United States
              Environmental Protection
                                          Solid Waste and
                                          Emergency Response
November 1994
               Office of Solid Waste
               Fact  Sheet
   The Environmental Protection Agency (EPA) is announcing its Strategy for Hazardous
   Waste Minimization and Combustion. The Strategy contains EPA's goals and vision, and
   also outlines a series of actions for the Agency's hazardous waste program. The Strategy
   represents a major milestone in the Agency's ongoing commitment to determine how best to
  .integrate source reduction and environmentally sound recycling into the national hazardous
   waste program and also how best to assure the public of safe operation of hazardous waste
   combustion facilities.  This document culminates 18 months of intensive effort by EPA and
   other interested parties under the Draft Strategy on Hazardous Waste Minimization and
   Combustion, announced by Administrator Carol M. Browner In May 1993.

 EPA's May 1993 Draft Strategy
 on Hazardous Waste
 Minimization and Combustion
 announced an initial set of goals
 and launched a series of steps to
 maximize reduction of the
 amount of hazardous waste
 generated and to ensure safety
 and reliability of hazardous waste
 combustion in incinerators,
 boilers, and industrial furnaces.
 The Draft Strategy enabled EPA
 to take a leadership role in the
 broad national dialogue seeking a
 balanced resolution of difficult
 and controversial waste issues.
The Draft Strategy also served as
 the focal point for all interested
 parties to take a fresh look at
 how to achieve a fully integrated
                                        waste management program 
                                        one that has the proper
                                        emphasis on source reduction
                                        and environmentally sound
                                        recycling and one that defines an
                                        appropriate role for hazardous
                                        waste combustion.

                                        These wide-ranging but sharply
                                        focused discussions have
                                        provided significant input on
                                        many key issues, including: the
                                        need for increased waste
                                        minimization, EPA's approach for
                                        upgrading regulatory controls on
                                        combustion units, flexible means
                                        to enhance public participation
                                        in permitting and to address
                                        environmental justice concerns,
                                        and the importance of aggressive,

credible compliance and
enforcement at combustion

In addition to the broad national
dialogue, EPA has taken a
multitude of significant actions
over the last 18 months in
pursuit of the strategic goals (see
Attachment for a list of major

EPA's Strategy

GOALS:  The backbone of EPA's
Strategy are eight goals. These
goals provide the framework for
EPA's future actions and for
reaching the best possible
solutions to the issues that have
arisen and will undoubtedly
continue to arise over the
management of hazardous waste
in the United States. These goals

 Public Outreach and EPA-
State Coordination: Continue
to facilitate an open and broad
national dialogue among all
stakeholders on significant
hazardous waste issues. Give
top priority to working with
states as co-regulators of
hazardous waste.

 Waste Minimization:
Under the Hazardous Waste
Minimization National Plan,
reinforce strong preference for
source reduction over hazardous
waste management in order to
reduce both the long-term
demand for treatment, storage,
and disposal capacity and the
quantities of persistent,
bioaccumulative, and toxic
constituents that need to be
managed. In partnership with
states, industry, and local
communities, pursue aggressive
use of waste minimization
measures with primary emphasis
on voluntary actions. Afford
members of the public a greater
opportunity to become aware of
waste minimization activities in
their communities.

 Role of Combustion and
Alternative Technologies:
Maintain appropriate role for
combustion, and continue  to
ensure that combustion and
other treatment facilities reduce
toxicity, volume, and/or mobility
of hazardous wastes in a manner
that is protective of public
health.  Foster the commercial
development and use of
alternative treatment and other
innovative technologies that are
safe and effective in reducing the
toxicity, volume, and/or mobility
of RCRA industrial process and
remediation wastes.

