United Stales Office of Solid Waste EPA/530-R-92-Q20
Environmental Protection and Emergency Response May 1992
Agency (OS-305)
vvEPA RCRA Waste
Minimization Action
Plan
Printed on paper that contains
at least 50% recycled fiber
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THERCRA
WASTE MINIMIZATION ACTION PLAN
May, 1992
prepared
by
EPA Waste Minimization Task Group
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Contact
Waste Minimization Branch
Office of Solid Waste
(703)308-8402
3 cf
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THE RCRA WASTE MINIMIZATION ACTION PLAN
CONTENTS
Page
ACRONYMS [
INTRODUCTION l
SECTION 1 - BACKGROUND
A. EPA's Pollution Prevention Program 1
B. Integrating Source Reduction and Recycling
into the National RCRA Program 2
C. Goal of the RCRA Waste Minimization
Action Plan 3
D. Definition of Terms 4
E. The Four Basic Premises of the
RCRA Pollution Prevention Action Plan 4
F. Formulating the Action Plan 6
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SECTION 2 - KEY RCRA WASTE MINIMIZATION ACTIVITIES
Key Activities
I. Promoting RCRA Hazardous Waste Source
Reduction and Recycling Through Permitting 8
II. Implementing Source Reduction and Recycling
Through RCRA Enforcement Activities 12
HI. Providing Outreach on OSW's Source
Reduction and Recycling Activities 15
IV. Evaluating Needs and Methodologies to
Measure Waste Minimization 17
V. Incorporating Source Reduction and Recycling
in Future Listings 19
VI. Incorporating Source Reduction
and Recycling in the BDAT Process 22
VII. Identifying and Promoting Source Reduction and
Recycling Opportunities for Special Wastes 25
VIII. Evaluating Generators' Perspectives on
Incentives and Barriers to Waste Minimization 28
IX. Evaluating Waste Minimization Projections
Made in State Capacity Assurance Plans 31
X. Improving Hazardous Waste Recycling
Program Implementation 33
XI. Providing Flexibility .to Target RCRA State
Grant Funds to Waste Minimization Needs 35
XII. Demonstrating Source Reduction and Recycling
at Specific Facilities 37
Xlil. Supporting Technical Assistance Efforts 40
XIV. Managing and Supporting Implementation
of the Action Plan 42
Appendix A: Responses to the October 5, 1991
Federal Register Notice on Waste Minimization 44
Appendix B: Discussion at the Focus Groups 45
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ACRONYMS
ANPRM
ASTSWMO
BDAT
CABD
CAD
CAP
CPB
HSWA
NACEPT
OAR
OE
OPPE
OPPT
ORD
OSW
OSWER
OW
OWPE
PPIC
PSPD
RCRA
RDB
RED
RIP
SWB
TRI
TSCA
WMB
WMD
Advanced Notice of Proposed Rule Making
Association of State and Territorial Solid Waste Management
Officials
Best Demonstrated Available Technology
Communication Analysis and Budget Division
Characterization and Assessment Division
Capacity Assurance Plan
Capacity Programs Branch
Hazardous and Solid Waste Amendments
National Advisory Council on Environmental Policy and Technology
Office of Air and Radiation
Office of Enforcement
Office of Policy Planning and Evaluation
Office of Pollution Prevention and Toxics
Office of Research and Development
Office of Solid Waste
Office of Solid Waste and Emergency Response
Office of Water
Office of Waste Programs Enforcement
Pollution Prevention Information Clearinghouse
Permits and State Programs Division (OSW)
Resource Conservation and Recovery Act
Regulatory Development Branch (OSW)
RCRA Enforcement Division (OWPE) '
RCRA Implementation Plan
Special Wastes Branch (OSW)
Toxic Release Inventory
Toxic Substances Control Act .
Waste Minimization Branch (OSW)
Waste Management Division (OSW)
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THE RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)
WASTE MINIMIZATION ACTION PLAN
INTRODUCTION
Over the past several years, the U.S. EPA has
emphasized pollution prevention as a preferred
method of environmental protection over "end-of-
pipe" treatment and disposal approaches. EPA
Administrator William Reilly has continually
stressed the importance of pollution prevention
and has focused Agency resources on minimizing
or eliminating the adverse effects of pollution in
our lands, air, and water. Congress reinforced
this approach by enacting the Pollution Prevention
Act of 1990 that established a national policy on
pollution prevention. EPA's implementation of
the Resource Conservation and Recovery Act
(RCRA) included pollution prevention as an
integral element in all of its programs and will
continue to do so.
To further EPA's pollution prevention goals, this
plan has been developed to incorporate pollution
prevention into various established RCRA
activities. This document, the RCRA Waste
Minimization Action Plan (referred to throughout
this document as the "Action Plan"), outlines
those activities expected to be implemented over
the next five years that will integrate the Agency's
Pollution Prevention concepts into the RCRA
program. The Action Plan is divided into two
major parts. Section I describes EPA's pollution
prevention program; the goals of the Action Plan,
including the Plan's four basic premises; and how
the Action Plan was formulated. Section II
identifies specific activities where source reduction
and recycling will be pursued as part of RCRA
projects or programs. This section describes
specific projects and provides general time frames
for completing these tasks.
SECTION I. BACKGROUND
A. EPA's Pollution Prevention Program
EPA's commitment to pollution prevention is part
of an overall restructuring of the Agency's
environmental agenda, spurred both by the
magnitude and seriousness of the environmental
risks that must be addressed in the 1990s and
beyond, and our increasing understanding of the
complexity of ecological systems. To address
these environmental challenges, EPA issued a
Pollution Prevention Strategy in January 1991.1
This Strategy outlines EPA's pollution prevention
policy and objectives, and is designed to:
set forth a program that will achieve specific
objectives in pollution prevention within a
reasonable time frame, and
provide guidance and direction for efforts to
incorporate pollution prevention within EPA's
existing regulatory and non-regulatory programs.
As one of the initial efforts to address the first
objective, EPA initiated the 33/50 Project
(formerly called the Industrial Toxics Project
(FTP)). The 33/50 Project aims, through
voluntary pollution prevention activities, to reduce
releases and off-site transfers of a targeted set of
17 toxic chemicals from an aggregate of 1.4 billion
pounds in 1988, to 938 million pounds by the end
of 1992 (a 33 percent reduction) and finally down
to 700 million pounds by the end of 1995 (a 50
percent overall reduction). Several components of
this Action Plan target industries generating these
17 chemicals and can be useful in supporting
EPA's 33/50 Project objectives.
The Strategy was issued by the Pollution Prevention Office (formerly part of the Office of Policy
Planning and Evaluation) which was reorganized under the Office of Pesticides and Toxic Substances.
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To meet its second objective, the Pollution
Prevention Strategy promotes a risk reduction
hierarchy that emphasizes hi descending order of
desirability: source reduction, environmentally
sound recycling, proper treatment, and safe
disposal. Under this hierarchy, source reduction
is the first step for reducing risks to public health
and the environment. The second step is
environmentally sound recycling of wastes that
cannot be reduced at the source. The third step,
for wastes that cannot be prevented or recycled, is
treatment in accordance with environmental
standards designed to reduce both the hazard and
volume of waste streams. The final step is to
safely dispose of treatment residuals in a manner
that minimizes the potential for environmental
release.
The Pollution Prevention Strategy recognizes that
the Agency will continue to promulgate and
enforce regulations required under its various
statutory authorities and that these regulations
continue to provide incentives to prevent pollution
by increasing the cost of managing waste and
pollution. However, EPA firmly believes that for
pollution prevention to succeed, it must be a
central component of Agency programs designed
to protect human health and the environment. To
achieve this goal, the Agency is moving to
incorporate pollution prevention into every facet
of its program, including Regional operations,
enforcement actions, regulations, permits, and
research and development. Many pollution
prevention activities are currently being
conducted. Summaries of some of these activities
can be found hi the October 1991 EPA
publication Pollution Prevention 1991: Progress
on Reducing Industrial Pollutants.
This Action Plan describes EPA's plan to
continue implementation of pollution prevention
concepts into RCRA programs as part of EPA's
integrated pollution prevention initiatives.
B. Integrating Source Reduction and
Recycling into the National RCRA
Program
The RCRA program divides waste into four broad
categories:
- hazardous waste (approximately 240 million
tons generated per year)
- municipal wastes (approximately 180 million
tons generated per year)
- industrial special wastes (approximately 5.2
billion tons of mining, cement kiln, oil and gas
development, and utility wastes generated per
year), and
- industrial nonhazardous waste (e.g., various
sludges and food wastes) (approximately 7.6
billion tons generated per year)
The EPA programs addressing these four.waste
types are at various stages of development, as are
the respective source reduction and recycling
strategies.
EPA initiated the first elements of a hazardous
waste pollution prevention program following the
passage of the Hazardous and Solid Waste
Amendments of 1984 (HSWA). This is because
HSWA itself placed a higher priority on waste
minimization than treatment or disposal of
hazardous waste. In particular, Section 1003 of
HSWA establishes that a national policy under
RCRA shall be to "minimize the generation of
hazardous waste by encouraging process
substitution, materials recovery, properly
conducted recycling, and reuse and treatment." In
addition, several provisions were included in
2 This figure does not take into account the impact of the new Toxicity Characteristics rule which will bring
a significant volume of previously unregulated waste into the federal hazardous waste management system.
