530F93010
Environmental Fact Sheet
Source Reduction and Combustion
of Hazardous Waste
The Environmental Protection Agency (EPA) is issuing a directive to its Regional Offices outlining the
importance of source reduction and a series of protective actions to be taken during the permitting of
hazardous waste incinerators and boilers and industrial furnaces (BIFs). In addition, EPA is issuing
guidance on the elements that should be included in a generator's waste minimization program in
order to properly certify that the generator has a waste minimization program in place. Finally, EPA
is issuing a draft strategy as the starting point for a broad and open evaluation of how source
reduction and waste combustion must be integrated in the nation's hazardous waste management
strategy.
Overview of the Combustion Debate
The role that combustion plays in hazardous waste management has
changed dramatically over the last decade and a half. Early on, disposal of
hazardous waste primarily involved putting wastes into landfills and surface
impoundments. As we reached the mid-1980's, there arose a widespread
recognition that land-based disposal practices were continuing to present long term
pollution problems, particularly with respect to contamination of the nation's ground
water.
In 1984, the Resource Conservation and Recovery Act (RCRA) was
substantially amended by the Hazardous and Solid Waste Amendments (HSWA).
These Amendments charted a new course for hazardous waste management -
away from historic land disposal practices and towards much greater use of
treatment technologies prior to disposal. HSWA also further articulated the national
policy to emphasize pollution prevention as the first and primary goal for the waste
management program.
As a result of this change, combustion of hazardous waste in incinerators and
boilers and industrial furnaces (BIFs) began to increase substantially. Concurrent
with increased use of combustion as a form of waste management, public concerns
began to be voiced about the safety and reliability of combustion facilities. In
addition, citizens began to ask whether an overabundance of combustion capacity
serves to undercut reduction of waste generated at industrial facilities.
At this juncture, EPA has decided to initiate a fresh look at how to achieve a
fully integrated waste management program in which source reduction is given its
proper emphasis and in which the role of combustion is carefully considered. As
detailed below, this involves the establishment of a broad dialogue on these national
policy questions under the joint leadership of EPA and the states. At the same time,
EPA will take a series of interim actions designed to further ensure the safety and
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reliability of hazardous waste combustion in incinerators and BIFs while longer-range
scientific research is being conducted and while technical amendments to the
regulations are being evaluated. These interim actions will help to ensure that
operation of combustion facilities do not present unacceptable risks to human health
or the environment.
Background Facts and Figures
About 5 million tons of liquid, semi-solid, and solid hazardous waste are
burned each year in hazardous waste incinerators and BIFs. In everyday terms,
these 5 million tons would fill up a line of tank trucks stretching from Washington,
D.C. to Los Angeles, some 2400 miles. About 90% of the wastes combusted today
are generated by 10 industry categories, which comprise major segments of
American industry, for example, petroleum refineries, agricultural chemical
manufacturers, and organic and inorganic chemical plants. Common types of
wastes being combusted are spent solvents, distillation bottoms, and off-spec
organic chemicals and products.
EPA's incinerator regulations were adopted under the Resource Conservation
and Recovery Act (RCRA) in 1981. In 1988, EPA's Office of Solid Waste issued
supplemental guidance that directed use of the RCRA "omnibus" permit authority to
add controls for emissions of metals, products of incomplete combustion (PICs), and
hydrochloric acid (HCI) into new incinerator permits on a case-by-case basis.
As of July 1,1993, there are 190 hazardous waste incinerators, 149 of which
can operate under final permits and another 22 of which are operating in interim
status pending final resolution of their permit applications. Another 19 facilities have
submitted permit applications for new incinerator units. There are 27 commercial
incinerators in the United States, 21 of which are in commercial operations today.
Major types of BIFs burning hazardous waste include cement kilns,
lightweight aggregate kilns, and industrial and utility boilers. Currently, there are 159
BIFs, of which some 34 are commercial facilities accepting wastes from other
generators. BIFs are subject to comprehensive EPA RCRA regulations that were
promulgated on December 31,1990 (56 Fed Reg. 7134, Feb. 21,1991). Among
other key features, these regulations contain controls on metals, PICs, and HCI
being emitted from BIF facilities. At the present time, these controls are imposed as
interim status standards. No BIFs have yet received final permits although a number
of permit applications have been recently filed.
