&EPA
United States Solid Waste and
Environmental Protection Emergency Response EPA530-R-94-010
Agency (5305) May 1994
National Roundtable
on Hazardous Waste
Minimization and
Combustion:
November 15-18, 1993
Summary Report
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CONTENTS
ection
Page
EXECUTIVE SUMMARY 1
1.0 INTRODUCTION 6
2.0 INTRODUCTION TO THE WASTE MINIMIZATION SESSION 6
3.0 PANEL DISCUSSION 8
4.0 WASTE MINIMIZATION GOALS SESSION 12
4.1 HAZARDOUS WASTE MANAGEMENT FACILITIES GROUP 12
4.2 HAZARDOUS WASTE GENERATORS GROUP 13
4.3 EPA AND STATE REGULATORS GROUP 14
4.4 TECHNICAL ASSISTANCE CENTERS GROUP 14
4.5 PUBLIC INTEREST GROUPS . 15
4.6 HETEROGENEOUS GROUP 16
5.0 WASTE MINIMIZATION ROLE SESSION 18
5.1 HAZARDOUS WASTE MANAGEMENT FACILITIES GROUP 18
5.2 - HAZARDOUS WASTE GENERATORS GROUP 19
5.3 EPA/STATE REGULATORS GROUP , 20
5.4 TECHNICAL ASSISTANCE CENTERS GROUP 21
5.5 PUBLIC INTEREST GROUP 22
5.6 HETEROGENEOUS GROUP SESSION 22
6.0 RANGE OF MECHANISMS TO ACHIEVE WASTE MINIMIZATION GOALS
SESSION 23
6.1 NONREGULATORY MECHANISMS GROUP 24
6.2 RCRA FEDERAL REGULATORY MECHANISMS GROUP (PERMITS
AND ENFORCEMENT ACTIONS) 25
6.3 RCRA FEDERAL REGULATORY MECHANISMS GROUP (GENERATOR
AND LDR REGULATIONS) 26
6.4 GENERAL ISSUES GROUP 27
6.5 NON-RCRA FEDERAL REGULATORY MECHANISMS GROUP 29
6.6 STATE REGULATORY MECHANISMS GROUP 29
7.0 BIG PICTURE ISSUES 31
8.0 WASTE MINIMIZATION SUMMARY 34
9.0 INTRODUCTION TO THE SESSION ON TECHNICAL COMBUSTION
STANDARDS 35
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10.0 GENERAL COMBUSTION ISSUES 39
10.1 TECHNOLOGY-BASED COMPARED WITH RISK-BASED STANDARDS ... 39
10.2 SITING REQUIREMENTS 41
10.3 SITING RESTRICTIONS 41
10.4 EXEMPTION FOR "NONTOXIC" HAZARDOUS WASTE 42
10.5 FUTURE INCINERATION CAPACITY 42
11.0 METALS COMBUSTION ISSUES 43
11.1 LIMITS ON PM 43
11.2 LIMITS ON INDIVIDUAL METALS 43
11.2.1 Forms of Control 44
11.2.2 Variability in Metal Feed Rate 44
11.2.3 Generic vs. Source-Specific Limits 44
11.2.4 Continuous Emissions Monitoring 45
11.3 NEED FOR CONTROLS ON BOTH PM AND METALS 45
11.4 WASTE MINIMIZATION CONSIDERATIONS 46
12.0 ORGANICS CONTROLS 47
12.1 CONTROLS ON DIOXIN 47
12.1.1 Limits on Dioxins 48
12.1.2 Controls on Total Congeners vs. Toxicity Equivalents 48
12.1.3 Exemption for Nonchlorinated Wastes 49
12.2 CONTROLS ON OTHER ORGANIC EMISSIONS 49
12.2.1 Risk from Dioxin vs. Other Organics 50
12.2.2 Surrogate for Other Organics 50
12.2.3 Effect of Waste Minimization 51
12.2.4 Quantifying Emissions for Risk Assessments 51
13.0 OTHER COMBUSTION ISSUES 52
13.1 FUEL BLENDERS 52
13.2 TRIAL BURNS 53
13.3 CAMPAIGN BURNING 54
13.4 SAMPLING OF FEED STREAMS 54
13.5 RECORDKEEPING 54
13.6 STATE REGULATIONS 55
13.7 EMERGENCY SAFETY VENTS . . 55
13.8 SAMPLING OF GAS STACKS 55
u
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CONTENTS (continued)
Section
14.0 CONCLUDING REMARKS
Page
. 56
PLENARY SESSION SLIDES
APPENDIX A
AGENDA
APPENDIX B
DISCUSSION DOCUMENTS
APPENDIX C
LIST OF PARTICIPANTS
APPENDIX D
LIST OF OBSERVERS
APPENDIX E
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CONTENTS (continued)
Section
Page
Table
TABLES
FORMAT OF THE WASTE MINIMIZATION SESSIONS OF THE NATIONAL
ROUNDTABLE ON HAZARDOUS WASTE MINIMIZATION AND
COMBUSTION
FORMAT FOR THE TECHNICAL COMBUSTION SESSION OF THE NATIONAL
ROUNDTABLE ON HAZARDOUS WASTE MINIMIZATION AND
COMBUSTION
11
39
IV
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NATIONAL ROUNDTABLE ON HAZARDOUS WASTE MINIMIZATION
AND COMBUSTION: November 15-18, 1993
SUMMARY REPORT
EXECUTIVE SUMMARY
This document summarizes the proceedings of a national roundtable on hazardous waste minimization
and combustion held November 15 through 18, 1993 in the Washington, D.C. area. Participants in
