United States
Environmental Protection
Agency
Solid Waste and
Emergency Response
(5305)
EPA530-N-94-005
September 1994
v>EPA Strategy Update
A Newsletter on EPA's Hazardous Waste
Minimization and Combustion Activities
THE
Director's Chair
by Mike Shapiro
Director, EPA Office of Solid Waste ,
Welcome to
Strategy Update,,
This quarterly bul-
letin will provide
you with information on Office oft
Solid Waste, (OSW) activities associ-
ated with^EPA's" Draft Hazardous
Waste, Minimization attoT, Combus-
tion Strategy. The goals of the draft
strategy, released in. May 1993, are:
(1) greater source reduction of jhkz-
arddus Waste; (2) earlier and, more
effective public participatiori at indi-
vidual sites and in setting a national
source reductton* agenda; (3) 5m- ;
proved safety controls on,hazardous
waste facilities; (4) better scientific
understanding with regard to waste
combustion issues; and (5), use of
full legal authority nx permitting
and enforcement. ~
As you will read irrthis issue of the
Strategy Update, EPA, j-d.rea4y.has be-
gun taking action to meet the goals
outlined in the Draft Strategy. The
Agency introduced in May its draft^
Exposure, Assessment Guidelines,*
intended to increase '"the"', effective-
ness of risk screening assessments at
RCRA hazardotts waste combustion
facilities, In June, EPA released its
proposed rule to enhance pubjic in-
volvement arid permitting, designed
to improve the permitting ^process
and facilitate increased public par-,
ticipation, ^And the Combustion
Emissions" Technical Resource Docu-
ment was released in May as the
initial step in EPA's development of
improved standards for hazardous
waste combustors.
(ConQoued onpsge '4)
WASTE MINIMIZATION
Waste Minimization Plan Released
|n May 24, EPA released a Draft RCRA Hazardous Waste Minimization
^National Plan that, when implemented, will help reduce the amount
and toxicity of RCRA hazardous waste, particularly when such reductions bene-
fit more than one environmental medium. In releasing the Plan, EPA empha-
sized that the document is a draft that will be subject to a broad and open
national review.
Phase I of the Draft Plan applies to hazardous wastes containing significant concen-
trations of metals and/or halogens likely to be combusted in boilers and industrial
furnaces or hazardous waste incinerators. Implementation of Phase I is planned to be-
gin this fall. A key component of the Draft Plan is setting priorities to promote waste
minimization. EPA recently announced in the Federal Register availability for review
and comment its draft methodology entitled "Setting Priorities for Waste Minimiza-
tion." The public comment period for the draft methodology document extends
through September 9,1994.
Under Phase II of the Plan, EPA intends to move beyond hazardous waste man-
aged in combustion units to promote source reduction and recycling for wastes
managed by other practices. Phase II of the Plan will continue to focus on
wastes that pose the greatest multi-media hazard and exposure potential.
To seek further comment on the Draft Plan, EPA will be holding a meeting with
stakeholders on Phase I of the Draft Hazardous Waste Minimization National
Plan in Washington, DC, on September 20-22, 1994. The public is welcome to
observe discussions among invited participants, who will include representatives
of environmental organizations, regulated companies, industry trade associa-
tions, pollution prevention technical assistance centers, and state, local, and fed-
eral regulatory officials.
Copies of the Draft Hazardous Waste Minimization National Plan and the draft
methodology document and information regarding the time of the September
meeting can be obtained by calling the RCRA Hotline.
Recycled/Recyclable
Printed on paper that contains at
least 50 percent recycled fiber
-------
ns andmanystatc
final permit
gyrating in-
jojrs^nd,iiJ3i TOuersjnd^giaiiigTal^
'urnac,S§ (BiFs) are currently tin- 1
_ !'.'!""."' ' feraHKB«yg
ous waste.oco|nDUS- '
SnaO!
aiyi.ifttMB** *U«KitoJi;'«Maii
demilitati-
enualyln the universe'.
onsite incmera-
"lh"
ors wthdrew from the tu»verse •'••.
jiiihniiiissi; jiBiiiiiia JMiiliinitKisiiihsimiiiiiiniitiH^aiK.BB! a» Sjiiit«UiJ!ui.«:(™ sm^sffia.'Si'fcsR-K-ss
i Jp! Jilflljlllia J^IpniWIHKhSligilliiniltlH^aiK.BB! !H UMUMttH «Elt^Sffia.'ai'ffi:-
iperfratted facilities (rnost units
bui): cotamer-
_ity;,_an 3 interim status
«Sides tl libirutiercial and 2
"^^ ............... zxl*. ------ *~ .. .....