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HSWA that were intended to minimize the
generation of hazardous waste. One set of such
provisions was the land disposal.restriction
requirements; these stringent land disposal
restrictions created additional incentives for
generators to look for ways to reduce the volume
and/or toxicity of the hazardous waste they
generate.3 Another provision contained in the
statute was the requirement for hazardous waste
generators and treatment, storage, and disposal
faculties to certify that they have waste
minimization programs in place and to report on
waste minimization efforts biennially.
In order to implement these provisions, EPA took
an aggressive role hi pursuing waste minimization
as a primary national strategy. For example, as
an initial action, a guidance entitled, "Guidance
to Hazardous Waste Generators on the Elements
of a Waste Minimization Program" (1989), was
drafted to assist the regulated community in
complying with the requirement to have a waste
minimization program in place. This document
which has since been revised and renamed
"Facility Pollution Prevention Guide" provides
guidance to the regulated community by
describing several basic waste minimization
program elements which can be included in a
faculty's waste minimization program.
Also in 1989, OSW published "The Solid Waste
Dilemma: An Agenda for Action." The central
goals Outlined in this document Were to reduce
the generation rate of municipal solid waste, and
to manage safely and effectively those wastes
which cannot be reduced or recycled. The
"Agenda for Action" will be updated this year
reflect the dynamic changes that have occurred in
the past two years. In order to obtain further
information on the "Agenda for Action", call EPA
at 1-800-424-9346.
EPA also initiated a strategy for characterizing
the industrial nonhazardous waste universe. EPA
plans to work with States, industry, environmental
groups and the public to identify potentially high
risk industrial nonhazardous waste and waste
management practices, as well as current
industrial waste source reduction and recycling
practices. Current projects include a review of
State industrial waste programs, profiling specific
industry waste generation and management
problems, clarifying the definition of industrial
solid waste, pilot recycling analyses of specific
problem wastes, development and implementation
of a pollution prevention strategy, and tasks to
identify potentially high risk industrial
nonhazardous wastes.
The Action Plan focuses on waste minimization
activities for hazardous and special waste
programs. As noted above, OSW's Municipal
Waste Program has already been addressed in the
"Agenda for Action". Efforts focusing on
industrial nonhazardous waste are under way, but
are not a primary focus of this document because
the program is in its formative stages. In
formulating the Action Plan, special consideration
was given to the Agency's blueprint for a national
pollution prevention program, past RCRA
accomplishments, the mandates contained in
RCRA, and the status and scope of various waste
programs.
C. Goal of the RCRA Waste
Minimization Action Plan
The overall goal of the Action Plan is to ensure
cost-efficient protection of public health and the
environment by contributing to a strong risk
.reduction program that encourages waste
minimization, cooperative pollution prevention
programs and special waste initiatives. As noted,
the Action Plan's major initiatives are focused on
hazardous waste and special waste source'
EPA conducted a study on the cumulative costs of the HSWA amendments entitled, "The Cost of Clean."
The study found the costs for the amendments to be enormous and many sources, both within EPA and
trade associations, have claimed that due to these costs, generators are striving to reduce waste. In addition,
several Regulatory Impact Analyses have documented this generator response to specific waste regulations,
and industry conversations with EPA support the assertion that the HSWA amendments have influenced
generators to implement waste minimization programs.
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reduction and recycling programs. The Plan
outlines efforts to expand ongoing waste
minimization activities and integrate new
initiatives into these developing programs.
Because of the diverse nature of the RCRA
program, the establishment of a specific goal or
target for risk reduction is inappropriate at this
time. The Plan's primary strategy relies on the
continuous improvement and integration of source
reduction and recycling initiatives into these
programs. The Action Plan includes a range of
activities which integrate pollution prevention
through both RCRA regulatory and non-
regulatory initiatives. The Agency has sought
opportunities in RCRA to promote continued
improvement in source reduction and recycling :
through: ,
standard setting, including the listing of
hazardous wastes and the establishment of Best
Demonstrated Available Technology (BDAT) as a
prerequisite for land disposal of hazardous waste;
facility permitting; - .
reporting requirements;
support of State activities, including permitting,
facility-level planning, and technical assistance;
support of EPA Regional Office activities,
including permitting, inspection, and enforcement;
support of and coordination with EPA's Office
of Waste Programs Enforcement, including
RCRA inspection, and enforcement;
support of and coordination with EPA's Office
of Research and Development; and
support of and coordination with other EPA
offices, including the Pollution Prevention Office,
the Office of Air and Radiation, the Office of
Water, and the Office of Toxic Substances.
We intend to report annually on the progress
made in promoting source reduction and recycling
in each of these areas, and to update this Action
Plan, as appropriate.
D. Definition of Terms
The activities discussed in this Action Plan will be
used to promote "waste minimization.11 To better
understand this document, a few key terms are
defined below:
"Source reduction" (as defined by the Pollution
Prevention Act of 1990) - equipment or
technology modifications, process or procedure
modifications, reformulation or redesign of
products, substitution of raw materials, and
improvements in housekeeping, maintenance,
training, or inventory control (i.e., techniques for
companies to track the use of toxic materials and
resulting wastes). Source reduction does not
include recycling, treatment, or disposal.
"Recycling" - using, reusing, or reclaiming
materials/waste, including processes that
regenerate a material or recover a usable product
from it.
"Waste Minimization" - source reduction and the
following types of recycling: (1) beneficial
use/reuse, and (2) reclamation. Waste
minimization does not include recycling activities
whose use constitute disposal and burning for
energy recovery.
"Pollution Prevention" - in industry implies efforts
to reduce or prevent pollution at the source
through cost-effective changes in production,
operation, and raw materials use.
E. The Four Basic Premises of the
RCRA Waste Minimization Action Plan
1. A wide variety of both regulatory and non-
regulatory activities is needed to promote waste
minimization, and while performance standards
may prove useful in promoting waste
minimization in some cases, they should not be
the primary means by which EPA promotes waste
minimization across industry.
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In the Hazardous and Solid Waste Amendments
of 1984, Congress required EPA to study the issue
of whether "standards of performance or other
additional actions" for reducing hazardous waste
generation were "feasible and desirable." EPA
believes that production processes that would be
the subject of waste minimization performance
standards are generally much more complex than
end-of-pipe treatment methods. RCRA
regulatory development efforts would not
necessarily result in standards that adequately fit
the entire regulated community. The standards
could be too strict for some firms while being too
lax for others, and the degree of stringency would
not generally be commensurate with the need for
increased waste minimization efforts.
In accordance with the direction given under
HSWA and the Pollution Prevention Act of 1990,
the vast majority of EPA's pollution prevention
initiatives, to date, have been non-regulatory in
nature and have been designed to develop and
disseminate information. The 33/50 Project and
the transfer of pollution prevention technology
through development and operation of the
Pollution Prevention Information Clearinghouse
(PPIC), various demonstration projects, and the
State grant program all have been structured to
foster voluntary compliance.
Nevertheless, EPA recognizes that there may be
some technologies or processes where
performance standards may be appropriate (on a
case-by-case basis). In fact, EPA will consider
source reduction and recycling methods in the
development of some Best Demonstrated
Available Technology (BOAT) standards and
listings of hazardous waste as identified in this
Action Plan. This is consistent with the stated
goal for this Action Plan and the Pollution
Prevention Strategy.
2. The Action Plan will incorporate source
reduction and recycling concepts into the current
EPA programs which are designed to safeguard
public health by preventing the mismanagement
of hazardous wastes, but have sometimes' affected
the Agency's ability to promote source reduction
and recycling.
Promoting source reduction and recycling may
require changes to the way EPA develops and
implements certain of its programs. The Action
Plan outlines the first steps for making short-term
changes in certain RCRA programs. Activity VIII
is specifically designed to collate all identified
barriers as well as potential incentives for waste
minimization as perceived by the generators of
hazardous wastes. Many of the activities in the
Action Plan will also examine the potential for
short-term and long-term changes in these and
other RCRA programs that will further foster
source reduction and recycling.
These Action Plan activities should address EPA
statutes and regulations which sometimes make it
difficult to promote the use of source reduction
and recycling in addressing environmental
concerns. For example, the promulgation of a
regulation may require the regulator to implement
the rule by a certain date and may not afford the
regulator the opportunity or incentive to look for
source reduction and recycling solutions. Barriers
to source reduction and recycling may not actually
be single obstacles, such as a single regulatory or
statutory provisions, but rather may be a
combination of a number of environmental
statutes, regulations, and policies imposed on the
regulated community.
3. A cross-media perspective that addresses both
toxicity and volume reduction is essential to
promoting source reduction and recycling.
It is very difficult to separate the effects of the
RCRA program from those of the air and water
programs when promoting the changes to
production processes involved in source reduction
and recycling. Both the Pollution Prevention Act
of 1990 and the Pollution Prevention Strategy
(January 1991) reflect this fact in using the cross-
media Toxics Release Inventory (TRI), rather
than any of the Agency's single-program reporting
requirements, as the basis for pollution
prevention-oriented reporting requirements. A
multi-media approach to reduce both toxicity and
volume of waste also ensures that one program
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does not inadvertently transfer risks from one
regulated medium to another. The permitting and
barriers study activities identified in this Action
Plan are intended to promote a cross-media
perspective on toxicity and volume reductions.
As a result, this Plan has been structured to focus
on multi-media issues whenever feasible and
appropriate. Many of the activities described in
this plan attempt to support multi-media pollution
prevention initiatives, and therefore, many of
these activities require support and participation
from the other EPA media program offices.
4. The States are the central focus for source
reduction and recycling activity, although EPA
has an essential leadership role in the national
pollution prevention program.