 Emission Standards and
Controls: Develop and impose
more rigorous controls on
combustion facilities  based on
an assessment of available
technologies and current
science. Develop these controls
as a coordinated effort to
implement both RCRA and the
Clean Air Act authorities for
hazardous waste combustion
facilities. Ensure that hazardous
waste combustion facilities do
not pose an unacceptable risk to
human health or the

  Enforcement and
 Compliance Assistance:
 Continue aggressive compliance
 and enforcement efforts against
 hazardous-waste burning
 incinerators and boilers and
 industrial furnaces (BIFs) while
 working with industry to ensure
 that EPA's regulations are
 understood and followed.
 Enhance public confidence in
 Agency oversight activities and
 facility compliance by promoting
 public understanding of these
 activities and increased
 opportunities for public
 involvement in the enforcement

  Public Involvement In Permit
 Process: Enhance public
 involvement opportunities in the
 process for considering permit
 applications for combustion
 facilities. Take  appropriate
 actions  to ensure that local
 communities are fully informed
 about the RCRA decision-making
 process (including waste
 minimization opportunities) and
 have an opportunity to
 participate in that process.

  Facility Permitting Priority:
 Give higher priority to those
 facilities for which a final permit
 decision would result in the
 greatest environmental benefit or
 the greatest reduction in overall
 risk to the public.  Give lower
 priority to permit decisions on
 new combustion facilities that
 are not replacing older facilities.

  Risk Assessment:  Advance
scientific understanding on
combustion issues amd risk
 assessment, and ensure that
 permits are issued at facilities in
 a manner that protects against
 unacceptable risks to human
 health and the environment.
 Use sound science in technical


 The Strategy builds upon the
 dialogue and actions taken over
 the last 18 months. A broad
 range of activities (many of
 which are already under way)
 will be undertaken to implement
 the Strategy. Among these are:

  Implementation of the
 Hazardous Waste Minimization
 National Plan. Under the
 National Plan, EPA will promote
 source reduction and
 environmentally sound recycling
 for the waste constituents that
 present the greatest potential
 hazard to human health and the
 environment ~ i.e., persistent,
 toxic, and bioaccumulative
 waste constituents.  EPA's goals
 are to reduce the most
 persistent,  bioaccumulative,
 and/or toxic constituents in
 hazardous waste by 25%
 nationally by the year 2000, and
 by 50% nationally by the year

  EPA will continue to
 emphasize the "public right to
 know," particularly with respect
 to waste minimization activities
 at generating facilities and at
 combustion facilities. To that
end, EPA will provide enhanced
level of information to the public
and stakeholder groups through

newsletter and electronic media.
EPA will also explore use of
information outreach programs
and technical assistance.

  EPA will continue its
commitment to working closely
with States as partners and4 co-
regulators.  To that end, the EPA-
State Steering Committee will be
involved on significant policy and
technical issues, and state
representatives will continue to
be brought into EPA planning
efforts  and work groups early in
these processes.

  The Strategy recognizes that
combustion of hazardous waste
is a process that substantially
and permanently reduces the
toxicity and volume of virtually
all organic-bearing waste
streams.  However, EPA also
recognizes the controversy that
has arisen over the use of
combustion for hazardous waste,
both with respect to ensuring
proper treatment/destruction
and more fully characterizing the
risks from combustion
emissions.  As a result, EPA is
making a commitment in the
Strategy to  identify and address
barriers that stand in the way of
commercial development and use
of safe  and  effective innovative

  EPA will develop and
promulgate rules that impose
more rigorous controls on
combustion facilities based on an
assessment of available
technologies and most current
science. The proposed rule is
scheduled for September 1995,
with a final rule scheduled for
December 1996. The intent is to
develop this rule in a
coordinated manner under both
RCRA and the Clean Air Act
authorities. EPA will encourage
all combustion facilities to
implement the proposed
standards to reduce emissions
as quickly as  possible, and will
itself examine how to implement
the final rule  in a manner that
achieves the greatest possible
immediate reduction in dioxin,
furan, and metal emissions at all
hazardous waste combustion
facilities, including consideration
of whether and how to reopen
and modify existing permits as

  Current efforts will be
vigorously pursued, both  inside
and outside EPA, to test
continuous emission monitors
(CEMs) for toxic organics  and
metals and to stimulate their
commercial availability and use
as soon as possible. The  goal is
to have these CEMs installed at
hazardous waste combustion
facilities as soon as possible  in a
manner that affords public
access to the  monitoring results.

