&EPA
               United States    . "  Solid Waste and
               Environmental Protection  Emergency Response
               Agency          (5305)
                          EPA530-D-94-OD1
                              May 1994
RCRA Waste
Minimization
National Plan
               DRAFT
                      /T~V Recycled/Recyclable
                         O Printed on paper that contains at
                      _j(~/ least 50% post-consumer recycled fiber

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         Th* Draft RCRA Waste Minimization National Plan

BACKGROUND

     The United States  Environmental Protection Agency (EPA)  has
devoted much of its efforts  in the past to the treatment and
clean-up of pollutants  after they are generated,  and,  in fact.
great strides have been made in environmental protection over the
past 20 years.  However,  end-of-pipe controls alone are not the
answer to the important environmental issues today facing the
United States.

     In 1991, approximately  290 million tons of hazardous waste1
was generated in the United  States,  and approximately  3.4 billion
pounds of toxic chemicals was released into the environment.
This Administration and EPA  are committed  to encouraging
prevention of pollution at the source whenever possible,  and
therefore, to reducing  the amount of hazardous waste generated  in
the first place.  Administrator Browner said in her 1993  Earth
Day statement that "this Administration is committed to making
pollution prevention the guiding principle of all  our
environmental efforts."  This Draft  RCRA Waste Minimization
National Plan is a reflection of that6*'commitment.   This plan  is
intended to be the vehicle to develop  a sound and  sensible
national policy for hazardous waste  management that places our
highest priority on source reduction followed by recycling.

     The Resource Conservation and Recovery Act (RCRA), as
amended by the Hazardous and  Solid Waste Amendments of 1984
(HSWA), emphasizes a national  policy that  focuses on source
reduction as the highest priority.  With the passage of HSWA,
congress specifically declared  that the reduction or elimination
of hazardous waste generation  at the source should take priority
over management of waste after  it is generated.  In particular,
section 1003(b), 42 U.S.C. 6902(b), of RCRA declares it to be the
national policy of the United  states that,  wherever feasible,  the
generation of hazardous waste  is to be reduced or eliminated as
expeditiously as possible.  Waste that is nevertheless  generated
should be recycled, treated,   stored, or disposed of so  as to
diminish the present and future threat to human health  and the
environment.

     In 1990, Congress further confirmed the key role of
pollution prevention in the nation's environmental protection
scheme, by passing the Pollution Prevention Act.  In section
       Based on 1991  Biennial Report Data, U.-S. EPA

       Based on "1991 Toxics Release Inventory", United States
Environmental Protection Agency,  EPA 745-R-93-003, May, 1993.

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6602(b) of this law, 42 U.S'.C.  I3101(b), Congress stated  that  the
national policy of the United States  is, first, to prevent  or
reduce pollution at the source  whenever feasible; second,
pollution that cannot be prevented should be recycled  in  an
environmentally safe manner, whenever feasible; third, pollution
that cannot be prevented or recycled  should be treated in an
environmentally safe manner whenever  feasible; and, finally,
disposal or other release into  the environment should  be  employed
only as a last resort and should be conducted in an
environmentally safe manner.  Thus, Congress essentially  codified
as law the hierarchy of management options that mirror those
followed by EPA's waste management programs over the past fifteen
years, i.e., prevention first,  then environmentally sound
recycling, treatment, and disposal.

     "Waste Minimization" is the term used by Congress in the
Resource Conservation and Recovery Act (RCRA).  During a  series
of Roundtable discussions held  by EPA on waste minimization and
combustion, a number of.stakeholders  recommended that  EPA not use
the term "waste minimization,"  but instead suggested that the
Agency focus on pollution prevention.  Part of the concern
expressed was that reductions in toxicity and volume brought
about by treatment may be argued to constitute waste
minimization.   These commenters believe that this is
inconsistent with EPA's focus on pollution prevention.

     We are sympathetic with these commenters' concerns.
However, EPA defined "waste minimization" in its Guidance to
Hazardous Waste Generators on the Elements of a Waste
Minimization Program, (58 Federal Register 31113 - 31120, May 28,
1993) to include only source reduction and environmentally  sound
recycling.  In that guidance, EPA also expressed the view that
recycling activities closely resembling conventional waste
treatment activities (such as burning for energy recovery)  do not
constitute waste minimization and that treatment for the purposes
of destruction or disposal is not part of waste minimization, but
is, rather, an activity that occurs after the opportunities for
source reduction, followed by recycling been pursued.  Therefore,
reductions in volume brought about by treatment do not constitute
waste minimization.  The term source  reduction used here  is
defined in the Pollution Prevention Act  to  mean  any  practice
which reduces the amount of any hazardous substance,  pollutant or
contaminant entering any waste  stream or otherwise released into
the environment (including fugitive emissions) prior to
recycling, treatment, or disposal; and reduces the hazards to
public health and the environment associated with the  release of
such substances, pollutants, or contaminants.

     Considering the limits of  definition of waste minimization,
       (Pub. L. 101-508, 42 U.S.C.  13101,  et seq.)

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the Agency, specifically solicits comments on whether the term
"waste minimization"  should  be changed as part of this plan.
Until we receive  comments  on this issue,  we will use this term in
this document.

    DRAFT HAZARDOUS WASTE MINIMIZATION AND COMBUSTION STRATEGY

     On May 18, 1593, EPA  Administrator Carol M.  Browner
announced the overall Draft  strategy  on Hazardous Waste
Minimization and  Combustion  (also referred to as the Draft
Strategy).  The Draft Strategy was designed,  among other things,
to reduce the amount  of hazardous waste generated in this country
and indicated that one  of  its  primary goals was  to establish  a
strong preference for source reduction over waste management, and
to better address public participation in setting a national
source reduction  agenda.   The Draft RCRA Waste Minimization
National Plan (RWMNP) is the primary  vehicle for addressing
source reduction  under  EPA's overall  1993  Draft  Hazardous Waste
Minimization and  Combustion  Strategy.

     To facilitate public  dialogue on both waste minimization and
combustion, EPA has held a series of  Roundtables,  where  public
interest groups,  citizens, industry,  state and Federal
regulators, and technical  experts in  pollution prevention were
invited to discuss a  broad range  of issues.   Some key messages
related to waste  minimization  came out  of  these Roundtable
discussions.  It  is EPA's  intention to  use the messages  that were
heard in these Roundtables as  building  blocks for our RCRA Waste
Minimization National Plan.  These messages  include:

     •    Emphasize the  multi-media aspects of pollution
          prevention. Focus  on pollution prevention in all
          aspects of waste management,  and assure that we really
          get source reduction, rather than a shifting of
          pollutants from  one media to another.

     •    Reinforce the waste management hierarchy that has been
          stated  in RCRA, the Pollution Prevention Act,, and
          reiterated in Administrator Browner's memo on EPA's
          Pollution Prevention Policy.  Demonstrate a strong
          preference for source reduction by bold action,
       Among the other goals  of  the  overall  1993 Draft Strategy
on Hazardous Waste Minimization and Combustion are:  strengthening
federal controls governing hazardous waste incinerators  and
boilers and industrial furnaces (BIFs); enhancing  public
participation at the time of and prior to permitting a facility;
full risk assessments at each incineration/combustion facility to
be permitted, and taking that assessment- into consideration at
the time of permitting; and ensuring that regulatory and permit
requirements are vigorously enforced.

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          including resource shifts from end-of-pipe activities
          to source reduction initiatives.

     •    Allow flexibility to both States and industry to
          undertake efforts that will achieve real reductions in
          pollution and generation of wastes.

     •    Prioritize all efforts in pollution prevention based on
          the highest risks.

     •    Establish expectations, accountability, and recognition
          of continuous improvement in both the private and
          public sectors.  Develop objective, measurable,
          indicators of success.

     •    Empower the public.  Involve the public more
          effectively in shaping EPA's pollution prevention
          policies.    -

SUMMARY OF RCRA WASTE MINIMIZATION NATIONAL PLAN

     This document delineates EPA's initial thoughts on a RCRA
Waste Minimization National Plan for all RCRA hazardous wastes.
(The first phase of the Plan will focus on combusted wastes; the
second phase will look at all RCRA hazardous wastes).  EPA
emphasizes that this document is a draft that will be subject to
a broad and open national review and discussion.  After all
viewpoints and ideas are heard and considered, EPA will shape the
final RCRA Waste Minimization National Plan.  There are six key
components to this Draft Waste Minimization National Plan, and
they are outlined briefly below. (See Exhibit 1.)