SilESli
was issued by me state of •
±- m^m my.™ y ™, "f -!*i"n!., iff-Kjl^ ^!jSf!S!i 1*3£j£iv, 1-, n-ir.v^
iexas^irjjFebruarY 19g4,..|PA,.||—
_.,:,,.,gg.^_,|s_,.^
SBcaOion for Marine Shale
"""•f i-a"""~
r.LA,
interim statijs
ities have withdrawn from
WASTE MINIMIZATION
Biennial Report to Be Released
This 'fall, EPA plans to publish the National Biennial RCRA Hazardous
Waste Report (based on 1991 data), including a list of generators who
were classified as Large Quantity Generators (LQGs) in ,1991. Under RCRA,
these LQGs are required to certify that they have waste minimization programs
in place. Because the list is based on information concerning waste generation
practices in 1991, for various reasons a generator on the list may no longer be
an LQG and thus no longer subject to these requirements. The Report and the
LQG list will be available in printed form, on diskette, and on-line via EPA's
public access server on the Internet. The Report's data files will also be available
on the Internet.
Three Companies Win EPA Waste Minimization Awards
|uring the Waste Minimization and Combustion Roundtable hosted by Re-
'gion 5 in Chicago on April 30, Special Waste Minimization Awards were
given to three Midwest companies who demonstrated "environmental awareness,
innovative approaches, and bold corporate action." The winners were:
Enamel Products and Plating Co. (Portage, IN). Through process changes
and substitution of raw materials, this company cut the use of glycol ester by
over 10,000 gallons and saved more than $10,000 in 1992. Enamel Products
and Plating also cut annual wastewater discharges by 92,000 gallons, energy
consumption by 19 percent, and water use by 5 million gallons.
Chrome Deposit Corporation (Portage, IN). Also through process changes
and substitution of raw materials, Chrome Deposit cut wastewater sludges by 51
percent, saving over $10,000 in disposal costs. The company also cut wastewa-
ter discharges by 43 percent. •....-.•..
./
Mead Packaging Division (Chicago," IL). Mead Packaging has replaced sol-
vent-based inks with water-based inks and has been regularly recycling nonhaz-
ardous wastes, including over 15 tons of steel banding. The company also is
changing the packaging of incoming inks, which will eliminate the need to dis-
pose of over 1,000 plastic totes and drums.
COMPLIANCE AND
ENFORCEMENT
'ince May 1993, EPA has announced two major enforcement initiatives
^targeted at boilers and industrial furnaces and hazardous waste incinera-
tors. Developed in conjunction with state offices, the initiatives were launched
in September 1993 and February 1994, respectively. Under these two initiatives,
enforcement actions have been taken at 53 facilities, with nearly $25 million in
proposed new penalties and $2.5 million in settlement (collected) penalties.
From May 1993 through February 1994, two-hundred and eight hazardous
waste combustion facilities comprising 60 percent of the total universe of these
facilities have been inspected. One-hundred and four facilities had no violations
detected, for a compliance rate of 54 percent. Of the 88 facilities that had poten-
tial violations, a total of 408 potential violations were identified. As of March 1,
1994, forty-five percent of these potential violations had been corrected.
-------
PERMITTING AND PUBLIC INVOLVEMENT
Roundtable Gatherings Held
"our 1-day Regional Roundtables on Hazardous Waste Minimization and
Combustion were held in San Francisco, Houston, Chicago, and Atlanta in
April and May. Approximately 500 participants and observers shared their views with
EPA on a broad range of issues, including pollution prevention, combustion stand-
ards, permitting, compliance and enforcement, environmental justice, siting, and risk
assessment. Summary reports of the Roundtables will be sent to attendees.