the roundtable, which was sponsored by the Office of Solid Waste, at U.S. Environmental Protection
Agency (EPA) Headquarters, addressed a variety of issues related to hazardous waste minimization
and combustion. To discuss topics, participants, including EPA and state regulators, and
representatives of public interest groups, hazardous waste management facilities, hazardous waste
generators, and technical assistance centers, were separated into breakout groups — six groups for the
waste minimization session and five for the combustion session. The groups developed ideas and
recommendations, which then were presented when the participants reconvened in plenary sessions
attended by all participants. Topics discussed during the roundtable included:
• Goals of hazardous waste minimization efforts
• Roles of stakeholders in achieving waste minimization
• Mechanisms to implement waste minimization
• Big picture issues related to waste minimization
• General issues involving combustion of hazardous waste
• Control of emissions of toxic metals from hazardous waste combustion units
• Control of emissions of toxic organic compounds from hazardous waste combustion units
• Other issues involving combustion of hazardous waste
Many of the participants held similar views on the broadest goals that were expressed for waste
minimization. Most of the groups agreed that the goal for pollution prevention should be the
implementation of a flexible, multi-media approach. All groups believed that one goal should be to
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remove disincentives and create incentives (for example, tax credits) for progress in implementing
pollution prevention. All groups also agreed that research and development in pollution prevention
should be increased and that additional technical assistance for pollution prevention should be
provided to parties engaged in pollution prevention efforts. In addition, many groups agreed that
more combustion research should be conducted. Industry, represented by participants from hazardous
waste management facilities and generators, generally also supported the goal of including all parties
involved (for example, generators and treatment and disposal facilities) in a multi-media approach that
highlights pollution prevention. The public interest groups held that the goal of waste minimization
should also include the eventual phase-out of production and elimination of release of all toxins.
Finally, the groups discussed goals in terms of percentage reduction of hazardous waste, but no
consensus was reached on the actual percentages to be achieved or the time frames for doing so.
During discussions of roles of stakeholders in achieving waste minimization, most participants agreed
that it is the generators' responsibility to implement waste minimization, but that the other stakeholder
groups can play a large part in assisting generators. Some of the stakeholder groups believed that it
is the responsibility of generators to communicate their progress in pollution prevention to the public.
Many of the stakeholder groups believed that it is the responsibility of EPA and state regulators to
(1) develop better measures of success in pollution prevention and communicate those measures and
(2) eliminate disincentives to pollution prevention. Several of the groups saw the role of technical
assistance centers to be provision of technical and financial assistance to generators, particularly
small-quantity generators. Finally, the public interest groups saw their role to be education and
establishment of citizens committees to bring problems related to specific sites to the government.