     SUMMARY OF THE KEY COMPONENTS OF THE PLAN

Sstablish Goals - In launching the Draft RCRA Waste Minimization
National Plan, EPA will be focusing on a number of specific
goals, including reducing the amount and toxicity of hazardous
waste that is generated, particularly when such reductions
benefit more than one environmental medium.  EPA will achieve
these goals through a variety of voluntary and regulatory
programs.  EPA's near-term goal is, through implementation of
this plan, to achieve, nationally, a X% reduction (through source
reduction and recycling) of highly toxic and persistent hazardous
wastes that are currently combusted, by the year 1997.  Over the
longer-term, EPA's target is to achieve, nationally, an overall
reduction of Y%  (again, through source reduction and/or
recycling) of all RCRA hazardous waste, by the year 2000.

     EPA is seeking comments on whether a numeric goal is
feasible, what a numeric reduction goal should be based on;
whether it is necessary to have two (or three) numeric goals —
one relating to the reductions in the quantity of waste

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 generated/ another relating to reductions  in the quantity of
 hazardous waste requiring treatment and disposal,  (and possible a
 third to reflect a reduction in toxicity of the wastes
 generated); the specific number (s) to choose as a goal, and what
 critical factors will influence achieving this stated goal   EPA
 believes that a stated goal (or goals) is necessary and will
 serve as a focal point for all who have a role to play to adjust
 their level of commitment.                        *  y    aajust

 Set Priorities for Source Reduction and Recycling Pff^+g « EPA
 ™Ln??*?»d jnitially on She "multi-media hazard and exposure
 potential" of as-generated wastes.  In the first phase of this
 Plan, EPA is focusing on wastestreams that are typically
 combusted that potentially contain metals and/or halogens.  Bv
 using this approach,  we will promote pollution prevention for the
 ?For S™a^lr-it°XiC;v,?ersistent' and/or ^accumulative wastes.
 (For more details on this process, see the section "Components of
 the Plan/Setting Priorities for Source Reduction and Recycling.")

      To effectively reduce wastes, EPA will,  ultimately,  focus on
 the processes that generate these wastes.   It is by focusing on
 the industrial process that we  are able to identify true  source
 TSfn?^011'  ^1CS^ use Deduction,  and recycling  opportunities,  and-
 identify multi-media  impacts and  benefits.  By  identifying
 industrial processes  that generate high-hazard  wastes, there  is
 potential to reduce not only the  generation of  hazardous wastes,
 but also to reduce the .risk of  future  releases  of toxic
 constituents to all environmental  media, and the risk of
 subsequent exposure to occupational workers, the general public
 and the environment.   Therefore, although the focus  of this plan

                                                           has
Identify/Evaluate Source Reduction and Recycling Opportunity *« -
™.wi11 rely on the Office of  Research and Development, the
Office of Solid Waste, technical assistance centers, and
universities to help identify source reduction and/or recycling
opportunities for these industrial processes, and evaluate the
technical and economic feasibility of such opportunities, as well
as any cross-media shifts that  are of potential concern.

Array Mechanisms for Effecting  Source Reduction and Recycling -
There are approximately 22,000  large quantity generators of
hazardous waste,  and approximately  175,000  small quantity
hazardous waste generators.  There is great diversity among these
generators — they span a wide range of industrial sectors,  are


       Based on  1991  Biennial Report  Data, U.S. EPA.  (Large
quantity generators being defined as those facilities that  report
that they have generated more than 1,000  kilograms  of hazardous
waste in one or more months in a given year.)

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of varying size and technological  sophistication,  and  have/have
not demonstrated an intent to prevent pollution.
     ,, recognizes that many mechanisms may be effective  in
achieving the goal of preventing pollution, ranging  from
regulatory to non-regulatory in nature, and that no  one mechanism
alone will suffice to achieve maximum pollution prevention.   (For
a more detailed discussion of mechanisms see below,  Exhibit 3 and
"Components of the Plan/Mechanisms to Foster Source  Reduction and
Recycling.")

     EPA will array those mechanisms that would most effectively
help achieve reductions in these wastestreams and foster source
reduction and/or recycling within the industrial processes.  EPA
will then encourage all stakeholders to identify the roles they
can play in further developing and implementing these mechanisms.

Implement Mechanisms - EPA intends to serve primarily as an
initiator and facilitator of this Draft RCRA Waste Minimization
National Plan by setting general goals, reducing barriers, and
better enabling States, industry, and the public to  achieve
pollution prevention.  EPA seeks comments from all stakeholders
on their views of the roles that States, EPA, industry, and the
public should play in implementation of this plan.   (See the
Section "Roles of the Federal Government, States, Industry,
Technical Assistance Centers, and the Public" for a more detailed
discussion of roles.)

     EPA believes it is absolutely essential to recognize and act
in concert with the diversity and proactive stance of many States
and industry.  Our Draft RCRA Waste Minimization National Plan
will need to afford flexibility to both the States and industry
to continue their proactive efforts,  and to allow them to
continue to take true ownership of the challenge to prevent
pollution.  Thus, in implementing this Plan, EPA will build on
existing State requirements,  and attempt to avoid and reduce,  to
the extent possible, any unnecessary redundancies or
inconsistencies.  States will play a key role in any meaningful
implementation of this Plan.   At the same time,  EPA intends for
the Draft RCRA Waste Minimization National Plan to encourage
those states and industries that have not already begun to
explore avenues for achieving source reduction and recycling,  to
do so.

Measure Progress Being Made - EPA will develop a definition of
success and a method to measure progress in achieving that
success.  Open discussion with all stakeholders will be
essential.  Significant effort is already underway,  with pilot
projects with four States, to study methods and data used to
measure source reduction and recycling.   Such efforts will help
the Agency develop a methodology for measuring success of the
Plan.  It will be more difficult to develop a methodology that

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EXHIBIT 1
            SUMMARY OF THE KEY COMPONENTS OF THE  PLAN
                         ESTABLISH GOALS
 Reduce quantity and toxicity of hazardous waste through source
 reduction and then recycling	
        SET PRIORITIES FOR SOURCE REDUCTION AND RECYCLING
           Rank wastestreams based on multi-media hazard and
           exposure potential, then
           Rank industrial processes based on hazard of
           wastestreams they generate
           Select priorities among industrial sectors,
           processes, wastestreams, and/or constituents
                        IDENTIFY/EVALUATE
           SOURCE REDUCTION AND RECYCLING OPPORTUNITIES
      With the ultimate goal of optimizing sourc* reduction
      above other methods, when feasible.
      Consider:
      o    technical feasibility
      o    economic feasibility
      o    economic impacts
      o	cross-media transfers
  ARRAY MECHANISMS FOR EFFECTING SOURCE REDUCTION AND RECYCLING
            Non-regulatory vs. regulatory mechanisms.
      Consider:
      o    other EPA initiatives that are relevant
           to OSW's stated goals
      o    which option(s) will result in the greatest
           environmental benefits
      o    resource constraints for effective
           outreach/implementation
 	o    our sphere of influence   	
                      IMPLEMENT MECHANISMS
 Employ regulatory development,  guidance,  permitting,  voluntary
 challenge programs, and coordinate with Regions,  States,
 technical assistance centers to both implement and develop
 measures of success.
                   MEASURE PROGRESS BEING MADE

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                                8

looks at reductions in the toxicity of the wastestreams
generated.

     PHASING OF THE PLAN

     There will be both a short-term and longer-term phase of the
Draft RCRA Waste Minimization National Plan, which will be part
of and coordinated with the other elements of EPA's Draft
Hazardous Waste Minimization and Combustion Strategy, as
announced in 1993 and as it further develops.

     In the short-term, EPA will address the source reduction and
recycling of those hazardous wastes that have the potential to be
combusted in either boilers and industrial furnaces (BIFs), or
hazardous waste incinerators, in keeping with the high priority
the Administrator has placed on the overall Draft Hazardous Waste
Minimization and Combustion Strategy.  A Final RCRA Waste
Minimization National Plan for these wastes.will be released in
November of 1994.

     A longer-term effort, which will ensue after November, will
also be initiated, applying much of what we learn and develop
through dialogue with the public and access to additional data,
to address minimization of all RCRA hazardous wastes.  EPA will
take a comprehensive approach to understanding how waste is
generated and managed in this country and the role source
reduction can play as another "mode of management."  EPA believes
that multi-media benefits will result from such an approach.

     Many components of the longer-term effort will derive from
and, therefore, be similar to those in the shorter-term effort.
The details that are presented in this document are a reflection
of the data and analyses that have been performed to date,
specific to wastes that have historically been combusted at
either hazardous waste incinerators or BIFs.  Therefore, the
particular focus of the broader and more longer-term actions have
not yet been identified and are not presented in this document.