  By summer 1995, EPA is
scheduled to finalize the rule to
enhance general public
involvement opportunities in the
process for considering permit
applications for combustion and
other RCRA facilities, and to
better address limiting
operations at facilities that fail
trial burns during interim

  EPA's strong and aggressive
program of inspections and
enforcement actions at
hazardous waste handling and
combustion facilities will
continue. Emphasis will be
placed on policies and
procedures that maximize facility
compliance, that increase public
confidence in Agency oversight
activities and in facility
compliance, amd that enhance
public understanding of and
involvement in the enforcement

  Avenues to be explored in
pursuing these enforcement-
related objectives are: (1)
including provisions in
hazardous waiste settlement
agreements to establish citizen
advisory committees or to create
publicly accessible, real-time "on-
line" compliance monitoring
systems; and (2) expanding the
use of pollution prevention and
waste minimization strategies in
consent agreements through
compliance requirements and
Supplemental Environmental
Projects (SEPs).

  Higher workload priority will
be given to those facilities for
which a final  permit decision
would result in the greatest
environmental benefits to the
surrounding community or the
greatest reduction in overall risk
to the public. Permit renewals
can be included in the high
priority category. The Agency
will maintain its current policy of
lower priority for work on
applications involving new, non-
replacement combustion
  The Strategy also maintains
the current policy that risk
assessments, including indirect
exposure pathways, should be
performed prior to final permit
determinations. The Agency will
continue availability of HQ-
Regional Risk Assessment
Review Team in scoping,
performing, and/or reviewing
risk assessments.

   The Strategy reaffirms EPA's
commitment to the principle
that the best approaches to
hazardous waste minimization
and management will be most
easily found and implemented in
a spirit of cooperation and
partnership among the
interested parties.  To that end,
the Strategy signals that EPA
will continue to serve as a chief
catalyst for broad and open
discussions among all interested
parties and, in particular, to
foster a full and open
relationship between RCRA
facilities and their surrounding


 Major actions implementing the Draft Strategy on Hazardous Waste
 Minimization and Combustion since May 1993 include:

  Over the past 18 months, members of the public (especially citizens
 from the local communities affected by hazardous waste activities),
 industry, public interest groups, and state officials have engaged in an
 essential, broad national dialogue on hazardous waste. This dialogue
 has occurred at a 4-day National Roundtable on waste minimization
 and combustion held in Washington, D.C. in November 1993, at four
 Regional Roundtables held in April-May 1994 in San Francisco,
 Houston, Chicago, and Atlanta, as well as in hundreds of informal
 meetings with individuals or stakeholder groups.

  In response to citizen requests for greater availability of information
 on the Draft Strategy, EPA has made key documents available on
 electronic networks and has begun a Strategy Update newsletter.  The
 Newsletter is currently mailed to over 3000 individuals, companies,
 and organizations.

  In November 1993, Administrator Browner sent letters to
 approximately 22,000 large quantity generators of hazardous waste
 that were required to certify that they had a waste minimization
 program in place in 1991.  Letters were also sent to approximately
 12,000 chief executive officers of the parent corporations of those
 generators. The letters referenced current requirements on having
 waste minimization programs and encouraged the companies to make
 those programs available to the public.

   EPA provided for broad public input into and review of its Draft
 National Hazardous Waste Minimization Plan, released in May 1994.
 This dialogue has resulted in significant advancements during
 development of the final National Plan, which is being released in
 concert with this Strategy.

