which has a capacity of 70,000 mt annually. Landbased incineration is the major technology at this

facility. It is unclear if and to what extent this will

affect the need for Finland to continue to export

PCBs and other wastes.

Incineration at sea has twice been used to destroy wastes (a total of 5,250 mt) from one of Finland’s petrochemical plants, which is closed at least

for the time being. No definitive policy statements

by Finland regarding ocean incineration are

available.

France

France estimates that it annually generates 18

million mt of hazardous industrial waste, 2 million

mt of which are especially toxic or hazardous. In

1982, approximately 200,000 mt of this waste was

incinerated at 10 ‘‘special collective plants’ located

throughout France. A comparable quantity was incinerated in onsite facilities operated by various industrial firms. Of the 10 commercial facilities,

which have a total annual capacity of 205,000 mt,

4 are equipped to incinerate chlorinated wastes, and

3 can burn only liquid wastes. These facilities compete with 5 cement kilns, which have recently increased their share of the market for wastes with

high heat content.

France points to insufficient capacity and the high

cost of land-based incineration of organochlorine
200 ● Ocean Incineration: Its Role in Managing Hazardous Waste

wastes as factors motivating its use of ocean incineration. Waste to be incinerated in the North Sea is

directed to the ports of Le Havre, France, and

Antwerpj Belgium, the latter receiving primarily

or exclusively wastes with high chlorine content.

Waste generators do not have direct access to incineration vessels, which receive waste only from

treatment plants. Annual quantities incinerated at

sea since 1979 have ranged from 4,600 mt to 11,700

mt, averaging about 10,000 mt.

France anticipates that a gradual increase in landbased incineration capacity and decreases in its cost

will reduce the quantities of waste incinerated at

sea.

Federal Republic of Germany

The Federal Republic of Germany (FRG) estimates that its annual production of industrial special or toxic waste amounted to about 4.5 million

mt in 1980. A total of 17 land-based incineration

plants handle an unreported portion of these special wastes.

The FRG has expressed a variety of views on

the use of ocean incineration. According to its submission to the Oslo Commission (14), the FRG

regards ocean incineration ‘‘to be ecologically the

soundest of the available methods for the disposal

of halogenated hydrocarbons’ but not ‘‘an ideal

disposal method, ” preferring to develop appropriate reuse and recycling efforts. These methods include land-based thermal destruction technologies

that provide for recovery or reuse of chlorine

residues released during the process, as well as more

conventional heat recovery.

Permits for incineration at sea are evaluated with

respect to need on a case-by-case basis, with the

unavailability of alternative capacity on land being the major criterion. Wastes to be incinerated

at sea are prohibited from containing chlorinated

dibenzofurans, PCBs or PCTs, dioxins, or DDT.

Quantities of waste incinerated at sea have ranged

as high as 100,000 mt annually but have gradually

decreased since 1980. For example, a reported

41,000 mt of German waste was incinerated at sea

in 1983. Nevertheless, the FRG remains the greatest user by far of ocean incineration.

In its response to the OTA survey, the FRG

stated its intent to make ‘‘every effort to terminate

incineration at sea as soon as possible. The FRG

anticipates significant decreases in future quantities of waste incinerated at sea, especially for highly

chlorinated wastes (those with chlorine content

greater than 45 percent), because of completion of

a new land-based incinerator in 1987 and greater

application of perchlorination and other reuse technologies (1 7). However, the lack of sufficient landbased capacity precludes the FRG from

a date for ending ocean incineration.

specifying

The Netherlands

The Netherlands annually generates about 1 million mt of chemical waste, half of which is currently

treated or disposed of offsite. Of the waste treated

offsite, about 86,000 mt is incinerated on land or

at sea. The AKZO treatment facility can incinerate wastes with a high chlorine content (as high as

45 percent; see ref. 17) and regularly receives such

wastes from Sweden.

The Netherlands regards “incineration at sea,

albeit an environmentally acceptable procedure, as

a temporary expedient; land alternatives are to be

preferred . Efforts are underway to develop further land-based incineration capacity and make

greater use of recycling methods.

