United States      Solid Waste and
Environmental Protection Emergency Response
Agency        (OS-305)
                                     EPA530-F-93-023
                                       August 1993
vvEPA
Draft Strategy on
Combustion and Waste
Minimization
              Project Plans
Printed on Recycled Paper

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              UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                        WASHINGTON, D.C. 20460
                                                       OFFICE OF
                                              SOLID WASTE AND EMERGENCY RESPONSE
                         August  31,  1993
NOTE


TO:



FROM:
Recipients of
Combustion

Jeffery Den
Office of So
s Plans for EPA's Draft strategy on
   imization
   *
  irector
     The attached  document is an overview of EPA's  project plans
for  implementing  the  Draft  Strategy on  Combustion  and  Waste
Minimization  released  on  May  18,  1993.   We  have  attempted  to
summarize  the main  projects  that  EPA will  undertake and  their
constituent elements, and  to provide  general  time frames in which
Agency action is expected.

     As each project is pursued, a host of issues and concerns will
undoubtedly be  raised by the various  stakeholders involved.   The
Agency expects to address these issues and concerns as they arise,
but we have not attempted to detail them in these project plans.
Rather, our intention is for thes^ plans to inform the stakeholders
on the avenues  that are or  will become available in which their
issues and concerns  can be fully explored.

     If you have any questions about  these project  plans,  please
contact the individual  designated in each area or Matt  Straus  or
Fred Chanania in our Waste Management Division  (703-308-8414) .
                                                         Printed on Recycled Paper

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                      PROJECT PLANS




                           FOR




EPA'8 DRAFT STRATEGY ON COMBUSTION AND WASTE MINIMIZATION
                       August 1993

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                             PREFACE
     The attached project plans provide an initial overview of
the implementation of specific elements of EPA's Draft Strategy
on Combustion and Waste Minimization, released on May 18, 1993.
These project plans reflect comments from the State-EPA Committee
on Hazardous Waste Management.  A number of issues raised by the
State-EPA Committee, even if not specifically noted in the
project plans, will be addressed in the context of individual
projects as they are developed.  In addition, EPA will continue
its outreach program to all stakeholders to ensure that all
important concerns and points of view are considered in these
projects as well as in other implementation aspects of the Draft
Strategy on Combustion and Waste Minimization.

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                   DRAFT STRATEGY  PROJECT  PLANS

             WASTE MINIMIZATION AND SOURCE REDUCTION

outreach. Discussion Document, and Roundtable

     The Agency needs to forge broad partnerships for
aggressively pursuing source reduction of all types of waste
being generated.  Industry input,  adoption, and implementation of
source reduction and recycling initiatives, as well as addressing
environmental group concerns are, keystones.  EPA will have a
series of meetings with industry,  environmental and citizen
groups, and states to hear their views and recommendations.  The
Agency also plans to have a national Waste Minimization
Roundtable meeting in November 1993 that will bring all parties
to the table to discuss and strategize how best to optimize
hazardous pollution prevention in this country.

     In its meetings, the Agency will discuss all effective
mechanisms to encourage source reduction and recycling of all
types of waste, although an initial emphasis may be placed on
combustible waste.  RCRA has limitations on its regulatory
authority regarding source reduction and recycling at the
generator level; however, some progress has been made through
enforcement and permitting activities in initiating waste
minimization activities.

     Prior to the national Roundtable in November 1993, the
Agency will release for review a Discussion Document.  This
Discussion Document will look at specific mechanisms for source
reduction within RCRA, and through state authorities and
voluntary mechanisms.  The Discussion Document will also frame
the key waste minimization issues as a means to facilitate the
dialogue at the Waste Minimization Roundtable expected to be held
in November 1993.

Interim Final Guidance on Waste Minimization Program in Place

     Published in the Federal Register on May 28, 1993, the
intention of this Guidance is to:  1) provide a centerpiece that
can be used to focus generators' efforts in hazardous waste
minimization; 2) clarify EPA's policy on what an adequate wast«
minimization program in place under RCRA should look like; 3)
specify what activities EPA considers to be "waste minimization;"
and 4) open a debate on the relative merits of different kinds of
recycling.  The public has been invited to submit written
comments on this Guidance.  In addition, we will have discussions
about this Guidance at the November Roundtable with industry,
states, environmental and citizen groups,  and the Regions.  We
anticipate addressing these comments in mid-1994, most likely
through publication of a final guidance document.

