Market conditions and government proscriptions are together reducing the number of RCRA-permitted hazardous waste incinerators available to help you with your hazardous waste disposal. There are several different reasons for this shortage, which we will discuss in a moment, along with some answers to how you can resolve this problem as a hazardous waste generator.
Is there currently a shortage of RCRA-permitted hazardous waste incinerators?
The volatile landscape across the hazardous waste disposal market is generating some uncertainty about whether nationwide incinerator capacity will remain adequate to meet demand. LQGs and SQGs are already experiencing slowdowns in hazardous waste incineration.
The great majority of hazardous waste incinerator facilities are currently backlogged for several months, and some are telling prospective customers that they will not approve or accept materials needing incineration for 60 to 90 days from the date of the query.
Why is there a decreasing number of RCRA-permitted hazardous waste incinerators?
There is a solid business case for consolidation among small players in any industry, and RCRA-permitted incinerator companies are no different.
Companies merge to become larger and more viable entities in their marketplace. But that means fewer entities overall. And in the case of RCRA-permitted hazardous waste incinerators, it portends fewer options for businesses that require hazardous waste disposal services of the incendiary sort.
Exacerbating the declining numbers of hazardous waste incinerators are escalating federal regulations, permit denials, statutory limits on landfills, and stricter fire codes. For example, when regulators rescind storage permits, it results in material gluts of hazmat that need immediate processing and incineration—swelling demand.
Facility downtime for repair and maintenance (e.g., incinerator rebricking) also lowers supply in the face of this increasing demand. And then there are those economic pandemic-driven labor issues. Among them:
- Like most companies, RCRA-permitted incinerator facilities are coping with labor, transportation, and parts (supply chain) shortages.
- Severe weather in the southern U.S. has caused shutdowns and consequent downtime for unscheduled maintenance.
- Increased manufacturing (after the pandemic) has increased nationwide amounts of hazmat in need of incineration
How does the hazardous waste incinerator shortage affect hazmat generators?
The shortage of hazardous waste incinerator capacity is causing many fuel-blend or solvent-based waste streams to back up. This presents a problem for hazardous waste generators relative to the time restrictions set by the RCRA for onsite hazardous waste storage.
These are by generator category:
- A VSQG can store up to 13,227 lbs. of hazardous waste onsite for up to 180 days without a storage facility permit; or up to 270 days if the waste must be transported more than 200 miles for storage, treatment, disposal, or recycling.
- An SQG can hold no more than 13,200 lbs. of hazardous waste onsite at any one time.
- An LQG can accumulate hazardous waste on-site for up to 90 days in specified units without obtaining a storage permit or interim status.
How can you protect yourself against the shortage of hazardous waste incinerators?
- Keep close tabs on your hazardous waste volumes so that you know how much you have onsite at any one time and how quickly that amount is increasing.
- Don’t procrastinate to schedule hazardous waste pickups. Schedule them at closer intervals; it’s easier to dispose of smaller rather than larger quantities.
- Investigate alternatives to incineration such as fuel blending (see 6) and recycling (see 7).
- Keep accurate records (see 5).
How should you document difficulties relative to the shortage of hazardous waste incinerators?
When it comes to the EPA, you’re much better off seeking permission now than pleading for forgiveness later. (Pleading requires lawyers, time, and money: not good.)
That said, if you’re crowding the RCRA hazmat-storage time limits because you can’t get the stuff burnt, then you would do well to contact your EPA regional office and ask for their guidance and wisdom about how to manage things. (You should also call us for expert advice.)
Don’t just ring them up. Although your call is undoubtedly “important to us,” it’s not adequately documentable in the event things go south for you. Besides calling, we would suggest a nice polite letter that documents your efforts toward compliance, which should reference:
- Dates, quantities, and descriptions of your hazardous waste
- Your Herculean efforts to maintain safe hazmat storage as you try to find an available hazardous waste incinerator (Again, call us.)
- Records of correspondence with hazardous waste incinerators that you’ve tried to employ
- Other disposal options you’re considering and about which you’re seeking guidance (see 6)
Once your languishing hazmat is on its way to a hazardous waste incinerator, we also would recommend notifying your EPA regional office with the details so that they don’t feel compelled to visit and inspect your premises: they’ll know the stuff has gone to the inferno. (Move along folks…nothing to see here.)
What is fuel blending?
You’re likely familiar with the idea of fuel-blending from experience at your local gasoline pump. For example, you find so-called E-10 almost everywhere, which is ten percent ethanol. E-85 is 85 percent ethanol. B-2 is five percent biodiesel. There are others—and they are known as “on-spec” for meeting the purity and proportional requirements specified by the EPA.
What does this have to do with hazardous waste disposal?
One way to lessen the amount of hazmat you need to store is to recycle the valuable constituents of such wastes for reuse. E.g., blend them into fuel. Beyond the obvious economic benefit, recycling mitigates damage to the ecology by reducing the number of materials requiring hazardous waste disposal; and fuel-blending has the added benefit of reducing fossil fuel consumption.
For example, a post-manufacture cleansing process that uses acetone will yield a hazardous waste that contains the spent acetone along with the solute it removed (e.g. electroplating residues such as chrome or cadmium). Recovering the acetone by distillation and using it again for the same process (or something akin) is a simple case of recycling for energy recovery.
Although the thermal energy of the acetone cannot be adequately salvaged in isolation, it burns more efficiently when mixed with other fuels (e.g., gasoline); and the combination can then be used to power one or another industrial process.
How can recycling help?
Saturated lacquer-thinners, acetones, chlorides, and other industrial solvents can be processed to render a percentage of their bulk into a reusable product—typically as much as 80 percent. In the simplest scenario, these are returned to your facility for re-use in combination with their more-expensive virgin counterparts.
Thereby, you can realize savings across the entirety of your operation by reducing your need for virgin solvent by 80 percent, commensurately decreasing your hazardous waste storage needs.
Or another way to look at it: if you’re an LQG disposing of 1 million gallons of spent industrial solvent per month, recycling that waste so that you can reuse 80 percent of it will effectively cut your hazardous-waste stream to only 200 thousand gallons.
In relatively rare cases where recycled solvents cannot be reused, there are hazardous waste management companies that can broker the recovered product for you. Thus, you still realize a monetary benefit relative to traditional hazardous waste disposal costs.
What’s the upshot?
Pardon our French. But enforcing rules is the raison d’être for bureaucracies, and the EPA is a paradigm case. As such, it’s unlikely that EPA officialdom is going to make ad hoc exceptions on the fly to accommodate a national shortage of hazardous waste incinerators.
Bureaucracies don’t work that way.
Instead, they’ll enforce the rules until reality catches up with them, by which time you’ll have been exposed to the slings and arrows of outrageous fortune, which can include fines, sanctions, lawyers, bad publicity, and—above all—copious amounts of money.
Don’t let it happen.
At Hazardous Waste Experts, providing simple, affordable, sustainable solutions to hazmat challenges is our raison d’être. We’re a nationwide hazardous waste management provider with a 20+ year legacy of assessing how businesses generate hazardous waste, developing ways to reduce waste streams, and thereby reducing your need for hazmat storage.
Get expert advice today—or call us at 800-936-2311.
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