A new land-based incinerator is scheduled to begin operation in 1987. If future policy analysis determines that this land-based incinerator constitutes

a practical land-based alternative preferable t.

ocean incineration, The Netherlands expects a

sharp decline in the quantities of waste incinerated

at sea (1 7).

The Netherlands has played a central role in

much of the testing of the Vulcanus ships that has

occurred to date; as a result of these studies, it believes that all international requirements are generally being satisfied. As described previously, The

Netherlands plans to conduct an ocean incineration research burn of PCB-containing wastes in late

1986 or early 1987, motivated by the loss of landbased incineration capacity in the United Kingdom

and France (10, 18).
Ch. 12—The Regulation and Use of Ocean Incineration by Other Nations • 201

Norway

Norway estimates that it annually generates

about 120,000 mt of hazardous waste, 75 percent

of which is used oil or oily wastes. Norway uses a

large-capacity cement kiln for destroying significant quantities of incinerable liquids and sludges.

Tar wastes from vinyl chloride production,

amounting to some 8,000 mt annually, are currently incinerated at sea. To provide an alternative, Norway is considering the construction of a

land-based incinerator equipped to reclaim hydrogen chloride.

Norway’s official position is that ocean incineration should be terminated as soon as possible. Although its use of incineration at sea has gradually

increased, Norway anticipates gradually reducing

its use over the next 5 years, as sufficient land-based

incineration capacity and recycling technologies are

developed.

Sweden

Sweden estimates that a total of 482,000 mt of

hazardous waste was generated in 1978. About half

of this quantity was treated or disposed of at the

site of generation. Most of Sweden’s waste that is

sent offsite is treated by the State-owned waste treatment network (SAKAB) or by 1 of about 20 other

government-licensed waste treatment companies.

SAKAB has recently completed a new hazardous

waste treatment facility, which uses a large-capacity

rotary kiln incinerator, but which cannot” handle

highly chlorinated wastes.

Sweden has taken a generally restrictive position

in international discussions on ocean incineration,

stating that it ‘ ‘will accept incineration at sea as

a last resort during a transition period, if no landbased treatment alternatives exist. A Swedish law

dating from 1971 prohibits dumping or ocean incineration from Swedish ports or Swedish vessels.

However, Sweden has used incineration at sea on

foreign vessels to a limited extent in recent years:

6,420 mt of organohalogen wastes of Swedish origin were incinerated at sea in 1982. No applications have been approved for such activity since

1983.

Sweden regards land-based incineration as the

most practical and preferable alternative to ocean

incineration. However, the lack of sufficient capacity, especially to process chlorinated wastes, is cited

as a major obstacle to ending Sweden’s 1imited reliance on ocean incineration.

Switzerland

Because of insufficient land-based incineration

capacity within Switzerland, about 10,000 mt of

organic wastes are exported for incineration. Those

wastes with a high (greater than 15 percent) chlorine content are, without exception, sent for incineration at sea. This quantity averages about 5,000

mt annually and has been increasing over the last

several years. Switzerland expects that the quantities of waste it incinerates at sea will continue to

increase at least in the short term, because of stricter

controls over land disposal and the length of time

required to develop land-based capacity. For the

long term, Switzerland regards land-based incineration to be environmentally preferable to ocean incineration because of the greater control the authorities are able to exert on land.

United Kingdom

A total of 3.78 million mt of ‘hazardous and difficult wastes’ are disposed or treated offsite in the

United Kingdom each year. An estimated 2 percent (80,000 mt) is incinerated at 11 land-based facilities. The recent closure of one very large landbased incinerator has increased demand for incineration at sea (1 7).

In 1982, the United Kingdom used incineration

at sea for only 852 mt of waste, ‘‘which would have

presented special problems if incinerated in landbased units. Ocean incineration has been increasingly used since 1981: 2,700 mt in 1983 and 3,500

mt in 1984 were incinerated at sea. The United

Kingdom regards ocean incineration of certain

wastes to be the best practicable environmental option (5).
202 ● Ocean Incineration: Its Role in Managing Hazardous Waste

1.

2.

3.

4.

5.

6.

7.

8.

9.