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            of List of Generators Reguired to Have Waste
           * Programs \p p--- —
     RCRA sections 3002(b) and 3005(h) require hazardous waste
generators to sign waste minimization certifications on their
hazardous waste manifests and, if those generators are also
permittees of treatment, storage, and disposal units, to have a
waste minimization program in place.

     EPA will publish a list of generators who must certify that
they have programs in place and will send letters to these
companies requesting that they make their programs public to the
extent consistent with business confidentiality considerations.
The letters to companies will be sent out in the second quarter
of FY 1994, and the list published in the third quarter of FY
1994.

Targeting

     In addition to addressing major issues associated with
hazardous waste management, EPA will concentrate its efforts on
specific waste streams and on those industries and processes
that, when waste streams are minimized, will result in the
greatest environmental benefit.  In addition, the technical
feasibility of reduction in waste streams as well as
compatibility and coordination of federal and state waste
minimization programs will be considered.  Available data bases,
such as the BRS and TRI, will be used to assist in this
evaluation.  The analysis of the generator universe will begin in
the third quarter of 1993.  A draft targeting plan will be put
together in the second quarter of FY 1994.  Implementation of
that plan will begin thereafter.

     It should be emphasized that the Office of Solid Waste (OSW)
sees value in reduction of all hazardous waste.  However, the
initial focus will be on those wastes that ultimately are
incinerated or burned in boilers or industrial furnaces.  This is
mainly a starting point from which EPA will begin our waste
minimization campaign in the context of RCRA wastes.  OSW will
continue and expand its efforts in seeking to minimize ALL
hazardous wastes, and will gain valuable lessons that can be
applied to the larger generation universe from this combustion
strategy.  At the same time, OSW will also be looking carefully
on the impacts of waste minimization on the amount of capacity
available for waste combustion.  On this and all other issues,
EPA will work closely with the states.

Final Waste Minimization and Waste Management Strategy

     After the Waste Minimization Roundtable and other analysis
has been done, EPA will finalize its Waste Minimization Strategy
most likely in the first quarter of FY 1995.  The final Waste
Minimization Strategy will of necessity have to be based on a
detailed understanding of the generator universe, the treatment

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universe, waste minimization opportunities that exist, state and
federal coordination, and impacts of waste minimization on
manufacturing as well as waste generation and treatment.  In
addition, the Agency will also need to understand the impact of
its final strategy on the amount of capacity available for waste
combustion and the states' capacity assurance plans.
 L
     This strategy will include mechanisms that the Agency
believes will be the most effective in achieving source reduction
and recycling.  Many of these mechanisms may lie both within
current RCRA authority as well as outside of RCRA.  In evaluating
these mechanisms, the Agency will also be cognizant of the
economic and operational impact on both the generators and the
hazardous waste treatment industry.  EPA will look carefully at
many of these issues, including: the beneficial role that source
reduction can play in helping combustion units meet technical
standards; the shifts in the use of virgin fuels and price of
fuels burned in boilers and industrial furnaces, the price of
treating hazardous waste, shifts in recycling as a result of
source reduction; operational behaviors of industry changing as a
result of source reduction and recycling; understanding the
decrease or increase in risks and environmental trade-offs
resulting from increased source reduction and recycling activity;
the economic impacts to the combustion industry; and the economic
impacts and benefits to the generators.

CONTACT:  Donna Perla  703-308-8402

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                   DRAFT STRATEGY  PPn.TgrT  PLANS

                        TECHNICAL  STANDARDS

     The  primary  effort is  to  review  and  evaluate the current
 regulations  for incinerators,  boilers, and  industrial furnaces
 burning hazardous waste to  determine  which  provisions should be
 revised to strengthen the controls, to make them more readily
 implementable, and to clarify  ambiguities.  In addition, EPA will
 continue  on-going activities to implement the Boiler and
 Industrial Furnace (BIF) rule.  Finally,  EPA will evaluate
 alternative  treatment technologies to identify the advantages and
 disadvantages of  available  treatment  technologies as possible
 alternatives to combustion.