Hazardous waste generators, the primary subjects
of source reduction and recycling programs, are
most directly affected by State regulatory agencies
rather than by EPA. Generally, permitting,
inspections, enforcement, and reporting activities
are implemented in partnership with the States.
Facility source reduction and recycling programs
should place emphasis on State agencies having
lead responsibility, with EPA providing support.
F. Formulating the Action Plan
The RCRA Waste Minimization Action Plan is a
combination of two efforts; a plan by the Waste
Minimization Task Group composed of
representatives from each OSW division, EPA
Regions IV, V, and X, the Office of Pollution
Prevention and Toxics, the Office of General
Counsel, and the Office of Waste Programs
Enforcement, and a plan developed by the Office
of Waste Program Enforcement relating
specifically to compliance monitoring and
enforcement activities. This Task Group, chaired
by the Waste Minimisation Branch of the Waste
Management Division, reviewed the latest source
reduction and recycling developments in the
Agency and States. In addition to the Pollution
Prevention Act of 1990, the Pollution Prevention
Strategy (January 1991), and 33/50 Project, the
Task Group drew information from two other
important sources.
To begin the process, the Waste Minimization
Branch analyzed and summarized the
approximately one hundred and twenty responses
to the October 5, 1990 Federal Register "Notice
and Request for Comment on Desirable and
Feasible Incentives to Reduce or Eliminate the
Generation of Hazardous Waste," and provided a
summary to the Task Group. A summary of the
responses to the Federal Register Notice is
contained in Appendix A.
Second, the Waste Minimization Branch co-
sponsored three focus groups in which other EPA
program and Regional offices, States, industry, the
environmental community, and other interested
parties participated. Each focus group addressed
a specific program area as follows:
- the first focus group, cosponsored with EPA
Region V, met in Chicago, Illinois and discussed
waste minimisation and permitting;
- the second group, cosponsored with EPA
Region IV, met in Atlanta, Georgia and discussed
methods of evaluating waste minimization
programs; and
- the third group, cosponsored with the Pollution
Prevention Office, met in Rosslyn, Virginia, and
discussed waste minimization and standard setting.
The Task Group analyzed the results of the focus
groups, including other sources of information,
and drafted a general plan for incorporating waste
minimization into RCRA standards, permits,
reporting requirements, State grants, and technical
assistance programs.
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SECTION IL KEY RCRA WASTE MINIMIZATION ACTIVITIES
The following section outlines the key activities
that the Waste Minimization Task Group
identified as critical elements of the RCRA Waste
Minimization Action Plan. Each activity contains
a brief discussion of various tasks along with
general timelines for completing the tasks. EPA
anticipates that these activities and the schedules
set forth may change depending on the evolution
of specific Action Plan goals and on budget and
funding
availability. While some activities are interrelated
or similar, they have been intentionally presented
separately to sharpen the focus of the Action
Plan's specific tasks and-to encourage the most
effective assignment of available Agency
resources. EPA has cross-referenced related tasks
as well as those activities that directly impact each
other.
All of the activities presented in the Action Plan are listed in the table below.
KEY ACTIVITIES
I. Promoting RCRA Hazardous Waste Source Reduction and Recycling through Permitting
II. Implementing Source Reduction and Recycling through RCRA Enforcement Activities
HI. Providing Outreach on OSWs Source Reduction and Recycling Activities
IV. Evaluating Needs and Methodologies to Measure Waste Minimization
V. Incorporating Source Reduction and Recycling in Future Listings . - -
VI. Incorporating Source Reduction and Recycling in the BDAT Process
VII. Identifying and Promoting Source Reduction and;Recycling Opportunities for Special Wastes
Vin. Evaluating Generators' Perspectives on Incentives and Barriers to Waste Minimization
IX. Evaluating Waste Minimization Projections Made in State Capacity Assurance Plans
X. Improving Hazardous Waste Recycling Program Implementation
XI. Providing Flexibility to Target RCRA State Grant Funds to Waste Minimization Needs
XTT. Demonstrating Source Reduction and Recycling at Specific Facilities
Xin. Supporting Technical Assistance Efforts
XTV. Managing and Supporting Implementation of the Action Plan
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L PROMOTING RCRA HAZARDOUS WASTE SOURCE REDUCTION
AND RECYCLING THROUGH PERMITTING
Objective:
Promote RCRA hazardous waste source reduction
and recycling through the RCRA permitting
program. The focus of this activity is to:
provide permit writers with additional training
so that they can discuss waste minimization -
concepts "with, and provide waste minimization
technical information to permittees,
develop the RCRA permitting process to
include consideration of cross-media impacts :
during the permitting development process, and
understand what variables will influence or ,.
control the development of cross-media permitting
program.
Background:
In 1976, the Office of Solid Waste (OSW) issued
a statement outlining the hazardous waste
management hierarchy along with proposed
guidance for a waste minimization program.
Despite this, waste minimization is not currently
central to RCRA hazardous waste permits. As a
first step to remedy this situation, the Permits and
State Programs Division (PSPD), with Regional
input, will prepare a policy statement on the
importance of waste minimization. This statement
will provide additional justification for permit
writers seeking to foster waste minimization in the
permits they issue.
In addition, many Regions and States are
currently incorporating waste minimization
requirements into their permits. To encourage
the exchange of information regarding these
experiences, PSPD will publish a document
summarizing the use of waste minimization
requirements in permits. This information will
eventually be incorporated into the Pollution
Prevention Information Clearinghouse (PPIC).
Source reduction and recycling efforts are
especially important when there is little permitted
treatment capacity, as with mixed hazardous and
radioactive waste. When the surveys on the
amount of mixed waste generated become
available (some time in 1992), OSW will have
more data to identify large volumes of mixed
wastes and be able to target them for reduction'in
the future.
Finally, pollution control devices permitted under
the Clean Air Act and the Clean Water Act
generate significant quantities of hazardous waste
(sludges, bottoms, bag-house and precipitator
dusts, etc.). In this case, air and water permit
writers will be provided with the procedures and
training needed to assist firms to implement
pollution prevention measures rather than shifting
wastes from air or water streams into the RCRA.
waste stream.
Activity Description:
RCRA ACTIVITIES
develop and publish a Facility Pollution
Prevention Guide;
prepare a policy statement for Regions and
States reaffirming the importance of waste
minimization in the management of hazardous
waste;
publish a document summarizing the use of
waste minimization in permits and establish a
mechanism to input this information into PPIC to
allow systematic exchange of information among
permit writers; and
identify particular mixed waste streams for
waste minimization based on a mixed waste
survey.
8
3
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CROSS PROGRAM ACTIVITIES
EPA will support and draw from several cross-
media source reduction and recycling pilot
projects that are either currently in progress or
are soon to be developed, including:
initiatives taken by several EPA Regions to
request and review the waste minimization plans
of RCRA permittees and generators;
the Amoco demonstration project, a joint
EPA/Amoco effort focusing on identifying and
implementing multi-media pollution prevention
techniques as part of a cross-media permit
development process; and
State-sponsored projects in Kansas,
Massachusetts, New Jersey, similar to the Amoco
project in that they will focus on several specific
industrial facilities to identify the best means of
promoting or allowing source reduction and
recycling through the permitting process.
Drawing from the projects discussed above EPA
plans to:
develop training programs and guidance to
assist Federal and State RCRA permit writers;
assist and provide training to air and water permit
writers in assessing the RCRA implications of the
air and water pollution control technologies being
permitted;
provide training to Regions and States on
waste minimization guidance.
identify two or more pilot Regions and pilot
permittees within those Regions to begin to apply
guidance for incorporating waste minimization
into RCRA, air, and water permit issuance (May
be in cooperation with States);
per findings of the above pilot project, update
the training programs and guidance developed to
assist Federal and State RCRA permit writers;
provide training to Regions and States on
updated guidance and begin implementing in all
Regions and authorized States.
Cross Reference to Activities: II, VI, XIII, XIV
3V-/ 5"
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, PROMOTING RCRA HAZARDOUS WASTE SOURCE REDUCTION AND RECYCUNG THROUGH PERMITTING
RCRAACnvmES
1.1 Develop and publish the "Facility Pollution
Prevention Guide".
Responsibility: Lead: WMD/WMB; Team: WMD/WMB,
Regions, States, OPPT, OWPE
I.2 Prepare with Regional input, policy statement on
waste minimization in permitting.
Responsibility: Lead: PSPD; Team: WMD/WMB,
Regions, States, OPPT, OWPE
I.3 Develop document summarizing waste minimization
activities In permitting.
Responsibility: Lead: PSPD; Team: WMD/WMB,
Regions
I.4 Identify waste minimization opportunities in mixed
waste.
Responsibility: Lead: PSPD; Team: WMD/WMB,
CROSS PROGRAM ACTIVITIES (Optional
I.5 Develop and publish guidance for RCRA, air, and
water permit writers in assessing RCRA implications of
air and water pollution control technologies being
permitted.
Responsibility: Lead: WMD/WMB, WMD/WTB; Team:
OAR, OW
1 .6 Provide training to Regions and States on I.5
guidance.
Responsibility: Lead: WMD/WMB, WMD/WMB; Team:
OAR, OW
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1. PROMOTING RCRA HAZARDOUS WASTE SOURCE REDUCTION AND RECYCUNG THROUGH PERMITTING (Continued)
1.7 Identify two or more pilot Regions and pilot
permittees within those Regions to begin to apply
guidance for incorporating waste minimization Into
RCRA, air, and water permit issuance (May be in
cooperation with States).
