C-suite executives are still scrambling to develop compensatory strategies for getting hazmat offsite and incinerated within mandated RCRA timeframes. And so are their lieutenants: the compliance officers, operations managers, and EHS professionals charged with the tactical nitty-gritty of getting the job done efficiently, safely, and legally.

This blog entry reviews the problem and discusses some possible workarounds. Q&As include:

1. What is the current magnitude of the incinerator shortage problem?
2. Why does the incinerator shortage problem persist?
3. How can you reduce the amount of waste requiring incineration?
4. How can consolidating waste streams lessen the need for incineration?
5. How can conservation lessen the need for incineration?
6. How can recycling lessen the need for incineration?
7. How can fuel-blending lessen the need for incineration?
8. How can landspreading lessen the need for incineration?
9. What is EPA guidance concerning the shortage of RCRA-permitted incinerator facilities?
10. How should you document difficulties caused by the incinerator shortage?
11. How can software help you manage the RCRA-permitted incinerator shortage?

1. What is the current magnitude of the incinerator shortage problem?

All indications are that the majority of hazardous waste incinerator facilities remain backlogged for several months. Some are telling prospective customers that they cannot approve or accept materials for incineration until 60 to 90 days from the initial date of the query.

2. Why does the incinerator shortage problem persist?

Like many current market distortions, the shortage of RCRA-permitted incinerator facilities is traceable to post-pandemic economics. Consider:

• As are most companies, incinerator facilities are coping with labor and transportation shortages.
• Chronic supply-chain woes make getting parts for incinerator repair & maintenance (e.g. rebricking) difficult, exacerbating downtime.
• Recent severe weather has been causing shutdowns for unscheduled maintenance.
• A post-pandemic rebound in manufacturing has increased the amount of hazardous waste that needs to be incinerated.

Along with these transient factors is the enduring business case for consolidation among small players. Companies merge to become more viable and significant in their marketplace, meaning fewer of them will be overall. RCRA-permitted hazardous waste incinerators are no different, which presages fewer choices for generators seeking hazmat incineration.

3. How can you reduce the amount of waste that requires incineration?

Herein we discuss three strategies:

• Waste stream consolidation (See Q.4)
• Conservation (See Q.5)
• Recycling (See Q.6)
• Fuel blending (See Q.7)
• Landspreading (See Q.8)

4. How can consolidating waste streams lessen the need for incineration?

Mixing compatible waste materials into larger shipping containers reduce the number that you need to ship. Not only does this bring down your handling and transportation costs, it effectively reduces the number of containers that need to be stored and queued for incineration. There are two caveats, however:

• Mixing one kind of waste randomly with another can generate dangerous chemical reactions. Proceed cautiously.
• If you mix two pounds of nonhazardous waste with two pounds of hazardous one, you wind up with four pounds of hazardous waste in need of incineration—effectively doubling your troubles.

5. How can conservation lessen the need for incineration?

Hazardous waste can be a leftover virgin product that is considered a listed or characteristic material by the EPA. And while it might sound simple to advise “buy less so you can throw away less,” corporate silos often make this difficult.

For example, if your waste managers are bonused to minimize disposal costs, but your purchasing people get rewarded for having more than enough chemicals at-the-ready for production spikes, then your teams are working across purposes.

For this reason, conversations about reducing chemical waste have to include stakeholders across all departments, emphasizing its comprehensive benefits, so that everyone understands its potential contribution to the corporate bottom line—and their respective bonuses.

Of course, adding to your challenge is that anything that sounds like just-in-time (JIT) inventory management is nowadays a hard sell. Post-pandemic supply-chain snafus encourage copious stockpiling.

6. How can recycling lessen the need for incineration?

Aside from the eco-friendly arguments for recycling, there is a solid economic case for such efforts—and even more so as the incinerator shortage nowadays makes lingering hazmat a potent onsite liability. Consider:

Industrial solvents such as lacquer thinners, acetones, and chlorides can be processed to render up to 80 percent of their volume into reusable products, which can then be blended with their virgin counterparts (or other fuels) for reuse at your facility.

By so doing, you can significantly reduce your need for virgin solvent while decreasing your hazmat storage needs at the same time.

In the relatively rare case wherein a recycled solvent cannot be reused, some companies will broker the recovered product on your behalf, so that you can still realize significant savings relative to the cost of traditional hazardous waste disposal.

7. How can fuel-blending lessen the need for incineration?

One way to decrease the amount of hazardous material needing incineration is by blending its retrievable components into fuel.

For example, consider any post-manufacture cleansing process that employs acetone. It will yield a hazardous waste containing the spent acetone along with the removed solute (e.g. residual chrome or cadmium from electroplating).

Instead of being stored and queued for incineration, the hazardous waste can be distilled to recover the acetone, which can subsequently be reused for the same process or something similar.

While the thermal potency of the recovered acetone will be weaker than its virgin counterpart, it will nonetheless burn efficiently when mixed with other fuels (e.g. gasoline), yielding a lower-cost “blended fuel” that can be used for one or another industrial process.

8. How can landspreading lessen the need for incineration?

Although it might seem counterintuitive, instead of incineration, many wastes from industrial and manufacturing activities are recoverable and can be added to fields for farming benefits or ecological improvements. For example:

• Many sludges and byproducts from industrial and mining processes contain from 45 to 80 percent organic matter that can beneficially stimulate biological activity in the soil.
• Some of these sludges and byproducts are also rich in calcium, which can make soils less acidic.
• Composted sludge helps maintain humus in the soil, thereby aiding water retention and fighting soil erosion.

However, be mindful that in most jurisdictions, landspreading requires a preliminary study to determine if there is any agricultural benefit from the waste under consideration, make sure it is environmentally harmlessness, and assess the impact of adding it to the soil.

9. What is EPA guidance concerning the shortage of RCRA-permitted incinerator facilities?

Per EPA guidance (PDF), as a hazardous waste generator, you can request a 30-day timeline extension from your local implementing authority for “unforeseen, temporary, and uncontrollable circumstances.” These extensions might be renewable, depending on the circumstances. The local implementing authority is probably your state environmental agency, which has the power to accept or reject your extension request. Be prepared to present proof that you cannot get your hazmat shipped and burned (See Q.10).

10. How should you document difficulties caused by the incinerator shortage?

Although you might start by telephoning your state environmental agency, remember that telephone calls are not adequately documentable. You need additionally to write to the agency with such information as:

• Dates, quantities, and descriptions of your hazardous waste
• Your efforts to maintain safe hazmat storage as you try to find an available hazardous waste incinerator
• Records of correspondence with RCRA-permitted incinerator facilities that you have tried to engage
• Other options you are considering and about which you are seeking guidance (see Q.3)

11. How can software help you manage the RCRA-permitted incinerator shortage?

In the best of times, the comprehensive management of hazardous waste requires communication and coordination among a hierarchy of employees, beginning with C-suite and including other executives and managers charged with overseeing regulatory compliance and EHS concerns.

The ongoing shortage of RCRA-permitted incinerators intensifies this requirement. You need real-time data regarding how much hazardous waste you are generating, how it is accumulating, and when and where it is being queued for deferred disposal.

This cannot be done with texting, emails, conference calls, and ad hoc meetings. You need a comprehensive software solution that centralizes such dynamic information so that you can track and react to it before it becomes problematic not only as an operational issue but also as a legal liability.

In that regard, we would appreciate an opportunity to tell you about the PegEx Platform—designed and developed exclusively for hazardous waste management by people in the hazardous waste business.

Request a FREE demo

Thank you for reading our blog!