During the discussion of mechanisms to achieve waste minimization goals, the participants examined a
variety of mechanisms under the Resource Conservation and Recovery Act (RCRA), other federal and
state environmental statutes, and nonregulatory mechanisms. Regarding the use of RGRA regulatory
mechanisms, several participants considered the current certification requirements for waste
minimization ineffective and suggested that EPA and the states require generators to demonstrate that
they have a "program in place" and demonstrate that such/a program is achieving progress. In
general, members of the group discussing the use of RCRA permits and enforcement actions to
implement waste minimization concluded that permits may not be an effective means of implementing
waste minimization. The participants who discussed the use of non-RCRA federal regulatory
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mechanisms recommended that EPA develop a single, enforceable permit'process to address
generation of pollutants across all media. Suggestions for the use of state regulatory mechanisms
included use of state multi-media permits, provision of flexibility for the states in implementing
pollution prevention regulations, and transfer of experience in implementing pollution prevention
between the states and EPA. Finally, members of the nonregulatory mechanisms group stressed the
use of technical assistance programs, dissemination of information, professional accountability, and
economic incentives to achieve waste minimization goals.
When asked to identify "big picture" issues that are important to the implementation of waste
minimization, many of the participants identified three of greatest importance: (1) adopting a multi-
media approach, (2) developing clear measures of progress, and (3) using EPA's waste management
hierarchy. Many participants believed that, if it is to implement an effective multi-media approach to
waste minimization, EPA must restructure its regulatory programs to remove barriers to the
implementation of pollution prevention. However, there was no clear consensus on what a list of
these barriers would contain or on how to accomplish that goal. Several groups also provided
suggestions for means of measuring progress in pollution prevention, including the suggestion from
public interest groups that increased reporting should be required of generators. Finally, several
comments were presented concerning the use of EPA's waste management hierarchy. Although those
comments were diverse, most of the participants agreed that stakeholders should focus their efforts on
the top of the hierarchy (for example, on source reduction). There was considerable disagreement
between public interest groups and some industry representatives about the status of combustion in the
hierarchy. Public interest groups maintained that combustion should be near the bottom, while
industry representatives maintained that, in some cases, it should be moved up.
In the discussion of general combustion issues, participants discussed several items, including the use
of technology-based versus risk-based standards, siting requirements, and future incineration capacity.
There was considerable agreement over the use of technology-based versus risk-based performance
standards. Most participants agreed that there is considerable uncertainty about the use of risk
assessments and that the science involved in risk assessment should be improved. Consequently,
many participants proposed the use of the risk assessments only as a backup to technology-based
performance standards. However, many of the public interest groups held that risk assessments are a
completely unacceptable tool and that their results are not trusted by the public. Industry
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representatives and EPA ancLstate regulators generally agreed that joint RCRA, Clean Water Act, and
Clean Air Act technology-based performance standards should be developed. With regard to siting
requirements, the participants were divided on the question as to whether standards should apply
equally to existing and new facilities. All groups agreed that environmental equity and sensitive
environments should be considered when siting restrictions are developed. The public interest groups
felt that no new incinerators should be sited.
The participants discussed a variety of issues regarding control of toxic metals, including the
problems of using a particulate matter standard as a surrogate for toxic metals, the need for controls
on both particulate matter and metals, and limits on individual metals. The majority of participants
believed that particulate matter is not an effective surrogate for metals and that controls are needed for
both metals and particulate matter. No consensus was achieved on how to set limits on individual
metals. Industry representatives and EPA and state regulators suggested several approaches to
establishing limits for individual metals that involve various combinations of technology-based
standards, risk-based standards, or limits on the amount of metals that can be emitted. The public
interest groups generally maintained that metal-bearing wastes should not be fed to incinerators or
BIFs, but if they are, controls must be imposed on residues and products generated by such devices.
Industry representatives were divided on the question whether all combustion devices should be
subject to the same generic emissions standards (or whether source category-specific standards should
be developed), while most of representatives of the public interest groups held that all combustion
units should be subject to the same standards. Finally, almost all participants stated that the
rtechnology does not yet exist to allow continuous emissions monitoring (CEM) of metals. EPA and
state regulators believed that CEM for metals should be pursued actively, while representatives of
industry were divided on the issue.