     ISSUES FOR DISCUSSION WITH THE PUBLIC

     EPA  is seeking comment on a number of issues related to
these key components of the Plan.  First, EPA is seeking
participation from all stakeholders to define measures of success
and is seeking comments on the advantages and disadvantages of
stating a numeric goal for this national waste minimization plan,
as well as identification of some of the concerns of various
parties in either stating or not stating a numeric goal.  Second,
EPA will  distribute sometime in July, in a separate document, for
review, the methodology that was used to identify those wastes
that have been highlighted for the Plan, and will seek comments
on that methodology.  Third, EPA will want to "ground-truth" the
technical validity of our information (i.e., whether specific

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industrial processes generate  specific high-hazard wastes,
whether identified source  reduction  and recycling opportunities
are feasible, and to what  extent  these opportunities have already
been adopted by  industry).   Fourth,  regulators,  industry, and the
public will be invited to  discuss the  effectiveness of  the  kinds
of mechanisms that are mentioned  below (e.g.,  regulatory  vs.  non-
regulatory approaches, or  a  mix of the two).   EPA will  also seek
input on the portion of the  Plan  to  develop a  voluntary program;
in particular, EPA believes  it is important for  both industry and
the public to share ownership  and participate  in this voluntary
program, and to  help define  incentives for industry to  reduce
wastes.  Finally, EPA will be  seeking  comment  on the best focus
for our more comprehensive long-term phase.

COMPONENTS OF THE PLAH

     SETTING GOALS

     As stated above, the overall  goal of the  Draft RCRA Waste
Minimization National Plan is: (l) to  reduce the amount and
toxicity of hazardous waste  that  is  generated  in this country,
particularly when such reductions  will lead to. multi-media
environmental benefits, (2)  to expedite continual  improvement in
movement towards the top of  the waste  management hierarchy; and
(3) to improve the recycling and management of wastes that  cannot
be reduced in a way that results  in  a  net reduction of
environmental loadings to all media;

          Many States and voluntary  programs associated with EPA
have stated specific quantitative  goals for reductions in
generation of wastes and/or  releases of toxic constituents to the
environment.  This has posed a challenge not only to the
generators, but also to the  initiators of such programs to
establish a baseline from which progress is measured and to
develop equitable methods by which to measure progress.   EPA
recognizes the difficulty of measuring real reductions,  given the
diverse profile of progress amongst  facilities and the
possibility that pollution prevention achieved upstream may not
result in reduction in either toxicity or volume of wastes
downstream.  Therefore, a definition of success for the waste
minimization plan must be carefully developed and stated.
However, EPA believes that a stated numeric goal will serve  as a
focal point for all who have a role to play to adjust their  level
of commitment to achieve this important goal.   It is possible
that rather than stating goals in terms of percentage reductions
in waste,  that EPA could develop  more "quasi-quantitative" goals,
(e.g.,  the number of generators which,  relative to their own
defined baseline generation,  have reduced the quantity and/or
toxicity of their waste by some meaningful percentage, or  who
have investigated and implemented source reduction
opportunities).

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                                10

     SETTING PRIORITIES FOR SOURCE REDUCTION AND RECYCLING

     EPA believes its efforts should be focused in areas
resulting in the greatest multi-media environmental benefits, in
order to obtain the greatest return on investments in
environmental protection.  There are many criteria upon which to
prioritize source reduction and recycling efforts; EPA is
suggesting that those wastes that pose the greatest multi-media
hazard and exposure potential  when generated be the focus of
this Plan.

     Initial Focus on Metals and Haloaenated Oraanics

     EPA will focus initially on wastestreams containing metals
and/or halogens (e.g., chlorine, bromine) in its priority-setting'
for hazardous wastes that are typically.  A number of
participants at the National and Regional Roundtables expressed
particular concern about metals and halogenated organic compounds
in wastes going to combustion units.  EPA's data support the view
that the higher the feed rate of halogens, the greater the mass
emission rate of halogenated organics.  Given that halogenated
organics can often be more of a human health hazard than non-
halogenated compounds, EPA believes it to be appropriate to
minimize emissions of toxic halogenated compounds.

     The second concern relates to the role that metals and
halogenated waste streams play regarding formation of certain
toxic products of incomplete combustion (PICs), most notably
dioxins and furans.  Dioxins and furans can be formed in two
major ways when halogenated waste streams are combusted •— first,
during the combustion process itself and, second, in dry
particulate matter (PM) control systems (e.g., fabric filters and
electrostatic precipitators).  The presence of chlorine (and
other halogens) has an effect on the formation of toxic PICs.
One recent analysis of EPA's dioxin data base indicates that
there is a correlation between chlorine feedrate and dioxin
emissions.  Thus, looking at the source reduction opportunities
for halogenated waste streams can potentially have an impact on
the level of dioxin emissions.

     With respect to metals and PIC formation, certain metals
(e.g., copper) are thought to catalyze the synthesis of dioxin
via enhanced reaction potentials with HCl to form C12.  The  C12
        Wastes with the greatest multi-media hazard and exposure
potential are those that are the most pervasive, toxic, mobile,
persistent, and/or bioaccumulative, considering the air, surface
water, ground water, and soil exposure pathways.  As discussed
below, this assessment is based on the characteristics of the
waste as it is generated; it does not consider actual management
practices, releases, or exposures.

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                                11 "•

then reacts with organics  (probably available  aromatics)  to  form
dioxins.  It is not uncommon to find free C12 in the stack gas at
hazardous waste combustion devices.  Even though catalyzing
metals may not be of as much significance as other  factors  (e.g.,
amount of organic dioxin precursors, temperature, etc.),  the
contribution of metals to PIC formation remains of  some concern.

     EPA also believes there is benefit beyond reducing potential
risks from combustion of these wastes.  By reducing the
generation of these toxic compounds, we should be reducing the
risks from having to manage these wastes in any form.  Metals are
persistent, are not destroyed during combustion, and many
bioaccumulate.  Halogenated organic compounds  have  also been
studied extensively and many are known or suspected to be
carcinogens.  In addition, many solvents containing halogens are
of concern when released to the environment; for example, some
have been associated with ozone depleting atmospheric chemical
reactions, while others,have been found to create special ground-
water contamination problems.  Thus, our focus on metal bearing
and/or halogenated waste streams for our initial source reduction
and recycling efforts could make a significant contribution  to
the reduction in environmental loadings of either metals  or
halogens and translate into other multi-media  benefits, even if
that contribution cannot be precisely quantified at the present
time.

     Overview of Methodology For Setting Prioritie's

     For metal and halogenated wastestreams going to combustion,
EPA has developed a methodology for setting priorities for source
reduction and recycling based on several of the central themes
expressed during the November 1993 National Roundtable
discussions on Waste Minimization and Combustion.   These  themes
included: setting priorities based on risk; adopting a multi-
media approach to promote source reduction and recycling; and
encouraging movement up the waste management hierarchy (with a
clear preference for source reduction).  Additional factors
influencing development of the methodology were: the need to
construct an approach quickly, in keeping with the  ambitious
schedule for the Draft Hazardous Waste Minimization and
Combustion Strategy; the desire to utilize an existing screening
methodology that had undergone peer review; the need to rely upon
readily-available data sources; and the desire to develop a
flexible screening tool that could be readily understood  and
adapted by other users.   (EPA plans to prepare and  submit a
detailed document describing the methpdology for public comment
in July, 1994.)

     EPA's methodology is intended to serve"as an initial step in
an ongoing process of refining priorities for source reduction
and recycling.  While EPA Headquarters can develop  broad national
priorities for source reduction and recycling, EPA  Regions and

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                                12

States are likely to be in a better position to establish
specific priorities based, on their particular environmental
concerns.  These Regional and state concerns could include such
things as: addressing waste generation or releases from
particular industries; reducing risk to particular human and
ecological receptors; ensuring availability of hazardous waste
management capacity; addressing industries or facilities with
compliance problems; protecting valuable natural resources (e.g.,
drinking water aquifers); and promoting environmental justice.
EPA Regions and States may often have access to better data on
waste characteristics, management practices, releases, exposures,
and risks for specific facilities.  In fact, EPA recognizes that
a number of Regions and States are already conducting their own
prioritization efforts for source reduction and recycling.  The
Agency expects to gain from this experience and to complement
these approaches, to the extent possible.