Responsibility: Lead: WMD/WMB; Team: same as 1.5
1.8 Update 1.5 guidance per findings of 1.7.
Responsibility: Lead: same as 1.5; Team: same as 1.5
1.9 Provide training to Regions and States on updated
guidance and begin Implementation in all Regions and
authorized States.
Responsibility: Lead: same as 1.5; Team: same as 1.5
FY91
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IL IMPLEMENTING SOURCE REDUCTION AND RECYCLING
THROUGH RCRA ENFORCEMENT ACTIVITIES
Objective:
To promote pollution prevention through the
RCRA Enforcement Program. The focus of this
activity is to:
define -the appropriate role of pollution
prevention in enforcement;
identify opportunities for fostering such
prevention;
implement those initiatives that balance EPA's
enforcement objectives under RCRA with
pollution prevention goals; and
achieve effective use of enforcement authority
to require and promote compliance and pollution
prevention.
Background:
To date, EPA's strategy in promoting pollution
prevention has been primarily voluntary.
However, as discussed in the RCRA
Implementation Study, (BIS) even within a
voluntary scheme, the compliance and
enforcement program can and should play a
significant role in promoting pollution prevention.
Following up on the RIS, OWPE set out to find
ways to foster pollution prevention/waste
minimization activities through the enforcement
program. OWPE believes that making pollution
prevention objectives part of the enforcement
program can not only bring owners/operators
back into compliance, but further protect human
health and the environment by reducing the
generation of hazardous waste and lowering the
potential for harm.
Activity Description:
OWPE will initiate and develop pollution
prevention in enforcement through the following
activities:
OWPE will continue to provide flexibility to
Regions and States to direct compliance
monitoring and enforcement resources toward
pollution prevention projects. The FY93 RCRA
Implementation Plan (RIP) provides for Regions
and States to direct up to 25% of thek resources
toward State and Regional enforcement priorities,
including pollution prevention.
As recommended in the RIS, OWPE will
include a measure under the Strategic Targeted
Activities for Results System (STARS) for
pollution prevention projects in enforcement
settlements in FY93. STARS is a
management/accountability tool that focuses
environmental protection activity on the highest
priority program objectives.
The following activities will be conducted to
evaluate and promote the use of Pollution
Prevention and Waste Minimization in
Enforcement Settlements:
OWPE has been and will continue to assist
Region 2 in implementing a "pilot" pollution
prevention project with a Du Pont facility in
Deepwater, NJ. This pollution prevention project
creates a joint EPA-Du Pont technical workgroup
which will publish the results of a waste
minimization study of 15 processes from Du
Font's Chambers Works facility in Deepwater, NJ.
It is intended that the results of this study will be
useful to other industries in their attempts to
implement pollution prevention/ waste
minimisation. The project is scheduled for
completion in May 1993.
12
-------
OWPE will draft RCRA specific guidance on
including pollution prevention/waste minimization
in enforcement settlements, based on its
experience with the Du Pont case. The guidance
will include a discussion on the following topics:
- Confidential Business Information
- Stipulated Penalties
- Penalty Mitigation
- Advice on successful and timely implementation
of the pollution prevention/waste minimization
project
- Using publicity to promote waste minimization
and pollution prevention activities by requiring
facilities which undertake pollution prevention
projects, as part of enforcement settlements, to
make results available to the public.
OWPE received money from an Office of
Enforcement 2% Set Aside project to fund
Regional pollution prevention projects. This
money is to provide technical assistance to those
Regions which have included pollution prevention
in an enforcement settlement and need technical
expertise in either developing the project or hi
evaluating its progress.
- OWPE has funded a Region 8 proposal to train
inspectors on waste minimization for an upcoming
Regional enforcement initiative.
- OWPE will continue to evaluate and fund
Regional proposals under OE's 2% Set Aside
Project.
OWPE is developing a pilot for an
Environmental Extension Service. The pilot will
provide small businesses and communities with
RCRA regulatory and technical assistance. The
services provided include environmental education
and technical outreach focusing on pollution
prevention and waste minimization technologies.
In addition, the Environmental Extension Service
will provide small businesses and communities
with the "know-how" to establish and maintain
recycling centers and services. In the long term,
the service will facilitate the development of
markets for secondary materials.
OWPE undertook a 2% Set Aside project to
survey and analyze current Regional and State
inspectors' efforts in waste minimization in order
to develop a policy on the role of inspectors in
waste minimization. A workgroup, comprised of
HQ, Regional and State representatives, was
formed to identify the Regional needs and
concerns. The workgroup found that several
issues needed further clarification:
- the role of a RCRA inspector in encouraging
waste minimization
- the authority of RCRA inspector in enforcing
waste minimization requirements '
- guidance and training on the inspector's role in
promoting waste minimization
OWPE issued guidance, entitled The Role of
the RCRA Inspector in Promoting Waste
Minimization, in September of 1991. The .
guidance identifies the opportunities an inspector
has to promote
waste minimization and encourages inspectors to
engage in the following activities:
- checking the manifest for certification that the
owner/operator has a waste minimization
program in place
- checking the Biennial Report and Operating
Record requirements
- checking waste minimization language included
in the facility's permits, enforcement orders
and/or settlement agreements
- distributing information on waste minimization
technical assistance programs
OWPE will continue to evaluate and seek
feedback on the inspector policy and how it is
being implemented by the Regions.
OWPE will incorporate pollution prevention
training into its Advanced RCRA Inspector
Training Institute.
Cross Reference to Activities: I, VI, VII
13
-------
II. IMPLEMENTING SOURCE REDUCTION AND RECYCUNG THROUGH RCRA ENFORCEMENT ACTIVITIES
FY91
FY92
FY93
FY94
FY95
1Q
2Q
3Q
40
1Q
2Q
3Q
4Q
1Q 2Q 3Q 4Q
10 20 30
40
10
20
30
40
11.1 Draft guidance on Including pollution prevention and
waste minimization for use In enforcement orders.
Responsibility: Lead: OWPE; Team: OE. OFF,
Regions, OWS
II.2 Continue to encourage use of RIP-FLEX to Identify
and promote pollution prevention projects.
Responsibility: Lead: OWPE; Team: OSW. Regions
II.3 Evaluate Regional proposals for pollution prevention
projects under OE's2% Set Aside Funding..
Responsibility: Lead: OWPE; Team: OE, Regions,
OSW
II.4 Incorporate pollution prevention/waste minimization
into STARS Measures.
Responsibility: Lead: OWPE; Team: Regions, OSW
II.5 Increase pollution prevention/waste minimization
training for Inspectors through the RCRA Inspector
Institute.
Responsibility: Lead: OWPE; Team: NEIC, Regions,
OSW
VV
11.6 Continue to particpate and assist Region 2's efforts
in implementing the pollution prevention/waste
minimization project under the Du Pont consent
agreement.
Responsibility: Lead: OWPE, Region 2; Team:OPP,
ORD, OSW
11.7 Develop a pilot for an Enforcement Extension
Service.
Responsibility: Lead: OWPE, Team: Other Interested
Headquarters and Regional Offices
-------
m. PROVIDING OUTREACH ON RCRA'S SOURCE REDUCTION
AND RECYCLING ACTIVITIES
Objective:
One of our major goals in supporting EPA's
pollution prevention initiative is to provide
industry, States, Federal agencies, other EPA
program offices, and the public with information
in order to:
focus industry's and government's attention on
source reduction and recycling as the preferred
methods of environmental protection;
direct industry's attention to specific source
reduction and recycling opportunities;
provide State and other Federal programs the
benefits of our experience; and
engage the public, industry, and other
government bodies in the larger policy issues
involved in source reduction and recycling.
The goal of this activity is to develop and
distribute to both industry and States information
and material through the Pollution Prevention
Information Clearinghouse (PPIC), and other
technical assistance mechanisms.
Background:
EPA's strategy to encourage pollution prevention
includes a proactive technical assistance program
to all interested parties (industrial, regulatory,
public interest, and individual). The Pollution
Prevention Branch and Office of Research and
Development has expended a large portion of
their resources to develop and support a technical
assistance network (including the PPIC) which is
intended to provide a mechanism to transfer
pollution prevention information. Future activities
will focus on supporting established technical
transfer programs and developing additional (and
potentially independent) means to distribute
technical information.
Activity Description:
To meet this objective, information will be
collected on previous pollution prevention
activities and, distribute to interested
communities. In particular, information will be
distributed on:
special projects, such as. the EPA/Amoco
Project;
a summary of past studies on incentives and
barriers of source reduction, and recycling
programs; and
case studies on pilot programs will be made
available through outreach program and PPIC.
Cross Reference to Activities: I, II, VI, VII, VIII, XI, XIII, XTV
15
3V-
-------
III. PROVIDING OUTREACH ON OSWS SOURCE REDUCTION AND RECYCUNG ACTIVITIES
FY92
FY93
FY94
FY95
FY96
1Q
2Q
3Q
4Q
1Q
2Q
3Q
4Q
1Q
2Q
3Q
4Q
1Q
2Q
3Q
4Q
1Q
2Q
3Q
4Q
111.1 Publish, distribute, and speak In public on the
activities of this action plan.
Responsibility: Lead: WMD/WMB
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-------
IV. EVALUATING NEEDS AND METHODOLOGIES
TO MEASURE WASTE MINIMIZATION
Objective:
We will determine the various reasons to measure
waste minimization; evaluate and prioritize these
reasons; identify methodologies for evaluation to
determine the utility in addressing the "whys" of
measuring waste minimization; and implement an
evaluation process.
