&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 ------- ------- 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. ------- 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.) ------- 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. ------- 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 ------- 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.) ------- 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 ------- 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 ------- 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 ------- 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). ------- 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. ------- 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 ------- 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. . ------- 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._ ------- 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 ------- 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 ------- 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 ------- 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, ------- 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. ------- 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 ------- 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); ------- 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. ------- 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. ------- 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 ------- 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, ------- 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), _ ------- 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 ------- 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; ------- 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 ------- 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 _ ------- 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; ------- 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 ------- 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; ------- 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. ------- 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 ------- 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 - _ ------- 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- ------- |