Participants involved in the discussion of control of toxic organic compounds focused on two major
issues: control of emissions of dioxin and control of emissions of other toxic organics. Many
participants preferred technology-based performance standards for organic emissions supplemented
with either (or both) a national generic risk assessment or a site-specific risk assessment to ensure that
the controls were adequate to protect public health and the environment. Most participants agreed
that dioxin emissions could be reduced through the use of good combustion practices. There was
considerable debate over whether a dioxin limit should be established based on total congeners or
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toxicity equivalents. Many industry and EPA/state representatives favored the use of toxicity
equivalents. The public interest groups maintained that past emissions pf dioxin have been
unacceptably high and that no emissions of dioxin should be permitted. The participants also were
divided on the question of whether an exemption from the dioxin standard should be provided for
facilities burning nonchlorinated wastes. Many participants favored an exemption pending an
adequate demonstration of no harmful emissions from the facility, while others, particularly in the
public interest groups, opposed such an exemption because of the presence of naturally occurring
chlorine in feeds to hazardous waste combustion devices. Participants also disagreed on the adequacy
of surrogates (for example, carbon monoxide) used to control emissions of toxic organics, but they
generally agreed that better stack monitors are needed to ensure compliance with emission standards
for residual organic compounds.
Finally, the participants discussed a variety of issues related to the combustion of hazardous waste,
including the regulation of fuel blending, trial burns, and recordkeeping. Participants noted that fuel
blending is already regulated under RCRA, and many agreed that the amount of energy recovered and
the degree of burning for destruction should be factors in determining how burners should be
regulated and that blending of high metal content wastes to dilute the metals prior to burning should
be banned. The representatives of public interest groups and industry disagreed about the value of
trial burns. The public interest groups believed that trial burns are not representative of true
operating conditions (e.g., operators are on "good behavior" during the test while the regulators are
looking over their shoulders), while most industry representatives maintained that, in fact, trial burns
represent the worst operating conditions under which they would (and could) operate given that permit
conditions (i.e, operating limits) are based on operating conditions during the trial burn. However,
all groups agreed that the methods of selecting principal organic hazardous constituents and the
analytical detection limits for quantifying emissions should be improved. Finally, several approaches
to the quantification of the destruction and removal efficiency for organic compounds, including the
use of surrogates and real wastes, were discussed, although no consensus was reached on the issue.
Representatives of the public interest groups also maintained that the records of operations of BIFs
and incinerators should be made available to the public, and that greater standardization of
recordkeeping procedures should be required. Industry and EPA and state regulators generally agreed
with these suggestions and stated that it may be helpful to require computerization of such data.
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1.0 INTRODUCTION
The U.S. Environmental Protection Agency (EPA) Office of Solid Waste and Emergency Response,
Office of Solid Waste hosted a national roundtable meeting, November 15 through 18, 1993.
Through this meeting, EPA sought to stimulate the widest range of involvement and comment from
all participants to assist EPA and the states in developing a national waste management strategy that
will:
• Better integrate waste minimization into the national hazardous waste management program
under the Resource Conservation and Recovery Act (RCRA)
• Ensure that hazardous waste combustion standards for all RCRA hazardous waste incinerators
and boilers and industrial furnaces are fully protective of human health and the environment.
The roundtable was held in the Washington, D.C. area. Representatives of concerned parties were
invited to engage in an open dialogue on key waste minimization and combustion issues. Observers
of the discussions also were offered an opportunity to contribute their viewpoints at specific periods
during the discussions.
This paper is organized to parallel the organization of the roundtable which involved two separate, 2-
day sessions on waste minimization and waste combustion respectively. Chapters 2.0 through 8.0
summarize the Waste Minimization session which was conducted November 15 and 16, 1993 and
Chapters 9.0 through 14.0) summarize the Waste Combustion session which was conducted on
November 17 and 18, 1993.