  Also released in 1994 for public comment was EPA's Draft
 Methodology Document for Setting Priorities for Hazardous Waste
 Minimization.  This methodology is a key component of EPA's National

  A four-day focus group meeting in September 1994 was held in
Washington, D.C. to discuss the framework of and issues associated
with developing the RCRA Hazardous Waste Minimization National
Plan. Results of the discussions were integrated into the final National

 EPA's Office of Solid Waste (OSW) distributed to the Regions and
States an Addendum to the RCRA Implementation Plan (RIP) for FY '95
discussing how source reduction and recycling can be integrated into
the existing program (e.g., permits, enforcement agreements) and can
be pursued in non-regulatory initiatives, such as technical assistance,
training, and outreach.

 EPA initiated development of a rulemaking to upgrade the technical
emission standards and control for hazardous waste incinerators and
BIFs. EPA's initial technical analysis of the performance of existing
combustion units was released for full public review in May 1994 in the
Combustion Emissions Technical Resource Document (CETRED).
EPA's Office of Solid Waste (OSW) and the Office of Air Quality Planning
and Standards (OAQ'PS) have coordinated efforts to develop proposed
rules to set emission standards for sources that burn hazardous waste,
such as incinerators, cement kilns, light-weight aggregate kilns,
boilers, halogen acid furnaces, and other types of industrial furnaces.

 EPA and the States have undertaken three major enforcement
initiatives. The initiatives involved 93 complaints and settlements, all
of which addressed hazardous waste combustion violations. The
enforcement actions proposed over $31 million in new civil penalties,
while collecting nearly $6 million in settlement of ongoing actions.

 EPA and the States inspected over 200 facilities between May 1993
and March 1994, and made another 255 inspections at combustion
facilities between March 1994 and September 1994. Of the 255
inspections since March 1994,  115 were at BIFs and 140 at
incinerators.  Many facilities have been inspected a number of times.

 To improve compliance and enforcement efforts, EPA  has held
several compliance training sessions with Regional and  state
personnel, and has also held compliance workshops with industry
groups.  EPA is also preparing documents to better inform the public
how EPA's administrative enforcement process works, such as a "Plain
Language Guide to EPA Penalty Policies," scheduled for release this
year.  In addition, to increase understanding of the hazardous waste
regulations and the enforcement process, EPA released  an OSW
memorandum in October 1994 explaining the regulatory requirements
for intermediate waste treatment/fuel blending operations that handle
combustible and other wastes.

 EPA published a major proposal in May 1994 to revise the RCRA
rules to ensure that the public has a greater opportunity to participate
in the pennitting process. The proposal also included provisions to
limit operations at facilities that fail trial burns during interim status.
EPA directed Regions and States to begin implementation  of
appropriate portions of this proposal right away without waiting for it
to be finalized.

 EPA's Office of Solid Waste and Emergency Response convened a
task force in 1994 to explore avenues to address a number of
environmental justice and facility siting concerns raised, among other
places, at the national and regional roundtables on the Draft Strategy.
The Task Force recommendations complemented the Agency-wide
efforts, and have led to the initiation of a project to upgrade RCRA
facility location standards.

 The Regions and States have called in all permit applications for
commercial BIFs that are currently operating under interim states.
These permit applications have received higher priority in terms of
review and processing.  Permit applications and actions for new
facilities and for expanded capacity at existing facilities have been given
lower priority over the last 18 months.

 In connection with its current policy of requiring risk assessments to
be completed prior to making final permit determinations, 10 risk
assessments have been reviewed by EPA headquarters and regional
experts and a.bout another 20-30 are under way at individual
combustion facilities. To assist in this effort, EPA published two
significant technical documents  a draft Addendum to the 1991 ORE)
indirect risk guidance and a draft OSW combustion facility risk
assessment guidance (including a risk screening protocol). These
documents incorporate the latest information on performing risk
assessments, particularly with respect to indirect exposure pathways,
which have proven to be very significant in connection with combustion