United States
Environmental Protection
Agency
Solid Waste and
Emergency Response
(5305)
EPA530-N-95-002
January 1995
v>EPA Strategy Update
A Newsletter on ERA'S Hazardous Waste
Minimization and Combustion Activities
Overall Waste Minimization and Combustion Strategy Finalized
m November 18, 1994, EPA released its
iStrategy for Hazardous Waste Minimization
and Combustion. The Strategy is a major
milestone in the Agency's effort to determine how best
to integrate source reduction and recycling into the
national hazardous waste program, and also how best
to ensure safe operation of hazardous waste
combustion facilities. This comprehensive plan is the
culmination of 18 months of intensive work by EPA
and other parties.
The Strategy sets forth EPAs goals and overall vision for
the short-term future of waste minimization and
combustion under the Resource Conservation and
Recovery Act (RCRA). With source reduction and
environmentally sound recycling at the top of the
national agenda, the Strategy outlines actions to be
taken over the next several years to maximize reduction
and also to foster a broader range of effective waste
management alternatives. The Strategy also includes
measures to ensure the safe operation of hazardous
waste combustion facilities.
At the core of EPAs Strategy are eight goals that serve as
a framework for EPAs future actions in addressing
waste minimization and combustion issues. The goals
can be summarized as:
• Public Outreach and EPA/State Coordination—EPA
will continue to facilitate an open national dialogue
among states, industry, and local communities on
significant issues. Top priority will be given to
working with states as co-regulators of hazardous
waste.
• Waste Minimization—EPA will strive to reduce long-
term demand for treatment, storage, and disposal of
hazardous waste by promoting waste minimization
alternatives. In particular, EPA will work to involve
tRocyclod/Recyclabla
/Printed on paper that contains at least 50 percent recycled fiber.
generators and the public in voluntary activities such
as technology transfer and technical assistance,
especially to smaller companies.
i Combustion and Alternative Technologies—EPA will
foster the commercial development and use of safe,
effective, and innovative treatment technologies to
reduce industrial wastes, and will ensure that
combustion is safely regulated.
i Emission Standards and Controls—Using the best
available technologies and sound science, EPA will
develop and impose rigorous controls on combustion
facilities to ensure compliance with both RCRA and
the Clean Air Act. i (Continued on page 3)
WASTE
MINIMIZATION
National Waste Minimization
Plan Announced •
|n November 18, 1994, EPA announced the
Icompletion of its Hazardous Waste
Minimization National Plan. This Plan affirms
a national policy to prevent pollution and practice
source reduction to the maximum extent feasible. The
Plan establishes three: goals:
1) To reduce, as a nation, the presence of the most
persistent, bioaccumulative, and toxic constituents
by 25 percent by the year 2000 and by 50 percent
by the year 2005.
2) To avoid transferring these constituents across
environmental media.
(Continued on page 3)
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COMPLIANCE AND ENFORCEMENT B }
EPA Announces Third Hazardous Waste Cornbostion Initiative ^^*^
In November 1994, EPA announced its third
compliance and enforcement initiative to help
ensure that boilers and industrial furnaces (BIFs)
and incinerators are operated safely. Coming on the
heels of two prior combustion enforcement
initiatives in 1993 and early 1994, this initiative
entailed 32 enforcement actions generating $7.5
million in penalties against owners and operators of
incinerators and BIFs that burn hazardous wastes.
The initiative is an important component of EPAs
ongoing efforts to minimize risks associated with the
burning of hazardous waste. It places a high priority
on conducting inspections of combustion facilities,
both those that were not inspected in die previous
year and sites previously found to be High Priority
Violators. From March through September 1994, EPA
and the states inspected 255 hazardous waste
combustion facilities. Some facilities were inspected a
number of times.