2.0 INTRODUCTION TO THE WASTE MINIMIZATION SESSION
Matthew Straus, Director, Waste Management Division, U.S. Environmental Protection Agency,
welcomed participants and presented to them an overview of the status of hazardous waste
management and of waste minimization and hazardous waste combustion in particular. Mr. Straus
urged participants to consider the roundtable their opportunity to influence the future course of waste
management efforts through their participation in the discussion of draft strategies for encouraging
source reduction and recycling and for regulating combustion technologies, including burners and
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industrial furnaces (BIF). Mr. Straus pointed out that there are three main areas of concern in
hazardous waste management: combustion, waste minimization, and capacity. In the area of
combustion, he noted, issues are visible and controversial. The draft strategy provides an opportunity
for interested parties to examine technical issues in that area. AH parties, he pointed out, must
recognize that consensus on any subject is not likely, but all parties must participate in a frank and
open discussion.
Source reduction and recycling are waste minimization, said Mr. Straus, although there is some
confusion over terms. Efforts in the area of waste minimization initially gained ready support, and
there have been many successes. Today, there is a need to recognize such successes, whether at the
federal, state, or industry level. Now, said Mr. Straus, we must move forward to fully integrate
waste minimization into the waste management agenda, finding new ways to implement source
reduction and recycling. Identifying the need for a partnership between public and private sectors,
Mr. Straus urged participants to identify barriers; discuss the roles of government, industry, and the
public; and build a philosophy to support waste minimization programs.
Capacity issues, said Mr. Straus, concern whether the free market can control capacity and whether
caps can be employed. Strategies, he added, will be developed for all RCRA wastes.
The challenge of the coming days of the conference, Mr. Straus told participants, is to rise above
individual issues and explore new ways to make waste minimization a part of waste management
policy.
Elliot Laws, Assistant Administrator, Office of Solid Waste and Emergency Response, EPA, then
outlined the three priorities of the conference. First, he said, we must keep the public better
informed about the actual risks associated with hazardous wastes. We should develop in the public a
better understanding of the technical and policy framework and a realistic picture of what regulators
can and cannot do. Second, we must harmonize the goals of the key stakeholders: the public, EPA,
and operators. Last, regulators, communities, and public interest groups must become involved in the
formation of partnerships. Key considerations for effective policy making, said Mr. Laws, will be
bold, innovative programs; effective partnerships; emphasis on involvement, rather than
confrontation; and a well-informed public.
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During the next several years, EPA will give priority to efforts to build such partnerships and
involvement, working with states and interested groups. Another priority for EPA will be to address
public mistrust and close the gap between national policy and local interest. A third priority, which
Mr. Laws described as "challenging traditional thinking and taking afresh look," will involve
implementing new approaches, eliminating disincentives to waste minimization under RCRA, and
improving the RCRA system. Mr. Laws pointed out the need for public involvement in the RCRA
permitting process to ensure acceptance by the public of permitting decisions. He also noted that
some states are more advanced than EPA in such areas as source reduction, establishment of technical
standards, and public involvement. Such advanced approaches should be integrated into the national
effort, he said.
Mr. Laws' challenge to participants was to "bring experiences to bear on issues, break new ground,
and discuss new approaches."
3.0 PANEL DISCUSSION
A panel discussion immediately followed Mr. Laws' remarks. Panelists were Mark Woodall, Sierra
Club; Susan Ferguson, Texas Natural Resource Conservation Commission; Randy Price, DuPont;
Mike Benoit, Cadence Energy Recovery and chairman of the Cement Kiln Recycling Coalition
(CKRC) Executive Committee; and Phil Retallick, Rollins Environmental Services, Inc. Fred
Chanania, Project Director for the National Strategy on Waste Minimization and Combustion, OSW,
moderated the discussion.
Mr. Retallick stated that hazardous waste management in the United States is the envy of the world.
He said that the land disposal restrictions (LDR) have been the single most effective vehicle in
promoting waste minimization. He added that the regulated community recognizes the benefits of
reducing the amount of waste generated and, therefore, the cost of waste management. Under
RCRA, there is no strong incentive for recycling, said Mr. Retallick, and recycling efforts need
"revamping": for example, the use of contaminated solvents as feedstocks for solvent recovery rather
than as fuel.
