United States
                           Environmental Protection
                                               Solid Waste and
                                               Emergency Response
September 1994
v>EPA             Strategy  Update
                           A  Newsletter on  EPA's Hazardous Waste
                           Minimization  and  Combustion  Activities
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.
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                          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
                               '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.

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
                                     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 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
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.

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
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.
 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
 EPA  Documents on the Internet
 The following documents are available on the Internet via
 • Executive Summary Combustion Emissions Technical Resources Document (CETRED)
 • 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.