     A number of existing EPA and State pripritization
methodologies were reviewed, and an approach centering on
elements of the Superfund Hazard Ranking System (HRS) was
selected.   This HRS-based approach ranks hazardous wastestreams
based on data on waste quantity, constituent concentrations, and
the human and ecological toxicity of constituents.  The approach
also ranks wastestreams based on the physical/chemical properties
of constituents that influence their potential for fate and
transport via the air, surface water, ground water, and soils
pathways; these properties include mobility, persistence, and
bioaccumulation potential  (i.e., the potential for constituents
to accumulate in plant and animal tissues).  An overview of the
methodology is shown in Exhibit 2.

     Wastestream rankings are used, in turn, to rank industrial
processes  (or sources) based on hazard.  Industrial processes are
often employed by .many facilities within an industrial sector and
can generate multiple hazardous wastestreams (as well as
potentially resulting in direct releases to environmental media).
Consequently, examination of source reduction opportunities
centers  on identifying and modifying these processes.  Examples
of processes/source's resulting in hazardous waste generation
include  manufacturing activities, environmental control
technologies  (such as air scrubbers and wastewater treatment
technologies), clean-up of spills, remediation of hazardous waste
sites, and normal collection of leachate from landfills.  Please
note that this methodology focuses on routinely generated wastes,
excluding one-time wastes  (e.g.,  spills) and remediation wastes.
      7  Although the HRS is used by the Superfund program to rank
 abandoned hazardous waste  sites, parts  of the HRS  (e.g., the
 algorithms used to develop scores  for fate and transport
 potential of constituents  via different pathways)  are also
 applicable to ranking hazardous wastes.            .

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                                13
     By using the HRS-based approach to  focus  initially on  the
multi-media hazard and exposure potential of as-generated wastes,
we will promote pollution prevention for the most pervasive,
toxic, mobile, persistent, and/or bioaccumulative wastes.

     EPA is examining options for expanding the methodology to
further prioritize wastestreams based on waste management
practices, compliance/enforcement history, and releases.  These
options include: prioritizing hazardous  waste  generators  (and
their wastestrearas) based on their reported Toxics Release
Inventory  (TRI) releases and transfers;  prioritizing combustion
facilities (and the wastestreams going to them) based on their
TRI releases or the TRI transfers to them from off site; and
prioritizing combustion facilities (and  wastestreams going  to
them) based on the quantity and/or hazard of wastes received by
them.

     Prioritizing Metal-Bearing Wastestreams Based on Hazard

     In prioritizing wastestreams, EPA utilized the most recent,
comprehensive data available oh the quantities of hazardous waste
generated and managed in the U.S.: the 1991 Biennial Reporting
System (BRS)  data.  Data on constituent  concentrations  in wastes
were derived from two sources: the Hazardous Waste Identification
Project (HWIP) database (which is an updated version of the 1986
"National Survey of Hazardous Waste Generators"), and EPA expert
judgement about whether constituent concentrations in selected
wastes were likely to be "high" or "low."  EPA used the Superfund
Chemical Data Matrix to obtain data on the human and ecological
toxicities and physical/chemical properties of constituents.

     An overview of the prioritization methodology and initial
results is presented in this document only for metal-bearing
combusted wastestreams.  The prioritization process is still
underway for wastestreams containing halogenated organic
constituents; EPA plans to provide these results in the
methodology document to be provided for public comment in July.

     EPA identified "potentially metal-bearing" combusted
wastestreams by first compiling a list of the RCRA hazardous
waste codes that were known to contain significant levels of
metals or that could potentially contain significant levels  of
metals, based on hazardous waste listing determinations, data
from development of land disposal restrictions treatment
standards, and expert judgement.   EPA then selected all
wastestreams from the 1991 BRS database going to combustion  units
and containing one or more of the RCRA hazardous waste codes
identified as potentially containing metals._

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                               14
EXHIBIT 2
     SETTING PRIORITIES FOR SOURCE REDUCTION AND RECYLCINQ
             Rank Wastestreams Based on Multi-Media
             Hazard and Exposure Potential

             Methodology incorporates:

             o    Waste quantity

             o    Constituent concentrations

             o    Human and ecological toxicities of
                  constituents

             o    Physical/chemical properties of
                  constituents affecting their fate and
                  transport in air, surface water,
                  ground water, and soils    	.
             Rank Industrial Processes Based on the
             Hazard of Wastestreams they Generate
             Determine whether Priorities Should Be
             Established  on an Industrial Sector/
             Process, Wastestrearn, and/or Constituent
             Basis                              	

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                                15

     Potentially metal-bearing combusted wastestreams  fell  into
several "wastestreara categories," each requiring a different
ranking approach, based on the current availability of
constituent concentration data:

o    Wastestreams where it was possible to extrapolate detailed
     concentration data from matching wastestreams in  the HWIP
     database  (representing approximately 16 percent by weight of
     potentially metal-bearing combusted waste universe).

o    Wastestreams where expert judgements could be made about
     which constituents were present and whether concentrations
     were likely to be high or low  (approximately 27 percent of
     universe).

o    Wastestreams with highly-variable constituent content and
     concentrations (e.g, wastes that are hazardous due the
     characteristics of- ignitability, corrosivity, and
     reactivity) (approximately 70 percent of universe).

     Rankings were developed for the first two wastestream
categories and then used as the basis for developing preliminary
rankings for industrial processes and constituents, as discussed
below.  The ranking for a wastestream was obtained by  selecting
the highest-scoring constituent/pathway combination among all
constituents and pathways (i.e., individual wastestream hazard
scores were not obtained by summing hazard scores across all
constituents and across all pathways).

     One of the key limitations to EPA/s current approach to '
setting priorities for promotion bf source reduction and
recycling is the lack of data on the constituents present in
hazardous wastestreams and their concentrations.  These data are
critical to implementation of any hazard- or risk-based ranking
methodology.  EPA is currently working to develop additional
constituent data for wastestreams in all three wastestream
categories, with the goal of applying a single wastestream
ranking approach to wastestreams in all three categories.   EPA
invites suggestions on approaches that could be used to obtain
additional constituent data (e.g., EPA and States working in
partnership with treatment,  storage, and disposal facilities to
collect up-to-date constituent data for the wastestreams managed
at these facilities).

     Prioritizing Industrial Processes Based on Hazard

     EPA believes that focusing on the industrial processes  that
generate high-hazard wastes will lead ..not only to reductions in
waste generation, but also to multi-media po'llution prevention
benefits through reductions in releases to air,  ground water,  and
surface water and reductions in human and environmental
exposures.  EPA used data from the 1991 BRS to identify, to  the

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                                16

extent possible, the industrial sectors and processes  (or
sources) generating metals-bearing hazardous wastestreams.

     EPA used the wastestream rankings for the first two
wastestream categories to rank the industries and processes
generating the wastestreams.  This was done by apportioning the
overall hazard score for each wastestream to the individual
industry/process combinations generating it, on a waste quantity
basis.  Hazard rankings of industry/process combinations  were
developed for the first two wastestream categories, and the top-
ranking 50 industry/process combinations from each category were
then merged into a single list of "high-ranking industry/process
combinations."   (See Attachment 1) .  As shown, a variety  of
industries and processes are represented.  These high-ranking
industry/process combinations represent approximately  46  percent
of the total quantity of waste in the two wastestream  categories.
Please note that this list is meant to be illustrative, rather
than definitive, since work is underway to try to merge the three
wa'stestream categories and apply a single ranking methodology.
As a result/ wastestream rankings and industry/process rankings
are likely to change.

     A similar approach to that used to rank industry/process
combinations was used to identify "high-ranking constituents."
The five top-ranking metals from each wastestream category were
merged into a single list.   (See Attachment 2.)  As explained
above, this list 'is meant to be illustrative and rankings are
likely to change.

     These results represent wastes managed both on-site  and off-
site.  EPA expects that there will be. significant differences
between wastes managed on-site and off-site in terms of the
characteristics  of the waste and the industrial sectors and
processes generating the wastes.  For wastes managed off^site,
there may be additional distinctions between wastes going to
commercial and non-commercial  incinerators and boilers and
industrial furnaces  (BIFs).  Th« Agency plans to further  analyze
available data to explore thes« differences.

     Please note that the results presented in Attachments 1 and
2 may change as  a result of ranking additional constituents
 (e.g., halogens) in the wastestreams and in response to comments
on the ranking methodology.  During the next few months,  EPA
plans to refine  its data, ranking methodology, and results.

     EVALUATING/IDENTIFYING SOURCE REDUCTION AND RECYCLING
     OPPORTUNITIES

      EPA's ultimate goal is to prevent high-hazard wastes from
being generated  in the first place, wherever feasible, before
employing any other methods of management.  Therefore, source
reduction opportunities will be identified and evaluated before

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                                17
recycling opportunities.
     For high-ranking  industry/process  combinations,  the Office
of Solid Waste  (OSW) is  developing data to assess the feasibility
of source reduction and  recycling alternatives  in reducing waste
generation.  This data (which  comes primarily from the 1991 BRS
database) includes information on the most prevalent  forms of  the
waste, constituent content, whether many small  quantities and/or
a few large quantities contribute to total quantity,  and reported
management practices and locations by EPA Region  and  state.