Permitting Guidance on Trial Burn Failure Released
,n July 5,1994, EPA issued guidance for permit writers on successful and unsuc-
cessful trial burns. The guidance clarifies EPA's policy on trial burns for incinera-
tors and boilers and industrial furnaces. The guidance covers in detail (1) what
constitutes a successful trial burn; (2) how to handle invalid data collected during a trial
bum; (3) what constitutes an unsuccessful trial bum; (4) how to handle a request for a
trial burn retest; and (5) how to restrict operations after an unsuccessful trial burn.
Proposed Rule on Public Involvement and Permitting Published
Obtaining EPA
Documents
Through the
RCRA Hotline
Many EPA documents and other
information related to the Draft
Hazardous Waste Minimization
and Combustion Strategy can be
obtained by contacting EPA's
RCRA/Superfund Hotline.
- i
The RCRA Hotline can be
reached by calling (800) 424-
9346 or TDD (800) !553-7672 for
the hearing impaired. For Wash-
ington, DC, and outside the
United States, call 1(703) 412-
9810 or TDD (703) ;412-3323.
n the first regulatory action taken by EPA under the Draft Hazardous Waste
Minimization and Combustion Strategy, the Agency released its proposed
rule on public involvement and permitting on June 2, 1994. The comment pe-
riod is open until September 1, 1994.
Objectives of the proposed rule are to (1) expand opportunities for timely and effective public involvement in the RCRA permit-
ting process for all types of units; (2) improve permit modification regulations by clarifying the classifications of various types of
modification requests; and (3) better align permitting procedures for interim status combustion units with the more stringent
procedures for new combustion units, particularly with regard to trial burns. This proposed rule does not address technical
standards for incinerators or boilers and industrial furnaces, but does invite comments on enviromental justice and public in
permitting. EPA's goal is to publish a'final rule oh public involvement and permitting by July 19P5.
Call the RCRA Hodine to order the documents described, above.
RISK ASSESSMENT
Risk Assessment and Trial Burn Guidance Issued
H n May 1994, EPA released the Draft
fl Exposure Assessment Guidance for
RCRA Hazardous Waste Combustion
Facilities. The document provides de-
tailed methodologies for conducting
risk screening assessments, as well as a
revised list of hazardous constituents to
be evaluated.
The guidance document contains re-
vised information on how to plan and
conduct trial burns in light of the infor-
mation needed to conduct the indirect
risk assessments called for by the Draft
Waste Minimization and Combustion
Strategy. The guidance also explains
which waste characteristics and oper-
ating parameters (e.g., temperature) af-
fect the nature and amounts of
emissions from hazardous waste com-
bustors. Products of incomplete com-
bustion (PICs) are discussed in detail,
with recommentations for increased
stack measurements. The guidance also
covers how to use successful trial burn
data to develop fully protective permit
conditions for the incinerator, boiler, or
industrial furnace.
This guidance document was among
those discussed at an EPA Science Ad-
visory Board informal consultation on
June 29; EPA will continue to revise
the guidance based on the latest infor-
mation available. The guidance docu-
ment is available through the RCRA
Hotline.
In addition, EPA has convened a risk
assessment review group to assist rer
gions and states in planning, conduct-
ing, and reviewing risk assessments at
RCRA combustion facilities. This tech-
nical assistance group is comprised of
risk assessment experts from EPA's Of-
fice of Research and Development and
Office of Solid Waste, as" well as from
EPA regional offices.
-------
TECHNICAL STANDARDS
Combustion Emissions
Document Released
On May 24, EPA's Office of Solid
Waste announced release of the
Agency's Combustion Emissions Tech-
nical Resource Document (CETRED).
CETRED contains the Agency's pre-
liminary technical analysis concerning
emissions of dioxins/furans and par-
ticulate matter from certain types of ex-
isting devices that bum hazardous
waste: cement kilns, light-weight aggre-
gate kilns, incinerators, and boilers.