These inspection and enforcement actions reflect EPAs
commitment to deterring incinerators and BIFs from
violating RCRA combustion requirements and
returning any violators to compliance. The actions
also reflect the Agencys recognition of die public's
interest in ensuring that facilities that burn hazardous
waste do so properly. EPA will pursue guidance for
facilities that is clearer and more user-friendly, and
also will explore several avenues to increase public
confidence and involvement, including:
(1) Incorporating provisions in hazardous waste
settlement agreements to establish citizen advisory
groups or publicly accessible "on-line" compliance
monitoring systems.
(2) Using pollution prevention provisions in
enforcement consent agreements.
! EPA Enforcement Penalties
~ In its third Hazardous Waste Combustion
I Initiative, EPA enforcement and compliance
f".; actions included the following:
i • Ten admimstrative complaints were filed
FL against the owners and operators of one
'i, incinerator and nine BIFs.
u • Nine of the complaints were filed by EPA,
* and one was filed by the state of Michigan.
t • Together, the 10 complaints propose that
jr. the violators be assessed $4.2 million in
"' civil penalties.
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Twenty-two settlement agreements were
signed with three incinerators and 19 BIFs.'
Seventeen of the agreements were EPA
cases, three were led by Georgia, and South
Carolina and Utah each had one case.
The 22 agreements together recovered $3.3
million in cash penalties.
The agreements also generated nearly
$1 million worth of Supplemental
Environmental Projects (SEPs),
environmentally beneficial projects
performed by violators in exchange for
partial penalty reductions.
EPA and the states conducted 255
hazardous waste combustion, facility
inspections under the third Hazardous
Waste Combustion Initiative covering 77
percent of the total universe of 333
facilities.
Of the 255 inspected facilities, 115 were
BIFs and 140 were incinerators.
,
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WASTE
MINIMIZATION
Strategy Finalized (continued from page D
• Enforcement—EPA will continue aggressive
compliance and enforcement efforts against hazardous
waste boilers, industrial furnaces, and incinerators to
safeguard public health and safety..
• Facility Permitting Priority—Highest permitting
priority will be given to diose existing facilities where
final decisions have the greatest potential for realizing
environmental benefits or reducing risk to the public.
• Public Involvement in Permit Process—Opportunities
for public involvement in the combustion facility
permitting and enforcement processes will be
expanded.
• Risk Assessment—EPA will strive to ensure that
permits protect against unacceptable risk using up-to-
date, comprehensive mediodologies.
Copies of the Final Strategy can be obtained by calling
the RCRA Hotline at 800 424-9346.
Plan Announced (Continued from page 1)
3) To ensure that these constituents are reduced at their
source whenever possible, or, when not possible, that
they are recycled in an environmentally sound
manner.
EPA does not expect that each and every generator will
reduce the generation of diese waste constituents by the
levels and timeframes presented above. EPA intends for
these reductions to be achieved nationally by states and
generators working together.
To encourage flexibility in how industries will reduce
waste so diat the national goals.are met, EPA expects all
states and generators of hazardous wastes containing
these constituents to define their own baseline years, set
their own goals and target years for achieving their
goals, and track dieir own progress toward their goals.
This will allow states and generators drat have already
begun source reduction to measure their successes more
appropriately, and will allow diem to contribute to die
national goals in the most effective manner possible for
each facility. In die event that states and generators do
not make significant progress toward the goals over a
certain timeframe, EPA will consider whedier a greater
federal role is needed.
EPA Involves the Public
One of EPA^ main goals in developing die
Hazardous Waste Minimization and Combustion
Strategy and the Waste Minimization National
Plan was to incorporate the needs and wishes of various
stakeholders, including the general public. To accomplish
this, EPA held a series of meetings to focus on each of
diese key documents, i
After releasing die Draft Hazardous Waste Minimization
and Combustion Strategy in May 1993, EPA held bodi
national and regional discussions over die course of one.
year widi public interest groups, citizens, industry, state and
federal regulators, and1 technical experts. These discussions
focused on the goals of die strategy and covered a wide
range of combustion-related subjects, including permitting,
enforcement, and waste minimization. Summaries of these
discussions of the Strategy are available dirough the RCRA
Hotline at 800 424-93J46.