     The Office of Research and Development (ORD)  will analyze
the data, evaluate the technical  feasibility of source reduction
and recycling opportunities (e.g.,  the  applicability  and
effectiveness of alternative technologies),  and evaluate the
economic feasibility of  the opportunities (e.g.,  the  engineering
cost and return on investment  of  alternative technologies).  ORD
will then generate technical guidance documents highlighting the
most promising opportunities.   OSW will  work with ORD to evaluate
the economic impacts,  on generators and/or management facilities,
of either reducing or  recycling these wastes.   OSW will  also work
with ORD to identify potential  cross-media shifts  that may result
from source reduction  or recycling opportunities.

     In addition, OSW, ORD, and the Office of Enforcement and
Compliance Assurance (OECA) propose to work with  EPA  Regions,
States, and pollution  prevention  technical  assistance  centers to
identify and/or develop  training  modules  that will help  all
stakeholders identify  source reduction and  recycling
opportunities and will encourage  industry  to adopt these
opportunities, when feasible.         <

     MECHANISMS TO POSTER SOURCE REDUCTION AND RECYCLING

     EPA has identified  a wide variety of mechanisms that can be
used to foster minimization of these wastes.   These mechanisms
can be either regulatory or non-regulatory in nature.   (See
Exhibit 3.)   In developing this Draft RCRA Waste Minimization
National Plan, EPA believes it will be important to have an open
dialogue on the usefulness of  the different mechanisms, focusing
on those mechanisms resulting  in the greatest environmental
gains, and optimizing source reduction and recycling.   EPA will
also want to take advantage of the many successful pollution
prevention programs,  both on the State and Federal level that
have resulted in reductions in pollutants in specific  industrial
sectors.

     Flexibility for States:   Many States have been very
proactive in fostering and/or  requiring pollution  prevention,

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                                 18

 through a variety of mechanisms8.   These States may already have ;
 defined their priorities for source reduction and recycling goals
 and have initiatives underway.                       y<-j.j.ng goais


      For example,  California, with over 1,900 generators of

 S^ani1? ha?ard°US WaStS'  haS ™»erous'mandatory and voluntary
 state and local programs promoting pollution prevention
 including comprehensive facility planning and a voluntary
 *?°i^rable Wafte  Minimization Project,  in which 39 of the
 state's largest generators of combustible waste agreed to reduce
 these wastes by 50 percent,  and actually achieved a 53%
 reduction.   Massachusetts is  implementing a multi-media
            and Permittin<3 Program that incorporates facility'
          pollution prevention goals as a driving factor instate
 of  L^S^t°n reductfons«   Te*as,  generating the latest volume
 of  combustible wastes in the  country and having over iTsoo
 Sr^nn^     waste  9enerators,  also  has a comprehensive facility
 planning  program.   Oregon will be sponsoring its Fourth Annual
 Governor's  Award for  Toxic Use Reduction this  year? and also
     •                           •
     8                    * .            •
™. ,  .Generally,  three major categories of State pollution
£™f^10n  Pr°9rams.activities  can be  identified,  two  being of a
regulatory  nature  (i.e.,  facility planning and pollution
prevention  regulatory integration).

     1) Facility planning:  Within the past  five years,
     approximately 22 states have enacted pollution prevention
     facility planning laws.  Most of these  laws require
     facii^les t° conduct a facility specific review and
     identify particular pollution prevention actions that will
     be pursued.  Some States that don't require plannina
     strongly encourage it.                -»*'..•»

     2) Pollution prevention regulatory integration: about five
     states have enacted laws which integrate pollution
     prevention in some way into their regulatory development,
     permitting, inspection and enforcement programs.  These
     programs are more recently enacted.

     3) Voluntary technical assistance: most States,  plus  many
     counties and cities, provide companies with free and  usually
     confidential technical assistance.  This assistance is
     provided through: telephone hotline assistance,  source
     reduction and  recycling case studies and fact sheets,
     product and equipment information,  training,  on-site
     technical reviews and options analysis.   States respond to
     thousands of requests for assistance per year.   Some  States
     target particular groups  of companies. -  A few State programs
     have been in operation for 10 years.  Most are less than
     five years old.

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                                19

passed its Toxic Use Reduction and Hazardous Waste  Reduction Act
in 1989.   EPA is studying programs  in these and other  states to
explore the tools that are already available to implement  the key
elements of this Draft RCRA Waste Minimization National Plan.

     EPA recognizes that States are  the best judge  of their
priorities, and would expect the States to articulate how  the
goals of this waste minimization plan relate to their already
existing programs, and, wherever feasible and appropriate,
develop source reduction"and recycling strategies* and communicate
how they plan to implement such strategies.

     EPA is also aware of the various relationships that are
established between an industry and  the regulating  State.  EPA
therefore will seek to better enable the States to  effect  source
reduction, followed by recycling through a number of mechanisms.
First, more flexibility will be given to the States to  utilize
existing RCRA grant dollars for the  purposes of source  reduction
and/or recycling/ as deemed appropriate by the State.   More
resources will be designated specifically for initiating source
reduction and recycling activities related to high-hazard
wastestreams and -the industrial processes generating1 them.   (See
Attachment 1.)

     Flexibility for industry:  Many industries have implemented
source reduction and recycling programs and developed plans in a
variety of ways, to fit with their organizational structure and
their plant operations.  EPA recognizes the need for flexibility
in how industry achieves reductions, given the diversity of
industry.  The organizational level  at which pollution prevention.
activities are implemented by industries varies widely.   The
diversity of approaches is apparent  in examining source reduction
and recycling efforts at three organizations: -- Chevron,
Consolidated 'Freightways,  and Squibb Manufacturing Incorporated.

     o    At the corporate level, Chevron instituted the "Save
          Money and Reduce Toxics" (SMART)  program.  This is a
          "top down" program in which each Chevron operating **
          company follpws a corporate-wide policy.  The Chevron
          Research Company differed  from most of Chevron's
          companies in terms of waste streams.  Instead of having
          a few high volume waste streams*  there were hundreds of
          small waste streams in the form of used glass  vials.
          The used Vials used to be collected and transported to
          a hazardous waste landfill or incinerator at a cost of
          $5,000 per month. The company purchased a device that
          crushes the used vials and separates  the oil from the
          glass. After this process/'the oil is collected and
          recycled and the crushed glass is compacted. The cost
          of the crusher was $20,000; 'however the cost of
          disposing was approximately $5,000 per month and
          rising. The payback period on the crusher was  only a

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                                20
          few months.
     o    Consolidated Freightways does not have a clearly
          defined corporate policy. Instead, the employees at the
          facility took a "bottom up" approach to reduce
          hazardous waste. The employees developed and
          implemented the use of water soluble chemicals to
          replace a solvent used in the dust abatement of brakes
          and electronic equipment. This reduced their production
          of hazardous waste by 631 pounds a week at a savings of
          approximately $8,000 per year.

     o    Squibb Manufacturing Incorporated has a Hazardous Waste
          Reduction Plan, and has reduced a total of 849,300
          liters of salty wastes (i.e., aqueous solvent mixtures
          with organic and inorganic salts content with low
          heating value and toxic constituents) through several
          recovery and recycling schemes, and has reduced the
          generation of cold waste (i.e., diluted aqueous mixture
          with low heating value and toxic constituents at less
          than 100 ppm) by at least 60,500 liters and a projected
          annual reduction of 1,100,540 liters cold waste/year,
          through source reduction schemes.

     In addition, the Chemical Manufacturers' Association (CMA),
a technical trade association, has adopted a Code of Management
Practices which is designed to promote industry efforts to
protect the environment by generating less waste and reducing
pollutant emissions.  CMA's code requires facilities to inventory
wastes generated and the volumes released to land,  air, and
water, and to evaluate their potential impacts; seek employee and
public input before developing and implementing plans for
continual reductions; evaluate reducing wastes and releases at
their sources first before evaluating recycling or treatment
programs; include waste and release prevention objectives in
research and design of new or modified facilities,  processes, and
products; and to promote reductions of wastes and releases by
others.