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the House Committee on Science and Technology,

No. 61, 99th Cong., Ist sess., June 13 and 25, 1985

(Washington, DC: U.S. Government Printing Office, 1986).

S. Congress, House of Representatives, Hazardous

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, Library of Congress, Congressional Research Service, “Authority of EPA To Impose Financial Responsibility Requirement as Condition for

Ocean Incineration Permits” (Washington, DC:

Aug. 8, 1985).

U.S. Congress, O~ce of Technology Assessment, Technologies and Management Strategies for Hazardous

Waste Control, OTA-M-196 (Washington, DC:

U.S. Government Printing Office, March 1983).

U.S. Congress, Office of Technology Assessment,

Transportation of Hazardous Materials, OTA-SET304 (Washington, DC: U.S. Government Printing

Office, July 1986).

U.S. Congress, Office of Technology Assessment,

“Serious Reduction of Hazardous Waste for Pollution Prevention and Industrial Efficiency, in press

(Washington, DC: 1986).

U.S. Congress, OffIce of Technology Assessment,

“Wastes in Marine Environments, ” draft report

(Washington, DC: 1986).

U.S. Department of Transportation, U.S. Coast Guard,

u

u

Polluting Incidents In-and Around U.S. Waters,

Calendar Years ~982 and 1983, Commandant Instruction M16450.2F (Washington, DC: 1983).

S. Environmental Protection Agency, U.S. Department of Commerce Maritime Administration, U.S.

Department of Transportation Coast Guard, and

U.S. Department of Commerce National Bureau of

Standards, Report to the Interagency Ad Hoc Work

Group for the Chemical Waste Incinerator Ship Program, NTIS No. PB-81-1 12849 (Springfield, VA:

National Technical Information Service, September

1980).

S. Environmental Protection Agency, Office of Water

and Hazardous Materials, Division of Oil and Special Materials Control, “Final Environmental Im-
210 ● Ocean Incineration: Its Role in Managing Hazardous Waste

pact Statement of Designation of a Site in the Gulf

of Mexico for Incineration of Chemical Wastes’

(Washington, DC: 1976).

U.S. Environmental Protection Agency, Office of Water

Regulations, Criteria and Standards Division, Environmental Protection Agency Final Environmental

Impact Statement (EIS) for North Atlantic Incineration Site Designation (Washington, DC: Nov. 25,

1981).

U.S. Environmental Protection Agency, ‘‘Preliminary

Report, Research Permit for Incineration At Sea of

PCB Wastes, HQ 81-002, Results of Test Burn on

M/T Vulcanus, May 20, 1982, p. 57.

U.S. Environmental Protection Agency, Office of Water,

Incineration-At-Sea Research Strategy (Washington,

DC: Feb. 19, 1985).

U.S. Environmental Protection Agency, Office of Policy, Planning and Evaluation, ‘‘Summa~ and Conelusions, ” Assessment of Incineration as a Treatment

Method for Liquid Organic Hazardous Wastes

(Washington, DC: March 1985).

U.S. Environmental Protection Agency, Office of Policy, Planning and Evaluation, ‘ ‘Background Report

I: Description of Incineration Technology, ” Assessment of Incineration as a Treatment Method for Liquid Organic Hazardous Wastes (Washington, DC:

March 1985).

U.S. Environmental Protection Agency, Office of Policy, Planning and Evaluation, ‘ ‘Background Report

II: Assessment of Emerging Alternative Technologies, Assessment of Incineration as a Treatment

Method for Liquid Organic Hazardous Wastes

(Washington, DC: March 1985).

U.S. Environmental Protection Agency, Office of Policy, Planning and Evaluation, ‘ ‘Background Report

III: Assessment of the Commercial Hazardous Waste

Incineration Market, Assessment of Incineration as

a Treatment Method for Liquid Organic Hazardous

Wastes (Washington, DC: March 1985).

U.S. Environmental Protection Agency, Office of Policy, Planning and Evaluation, ‘ ‘Background Report

IV and Appendices: Comparison of Risks From

Land-Based and Ocean-Based Incineration, ” Assessment of Incineration as a Treatment Method for Liquid Organic Hazardous Wastes (Washington, DC:

March 1985).