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Mike Benoit commented that reliance upon waste combustion for energy recovery is important in the
effort to move away from landfills. Kilns, he said, are a waste minimization technology that reduces
generation of greenhouse gases. Cement kilns recover energy from waste and are "an excellent
bridge technology" while addtional waste minimization advances are achieved. Mr. Benoit pointed
out that industry supports more stringent standards and that the cause of waste minimization is
weakened by relaxation of the LDR regulations. "EPA's mid-80s strategy for waste minimization
worked," said Mr. Benoit, "and EPA should not forsake it."
Mark Woodall stated that he had attended the conference to discuss alternatives to combustion, not
combustion technology. He noted that many groups, such as environmental justice organizations and
Native American groups, were not represented at the conference and suggested a better approach
would be to "start at the grass roots." Mr. Woodall stated that the goal of the Sierra Club with
regard to the conference "is to reduce hazardous and toxic waste to avoid any combustion at all." He
added that the Sierra Club supports the RCRA strategy to phase out organochlorines and recommends
expansion of the list of toxic substances, full accounting to the public for materials at facilities, and
public participation in decision making with regard to RCRA combustion facilities.
Randy Price emphasized the need to maximize environmental gains and focus on real risks, while
remaining aware of the concerns of the public. There are many outstanding strategies for waste
minimization, he said, but facilities must be free to choose the strategies that are best for them.
Industries can be provided positive incentives to do so. Mr. Price said he agreed with the objective
of continually reducing the risk involved in handling hazardous waste, but asked "What, level of risk
is acceptable?"
Success can be measured by "the amount of waste avoided and the amount of waste managed safely,"
said Susan Ferguson. She identified needs related to identifying and measuring goals and improving
the quality of data. Ms. Ferguson recommended greater funding by EPA of support programs such
as outreach and technical assistance beyond EPA's regulatory role, as well as data systems. She
stated that participants should recognize that dialogue is beginning and that it is an ongoing activity
that will not produce immediate results.
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Fred Chanania then posed questions concerning issues such as reduction of paperwork, planning for
waste minimization, and industry's efforts to meet the expectations of regulators and the public.
Mr. Peter Wise, the lead facilitator, explained the format for the waste minimization sessions. The
format is summarized in Table 1.
TABLE 1
R^lATOFTOEWASraMIMVlIZATiONS^^
MINIMIZATION AND COMBUSTION
DATE
SESSION TYPE
SESSION DESCRIPTION
11/15/93
Plenary
Opening address and welcome by Matthew A. Straus, Director of the Waste Marq^prat Diviscn
of OSWER; overview of Ihe waste miAras^^fnrh^cn^ast^^B^Ijms, Assistant
Administrator ofOSWER; Panel discussion on the waste mirimizadcxi airi oombusdon strategy.
Breakout on Waste
Minimization Goals
Six separate groups discussed what their groups' goals should be with respect to waste
mWmizatioa Rve of the groups were composed of a single type of stakeholder, including
hazardous waste facflity managers, generators, regulators (state arrifedaaO, Public interest groups,
and technicaJ assistance cater staff. The sixth group was oor^xisedcf representatives fiorneaii
of the *o\emertioned stakeholder groups. Each breakout session had a facilitator, a recorder,
and from 12 to 20 participants. Several observers attended each breakout session.
Plenary
A representative fiom each breakout session presented the potential goals generated by that
breakout group.
Breakout on Waste
Minimization Roles
Sk separate groups discussed the roles members of their groups couM assume to meet the waste
mintaization goals te were gereratd The composition of the
groups was identical to that of the previous breakout groups on goals.
11/16/93
Plenary
A representative of each breakout session preserted the potertial roles generated by to breakout
group.
Breakout on
Mechanisms to
Achieve Waste
Minimization Goals
Sh separate groups discussed pctertM mechanisms for achie\drg waste r^ The
groups were organized according to the tjpe of mechanisms to be discussed, Wuding: 1) RCRA
federal regulatory (permte and enforcemert actions), 2) RCRA federal regulatory (generator and
LDR requirements), 3) Non-RCRA regulatory, 4) State regulatory, 5) Nonregulatory, and 6)
General. All groups were mixed, with rqxesentanves from each stakeholder group that
participated in the previous breakout sessions. All groups had fiom 12 to 20 particpants, a
facilitator, a recorder, and several observers.