In a separate set of discussions focused on the Draft Waste
Minimization National Plan released in May 1994, EPA
again sought input from stakeholders. The Agency held a
three-day focus group/public meeting widi "external
stakeholders," a one-day meeting widi states, and a one-
day meeting widi environmental groups. Input from
stakeholders helped EPA to define and reach consensus on
die Plan's objectives, virhich are as follows:
Objective 1: Develop a framework for setting national
priorities, identify constituents of concern, and develop
flexible screening tools for identifying priorities at
individual facilities. ;
Objective 2: Promote multimedia environmental benefits
and prevent cross-media transfers.
Objective 3: Demonstrate a strong preference for source
reduction; shift attention to die nations hazardous waste
generators to reduce hazardous waste generation at its
source.
Objective 4: Clearly define and track progress; promote
accountability for EPA, states, and industry
Objective 5: Involve the public in waste minimization
implementation decisions.
Summaries of these special waste minimization meetings
are available dirough the RCRA Hotline at 800 424-9346.
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TECHNICAL STANDARDS
Fuel Blending Regulations and Restrictions
Fuel blenders (those facilities that commonly mix
hazardous wastes for burning in boilers or
industrial furnaces) must comply with a
number of hazardous waste regulations under RCRA.
EPA issued guidance in late October 1994, which is
summarized below, to serve as the general clarification
of the regulations covering fuel blenders. Since the
operations performed by fuel blenders can be complex,
however, facility-specific concerns will continue to be
best addressed on a case-by-case basis. For more
information, call James Michael of EPA at 703 308-
8610 for permit-related matters, or Rhonda Craig of
EPA at 703 308-8771 on matters related to Land
Disposal Restrictions (LDRs).
* Permit Requirements—Because fuel blending facilities
often conduct storage and treatment activities, they
are subject to full RCRA regulation (including
permitting) with only very few exceptions. Facilities
blending fuel in tanks or containers can be exempt
from permitting, but only if the blending occurs at the
site where the wastes being blended were originally
generated. Additionally, some recycling operations at a
fuel blending facility could be exempt from
permitting, but not if the reclaimed materials are
sometimes sent off site for use as a fuel.
• Air Emissions Standards—Because fuel blenders
typically manage wastes with high organic content,
they must comply with standards that limit organic
emissions from 1) process vents associated with
distillation, fractionation, evaporation, solvent
extraction, and air or steam stripping operations that
manage hazardous wastes with 10 or more'parts per
million by weight of total organic concentration; and
2) leaks from equipment that contains hazardous
waste with 10 percent or more by weight of total
organics. In "addition, with the promulgation of the
Subpart CC standards (59 £R 62896, December 6,
1994), fuel blenders will need to place air emissions
controls on any tank, container, surface
impoundment, or miscellaneous unit that manages
hazardous waste having an average volatile organic
concentration equal to or greater than 100 parts per
million by weight.
I Transfer Facilities—Transfer facilities can store wastes
in containers without RCRA permits for up to 10
days. If these facilities selectively blend hazardous
waste fuels to meet a fuel specification, they must
have a RCRA permit. (Transfer facilities include
transportation-related sites such as loading docks,
parking areas, storage areas, and other areas where
shipments of hazardous wastes are held during the
course of transportation.)
i Land Disposal Restrictions—Offsite fuel blenders
must comply with various notification, certification,
and recordkeeping requirements under the LDRs if
they become a generation source for a prohibited
waste (e.g., if they combust a prohibited waste and
produce ash residues), or if they treat or otherwise
manage prohibited wastes. Prohibited wastes are ones
that must be treated to meet certain standards before
they can be land disposed. In some cases, a one-time
notice and certification is sufficient; in other cases, full
reporting of LDR information is required.
EPA Documents on the Internet
The following documents are available on the Internet via:.
gopher.epa.gov
http:\\www.epa.gov
• Strategy/or Hazardous Waste Minimization and
Combustion
• The Waste Minimization National Plan
• Addendum: Application of Waste Minimization National
Plan Approach to the Combustion Universe
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
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.
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