U.S. Environmental Protection Agency, Office of Policy, Planning and Evaluation, ‘ ‘Background Report

V: Public Concerns Regarding Land-Based and

Ocean-Based Incineration, Assessment of Incineration as a Treatment Method for Liquid Organic

Hazardous Wastes (Washington, DC: March 1985).

U.S. Environmental Protection Agency, Science Advisory Board, Report on the Incineration of Liquid

Hazardous Wastes by the Environment& Effects,

Transport and Fate Committee (Washington, DC:

April 1985).

U.S. Environmental Protection Agency, Marine Operations Division of the Office of Marine and Estuarine Protection, Assessment of the Impact of Incineration of Chemical Wastes in the Proposed North

Atlantic Incineration Site on Endangered and

Threatened Species (Washington, DC:July 9, 1985).

U.S. Environmental Protection Agency, Oflice of Solid

Waste and Emergency Response, “Supporting

Documentation for the RCRA Incinerator Regulations, 40 CFR 264, Subpart O—Incinerators, ” prepared by PEER Consultants, October 1984, NTIS

No. PB-86-1 10293 (Springfield, VA: National Technical Information Service, August 1985).

U.S. Environmental Protection Agency, IncinerationAt-Sea Regulation Development Task Force, Office

of Water Regulations, Criteria and Standards Division, “Summary of Public Comments on the Proposed Ocean Incineration Regulation” (Washington,

DC: September 1985).

U.S. Environmental Protection Agency, “Hearing

Officer’s Report on the Tentative Determination to

Issue the Incineration-At-Sea Research Permit HQ85-001” (Washington, DC: May 1, 1986).

Walton, G. C., and Dobbs, D., “Biodegradation of

Hazardous Materials in Spill Situations, ” in Control of Hazardous Material Spills (Nashville, TN:

Vanderbilt University, 1980), pp. 23-45.

Wastler, T. A., Offutt, C. K., Fitzsimmons, C. K., et al.,

Disposal of Organochlorine Wastes, EPA-430/9-75-

014, contract report prepared for the U.S. Environmental Protection Agency (Washington, DC: July

1975).

Weitkamp, C., “Methods To Determine Hydrogen

Chloride in Incineration Ship Plumes, ’ in Wastes

in the Ocean, vol. 5, D.R. Kester, et al. (eds. ) (New

York: John Wiley & Sons, 1985), pp. 91-114,

Weller, R. A,, “Mixing Down From the Microlayer:

The Role of Three-Dimensional Flows, ” paper presented at the Sea-Surface Microlayer Workshop,

Arlie, VA, Dec. 18, 1985.

Westat, Inc., National Survey of Hazardous Waste

Generators and Treatment, Storage and Disposal

Facilities Regulated Under RCRA in 1981, contract

report prepared by S. Dietz, M. Emmet, R. DiGaetano, et al., for the U.S. Environmental Protection Agency, Office of Solid Waste (Rockville, MD:

Apr. 20, 1984).

Westat, Inc., Used or Waste Oil and Waste Derived

Fuel Material Burner Questionnaire for 1983, prepared for the U.S. Environmental Protection Agency

(Rockville, MD: 1984).
References • 211

White, M., Governor of Texas, Testimony Before the

U.S. Senate Subcommittee on Environmental Pollution, Committee on Environment and Public

Works, Hearing on “Ocean Incineration of Hazardous Waste, ’’June 19, 1985 (Washington, DC: 1985).

White, R. E., Busman, T., Cudahy, J.J., et al., New

Jersey Industrial Waste Study, EPA/600/6 -85/O03,

prepared for the U.S. Environmental Protection

Agency, Office of Research and Development (Washington, DC: May 1985).

Young, D. R., Moore, M. D., Alexander, G. V., et al.,

Trace Elements in Seafood Organisms Around

Southern California Municipal Wastewater Outfdls,

Publication No. 60 (Sacramento, CA: California

State Water Resources Control Board, 1978).