11/16/93
(continued)
Plenary
A representative of each breakout session presented the potential mechanisms generated by that
breakout group.
10
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DATE
SESSION TYPE
Breakout on Big
Picture Issues
Plenary '"'
SESSION DESCRIPTION
Six groups each discussed a common set of big picture issues, bases on the issues that were most
important to the particular group. All groups were mixed, with representatives of all stakeholders.
All groups had from 12 to 20 participants^ a facilitator, a recorder, and several observers.
A representative of each breakout session presented the potential goals generated by that breakout
group.
The sessions are listed in the order in which they occurred on each date.
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4.0 WASTE MINIMIZATION GOALS SESSION
After the introductory session of the national roundtable, the participants were divided into six
preassigned breakout groups. The breakout groups included:
• Owners and operators of hazardous waste management facilities
• Hazardous waste generators
• EPA and state regulators
• Technical assistance centers staff
• Public interest groups
• Heterogeneous group
A summary of each breakout session is provided below.
4.1
HAZARDOUS WASTE MANAGEMENT FACILITIES GROUP
The hazardous waste management facilities group was composed of owners and operators of ;
hazardous waste treatment, storage and disposal facilities. They were asked to develop potential goals
for their group for the advancement of the waste minimization and combustion strategy. Their
discussion centered on the need to build the confidence of both regulators and the public in the
professional integrity of their industry. The group agreed that promotion of a message of
professionalism and dedication to continued protection of human health and the environment might
allay some concerns about combustion of hazardous wastes.
The group developed nine potential recommendations and then assigned priority to four that the group
wished to present in the plenary session. These goals were:
• Focus on pollution prevention in all aspects of waste management for all media, rather than on
the hierarchy, and allow flexibility in the hierarchy.
• Develop a concept of waste minimization that extends beyond generators and includes
treatment technologies.
• Avoid relaxation of environmental standards in the name of waste minimization.
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• Refine the combustion waste strategy by reorganizing it into a pollution prevention strategy
with subsections on:
- Source reduction
- Waste minimization
- Recycling
- Reuse
- Treatment - combustion
- Land disposal restrictions (LDR)
- Ranking of opportunities
4.2
HAZARDOUS WASTE GENERATORS GROUP
The hazardous waste generators group agreed their overall goal is to reduce potential risks associated
with wastes or releases to the environment, using EPA's hierarchy as a framework for actions and the
existing information contained in the toxic release inventory (TRI) as the public's measure of progress
in a manner that creates value for the corporation and the public.
The generators agreed on several initiatives:
• Working toward a multi-media approach that reduces overall risk arising from many sources
• Using existing sources of data, rather than devoting more resources to collection of data
• Using positive economic incentives, rather than regulation
• Developing a cost-effective approach
• Developing a program that is voluntary and flexible, to allow facilities to determine the most
effective way to achieve waste reduction
• Aiming for broad, yet flexible, participation (not necessarily 100 percent mandatory)
• Encouraging public involvement in the form of education, development of awareness, and
dialogue
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4.3
EPA AND STATE REGULATORS GROUP
All members of the EPA and state regulators group were asked to provide their goals or visions for
waste minimization. Approximately 30 items were identified by group members. Those items then
were crafted into a single goal. The group agreed that the goal should contain certain elements,
including quantitative criteria, a "level playing field" for all sites, and a multi-media approach.
The following goal was developed: The national goal is at least a 50 percent reduction of multi-
media pollutants through source reduction by the year 2000.
A subgoal also was defined, as follows: to achieve the maximum source reduction that is technically
and economically feasible at specific sites. The group also agreed that the following concepts are key
to implementation of the goal:
• Implementation of a multi-media approach that incorporates flexibility and accountability
• Elimination of disincentives for waste minimization and pollution prevention
• Creation of incentives
• Public involvement and empowerment
• Adjustment for production and economic growth, and credit for prior achievements in waste
reduction
4.4
TECHNICAL ASSISTANCE CENTERS GROUP
All members of the Technical Assistance Centers group were asked to develop a statement of goals
reflecting the group's perspective on waste minimization. Examples of statements of goals were
presented to the group. There was discussion of implementation of pollution prevention. The
participants were separated into two discussion groups. The ideas of each of the groups were
presented. The participants agreed that the goals should be relevant, attainable, and appropriate.