Background:
EPA has established reporting requirements for
hazardous waste generators and management
facilities under the RCRA Biennial Report. In
addition, Title El, Section 313 of the Superfund
Amendments and Reauthorization Act of 1986,
requires certain faculties to report air, water, and
land releases, and transfers of waste to off-site
locations.
Presently, these data gathering mechanisms limit
measurement of waste minimization, both in level
of detail and industry applicability. Further, the
degree to which different measurement interests
or needs can be met using the same data is
currently unknown. However, it is becoming clear
from the results of Phases I and II of Region X's
Measurement of Waste Minimization Project that
different organizations have different reasons to
measure waste minimization. Many companies
are interested in evaluating the effectiveness of
their waste minimization programs, while State
and Federal agencies use these program
evaluations to target areas of greatest need for
waste minimization and to measure State-wide
and national progress. Waste minimization
evaluations can also be used to monitor a
company's compliance with the terms of an
enforcement agreement imposing obligations to
install and operate pollution prevention projects.
In order to better address waste minimization
measurement through data collection, it is
necessary to:
Cross Reference to Activities: IX, X, XIII
clearly understand the purpose behind the
measurement;
identify methodologies that satisfy specific
purposes; and
identify and collect the data elements required
by the methodology.
Activity Description:
Region X, with support from OSW and Region V,
will continue their current efforts to study the
reasons for measuring waste minimization, as well
as identify methodologies to be developed and
tested that meet the various objectives of waste
minimization measurement.
To address these issues, a Needs Assessment
Workshop will be held in FY92 with
representatives from State and Federal agencies,
businesses, trade associations, research
organizations, and public interest groups. The
purpose of this workshop will be to explore the
reasons for organizations to measure waste
minimization.
Future phases of the project will seek to develop
and test methodologies for specific measurement
needs. This will include identifying measurement
objectives which represent the varying priorities of
different organizations. It will also identify the
different kinds and/or levels of data required to
meet these objectives. The results from these
studies may be used to better understand the
relative effectiveness of various State and Federal
source reduction and recycling activities, and to
update the procedure to evaluate source reduction
and recycling projections made in State Capacity
Assurance Plans.
OSW and other appropriate parties will then use
this information to make decisions on the actions
needed to better measure waste minimization, and
to explore why organizations need/want to
measure waste minimization.
17
-------
IV. EVALUATING NEEDS AND METHODOLOGIES TO MEASURE WASTE MINIMIZATION
IV.1 Determine and summarize the reasons why people
need or want to measure waste minimization. Hold
Needs AssessmentWorkshop to explore why measure
waste minimization.
Responsibility: Lead: Region X; Team: OSW, OPPT,
States, Regions, CABD
IV.2 Evaluate/synthesize/prioritize the whys and
determine which are Important; which EPA can address.
Responsibility: Lead: Region X; Team: OSW, OPPT,
IV.3 Identify methodologies to address the various
reasons for measuring waste minimization.
Responsibility: Lead: TBD; Team: Same as V.1
IV.4 Test the methodologies to see how well they
address the "whys."
Responsibility: Lead: WMD/WMB;Team: IV.1
(V.5 Develop Agency strategy to Incorporate findings
Into Information Management Strategy to address needs
to Measure Waste Minimization.
Responsibility: Lead: WMD/WMB;Team: OPPT,
CABD, Regions, States. CABD
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V. INCORPORATING SOURCE REDUCTION AND RECYCLING
IN FUTURE LISTINGS
Objective:
OSW will specify or incorporate source reduction
and recycling techniques and/or certain levels of
production efficiency in hazardous waste listing
determinations. In addition, OSW plans to
provide longer lead times to industry, where
appropriate, to allow newly regulated industries
time to identify and develop prevention
alternatives. The focus of this activity is to:
develop a methodology for listing program
staff to identify pollution prevention opportunities
as part of the listing development process,
identify standard criteria for incorporating
pollution prevention incentives into listings, and
promulgating new listings that include
pollution prevention incentives.
Background:
There may be opportunities to specify source
reduction and recycling techniques, or certain
levels of production efficiency in promulgating
hazardous waste listings. The Environmental
Defense Fund (EDF) "mega-suit" requires EPA to
conduct listing determinations on 14 waste
categories. Further, Best Demonstrated Available
Technology (BDAT) standards must be developed
as part of these hazardous waste listing
determinations. As such, it would be appropriate
to consider waste minimization technologies as
part of this process.
For example, OSW may be analyzing the mother
liquor generated from an industrial production
process, and may determine that the presence of
reactant in the mother liquor dictates the extent
to which the mother liquor is hazardous. If
reaction efficiency is below 99%, the mother
liquor would be considered hazardous, while if
reaction efficiency is above 99%, the mother
liquor would be considered non-hazardous.
Rather than listing all waste from such production
processes as hazardous, OSW could write a listing
for a mother liquor generated from the process
that achieves less than 99% reaction efficiency.
In addition, where appropriate, it may be possible
to alert the effected industry earlier to the
possibility of listing and work with it to develop
source reduction and recycling strategies. (This is
currently being done with the manufacturers of
azo dyes.)
Activity Description:
In order to use listing as a means to promote
source reduction and recycling, OSW will identify
industrial processes (based on the EDF/EPA
settlement) which:
are amenable to source reduction and recycling
approaches; .
generate releases of chemicals targeted by the
33/50 Project; and '
have important cross-media impacts.
OSW will then identify those source reduction and
recycling technologies which will assist a firm
from generating a hazardous waste, and consider
listing only those wastes generated from
production processes that do not use such source
reduction and recycling technologies.
Cross Reference to Appendices: I, II, VII, XIII, XTV
19
<;
-------
V. INCORPORATING SOURCE REDUCTION AND RECYCLING IN FUTURE LISTINGS
U)
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Activity One - Identify Industrial Process/Generate Waste Management Assesment
Activity Two - Work With Industry Identify Source Reduction and Recycling/Incorporate in Rules
Activity Three - Evaluate How Identified Source Reduction and Recycling Techniques Reduce Waste
-------
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V. INCORPORATING SOURCE REDUCTION AND RECYCUNG IN FUTURE LISTINGS (Continued)
Solvents II
Solvents III
Dtoxbis: Surface Protection (F033)
Azo/Benzidine Dyes
Anthraquinone Dyes
Triarylmethane Dyes
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VI. INCORPORATING SOURCE REDUCTION AND RECYCLING
IN THE BOAT PROCESS
Objective:
Under this activity, EPA will work to incorporate
source reduction and recycling in the Best
Demonstrated Available Technology (BOAT)
development process by conducting specific test
cases for well defined listed/characteristic wastes.
The focus of this activity is to:
investigate, develop, and implement a
procedure for considering source reduction and
recycling techniques in the development of BDAT
standards, and
promulgate BDAT standards that either are
based upon available source reduction or recycling
techniques (if authority exists) or describe such
techniques that can aid generators in meeting
BDAT standards.
Background:
EPA has identified and is in the process of
promulgating treatment standards for "newly listed
wastes." Of these newly listed wastes, Mining and
Mineral Processing and Wood Preserving, in
particular, are expected to be difficult subjects for
BDAT development. However, source reduction
and recycling are thought to be primary
candidates for these wastes. The EDF "mega-suit"
consent decree requires EPA to make 14 listing
determinations over the next several years.
Generally, EPA will develop BDAT hi
conjunction with any decision to list a waste. In
addition, the consent decree requires EPA to
develop BDAT for numerous existing hazardous
wastes. This decree provides EPA with additional
opportunities to consider incorporating waste
minimization hi the BDAT process.
Phase 2 Newly Listed Wastes (4/93 Final Rule)
Contaminated Soil
Toxic Characteristic - 26 Recently Added
Organics (D018 -D043)
D004 - D017 that were not Extraction
Procedure
(EP) toxic
Coke by-products - proposed
Chlorotoluene Production - proposed
Phase 3 Newly Listed Wastes (3/94 Final Rule)
Characteristic Mineral Processing Wastes from
over 20 Industries
Remanded Bevill (K064 - K066/K090/K091) -
(if
relisted)
Wood Preserving (F033 - F035)
Aluminum Potliners (K088)
BDAT standards will be developed for all future
listings in accordance with the EDF/EPA
negotiated settlement and the listing
determination schedule in the proposed consent
decree. Six months after final listing
determination, BDAT will be promulgated for
newly listed wastes (for complete and detailed
BDAT promulgation schedule see the attached
table).
Activity Description:
In developing BDAT standards for post-HSWA
wastes, EPA has published two Advanced Notice
of Proposed Rule Makings (ANPRM) asking for
relevant source reduction and recycling methods
(May 30, 1991, 56 FR 24444-24465, and October
24, 1991, FR 55160-55189). In addition, EPA will
hold meetings with industry to identify source
reduction and recycling opportunities, and will
incorporate such opportunities hi the proposed
and final rules. EPA will, at a minimum, perform
such evaluations for two Phase 2 wastes in
addition to the Wood Preserving and Mineral
Processing wastes. This activity will focus,if
possible, on industries and wastes targeted by the
33/50 Project but will also target listed wastes not
included in the 33/50.
Cross Reference to Activities: I, II, VI, IX, XIII, XIV
22
-------
VI. INCORPORATING SOURCE REDUCTION AND RECYCUNG IN THE BDAT PROCESS
VI.1 Two ANPRM'sasking about source reduction and
recycling opportunities for newly listed wastes.