 Upgrade Regulations

     To identify  and  discuss concerns with  the incinerator and
 BIF regulations,  EPA  expects to conduct a Roundtable for
 stakeholders in November, 1993.   Representatives of regulated
 facilities,  EPA Regions, states,  and  local  and national
 environmental and citizen organizations will be invited to
 participate.  To  facilitate discussions at  the Roundtable, the
 Agency will  develop a Discussion  Document containing a menu of
 issues/problems and possible options  for  resolution for
 distribution prior to the meeting.  The Discussion Document will
 be based  primarily on issues raised at the  BIF Roundtable held in
 February, 1993, comments to be solicited  from invitees to the
 upcoming  Roundtable,  and input from Agency-state groups involved
 in considering potential proposals to revise the regulations.

     EPA  will also evaluate whether additional emissions testing
 is needed to better characterize  organic  arid metals emissions,
 better understand the design and  operating  factors that affect
 emissions, and evaluate control alternatives.  Further, the
Agency will  evaluate  the need to  identify,  test, and validate
 better continuous emissions monitors.  In considering approaches
 and developing options  for  upgrading  the  technical standards, EPA
will also consider other issues related to  the design and
 execution of trial burns, the nature  and  coverage of state
regulatory programs,  new versus existing  facilities,
 encouragement of  "state of  the art" technology, and state
capacity  planning issues (to the  extent relevant).  In addition,
cross-program issues  related to waste combustion and Land
Disposal Restrictions will  be considered.

     The Office of Solid Waste (OSW)  will be holding discussions
with the Office of Air Quality Planning and Standards (OAQPS) to
determine whether to  issue  regulations under joint authority of
the Resource Conservation and Recovery Act  (RCRA)  and Section 112
of the Clean Air  Act  (CAA).  OAQPS' current schedule for
proposing MACT (maximum achievable control technology) standards
for cement kilns  is consistent with OSW's schedule for revising
the hazardous waste combustion rules; issuing rules under joint

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authority for hazardous waste burners  in other source categories
 (e.g./ incinerators,  industrial boilers, utility boilers, halogen
acid furnaces) will also be discussed".

     EPA's current plans are to propose revised combustion rules
in early 1995, and to promulgate final rules a year later.

on-Going Activities to Implement the BIF Rule

     EPA will continue work on a number of activities to
implement the BIF rule.  For example, the Agency is considering
the development of an administrative stay of the health-based
nonmetal limits for Bevill-excluded residues.

Evaluation of Alternative Treatment Technologies

     Alternatives to hazardous waste combustion involving
innovative treatment technologies have the potential to play a
role in the management of hazardous waste.  Although alternative
treatment technologies are available or under development, they
have individual advantages and disadvantages.  EPA's
investigation will use the results of on-going efforts wherever
possible (e.g., the American Society of Environmental Engineer's
Waste Tech program) to evaluate alternative technologies
considering factors including:  status of development; types of
waste matrices amenable to treatment; types of toxic compounds
amenable to treatment; treatment efficiency; treatment emissions;
residue management; cost; and administrative issues.  This
evaluation will start in Fall 1993 and be ongoing.  Results of
the evaluation will be factored into other projects (e.g., waste
minimization; technical standard development) on an as-needed
basis.

CONTACT:   Robert Holloway  703-308-8461

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                   DRAFT STRATEGY  PROJECT  PLANS

           PUBLIC  INVOLVEMENT  AND  PERMITTING RULEMAKING

     As an outcome of the May 18,  1393 Draft Combustion Strategy,
a rulemaking is underway to enhance public participation and
improve the permitting process at RCRA sites.   The focus will be
on identifying means to encourage effective public participation
and on maintaining the administrative feasibility of the
permitting process.

     In the area of public involvement, EPA is evaluating
possible proposals to expand participation in the following
areas:

          Application Submittal
          Draft Trial Burn Plan
          Draft Risk Assessment.

The permitting piece of the rulemaking will focus on proposals
for changes to procedures and regulations in the following areas:

          Revising 270.42 Appendix I modification table to more
          accurately reflect shake down and trial burn scenarios.

          Developing guidance on trial burn failure and
          retesting.

          Foreclosing continued operations, at interim status
          facilities at which permits have been denied.

A proposed rule is currently estimated to be published in the
Federal Register in the fourth quarter of FY 1994, and a final
rule is expected approximately one year later.