EPA's Objectives
In taking these actions, EPA has articulated several goals that will guide its
future actions and will provide the framework for debate on EPA's draft strategy.
These goals are:
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To establish a strong preference for source reduction over waste management, and
thereby reduce the long-term demand for combustion and other waste management
facilities.
To better address public participation in setting a national source reduction agenda,
in evaluating technical combustion issues, and in reaching site-specific decisions
during the waste combustion permitting process.
To develop and impose implementable and rigorous state-of-the-art safety controls
on hazardous waste combustion facilities by using the best available technologies
and the most current science.
To ensure that combustion facilities do not pose an unacceptable risk, and use the
full extent of legal authorities in permitting and enforcement.
To continue to advance scientific understanding with regard to waste combustion
issues.
The Process for Pursuing a National Strategy
Under RCRA, EPA and the States are partners and co-regulators of the
generation, transportation, treatment, storage, and disposal of hazardous waste.
EPA is firmly committed to the view that any evaluation of the role of hazardous
waste combustion in the hazardous waste management system must be undertaken
as a joint federal and state effort. To that end, an EPA-State Committee on
Hazardous Waste Management has been formed to further develop the national
strategy. The initial charge to this Committee includes focusing on aggressive
source reduction measures, improvements to technical and permitting standards,
facilitation of alternative treatment technologies, and developing a better scientific
foundation for decision making.
Furthermore, EPA intends to involve all stakeholders in this dialogue. EPA is
issuing a draft combustion strategy as a starting point for debate on needed source
reduction actions and regulatory changes that must be pursued, and will engage the
widest range of interested parties in this debate. In particular, EPA is emphasizing
aggressive use of source redtiction as the first and primary goal to be pursued with
respect to the generation of combustible wastes. However, EPA will immediately
pursue a number of actions to ensure that existing combustion facilities are operated
safely and without unacceptable risks to human health and the environment while
the discussions on the source reduction and the national waste management
strategy are taking place.
Actions Being Taken
While the national dialogue on source reduction and hazardous waste
combustion is taking place, EPA has issued a directive to its Regional Offices that,
effective immediately, calls for a series of actions to be taken in connection with
making permit decisions on incinerators and BIFs. These actions include:
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* . aggressive use of waste minimization measures as part of permitting and
enforcement efforts involving generators of combustible waste as well as
incinerators and BIFs, ' \
ensuring that a comprehensive risk assessment j including indirect exposures,
is conducted at each facility site, \
• . use of-omnibus- permit authority- to ineluderwher-^ necessary to protect human
health and the environment, dfoxin/furan emission limits and a stringent
particulate matter standard in new permits, j
providing for earlier and more effective public participation, and
giving low management priority to permitting any new incinerator and 8iF
capacity over the next 18 months unless the new facilities would replace and
be a significant improvement over existing capacity.
In addition, the directive targets incinerators and BfFs for enhanced inspection and
enforcement efforts-regarding compliance with ERA'S regulations and with individual
facility permit conditions. These enhanced inspection and enforcement activities will
also include use of waste minimization requirements as part of compliance actions.
With respect to source reduction, EPA is also issuing interim final guidelines
on the elements of a sound waste minimization program. These elements, which
span administrative, financial, and technical areas, should be contained in a
generators waste minimization program in order for that generator to make a proper
certification under RCRA. The RCRA statute requires that each generator of
hazardous waste make such a certification. \
On a broader scale, the Administrator is- convening a task force of EPA and
state officials to undertake a broad evaluation of source reduction and waste
combustion as integral components of the national waste management strategy.
Concurrently, EPA is issuing a draft combustion strategy as a starting point for
discussion on source reduction arid waste c
EPA is committed to ensure that all waste management technologies are fully
protective of human health and the environment. EPAjwilf not tolerate operation of
waste management facilities that present unacceptable risks to human health and
the environment The series of short and longer-term actions set forth in the
Administrator's directive to the Regions and proposed for discussion in the draft
combustion strategy are designed to achieve this end. These actions will ensure
that EPA doing what it can to pursue aggressive source reduction, to enhance
controls on existing combustion facilities, and to promote public participation in
permitting and source reduction efforts. I
R&vis&d August 1993
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