&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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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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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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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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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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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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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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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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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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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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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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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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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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