This document represents EPA's first,
preliminary step in the development of
regulations under RCRA and the Clean
Air Act to impose upgraded standards
on hazardous waste combustors.
CETRED identifies a dioxin/furan level
of 0.1-0.2 TEQ ng/dscm for the best-
controlled hazardous waste burners,
and a paniculate matter level of 0.005
gr/dscm.
EPA's intention in releasing CETRED is
to give the regulated community and
other interested persons the earliest
possible opportunity to understand the
nature of the technical analysis that
EPA is pursuing. Copies of CETRED are
available through the RCRA Hotline.
1HE
In addition, OSW is taking steps to
faddress^ ..... hazardous wastef i environ; .
mental justice issues and stay
abreast of Agency-wide initiatives
in response to the Executive Order
on Environmental Justice. For ex-
ample, in April, a Siting Task Force
was es^|blished to identify and %-
^|| options to address siting of
RCRA hazardous waste facilities. ;
The Task Force will examine op-
tions that range from setting
technical location standards (for
example, setback distances) to en-
hancing public information and
Input as part of the siting process.
Status of Activities on Technical Studies
[PA is continuing its efforts to develop the technical information pertinent
gto, among other things, revising emissions standards for hazardous waste
combustors under rules scheduled to be proposed by September 1995. High-
lights of these efforts include:
Dioxin Research. EPA's Air & Energy Engineering Research Laboratory
(AEERL) is conducting research on dioxin/furan formation mechanisms and
control alternatives. The research will include parametric testing of various types
of paniculate matter (such as cement kiln dust) to investigate how hydrochloric
acid (HC1), chlorine, temperature, oxygen, sodium, sulfur, and gas quench
(cooling) rate affect dioxin/furan formation.
Full-Scale Testing. EPA is developing a Test Plan for emissions testing at
full-scale, facilities to provide additional data regarding control of hazardous air
pollutants (for example, products of incomplete combustion (PICs), toxic met-
als, particulate matter as a surrogate for toxic metals, and acid gases). Testing
pursuant to this plan is expected to begin this fall.
Continuous Emissions Monitors (CEMs). EPA is continuing a major ef-
fort to promote the development of CEMs for metals, particulate matter, and
PICs. This summer, the Agency is developing performance specifications and
calibration procedures for metals CEMs. By the summer of 1995, the Agency be-
lieves that metal CEM developers may have progressed to the point where a full-
scale, long-term (i.e, 30 days) performance demonstration of a monitor will be
possible. If this expectation is met, EPA plans to conduct such a demonstration
shortly thereafter. In addition, EPA is continuing to investigate state-of-the-art
CEMs designed to monitor other hazardous air pollutants and plans to engage in
unilateral and/or multiparty efforts to promote the development of promising
techniques.
EPA Documents on the Internet
The following documents are available on the Internet via
gopher.epa.gov
http:\\www.epa.gov
• Executive Summary Combustion Emissions Technical Resources Document (CETRED)
(530-S-94-014)
• Draft RCRA Hazardous Waste Minimization National Plan (530-D-94-001)
• Summary of Draft Hazardous Waste Minimization National Plan (530-5-94-002)
• Memorandum RE: Mutton Prohibition (530-F-94-018)
• Memorandum RE: Immediate Implementation of Proposed Rule (530-F-94-017)
• Universe of Hazardous Waste Combustion Facilities (530-F-94-019)
• RCRA Expanded Public Participation and Revisions to Combustion Permitting Procedures:
Proposed Ruk (530-Z-94-007)
• Update to Hazardous Waste Minimization and Combustion Strategy, May 1994: Review of Past
Activities (530-D-94-002)
To retrieve these documents once you are in the epa.gov server, take the following pathway:
1) EPA Offices and Regions; 2) Solid Waste and Emergency Response; 3) Office of Solid
Waste; and 4) Waste Minimization and Combustion Strategy. From here, you can choose
from the following categories of information: general, public participation and permitting,
risk assessment, technical standards, and waste minimization. The documents above are
listed in these five categories.
------- |