     As stated earlier, many factors will influence the
development of effective mechanisms for source reduction and
recycling:

•    the characteristics of the waste, how it was generated,  and
     the technical and economic feasibility of reducing or
     preventing this waste;

•    characteristics of the generator universe (i.e., how many
     generators generate the waste; whether there are dominant
     generators of the waste or generation is fairly ubiquitous;
     the size of the facilities/industry sectors generating the
     waste);

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                                21

•    whether the focus would be on a specific constituent,  a
     specific waste, or a specific industrial process;

•    the overall multi-media'impacts of using a specific  >
     mechanism and an understanding of the broader life cycle
     implications, (e.g., what other waste(s) may be generated  in
     its place because of constituent substitutions, or in  some
     cases, minimizing hazardous waste generation may result in a
     shift of emissions to water or air ,  or in shifts of water,
     energy, or other natural resource use);

•    initiatives that have already been taken to address the
     generation of these wastes or constituents of concern,
     (e.g., if phase out of specific chlorinated solvents is
     already underway, it may be redundant with other efforts and
     ineffective to focus on these solvents);

•    whether a voluntary or a regulatory approach would be more
     effective, given many of the considerations above; and

•    which organization is in the best position to initiate
     change and effectively get results within the generator
     universe of concern.

     Voluntary Challenge Program

     Many generators have been proactive' and responsible in their
efforts to reduce the use of toxic substances in source
reduction, reduce releases of toxics to the environment,  and
increase their use of environmentally sound recycling.  EPA wants
to see an increased trend in industry's commitment to preventing
pollution, and is most interested in developing, with all
stakeholders, a challenge program that has meaning to both the
industrial and environmental communities alike.

     Recognizing that the Agency has initiated several voluntary
programs to date, as stated above, EPA will evaluate the
relevance of such programs to goals of our Draft RCRA Waste
Minimization National Plan.  However,  given the complexities of
waste generation, EPA believes a voluntary program focusing on
       For example,  a facility may switch from a  chlorinated
solvent cleaner to an aqueous cleaner.  Although the hazardous
waste generated by this facility will be reduced, the dirt being
removed through cleaning will be shifted into a water medium.
This may or may not be environmentally beneficial.  On the other
hand, chemical substitutions can result in increased hazardous
waste generation.  For example, a facility may switch to a
process chemical in response to the Clean Air Act that produces
no or low Volatile Organic Compounds (VOCs).   However, spent
chemical may result in the generation of a hazardous waste.

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                                22
EXHIBIT 3
GENERIC MECHANISMS FOR SOURCE REDUCTION AND RECYCLING
REGULATORY
FOCUS
STANDARDS
LDR
Treatment
Standards*

Technical
Emissions
Standards

Definition
of Solid
Waste &
other future
regulations
(reduce
barriers)

LDR
Treatability
and Case-by-
Case
Variances*















OTHER
REGULATORY
OPTIONS
Enforcement
Compliance
require wmin
in SEPs*

Increase
inspections
of generators
to encourage
source
reduction

Permitting/
omnibus auth .
to require
wmin*

Waste Min
Programs in
Place
Guidance

Use State
authorities
for requiring
Pollution
Prevention
Plans*

Capacity
Planning
required for
Phase II of
Capacity
Assurance
Plans
NON-REGULATORY

Industry Driven
Good Operating
Practices

Industry
Programs

Gov't Driven
Reg. Compliance
Costs

Tax Incentives

Release of Data
to the Public





















Voluntary
Program:

• Challenge
Programs

* Technical
Assistance

• R&D
Programs
(grants to
foster
innovative
technology)

* Education
Programs

* Partnering

* Reward/
Recognition
Programs

* Measurement

State
Grants &
RIP Flex






 These activities could require (but currently don't necessarily
require), rather than  just  foster,  source reduction and/or
recycling.

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                                23

hazardous waste generation reductions  is the  first  step.   Whether
more regulatory requirements are  needed depends  on  the  progress
to be shown  (particularly reductions of those wastes that  EPA
believes will result in the greatest environmental  gain);

     Because the generation of hazardous wastes  is  complex,
(i.e., the number, and size of generators, and industrial
processes generating these wastes varies), EPA believes many of
the quickly implementable solutions to reductions lie within the
generating universe.  The generators of hazardous waste are best
positioned to challenge their own workforce,  improve their own
technologies and to reconfigure and re-invest in their  operations
to achieve significant waste reductions that  lead not only to
environmental but economic gains.  Therefor®, a MAJOR component
of this waste minimization plan is a voluntary challenge to
industry to participate in achieving reductions in wastes.

     EPA will, in the near future, create a "forum for open
dialogue with industry, public interest groups, regulators, and
pollution prevention technical assistance experts, on the
development of such a voluntary program.

     EPA at this point suggests that.key components of  the
voluntary program should include:

*    The Challenge - EPA will launch a national program, inviting
     voluntary participation from generators.  EPA will identify
     wastes that are the focus of the challenge and why^ we have
     focused on these wastes, constituents, or sectors.   EPA will
     hold discussion with all stakeholders to afford input into
     how EPA defines success, the measures of success,  the
     timeframe in which action is desired,  and meaningful
     incentives that can be developed to assure industry
     participation.

*    Defining Success/Goals - EPA believes it is essential to
     define what reductions we want to achieve.  Since certain
     industries have already made great strides in achieving
     reductions in hazardous wastes and emissions, it is
     important to retain flexibility in defining success and
     progress towards our goals.  An emphasis on optimizing
     source reduction and continuous improvement in source
     reduction and then recycling will be a central focus.

*    Incentives/recognition Program - Incentives to encourage
     participation in the program are essential.   EPA will work
     with stakeholders to develop effective incentives and
     recognition program for those participating in the challenge
     program.

*    Outreach - EPA will need to  foster dialogue among all
     stakeholders, promote corporate openness, and encourage

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                                24

     companies to work closely with their communities.  Outreach
     will be necessary in communicating the goals of the RCRA
     Waste Minimization National Plan and voluntary initiatives,
     getting buy-in from all stakeholders, and identifying the
     needs of stakeholders (i.e., progress being made, technical
     assistance, identification of barriers to progress, etc.)

4    Removal of Barriers to progress - We will review regulations
     that could/should/or would have an effect on source
     reduction and/or recycling of wastes.  Through this effort,
     OSW will identify any barriers that have been inadvertently
     created, and for those regulations being developed, give
     high priority to creating incentives and efficiencies in
     reducing these targeted wastes.

•    Technical Assistance - Three levels of technical assistance
     will be initiated:

     •    Technical Assistance Centers - EPA will work with and
          through technical assistance centers, such as the
          Pollution Prevention Roundtable of State Officials and
          the NIST Manufacturing Technology Centers, to encourage
          and better enable these centers to focus on specific
          wastes;

     •    Technical Guidance Documents - ORD resources will be
          used to develop technical guidances on source reduction
          and recycling opportunities related to the processes
          generating specific wastes;

     •    Training -  Training will be developed for industrial,
          state, and regional audiences, on how to identify
          source reduction and recycling opportunities, as well
          as specific technical training on source reduction and
          recycling opportunities for wastes;

+    Fostering Innovative Technology - EPA's Office of Research
     and Development has set aside funds to create a research
     needs document to stimulate universities and private
     industry to develop innovative technologies that, in effect,
     lead to the minimization of targeted wastes;

•    Educational Programs - Working with leading universities,
     EPA would utilize existing and create new avenues to enhance
     curricula that would teach principles of source reduction
     and recycling, and encourage the development of specific
     modules that would address reductions of specific wastes.

     Regulatory and Enforcement Mechanisms:

     EPA has several regulatory opportunities to either create a
climate that encourages source reduction, followed by recycling,

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                                      25
or
            it,
           First, it has been argued that EPA hag already created an
      incentive for industry to minimize its waste, through the
      promulgation of a series of regulations related to HSWA's mandate
      to prohibit the land disposal of hazardous waste unless the
      wastes first meet some very stringent treatment standards.  The
      Land Disposal Restrictions regulations require that, prior to
      land disposal, hazardous waste must be treated using Best
      Demonstrated Available Technology (BOAT).  The cost of such
      treatment has been identified by some as a strong incentive for
      reducing the specific wastes subject to these treatment
      technologies.