Responsibility: Lead: WMD/WTB; Team: WMD/CPB
VI.2 Respond to ANPRM comments on source
reduction and recycling for Phase 1 wastes and
incorporate source reduction and recycling as BDAT,
where appropriate, and publish:
Responsibility: Lead: WMD/WTB; Team: WMD/WMB,
ORD
a. Proposed Rule
b. Final Rule
VI.3 Review ANPRM comments on source reduction
and recycling for Phase 2 and Phase 3 wastes.
Responsibility: Lead: WMD/WTB; Team: WMD/WMB
VI.4 Respond to ANPRM comments on source
reduction and recycling for Phase 2 wastes, incorporate
source reduction and recycling into BDAT for a- minimum
of two industries, where appropriate, and publish:
Responsibility: Lead: WMD/WTB, WMD/WMB; Team:
ORD
a. Proposed Rule
b. Final Rule
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VI. INCORPORATING SOURCE REDUCTION AND RECYCLING IN TOE BOAT PROCESS (CONTINUED)
VI.5 Work with Industry to Identify source reduction and
recycling opportunities and cross-media impacts for
Phases.
Responsibility: Lead: WMD/WMB,WMD/WTB;Team:
ORD
VI.6 Respond to source reduction and recycling
activities for Phase 3 wastes, incorporate source
reduction and recycling into BOAT for Mineral
Processing. Wood Preserving industries, where
appropriate and any others deemed appropriate and
develop/publish:
Responsibility: Lead: WMD/WMB, WMD/WTB; Team:
CABD/CAD.ORD
a. Proposed rule
b. Final rule
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VII. IDENTIFYING AND PROMOTING SOURCE REDUCTION AND
RECYCLING OPPORTUNITIES FOR SPECIAL WASTES
Objective:
OSW will identify and promote source reduction
and recycling opportunities for special wastes.
This activity is designed to:
continue the study of large volume waste
generating processes to identify source reduction
and recycling alternatives,
integrate pollution prevention concepts
(including, but not limited, to technical reduction
standards) into forthcoming guidance, and
support on-going and future research efforts
on large volume wastes concerning pollution
prevention opportunities.
Background:
The opportunities for waste minimization for
Special Wastes appear promising. RCRA Section
8002 requires the Agency to study and issue
summary reports to Congress regarding special
wastes. Special wastes are characterized by high
volume and low toxicity. These wastes, comprised
of mining wastes, crude oil and natural gas
exploration and production wastes, cement kiln
dust wastes, and wastes from the combustion of
fossil fuels, were exempted from RCRA
characterization as "hazardous wastes" in 1980 by
the Bevill and Bentson Amendments.
EPA must address, among other things, the
adequacy of current and potential measures to
utilize such wastes. The mining, mineral
processing, oil and gas, and coal-fired utilities
reports to Congress contain this information and
can serve as a basis from which additional source
reduction and recycling work can be initiated.
The Cement Kiln Dust Waste Report to Congress
that is being prepared during FY 91-93 will also
contain such information. The oil and gas study
mandate contains an additional and relevant
requirement: to prepare a Research, Development
and Demonstration (RD&D) Plan. The
regulatory determination for oil and gas wastes
contained an Agency commitment to develop a
list of recommended topics for the RD&D Plan
for Federal agencies, States, and industry to
pursue, including materials substitution and
recycling/reuse!
In addition, waste minimization is one of the five
major themes qf the National Energy Strategy
(NES) that are; directly associated with EPA's
waste management activities. NES calls for
reduction of quantity, persistence, and toxicity of
energy related Jvastes, promotion of research and
outreach coordinated by Department of Energy
(DOE) and EPA, and minimization of industrial
waste generation to conserve energy.
Progress hasjalready been made in the Special
Wastes arena' regarding waste minimization.
Chevron has instituted its "Save Money and
Reduce Toxics (SMART)" program in the oil
patch which: seeks to replace or reduce the usage
of toxic chemicals. By the end of 1989, Chevron
had reduced their waste by sixty percent. Also,
OSW and QTS are working cooperatively to
develop a program emphasizing source reduction
and recycling under the Toxic Substances Control
Act (TSCA). The program will address the two
principal wastes from the phosphoric acid industry
phosphogypsum and process wastewater.
Activity Description:
4-.
OSW will identify and promote source reduction
and recycling opportunities for special wastes by:
A series of investigations will be undertaken to
identify opportunities for source reduction and
recycling in each of the special waste areas. The
development of the oil and gas investigation will
be coordinated with a waste minimization project
recently, initiated by the American Petroleum
Institute (API) for oil and gas exploration and
production operations. The API effort focuses on
three areas: developing methods for measuring
waste minimization, estimating cost savings, and
developing information for use by State
legislatures. The mining investigation will be
coordinated with the Western Governors
25
< /
-------
Association (WGA) and Interstate Mining
Compact Commission (IMCC), both of which
have recently completed review of then- existing
State regulatory programs and have expressed an
interest in having a national program that
encourages Waste minimisation,
Based on the investigations, source reduction
and recycling will be made known to the mining
industry. Similarly, source reduction and recycling
will be made known to the oil and gas industry.
As opportunities for source reduction and
recycling are identified, the OSW Special Wastes
Branch will work with the Interstate Oil and Gas
Compact Commission (IOGCC), Society of
Petroleum Engineering (SPE), API, WGA, and
IMCC to develop technology transfer processes
(papers, conferences, training) to encourage the
adoption of source reduction and recycling
techniques. The oil and gas program will
determine the feasibility of creating a group
composed of industry, environmentalists, and
States to informally discuss waste reduction issues.
This group may ultimately develop into a federal
advisory committee.
The Special Waste Branch will continue the
development of a program under TSCA, including
source reduction and recycling opportunities, that
will address phosphoric acid production practices
and processes to reduce the risks posed by
phosphogypsum waste and process wastewater.
The Branch has already completed studies of
waste handling practices at a number of facilities
and will determine the feasibility of source
reduction and recycling options at those plants.
Under TSCA Section 6, the Agency has the
authority to prohibit or regulate any manner or
method of disposal of a chemical substance or
mixture by anyone who uses or disposes of it for
commercial purposes. Most importantly, TSCA
can be used to effectively explore, promote, and
enforce pollution prevention
and/or source reduction approaches hi the
phosphoric acid production industry. A program
developed under TSCA could be in the form of
regulations or non-regulatory industry guidelines,
or a combination of the two.
For oil and gas, EPA has committed to clarify
its regulatory determination for liquid and solid
wastes for tank bottom and crude oil reclaimers.
These operations sell nearly 3 million barrels of
crude oil reclaimed from waste annually, thus
preventing its release into the environment.
Preparation of the oil and gas Research,
Development and Demonstration (RD&D) plan
mandated by RCRA Section 8002(m) (2) will
commence, with substantial emphasis on source
reduction and recycling. Such a plan may include
descriptions of a series of research activities
leading towards determining the feasibility of
source reduction and recycling options. EPA's
regulatory determination identified source
reduction and recycling (materials substitution and
recycling/reuse) as areas of interest for the
RD&D Plan.
There have been recent technical changes in
the operation of froth flotation circuits hi the
beneficiation of lead ore. Research indicates that
computer control over the application rate of
chemicals hi the beneficiation circuit of lead ore
can lead to reduced use of chemicals, a finished
ore which contains less residual waste, and a
reduction of air emissions at smelters using the
purer ore. This effort would evaluate the use of
computer control of a beneficiation circuit at an
operating lead mine and determine if this method
could be applied to other metal mining
operations.
Cross Reference to Activities: I, II, XIII, XTV
26
-------
VII. IDENTIFYING AND PROMOTING SOURCE REDUCTION AND RECYCUNG
OPPORTUNITIES FOR SPECIAL WASTES
VII.1 Scoping Study Determine source reduction and
recycling in:
Responsibility: Lead: WMD/SWB; Team: WMD/WMB
a. mining
b. oil/gas
c. cement kilns
d. utility
VII.2 Integrate source reduction and recycling into
guidance for the sectors listed below.
Responsibility: Lead: WMD/SWB; Team: WMD/WMB
a. mining
b. oil/gas
VII.3 PhosphoricAcid source reduction and recycling
Responsibility: Lead: WMD/WMB
VII.4 Tank bottom/oil reclaimer source reduction and
recycling study.
Responsibility: Lead: WMD/SWB; Team: WMD/WMB
VII.5 Oil/gas RD&D plan documents
Responsibility: Lead: WMD/SWB; Team: WMD/WMB
VII.6 Source reduction and recycling opportunities in
Lead Beneficiation.
Responsibility: Lead: WMD/SWB; Team: WMD/WMB
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EVALUATING GENERATORS' PERSPECTIVES ON
INCENTIVES AND BARRIERS TO WASTE MINIMIZATION
Objective:
Our goal is to understand the critical factors in
generators' decisions to implement source
reduction and recycling projects. Also, to identify
the regulatory and non-regulatory barriers that
currently obstruct additional project
implementation. This activity will be developed
to:
continue with on-going investigations of"
generators and their motivations behind
implementing projects, specifically technical
projects and'motivations behind these projects or
what other technical factors discourage other
pollution prevention initiatives;
identify, using the results of these
investigations, future data requirements and
information needs to measure progress and target
future EPA waste minimization efforts to address
identified barriers;
identify where EPA, State and local regulations
hinder adoption of waste .minimization initiatives.
Specifically, identify those regulatory variables that
most directly impact decisions to adopt or develop
waste minimization initiatives;- and
better report the progress of the voluntary
waste minimization effort to Congress, industry
and the public.
activities relative to specific industries and more
importantly, processes. By. querying generators on
their source reduction and recycling projects, we
will be able to better understand how and to what
extent do State, local and federal efforts fill
generators' needs. In addition, we will also find
out what regulatory and non-regulatory barriers
exist.