Zurer, P. S., “Incineration of Hazardous Wastes At

Sea—Going Nowhere Fast, ” Chemical & Engineering News, Dec. 9, 1985, pp. 24-42.
Acronyms and Abbreviations
Acronyms and Abbreviations

BAT —Best available technology

B H C —Benzene hexachloride

Btu —British thermal unit

CAA —Clean Air Act

C B O —Congressional Budget Office

C E —Combustion efficiency

CERCLA—Comprehensive Environmental

C F R

co

CO2

COT P

C Z M

D D T

D E

D O T

D R E

E DC

EEC

EIS

EPA

F R

F R G

HCl

Response, Compensation and

Liability 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 Data

Management System

I M

I M O

L DC

MPRSA

mmt

mt

NMFS

NOAA

PCB

P C T

PIC

POH C

RCR A

SAB

SACSA

S GD

TCD D

TCD F

T D E

TSCA

USCG

—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
Index

accidents: see spills

accountability: 27,43,46

acid gases (also see hydrogen chloride): 12,14,57,

114,119,127,150

performance standard: 12,33,124,127,150

advanced oil recovery: 87

afterburners: see secondary chambers

Agent Orange: 120,180,181,183,184, 197

air nozzle: see atomization

air pollution control equipment or wastes: see

scrubbers

alkalinity: see acid gases

annual throughputs of incinerators: 101,102,107

Apollo vessels: 6,101,107,108,109,139, 141,182

aqueous waste: 55,57,59,143

ash: 58,99,121

atomization of waste: 93,115

rotary cup: 108,115

spray nozzle: 108, 115

At-Sea Incineration, Inc.: 8,25,108,109,182

Australia: 62,196,197

Austria: 197

automatic shutoff system: 126,127,128,142

background concentrations: 149,150

ballast and bilge waters: 128,184,185

Barcelona Convention: 193

barges: 108,113,138

versus self-propelled vessels: 113

Belgium: 143,197,198

benzene hexachloride (BHC): 61,126

best available technology: 26,39,40,110,115

bioaccumulation: 60,61,140,160,163,164

biological treatment/detoxification: 61,85

birds: 162,163

boilers and furnaces (also see cement kilns): 5,10,

49,60,76,84,93

bottom-dwelling organisms: 162,163

Brownsville, Texas: 3,182

buffering capacity of seawater: 5,12,15,57,114,123,

127,193

burner type: see atomization

cadmium: 36,120,122,147,149,150

Canada: 199

capacity: see hazardous waste, commercial incineration, ocean incineration, or land-based incineration

Captain of the Port (COTP): 38,41

carbon monoxide: 119,120,123,125,126

cargo transport and storage modes, see transportation

catalytic dehalogenation: 89

cement kilns: 49,57,84,85,201

CERCLA: 46,47,48,173

chemical treatment/detoxification processes: 61,63,

85,88

Chemical Waste Management, Inc.: 61,108,109,

143,144,147,151,181, 182,197,199

chlorinated and highly chlorinated wastes: 5,179,

180,193,197

advantages of ocean incineration: 4,10,14,23,

57,167

limitations of land-based incineration: 15,57,122

chlorination processes: 10,87

chlorine content: 15,57,84,109,122,123,124,151,179,

197,200

chlorine gas: 15,57,150

chlorine recovery: 87

Clean Air Act (CAA): 125,128,174

Clean Water Act (CWA): 47,127,152,173

Coast Guard: 37,38,39,41,108,110,1 13,114,129,

138,173

Coastal Zone Management Act: 129,173,182

combustion efficiency (CE): 33,123,124,125

commercial incineration: 11,16,55,93,101,103, 166

capacity and demand: 10,19,69,73,74,102,187

market: 48,73,75,167,187

of PCBs: 61,174

Commission of the European Communities: 195

comparison of land-based and ocean incineration

regulation: 11,40,122-129

releases of waste (also see spills): 11,133

accidental: 14,133,134,136

routine: 14,133,134

risks: 13,159-165

to human health: 14,159-161

to marine environment: 14,161-165

scrubbers: 11

technologies: 119-129

comparison of marine transport of hazardous waste

and nonwaste materials: 15,134,138,

140-142,163

PCBs: 61,140

quantities and types of material carried: 140,141

comparison to other sources of marine pollution:

15,146,147,149,198

compliance record of permit applicants: 24,49

Comprehensive Environmental Response, Compensation, and Liability Act: see CERCLA

Congress, role of: 4,38,40

Congressional Budget Office (CBO): 10,63,67,72,

73,74,81

containerization/containership vs. bulk storage and

transfer: 110,134,136

credibility of EPA or ocean incineration companies:

24,49

219
220 . Ocean Incineration: Its Role in Managing Hazardous Waste

data gaps: 44,45,63,67,100,133,152,154,161, 186

DDT: 23,61,126,182,200

dechlorination: 85,89

deep-well injection: see underground injection

demand: see hazardous waste

Denmark: 17,198,199

Department of Transportation (DOT): 37,112,173

destruction efficiency (DE): 12,14,26,33,34,39,62,

115,120,123,124,142, 145,183,184,187

destruction and removal efficiency (DRE): 12,26,

123,124

dibenzofurans: 35,119,120,124,125,200

dioxin (TCDD): 35,55,56,61,85,119,120,121,124,

125,126,146,180,181,183,200

dumping: 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 35,164,187

endangered species: 5,162,175,185

Endangered Species Act: 129,162,173

energy content: 5,23,55,59,109

energy recovery: 10,99,101

Environmental Oceanic Services Corp. (EOS):

108,109,128

environmental performance standards: see acid

gases or particulate emissions

EPA (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: 7,8,25

ethylene dichloride (EDC): 143,144,152,153

European Parliament: 195

Federal Republic of Germany: 17,18,62,193,197,

198,200

financial responsibility: 46

Finland: 197,198

fish: 161,164,165

flue gases: see emissions

fluid wall reactor: 88

fluidized bed incineration: see land-based incineration

food chain: see bioaccumulation

France: 197,198

fuel, use of hazardous waste as: see hazardous waste

fugitive emissions: 126,128,143,144

future market: see hazardous wastes or ocean incineration

geographic distribution of waste generation: see

ocean-incinerable waste

geographic restrictions on transportation of wastes:

24

Germany: see Federal Republic of Germany

Gulf of Mexico Incineration Site: see ocean incineration

halogenated solvents: 59,65,81

Hazardous and Solid Waste Amendments of 1984:

see RCRA

Hazardous Materials Transportation Act: 173

hazardous waste (also see RCRA)

capacity and demand for treatment facilities:

73,194,198

generation/inventory: 59,65

all hazardous waste: 63,70

incinerable waste: 63,65

ocean-incinerable waste: 65

projection of future quantities: 66

management hierarchy: 3,83

management strategy: 7,42,44

transportation (also see comparison of marine

transport): 111,112,139,152,153

geographic restrictions: 24

risks: 26,37

use as fuel: 76,84,85

Hazardous Waste Data Management System

(HWDMS): 100,103

Hearing Officer’s Report: 7,41

hearth incineration: see land-based incineration

hierarchy: see hazardous waste

high temperature electric reactor: 88

hydrochloric acid: see hydrogen chloride

hydrogen chloride (also see acid gases): 5,12,14,33,

57,114,119,120,123,124, 150,151

emission standard: see acid gases

recovery: 87

incentives for preferred practices: 4, 17, 19,43,46

incinerable waste: 9,55,70

projection of future quantities: 68

incineration: see commercial, land-based, or ocean

incineration

incineration sites: see ocean incineration

incinerator upsets: see upsets

industrial boilers and furnaces: see boilers and

furnaces

industries generating incinerable waste: 66,67

information gaps: see data gaps

infrastructure: see ports

interim status of ocean incineration: see ocean incineration

intermodal containers: 109-113,134
Index ● 2 2 1

International Maritime Organization: 194

international use of ocean incineration: 193-201

implications and trends: 6,17,198

number of voyages: 197

ports used: 197,198

practices and regulations: 17,194-198

quantities incinerated: 195-197

vessels used: 196-197

inventory: see hazardous waste

Italy: 197

Japan: 197

land-based incineration

capacity: 15,17,101,103

extent of use and number of facilities: 9,15,65,73,

100,102

location of facilities: 101,102

types:

fluidized bed: 97,100,174

hearth: 96,100

liquid injection: 37,93,94,95,100,102

rotary kiln: 14,37,55,93,95,96,100, 102

land disposal: 9,10,74,81,83,187

landfill: 9,60,81,83,127,167,187

land transportation: see hazardous waste

liability: 7,42,43,46,48,167

liquid extraction: 86

liquid incinerable waste: see ocean- incinerable waste

liquid injection: see land-based or ocean incineration

location of incinerators: see land-based incineration

London Dumping Convention (LDC): 36,45,62,

113,123,126,127,175, 183,193,194,197,198

marine mammals: 162,185

Marine Protection, Research, and Sanctuaries Act

(MPRSA): 38,40,41 ,45,46,122,123,173,175,

183,185

marine transportation: see hazardous waste

marine water quality criteria: 13,34,35, 122, 125

Maritime Administration: 8,182

market: see ocean incineration or commercial incineration

Matthias vessels: 193,195-197

mercury: 36,120,122,127,147

metals: 120,125,147

bioavailability: 121

chemical form: 13,36,58,121

content in incinerable wastes: 36,58,154,197

emissions: 13,26,34,35,36,121,153, 154,198

limitations: 13,23,33,35,121 ,122,124,147

scrubbers: 12,120

volubility: 121

volatilization: 58,120,149

microlayer: 12,16,114,145,150,151 ,161,163,164,165

Minnesota hazardous waste study: 69,72,74

mobile incinerators: 55,56,61,121,174

molten glass: 88

molten salt: 88

monitoring and sampling: 112,128,161,168,175, 176,

179,181,182,184,193

National Marine Fisheries Service: 162,185

National Oceanic and Atmospheric Administration:

182,183

need for ocean incineration: see ocean incineration

Netherlands: 17,18,62,194,197,198,200

neutralization

of acid gases: 57,114,123

of dumped acid waste: 12,151

of scrubber effluent: 99,152

New Jersey hazardous waste studies: 71,72,74

New York Bight: 146,148

nonhalogenated solvents: 57,58,59,65,81

normal stack emissions, see emissions

North Atlantic Incineration Site: see ocean incineration

North Sea: 12,16,17,107,143,151 ,179,180,182,

193-199

Norway: 197,201

ocean dumping: 4,6,12,40,148,149,151, 179,193-195

Ocean Dumping Regulations: 43,44,45,175

ocean-incinerable waste: 9,43,55,58,66,70

characteristics of: 5,55-59,109

geographic distribution of waste generation: 66,

68,69

versus solids and sludges: 12,14,48,55,64,65,68,

69,70,75

ocean incineration

capacity and demand: 15,75,107

companies: see individual names

comparison of technologies: 110

cost to generators: 13,43, 167

design features or standards: 108,115,193

type I and type II: 108,113

interim status: 4,18,19,21,22,194

liquid injection technology: 55,93,107

market: 21,48,167,193

need for: 4,10,22,41,45,75,76, 129

past burns: 16,61,120,161,179-185

permit length and renewal provisions: 24,40,50

permit types: 179,182

quantities incinerated: 179-182,195-197

scale of program: 21-25

site designation: 8,12,38,49,66,175,193

Gulf of Mexico: 49,162,179,185,186

North Atlantic: 49,134,162,182,185,186

other possible sites: 185, 195
222 . Ocean Incineration: Its Role in Managing Hazardous Waste

statutory authority to regulate: 6,38,40

vessels: see individual names

Ocean Incineration Research Strategy: see EPA

Ocean Incineration Regulation: see EPA

oils: see waste oils

onsite vs. offsite

incineration: 16,101,166,168

other management technologies: 66,71,72,23,168

organic liquids: 59,65,81

Oslo Convention/Commission: 17,193,194,195,

197,198

oxidative ultraviolet light: 89

parent compounds: see POHCs

particulate emissions/material: 12,33,58,120,125,127

environmental performance standard: 13,122,123,

124,147

past burns: see ocean incineration

PCBs: 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: 61,122,126,200

permits: see ocean incineration

persistence: 60,61,140,163

PICs: 12,14,26,35,1 19,125,127,146,153,187

plankton: 161,163-165,181

plasma arc: 88

plume: see emissions

POHCs (principal organic hazardous constituents):