           In addition, the Office of Solid Waste will, to the extent
      feasible, coordinate efforts with the various media Offices
      within EPA to more efficiently coordinate source reduction or
      recycling activities initiated or planned for waste streams of
      concern.  In addition, the new Office of Enforcement and
      Compliance Assurance (OECA) will be focusing on multimedia
      inspections.  There may be opportunities to use this multi-media
      approach to implement more source reduction or recycling which
      could result in the reduction in toxicity and/or volume of high-
      hazard wastestreams.  In.addition, the Agency-wide "Initiative
      for Commonsense Environmentalism" will look at specific
      industrial sectors and the interrelationship of various
      activities amongst all media Offices.  To the extent that high-
      hazard wastestreams are generated within these sectors, EPA would
      want to optimize the use of this Agency-wide Initiative to
      identify mechanisms to assure reductions in these wastes.  Also,
      generally, wherever there are opportunities for Pollution
      Prevention to be integrated into rulemakings, OSW will identify
      where such opportunities would contribute to the reductions of
      wastestreams with source reduction and/or recycling
      opportunities,

           EPA will also strive to use mechanisms such as Supplemental
      Environmental Projects, inspections of generators of wastes,
      permits, and the Waste Minimization Program in Place
      Certification  ,  In particular:

      o    EPA has negotiated Supplemental Environmental Projects
           (SEPs) with facility officials.  Many of these projects
           focus on identifying and implementing pollution prevention
           measures as a means of eliminating or reducing hazardous
           waste generation.

      o    EPA will explore initiating a program similar to a program
           10
               RCRA Sections  3002(b)  and  3005(h), as amended, 42 U,S,C.
       6922(b)  and  6925(h),
_

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                                26

     existing in Massachusetts, pursuant to which the State
     conducts multi-media inspections and provides pollution
     prevention technical assistance to facility personnel to
     solve compliance problems as part of the inspection and
     compliance process.

o    Several EPA Regions and States have begun to build upon
     HSWA's requirement for generators and TSD facilities to
     certify that they have a waste minimization program in
     place.  Many States that have obtained HSWA authorization
     have taken advantage of this HSWA requirement.  EPA
     published interim final guidance to hazardous waste
     generators and treatment, storage and disposal  (TSD)
     facilities on the elements of a waste minimization program-
     in-place on May 28, 1993.  This guidance provides generators
     and TSD facilities information on a flexible "menu" of
     activities they can use to comply with HSWA's requirement
     for these facilities to certify that they have a program in
     place to minimize waste generation.  EPA's next step in the
     process is to work within the federal, state, business and
     environmental network to expand the message in this guidance
     to cover prevention of toxic air and water releases in
     addition to hazardous waste.  EPA anticipates that this
     multi-media effort will proceed over the course of the next
     year.

     The Draft RCRA Waste Minimization National Plan will also
build on existing State authorities, requirements, and programs.
To the extent that States' believe that the reduction of these
wastes targeted under EPA's Plan is warranted, EPA would
encourage States to use whatever authorities exist to foster
source reduction and/or recycling that would result in the
reductions in these wastes, with the intent that industry would
focus on reducing these wastes.  EPA encourages both the Regions
and the States to coordinate in using authorities that may assure
greater reductions in high-hazard wastes.  EPA will be interested
to receive from States comments on how. their own defined
priorities and activities within their States relate to this
plan.  EPA will also want input from the States on what
meaningful mechanisms exist for the States to communicate
progress in achieving reductions in high-hazard wastestreams
identified, although EPA does not have any intentions of
prescribing to the States specific activities to achieve
reductions.

     ROLES OF THE FEDERAL GOVERNMENT, STATES, INDUSTRY,  TECHNICAL
     ASSISTANCE CENTERS AND THE PUBLIC

     This Draft RCRA Waste Minimization National Plan challenges
many organizations and individuals to evaluate what they can do
and then act in reducing the generation of hazardous waste.
Partnerships are essential in this endeavor, and every

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                                27

organization has a role to play.

     Discussions with the various stakeholders have shed
additional light onto the potential roles of various entities in
pollution prevention.  As can be seen from the list below, there
is much that everyone can do to result in the reduction of the
toxicity and volume of waste and to find more ways to prevent
pollution before it is generated.

     Role of the Federal Government

     The EPA, and other. Federal Agencies, such as the Department
of Energy, can use their resources, expertise, relationship to
all stakeholders, and respective legal authorities to accelerate
the reduction in both toxicity and volume waste generation.
Roles of Headquarters and Regional Offices may differ.

     As stated previously, it is EPA's intention to serve
primarily as an initiator and facilitator of this Draft RCRA
Waste Minimization National Plan by setting general goals,
reducing barriers, and better enabling States, industry, and the
public to achieving pollution prevention.

     EPA seeks comments from the public on their sense of which
roles the EPA would best serve in achieving reductions, as well
as which roles the public believes should be priorities for EPA.
Several areas in which EPA has already begun and seeks comments
on continuing to expand initiatives include:

EPA Headquarters;

•    Integrating pollution prevention into the regulatory
     requirements, policies, and guidances

     -    Assessing and eliminating regulatory loopholes and
          disincentives for source reduction and recycling;

          Creating incentives for source reduction and recycling
          to take place through consistent,  enforceable, and
          protective standards; creating incentives for the
          development of clean technology

•    Developing measurable indicators of success and developing
     better data and measurement methods;

•    Providing a clearinghouse of information;

•    Communicating what progress has been made nationally in
     source reduction and recycling to date; and setting and
     communicating environmental goals;

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                                28

EPA •* Regional and Headquarters?

•    Implementing the regulatory  and voluntary programs as
     appropriate and integrating  pollution prevention into these
     programs, wherever possible;

•    Encouraging and forming partnerships with States, industry,
     the public, and technical assistance centers, to work
     towards implementing source  reduction and recycling
     opportunities, and assist in creating these opportunities;

•    Using their authorities to encourage or require source
     reduction and recycling;

•    Facilitating State, university, and Federal government
     efforts to provide effective technical assistance;

•    Facilitating State use of their resources, expertise and
     authorities to integrate source reduction and recycling into
   .  their programs;

•    Identifying in which sectors (or industrial processes)
     source reduction is needed most, based on pollutant loading
     and toxicity, geographic and environmental justice concerns;

•    Enhancing education of the regulatory community and the
     public on how pollution prevention can improve compliance
     with environmental regulations;
     Role of the States

       Many States' roles overlap with the federal government's,
but many are unique, given their relationship to their regulated
community and the citizens of the State.  States are in a good
position to look at tailoring their policies and regulations to
specific regional issues related to industries located within
their borders.  States have already played a key role in gaining
momentum in pollution prevention, often through goals mandating
pollution prevention, as well as delivering compliance and
pollution prevention technical assistance.  The roles of States
include:

•    Implementing the regulatory and voluntary programs and,
     therefore, integrating pollution prevention into these
     programs;

          Creating incentives for source reduction and recycling
          to take place through consistent, enforceable,  and
          protective standards; creating incentives for the
          development of clean technology

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                                      29

                Assessing  and  eliminating regulatory loopholes and
                disincentives  for  source reduction and recycling;

                Using their  authorities  to encourage or require source
                reduction  and  recycling;

           Developing measurable indicators of  success and developing
           better data and measurement methods;

           Provide a clearinghouse of information;

           Providing technical assistance,  either  through  State-run or
           State-funded entities;

           Communicating what  progress has been made in source
           reduction and recycling, to date, within  their  State; and  to
           set and communicate environmental goals;
      •    Identifying in which sectors  (or industrial processes)
           source reduction is needed most, based on pollutant loading
           and toxicity, geographic and  environmental justice concerns;

      •    Enhancing education of the regulatory community and the
           public on how pollution prevention can improve compliance
           with environmental regulations;

           Role of Industry

           Industrial members of the regulated community can be either
      generators of waste, managers of waste (i.e., transporters,
      treatment, storage, and disposal facilities), or both.  Industry
      has an important role to play in the reduction in the toxicity
      and volume of hazardous waste.  Many have taken a proactive
      position, and can serve as role models for others.  The roles
      include:

           Generators

      •    Demonstrate a corporate commitment to pollution prevention;
           integrate source reduction and recycling into their business
           strategy;

           Specific activities under this type of role might include:
                Establish a source reduction and recycling audit
                program/make a commitment to implement findings;
                Facilitate or empower the corporation - every worker -
                to initiate source reduction and recycling;
                Prioritize pollution prevention activities by risk and
                cost;
                Focus on continuous improvement in source reduction;
                Identify the real cost and/or value of a waste
_

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                           30

     associated with a product, promote fuller capital
     budgeting and accounting for environmental effects and
     protection;
-    Conduct research and develop technologies leading to
     source reduction and recycling;
-    Choose vendors based on P2 commitments;

Provide support for technical assistance and waste
exchanges;

Develop good neighbor programs; involve the public directly
in corporate planning and pollution prevention goals; and
understand the public's pollution prevention expectations to
reduce;

Promote source reduction and recycling opportunities within
the regulatory community;

Develop a partnership with regulatory agencies to develop
data that allows measurement of progress and waste
generation, management, and reduction trends;

Assist smaller companies to achieve source reduction and
recycling;