Activity Description:
A cross-office EPA team, led by OSW, will
develop a methodological framework to
investigate generator's pollution prevention/waste
minimization experiences. This methodology will
be reviewed and revised with input from a
subcommittee of the National Advisory
Committee on Environmental Policy and
Technology (NACEPT, an EPA advisory
committee). In addition, it will be informed by
the Waste Minimization Measurement Project.
This project along with Activity V will help
identify which data elements we should be
collecting in the Biennial Report in order to
better understand pollution prevention progress.
Background:
A large number of activities exist at the Federal,
State, and local level that provide assistance to
generators in reducing their waste. While these
activities haye been steadily increasing in number
and scope during the past five years, there is little
information available as to the efficacy of these
Cross Reference to Activities: V, X
28
-------
VIII. EVALUATING GENERATORS'PERSPECTIVES ON INCENTIVES AND BARRIERS TO WASTE MINIMIZATION
EVALUATION
VIII. 1 Hold a focus group meeting on evaluation of
pollution prevention programs.
Responsibility: Lead: WMD\WMB; Team: OPPT,
Region IV
V' ""r--v- -
VIII.2 Form work group to identify potential users of
study. : ' .' -.: >.,?';:.- ;./.
Responsibility. Lead: WMB;Team: OPPT, NACEPT,
OAR, OW, Region X, ORD.
VIII.3 Produce compendium of Incentives and Barriers
studies completed to date.
Responsibility: Lead: same as (2); Team: same as
(2)
VIII.4 Develop methodologyto identify generators'
perspectives on incentives barriers to waste
minimization.
Responsibility: Lead: same as (2); Team: same as
(2)
VIII.5 Review methodology with NACEPT, revise as
necessary.
Responsibility: Lead: same as (2); Team: same as
(2)
VIII.6 Obtain OMB approval for data collection
vehicle.
Responsibility: Lead: same as (2); Team: same as
(2)
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Vlll. EVALUATING GENERATORS'PERSPECTIVES ON INCENTWES AND BARRIERS TO WASTE MINIMIZATION (Continued)
VIII.7 Collect data from targeted generators.
Responsibility: Lead: same as (2) Team: same as
(2)
VIII.8 Analyze data.
Responsibility: Lead: same as (2); Team: same as
(2)
VIII.9 Summarize and publish report..
Responsibility: Lead: same as (2); Team: same as
(2)
BIENNIAL REPORT MODIFICATION
VIII.1 0 Identify Information needs for collection in
Biennial Report.
Responsibility: Lead: WMD/WTB; Team: CABD,
CAD
VIII.1 1 Identify modifications to the Biennial Report.
Responsibility: Lead: WMD/CABD;Team: CAD,
Regions
VIII.1 2 Complete revisions to Biennial Report.
Responsibility: Lead: CABD; Team: WMD, CAD,
Regions
VIII.1 3 Publish modified 1995 Biennial Report
Form/Regulation.
Responsibility: Lead: CABD
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IX. EVALUATING WASTE MINIMIZATION PROJECTIONS
MADE IN STATE CAPACITY ASSURANCE PLANS
Objective:
We will develop criteria that the Agency can use
to evaluate waste minimization projections
reported in State Hazardous Waste Capacity
Assurance Plans. To accomplish'lhis, this activity
will be developed to:
identity and refine methodologies States can
use to portray base years and waste minimization
projections,
provide States the opportunity to test and
refine measurement methodologies, and
incorporate standardized measurement
methodologies into the Capacity Assurance
process (as well as provide these methodologies to
other EPA programs that might benefit from such
protocols).
Activity Description:
A team, led by OSW, will work with State CAP
coordinators, Regions, and other stakeholders in
developing criteria to evaluate source reduction
and recycling statements made in State CAPs.
For future evaluations of CAP waste minimization
projects in 1995, EPA may use results from the
Region X Measurement Project (in addition to
other sources) to provide an empirical basis on
which to update the procedure to evaluate source
reduction and recycling projections made in State
CAPs.
Background:
Several States have predicated their assurance of
hazardous waste management capacity in part on
progress hi minimi/ing waste. Further, EPA has
not identified how States should consider or
account for waste minimization in developing a
CAP, In addition, EPA has not yet developed a
means for substantiating such projections.
Cross Reference to Activities: V, IX
31
-------
DC EVALUATING WASTE MINIMIZATION PROJECTIONS MADE IN STATE CAPACnY ASSURANCE PLANS
'
IX.1 Work group formation.
Responsibility: Lead: WMD/CPB; Team: WMD/WMB,
Regions, OPPT, States, ASTWMO, Roundtable
IX.2 Provide empirical basis (if any); develop criteria to
evaluate source reduction and recycling projections
made in CAPs.
Responsibility: Lead: WMD/CPB; Team: WMD/WMB,
Regions, OPPT, States, ASTWMO, Roundtable
IX.3 Publish and distribute to States the criteria for
evaluating waste minimization projections made in the
CAPs.
Responsibility: Lead: WMB/CPB; Team: WMB/WMD
IX.4 Obtain comments on criteria. Revise criteria based
on comments.
Responsibility: Lead: WMD/CPB; Team: WMD/WMB,
Regions, OPPT, States, ASTWMO, Roundtable
IX.5 Evaluate waste minimization projections in CAPs.
Responsibility: Lead: WMD/CPB; Team: WMD/WMB,
Regions, OPPT, States, ASTWMO, Roundtable
IX.6 Review criteria used in evaluation 1993 waste
minimization projections. Revise criteria, if necessary.
Responsibility: Lead: WMD/CPB; Team: WMD/WMB,
Regions, OPPT, States, ASTWMO, Roundtable
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X. IMPROVING HAZARDOUS WASTE
RECYCLING PROGRAM IMPLEMENTATION
Objective:
We will pursue activities which encourage
environmentally sound recycling and improve
implementation of the RCRA regulatory program
as it applies to hazardous waste recycling.
Specifically, OSW will:
investigate regulatory requirements to identify
means to promote hazardous waste recycling, and
develop incentives (regulatory and non-
regulatory) for generators to recycle hazardous
wastes.
Background: ;
j
During the past year, EPA has worked on j
evaluating the current RCRA regulatory program^
as it applies to hazardous waste recycling, with }
particular focus on the issues of RCRA :
jurisdiction. Some of the more noteworthy
projects include:
the RCRA Implementation Study (RIS);
the Waste Minimization Incentives Notice and
Request for Additional Comment (55 FR 40881,
October 5, 1990 and 55 FR 50852 December 11,
1990); and
a series of three forum meetings held with
representatives of interested parties involved in
the hazardous waste management field, including
EPA Regional offices, State regulatory agencies,
industry and trade associations, environmental
advocacy groups, and the waste treatment
industry.
Activity Description:
OSW will engage in a number of activities to
encourage environmentally sound recycling by
integrating recycling considerations into hazardous
waste identification, tailoring regulatory
requirements, and developing appropriate generic
exclusions or exemptions to the hazardous waste
rules.
In addition, OSW will support Waste Systems
Information (WSI) and the Pacific Materials
Exchange (PME) to demonstrate computer
networks for waste exchanges.
Cross Reference to Activities: I, VI
33
-------
X. IMPROVING HAZARDOUS WASTE RECYCLING PROGRAM IMPLEMENTATION
Ij FY92
X.1 Special Collection System Rule
Responsibility: CAD/RDB
X2 Waste-Derived Cement notification rule.
Responsibility: CAD/RDB
X.3 Metal Reclamation Rule
Responsibility: CAD/RDB
X.4 Other Waste-Derived Products Rule
Responsibility: CAD/RDB
X.5 Support through grant partnership of the Waste
Systems Information and the Pacific Materials Exchange.
Responsibility: Lead: WMD/WMB
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XL PROVIDING FLEXIBILITY TO TARGET RCRA
STATE GRANT FUNDS TO WASTE MINIMIZATION NEEDS
Objective:
We will use the existing flexibility of the RCRA
Implementation Plan (RIP) to specifically
empower States to use grant funding to
implement State waste minimization activities.
The focus of this activity is to clarify the RIP and
the ability of the' States to use grant resources for
waste minimization projects and prioritization
rather than the review of the facility planning
requirements. We will accomplish this activity
through two mechanisms:
EPA will clarify in the Regional
Implementation Plan that waste minimization
activities are at the top of the waste management
hierarchy and reaffirm that States may use their
discretionary grant funds to underwrite such
activities.
In doing so, EPA will encourage States and
Regions to elevate the priority of facilities
requesting a permit with a view toward
accomplishing pollution prevention at those
locations.
Activity Description:
In the future, we will meet this objective by
allowing (through the RCRA Implementation
Plan), States and Regions the flexibility to
upgrade the priority of facilities for activities
based upon their waste minimization potential.
To develop this flexibility, we will study the
potential impacts that .such a change may have on
RCRA implementation. Further, we will develop
specific criteria that will assist States in
determining which types of waste minimization
activities should be considered for support.
Background:
Several States have passed laws requiring certain
sectors of the regulated community to develop
source reduction and recycling plans. These State
laws are consistent with the spirit of the provisions
in HSWA requiring each generator to certify that
it has a waste minimization program, in place.
From these plans, States may be able to identify
facilities with substantial opportunities for waste
minimization. By elevating the priority of these
operations for permitting through the RIP, States
may use their grant funds to foster waste
minimization.