34,119,127,145

pollution control devices, effluents: see scrubbers

polychlorinated biphenyls: see PCBs

polychlorinated terphenyls: see PCTs

Port and Tanker Safety Act: 173

Port and Waterways Safety Act: 173

port facilities and infrastructure: 66,108,109,167

port selection: 38

principal organic hazardous constituents: see

POHCs

products of incomplete combustion: see PICs

public concerns and involvement: 7,27,41,42,168

pyrolysis: 88,93,96,98

RCRA: see Resource Conservation and Recovery

Act

recovery and recycling: see waste recovery and

recycling

reduction: see waste reduction

residence time: 36,102,103,115,120,126

Resource Conservation and Recovery Act (RCRA):

40,46,56,63,120,121, 122,173,174

amendments: 3,10, 19,44,46,48,60,67,73,74,76,

82,83,84,85,121

classification of hazardous waste: 56,76

waste codes: 57,65

risks: see comparison of land-based and ocean incineration

rotary cup: see atomization

rotary kiln: see land-based incineration

Science Advisory Board: 12,14,34,37,120,133,142,

146,161,164,184,186

scrubbers: 98,99,101,149,193

capacity limitations: 15,57,122

removal of combustion products: 12,26,57,120,

123,124,127

waste (effluent or sludge): 11,15,58,63,99,114,

121,127,151,152,153, 193

SeaBurn, Inc.: 108,109,111,112,113, 128

seawater buffering capacity: see buffering capacity

seawater scrubbers: 13,108,114,128,145

secondary chambers: 36,93

Shell Chemical Co.: 179,197

shiprider: 37,41,129,168

site designation: see ocean incineration

sludge wastes: see liquid incinerable wastes or

scrubbers

small quantity generators: 72,76

solid wastes: see liquid incinerable wastes

solvent recovery: 85,87

Southern California Bight: 146,148

Spain: 197

spills: 14,15,111,113,133,134, 152,160,162,184

cleanup: 14,15,163

rates: 136,137

sizes: 138

standards: see acid gases, CE, DE, DRE, or particulate emissions

mass emission concentration or rate standard: 34

starved air incineration: 93

statutory authority: see ocean incineration

steam nozzle: see atomization

supercritical fluid extraction: 87

supercritical water reactor: 88

Superfund: see CERCLA

surface impoundment: 9,81,83,127

surface microlayer: see microlayer

Sweden: 17,197,201

Switzerland: 197,201

Tacoma Boatbuilding, Inc.: 8,25,108,182

tamper-proof or tamper-resistant devices: 128,129,

168

tank containers: see intermodal

TCDD: see dioxin

temperature requirements: 126,128

tetrachlorodibenzo-p-dioxin (TCDD): see dioxin

tetrachlorodibenzofurans (TCDF): see dibenzofurans
Index . 223

thermal destruction technologies (also see boilers

and furnaces): 84,88,

thin film evaporation: 87

total destruction efficiency (TDE): 34,120

Toxic Substances Control Act (TSCA): 40,41,60,

62,63,101,124,126,173, 174,184

toxicity of emissions: see emissions

transfer, handling, and storage: 139,144,152,153

transportation of hazardous waste: see hazardous

waste

trial burn requirements: 123,126,128

type I or type 11 vessel: see ocean incineration

unburned waste (also see POHCs): 12,119,127,

145,153

underground injection: 9,57,81,83,127,187

United Kingdom: 18,197,198,201

upsets (malfunctions) or upset conditions: 35,125,

127,133,136,142

U.S. Coast Guard: see Coast Guard

vessel construction and design standards: see ocean

incineration

vessels: see individual names

Vesta: 107,108,196,197

volatilization: see metals

Vulcanus 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, 128

waste end tax: 44

waste limitations: see metals

Waste Management, Inc.: see Chemical Waste

Management, Inc.

waste oils: 58,59,81,84

quantity: 65,66

recovery and recycling: 58,86

regulation 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 1,76,86

water content: 55,109,140

water quality criteria: see marine water quality

criteria

Westat survey: 63,72,73,100

wet-air oxidation: 98