Be a model company in taking the lead role and
responsibility for the waste that is generated from cradle
to grave;

Use life-cycle management information in advertising
practices to influence consumer buying and promote source
reduction and recycling; and communicate the linkage between
desired consumer products and associated wastes generated by
those products; label products to inform consumer about
wastes generated during product manufacture or servicing;

Communicate progress that has been made in source reduction
and recycling;
Treatment, storage/ and Disposal Facilities

Provide the best available technology to generators for
recycling, treatment, transport, and disposal of waste to
minimize toxic components of a waste and ensure that
residuals are protective of human health and the
environment;

Work with regulators to develop and strengthen environmental
standards to close loopholes and keep regulatory incentives
for source reduction and recyIcing;

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                                31

     Embrace pollution prevention.ethic in upper management
     practices and transmit this philosophy throughout the
     organization and to their customers;

     Provide data on actual composition of wastes and how it
     changes;

     Serve as a consultant and partner with generators:

          Identify how Pollution Prevention practiced by the
          customer translates to better compliance and avoids
          costs of additional control technologies at the TSD;

          Provide incentives to customers to minimize toxicity /
          quantity of wastes (for example, through a price
          structure that creates incentives to reduce wastes);
          promote source reduction options, followed by recycling
          options; encourage proactive wast^ segregation;

          Develop special programs for small-quantity generators
          by providing on-site source reduction, followed by
          recyIcing services, including: newsletters, fact
          sheets, process evaluations, research and development
          of innovative technologies, seminars for clients;

     Practice Pollution Prevention; develop cleaner treatment
     technology that generates less waste;
     Role of Technical Assistance Centers

Although many generators have in-house expertise, many generators
do not, especially small and medium-sized companies.  Technical
Assistance Centers can play a key role in the goal of reducing
the specific high-hazard wastes, by: 1) becoming familiar with
the wastes, 2) assisting in identifying technologically and
economically feasible source reduction and recycling
opportunities, 3) assisting in training and dissemination of
information to their clientele and 4) providing feedback on
barriers that are stopping industry from adopting more source
reduction and recycling.  Pollution prevention technical
assistants are often well positioned to disseminate information
and offer assistance, since they do not regulate or profit from
the facility operations and product sales, but rather have a
valued service to offer the facility.  Some specific activities
that have been suggested include:

•    provide technical assistance to businesses (focusing on the
     smaller businesses that do not benefit from and may not have
     access to large industries knowledge) on:
     -    research and development
          applied research

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                                32

     -    training/seminars/workshops

•    build and enhance national information networks;

•    foster relationships with non-traditional partners, such as
     among waste generators and banks, state and local
     governments, non-profit associations, development
     organizations;

•    support regulatory and non-regulatory programs;  (for
     example: support voluntary programs and internal integration
     of P2 within State agencies);

•    Focus efforts on developing and analyzing substitute
     products and processes

•    Be a primary non-governmental advocate for pollution
     prevention.

     Role of the Public

     The public  is an essential player in the development of a
national waste minimization plan, and is the ultimate beneficiary
of any source reduction and recycling efforts.  The  following
were some general roles identified at the Roundtable in November,
1993:

•    continue advocacy role for  implementation of source
     reduction and toxics use reduction;

     -    Engage the facilities  generating waste and seek
          continued  Pollution Prevention programs;
          Urge educational institutions to integrate source
          reduction  and recycling into the educational
          mainstream;
          Advocate industry and  government focus on  creating
          incentives for  source  reduction and eliminating
          disincentives for source reduction;

 •     Be  an  educator/communicator and  be educated:

      -    Educate  fellow  consumers on how buying patterns
           influence  source reduction  and recycling.
          Obtain information  on source reduction and recycling
          progress;
      -    Apply  good science  to address concerns;
          Have a multimedia outlook;
           Create/use effective'mechanisms to communicate to the
           rest of  the  public  the need for source reduction and
           recycling, status of  progress;

 •    Support funding for  technical  assistance centers;

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                           33

Help expand the scope of Pollution Prevention programs into
other areas of public administration;

Become involved in good neighbor programs with industry;

Demand compliance.

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Attachment 1: Preliminary Summary of High Ranking Industry/Source Combinations, Based on
                      Hazard of Metal-Bearing Wastestreams Generated
Industry
Air and Water Resource and Solid Waste Management
Aircraft Parts and Auxiliary Equipment, N.E.C.
Ammunition, Except for Small Arms
Cement, Hydraulic
Chemicals and Chemical Preparations, N.E.C.
Commercial Physical and Biological Research
Cyclic Organic Crudes and Intermediates, and Organic
Dyes and Pigments
Electric Lamp Bulbs and Tubes
Electric Services
Gum and Wood Chemicals
Hardware, N.E.C.
Highway and Street Construction, Except Elevated
Highways
Industrial Inorganic Chemicals, N.E.C.
Industrial Organic Chemicals, N.E.C.
Internal Combustion Engines, N.E.C.
Laminated Plastics Plate, Sheet, and Profile Shapes
Manmade Organic Fibers, Except Cellulosic Fibers
Manufacturing Industries, N.E.C.
SIC
9511
3728
3483
3241
2899
8731
2865
3641
4911
2861
3429
1611
2819
2869.
3519
3083
2824
3999
Source
Other pollution control or waste treatment
Other non-surface preparation processes
Discarded off-spec material
Unknown
Other pollution control or waste treatment
Spent process liquids removal
Oil changes
Product distillation
Product rinsing
Unknown
Oil changes
Oil changes
Product filtering
Stripping
Painting
Flush rinsing
Laboratory wastes
Oil changes
Unknown
Clean out process equipment
Discarded off-spec material
Laboratory wastes
Oil changes
Other, unspecified
Product distillation
Product filtering
Spent process liquids removal '
Tank sludge removal
Stripping
Air pollution control devices
Unknown
Other cleaning and degreasing
     Notes: SIC =- Standard Industrial Classification Code;
            N.E.C.  =* Not Elsewhere Classified

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         Attachment 1: Preliminary Summary of High Ranking Industry/Source Combinations,
               Based on Hazard of Metal-Bearing Wastestreams Generated (continued)
Industry
Medicinal Chemicals and Botanical Products
National Security
Natural Gas Transmission
Nonclassifiable Establishments
Ordnance and Accessories, N.E.C.
Paints, Varnishes, Lacquers, Enamels, and Allied
Products
Pesticides and Agricultural Chemicals, N.E.C.
Petroleum Refining
Pharmaceutical Preparations
Photographic Equipment and Supplies
Plastics Materials, Synthetic Resins, and
Nonvulcanizable Elastomers
SIC
2833
9711
4922
9999
3489
2851
2879
2911
2834

3861

*



2821


Source . j
By-product processing |
Laboratory wastes |
Other non-surface preparation processes
Product distillation
Product filtering
Product rinsing
Product solvent extraction
Spent process liquids removal
Other pollution control or waste treatment
Other, unspecified
Unknown .
By-product processing
Laboratory wastes
Clean out process equipment
By-product processing j|
Clean out process equipment |
Other, unspecified
Product solvent extraction
Other pollution control or waste treatment
Sludge removal
Wastewater treatment
Air pollution control devices
Product distillation
Spent process liquids removal
Flush rinsing
ncineration/Thermal treatment
Other non-surface preparation processes
Other production-derived 1 -time and
ntermittent processes
Product distillation
Spent process liquids removal
Product distillation ||
Spent process liquids removal jj
Unknown ]|
                                            -35 -
_

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Attachment 1: Preliminary Summary of High Ranking Industry/Source Combinations,
      Based on Hazard of Metal-Bearing Wastestreams Generated (continued)
Industry
Railroad Equipment
Refuse Systems
Secondary Smelting and Refining of Nonferrous Metals
Services, N.E.C.
Signs and Advertising Specialties
Small Arms Ammunition
Specialty Cleaning, Polishing, and Sanitation
Preparations
Synthetic Rubber (Vulcanizable Elastomers)
Truck and Bus Bodies
Wood Household Furniture, Except Upholstered
Furniture
SIC
3743
4953
3341
8999
3993
3482
2842
2822
3713
2511
Sourca
Painting
Air pollution control devices
Closure of management unit or equipment
other than by remediation
Clothing and personal protective equipment
Laboratory wastes
Other, unspecified
Other cleaning and degreasing
Other pollution control or waste treatment
Solvents recovery
Filtering/screening
Other, unspecified
Other surface coating/preparation
Other, unspecified
Routine cleanup wastes
Clean out process equipment
Flush rinsing
Spent catalyst removal
Spent process liquids removal
Painting
Painting
                                   -36-

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