Cross Reference to Activities: I, XIV
35
-------
XI. PROVIDING FLEXIBILiTYTOTARGETRCRA STATE GRANTFUNDS TO WASTE MINIMIZATION NEEDS
XI.1 Clarify the flexibility that States and Regions have to
upgrade the priority of facilities for activities based upon
their waste minimization potential in future RCRA
implementation plans.
Responsibility: Lead: PSPD; Team: WMD/WMB,
OWPE/RED, OPPT. Regions, OE
-------
XH. DEMONSTRATING SOURCE REDUCTION AND
RECYCLING AT SPECIFIC FACILITIES
Objective:
Demonstration programs can provide EPA, States,
industry, and other interested parties with valuable
information concerning source reduction and
recycling. Specifically, by supporting source
reduction and recycling demonstrations in a few
high-visibility industrial facilities, EPA can develop
information concerning:
the environmental and economic gains
associated with source reduction and recycling;
the incentives and disincentives to source
reduction and recycling created by regulations and
their proper enforcement;
alternative regulatory strategies that might
leverage additional incentives for reduction and
recycling; and
the interaction between the air, water, and
solid waste regulations and then- impact on cross-
media transfers and reduction/recycling
incentives.
The benefits of this program include EPA-
provided technical assistance to industry, specific
technical case studies, and environmental gains.
Lessons learned through such efforts will have use
and applicability throughout EPA program offices.
Activity Description:
EPA will develop such demonstrations by:
identifying a number of major industrial firms
by order of preference that are (a) involved in the
33/50 Project, (b) major generators of a
hazardous waste stream for which there is a
treatment/disposal capacity shortage, or which is
hard to treat, (c) located in high-priority
geographic areas, including international borders,
and (d) facilities which are not participating in the
33/50 project or do not release 33/50 pollutants.
selecting two major Federal facilities
participating in the EPA Federal facilities
pollution prevention initiatives (e.g.. the Risk
Reduction Engineering Laboratory's (RREL)
Cross Reference to Activities: I, III, VII, XTV
Waste Reduction Evaluations At Federal Sites
(WREAFS) program, or the Pollution Prevention
Branch's (PPB) Tidewater Interagency Pollution
Prevention Program, etc.)
working with these industrial and Federal
facilities to identify and implement source
reduction and recycling opportunities, by helping
each facility to (a) identify sources and quantities
of waste, (b) prioritize the waste streams
according to impact on human health and
environment, (c) identify source reduction and
recycling options relevant to the high priority ,
sources of waste, (d) choose the source reduction
and recycling methods to be implemented, and (e)
support implementation of the methods.
providing high visibility for the process and
findings at each facility through press releases and
public recognition.
In the past, the Waste Minimization Branch
supported one such demonstration effort at the
Amoco-Yorktown refinery. The effort focused on
identifying and implementing multi-media
pollution prevention techniques as part of a cross-
media permit development process. WMB plans
to support EPA source reduction and recycling
projects at specific facilities for FY92 and FY93.
(The ability for EPA to conduct as many
demonstrations as indicated will depend on
funding in future years.) EPA plans to conduct
up to two industrial case studies similar to and
based on the success of the joint EPA/Amoco
project. Shell Oil and Hughes Aircraft have
agreed to investigate their potential participation
in these case studies.
The Model States Cross-Media Permitting Project
will explore cross-media permit programs in
Kansas, Massachusetts, and New Jersey that are
obtaining source reduction and recycling gains.
The findings from this program will be
disseminated to interested States. This program
will be supported by Headquarters, Regional and
State-based technical assistance and evaluation.
These studies will be made available in the PPIC.
37
-------
XII. DEMONSTRATING SOURCE REDUCTION AND RECYCLING AT SPECIFIC FACILITIES
1 FY92
XII.1 Begin planning phase of demonstration projects by
applying the lessons learned from EPA/AMOCO project. .
Responsibility: Lead: WMD/WMB; Team: TBD
XII.2 Determine potential Federal Facilities for source
reduction pojectand resource allocation Issues with
other Federal Agencies. Responsibility: Lead:
WMD/WMB; Team: TBD
XII.3 Facility #1 - Federal facility- establish a
workgroup to plan out the following activities concerning
source reduction and recycling project.
Responsibility: Lead: WMD/WMB; Team: TBD
A) Environmental audit of selected site.
B) Assesscurrent source reduction and recycling
practices.
C) Assessaltemative source reduction and
recycling practices.
D) Identify the environmental and economic
benefits of source reduction and recycling.
E) Cost/Benefit analysis.
F) Produce Final Report.
XII.4 Facility #2 & #3- identify two major industrial firms
and establish a workgroup consisting of EPA and facility
employees to plan out the following activities concerning
the source reduction and recycling projects.
Responsibility: Lead: WMDAVMB; Team: TBD
A) Environmental audit of selected sites.
B) Assesscurrent source reduction and recycling
practices.
C) Assessaltemative source reduction and
recycling practices.
D) Identify the environmental and economic
benefits of source reduction and recycling.
E) Cost/Benefit analysis.
F) Produce Final Report.
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XII.5 Facility #4- Federal facility: establish a workgroup
to plan out the following activities concerning source
reduction and recycling project.
Responsibility: Lead: WMD/WMB; Team: TBD
A) Environmental audit of selected site.
B) Assesscurrent source reduction and recycling
practices.
C) Assessalternative source reduction and
recycling practices.
D) Identify the environmental and economic
benefits of source reduction and recycling.
E) Cost/Benefrtanalysis.
F) Produce Final Report.
XIII.6 Facilities #5 & #6- identify two major industrial
firms establish a workgroup consisting of EPA and
facility employees to plan out the following activities
concerning the source reduction and recycling projects
Responsibility: Lead: WMD/WMB; Team: TBD
A) Environmental audit of selected sites.
B) Assesscurrent source reduction and recycling
practices.
C) Assessalternative source reduction and
recycling practices.
D) Identify the environmental and economic
benefits of source reduction and recycling.
E) Cost/Benefit analysis.
F) Produce Final Report.
FING SOURCE REDUC
FY92
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XHI. SUPPORTING TECHNICAL ASSISTANCE EFFORTS
Objective:
OSW will ensure that the Pollution Prevention
Information Clearinghouse (PPIC) provides
adequate information on RCRA-related source
reduction and recycling, and to support State
technical assistance efforts. The PPIC is the
Agency's foundation for all technical assistance
since such assistance is a critical element in the
ultimate success of any waste minimization
program or approach. For more information on
how to access PPIC, call 1-703-821-4800. OSW
plans to:
continue to develop, contribute to, and review
technical information in the PPIC,
support demonstration projects that will result
in additional information, and
develop RCRA- and hazardous waste-specific
pollution prevention information to be added to
the PPIC.
Background:
EPA's PPIC can be used to support permit
writers in their efforts to address a facuity's needs
in an effective and environmentally protective
fashion. In order to be effective, PPIC must
compile as much RCRA-specific information on
waste minimization and pollution prevention as
possible, and update that information regularly.
Such an effort will require the following activities:
the information must be developed through
such means as pilot and demonstration programs;
the information must be transferred to those
interested in waste minimization or pollution
prevention activities; and
the information must be used as a part of the
program's or activity's implementation.
This can be accomplished through cooperative
agreements, regulatory development, facility
permitting programs, or enforcement actions,
depending on the particular situation.
This type of support and information development
will enable the PPIC to increase the resources
provided for the States and EPA to carry out
standard-setting and permitting activities discussed
in sections I, VI, VII, XI of the Action Plan, in
addition to the inspection and enforcement
activities discussed hi section II of the Action
Plan.
Activity Description:
This objective will be achieved by:
helping the PPIC staff market PPIC services
and training to RCRA Headquarter, Regional and
State staff;
developing strategy to incorporate RCRA
specific information into the PPIC;
developing RCRA-related source reduction
and recycling compendiums for those processes
that generate RCRA listed wastes ~ beginning
with those wastes containing chemicals targeted by
the 33/50 Project ~ to be included and distributed
by the PPIC;
participating in the PPIC staffs evaluation of
PPIC's RCRA needs; and
continuing to fund the National Rouhdtable of
State Pollution Prevention Programs.
Cross Reference to Activities: I, II, III, IV, V, VI, VII, VIII, IX, X, XI, XII, XIII, XIV
40
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XIII. SUPPORTING TECHNICAL ASSISTANCE EFFORTS
XIII. 1 Coordinate marketing of logon and input training
for Regional RCRA waste minimization technical experts.
Provide PPIC work stationsas needed to Regional
personnel.
Responsibility: Lead: WMD\WMB and ORD (OEETD)
PPIC
XIII.2 Develop source reduction and recycling
compendia for which information is available for all
processesthat generate RCRA listed (not characteristic)
wastes to be included and distributed by the PPIC.
Responsibility: Lead: WMD\WMB; Team: OSW\CAD,
ORD
XIII.3 Develop strategy for incorporating RCRA specific
information into PPIC.
Responsibility: Lead: ORD; Team: WMD\WMB
XIII.4 Develop strategy to increase use of PPIC by
RCRA waste minimization technical experts. Encourage
marketing the RCRA specific information (with respect
RCRA listed waste and topics) contained in the system.
Also assist PPIC in marketing study to understand the
needs with respect to RCRA wastes and topic.
Responsibility: Lead: ORD; Team: WMD\WMB
XIII.5 Continue funding to the Roundtable.
Responsibility: Lead: WMD\WMBandOPPT
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United States
Environmental Protection Agency
(OS-305)
Washington, DC 20460
Official Business
Penalty for Private Use
$300
EPA/530-R-92-020
May 1992
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