     EPA will also continue its public participation outreach
efforts through the RCRA Public Involvement Network.  The Network
is composed of EPA representatives who carry out RCRA public
participation activities in their affected Regions.  EPA, in
conjunction with the Network, drafted the RCRA Public Involvement
Manual.  This guidance manual provides information on how to
perform public involvement activities that are required as part
of RCRA and describes other techniques beyond the requirements
that staff can use to more effectively involve the public in th«
RCRA permitting process.  The manual is scheduled to be
distributed in Winter 1993.

CONTACT:  Victoria van Roden  703-308-8623

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                   DRAFT STRATEGY PROJECT PLANS

                         RISK ASSESSMENT


     The Agency's draft hazardous waste combustion strategy calls
for EPA Regions and States to conduct site-specific risk
assessments, including indirect exposure, at incinerator and BIF
facilities as part of the permitting process.  The purpose of the
risk assessment projects is to ensure that these risk assessments
are technically sound and that guidance and assistance are
provided to ensure that they are conducted in a timely and
consistent manner.

     There are two major activities under this project.  First,
EPA will develop guidance material to assist Regions and States
in conducting these assessments.  This guidance, which is being
developed by the Agency's Indirect Exposure work group, will
consist primarily of an addendum to the 1990 ORD document
"Methodology for Assessing Health Risks Associated with Indirect
Exposure to Combustor Emissions."  The addendum will update the
1990 ORD document where appropriate and provide additional detail
in some areas.  In addition, OSW will prepare another document
which will provide specific guidance on various implementation
issues needed to conduct risk assessments at hazardous waste
combustion facilities.  These materials are expected to be ready
in draft form for review and interim use by the Regions and
States by September 1993.  External peer review will also be
conducted, most likely in the first quarter of FY 1994.  EPA is
currently assessing other mechanisms to obtain outside input on
these materials.  Updates to the guidance to reflect external
comments and new information will be made in early 1994.

     Second, EPA will provide direct assistance to the EPA
Regions and States.  This will include headquarters response to
technical questions and will also include assistance in
identifying appropriate contract vehicles and funding sources
when needed by the Regions.  This process is already underway,
and tentative decisions on guidance materials are being provided
in response to questions.  Contract vehicles have been
identified, and assistance in getting access to them is
available.

CONTACT:  Alex McBride  202-260-4761

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                   DRAFT STRATEGY PROJECT PLANS

                          IMPLEMENTATION

     Headquarters  incineration experts will be available to
assist the Regions and  states as they encounter issues and
questions in  implementing the Combustion Strategy within their
programs and  at  specific sites.  Headquarters implementation
staff will remain  in close contact with Regional permit writers
through conference calls and meetings to identify and resolve
significant issues.  For example, the Implementation Subgroup
will take the lead on addressing issues such as how the
Combustion Strategy should affect Army chemical demilitarization
(nerve agent)  incinerators, popping furnaces (explosives
incinerators), and mixed (radioactive and hazardous) waste
incinerators,  and  will  be looking at how the activities presented
in the Combustion  Strategy relate to other RCRA permit program
activities.

     Members  of  the Implementation Subgroup will provide input to
rulemaking activities stemming from the strategy to assure
practicality  of  implementation through the permitting program.
Guidance will be developed to clarify (and make improvements to,
as appropriate)  EPA's policy on trial burn failures.  This
guidance will be transmitted to the Regional and state permit
writers and will be used as a support document in developing
amendments to permitting regulations.  The written guidance will
become available by the time the permitting/public involvement
regulatory amendments are proposed in early 1994.

     The Implementation Subgroup will also be developing
technical support  materials to assist the permit writers in using
the omnibus permit authority to implement, as necessary to
protect human health and the environment, the dioxin and
particulate matter controls set forth in the Strategy.  This will
include areas such as planning trial burns, interpreting trial
burn data, and setting permit conditions.  Because the Regions
and States are faced with immediate needs for planning trial
burns and other  near-term permitting actions, we expect to be
providing informal  technical support on an ongoing basis and
draft guidance in  Fall  1993.

     As information comes to light during OSW's rulemaking on
technical standards, the Implementation Subgroup will also work
with permit writers to assist their efforts with respect to
control measures in permits necessary to protect human health and
the environment.   The Implementation Subgroup will also provide a
link between  the general risk assessment guidance and technical
issues on site-specific risk assessments by working with the
Regional permit  writers to identify issues and coordinating with
OSW risk assessment personnel to develop resolutions.  This
effort has already  begun and will continue on an ongoing basis.

CONTACT:  Sonya  Sasseville  703-308-8648

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