They also should describe outcomes, be measurable (if possible), state conditions and standards, and
be brief.
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Although no goal was developed from the ideas collected from the groups, 14 discussion ideas were
presented. They include:
• EPA should make pollution prevention a real priority and strive for continuous improvement.
• Single-medium programs should be consolidated into a multi-media prevention program that
includes prevention and assurance of compliance.
• EPA should coordinate federal research and development and technical assistance activities to
support pollution prevention.
• Incentives and adequate resources are needed to encourage continuous action to reduce wastes
to a minimum (multi-media). All future regulations must include pollution prevention
provisions that are supported by state grant allocations and technical assistance.
• Each Regional office of EPA should have the responsibility for promoting pollution prevention
goals that reflect compliance actions, waste reduction (multi-media), and multi-media
inspections.
• EPA managers and programs should be held accountable for pollution prevention and for
facilitating state and local activities. By 1995, 50 percent of the time worked by employees
should be spent on implementing pollution prevention.
• EPA accountability goals and measures that do not support pollution prevention should be
removed or changed. Pollution prevention should be a factor in enforcement compliance
agreements by 1995; in 50 percent of agreements by 1997; and in 100 percent by 1999. .
EPA's pollution prevention expectations should be made clear to industry.
• Flexibility is needed in the mechanisms used for pollution prevention, recognizing the diversity
of generators and of the nature of relationships between particular industries and government.
• Assistance should be provided through existing technical assistance providers (federal, local,
and state).
4.5
PUBLIC INTEREST GROUPS
The public interest groups developed the following goals:
• Empower citizenry: Maximum participation of local citizenry is required. EPA should try to
persuade states to allow citizens to attend settlement conferences. More usable data should be
provided to citizens.
• Improve implementation: Empower citizens to assist EPA in implementing a RCRA strategy
to phase out the production and release to the environment of organochlorines and heavy
metals (toxins).
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4.6
Phase out all toxins: Reduce the amount of generated waste, and phase out production and
release of all toxins.
Eliminate combustion: The national goal should be to reduce waste generation and toxics use
enough to avoid any combustion.
Mandate source reduction: An immediate moratorium should be imposed on all plans for
new incinerators. Labeling should be regulated so that people know what toxins are present in
products.
HETEROGENEOUS GROUP
The heterogeneous group, unlike the other breakout groups, was made up of representatives of
various stakeholder organizations, including regulators, public interest groups, generators, and
hazardous waste management facilities. Members were asked to develop preliminary statements of
goals for waste minimization. After the group discussed the six initial goal statements, its members
developed a final goal strategy for waste minimization that, while not completely acceptable to all
stakeholders, reflected some common ground. There was general agreement that any waste
minimization strategy should emphasize:
• Protection of human health and the environment
• Regional and local flexibility (for example, in identifying toxics of concern)
• Minimization of shifts of pollutants from one medium to another (multi-media approach)
• Cost-effectiveness (sustainable projects)
The group's final goal statement was: The goal for waste minimization should be a priority-based
approach to the reduction of generation and release of toxic waste, including persistent toxics. The
focus of waste minimization efforts should be on the generators of products.
Although most group members supported a priority-based approach to waste minimization, the group
did not reach agreement on the criteria to use in establishing priorities. Criteria considered were
EPA's waste management hierarchy, characteristics of chemicals (for example, toxicity and
persistence), and cost-effectiveness.
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The group also developed an interim milestone of 50 percent voluntary-teduction in generation of
hazardous waste by the year 2005. Most stakeholders agreed that there should not be a "target" for
waste reduction (as opposed to a milestone) because of the problems that arise in measuring the
progress of waste reduction on a multi-media basis (for example, lack of data and fluctuations in
manufacturing volumes) and the lack of incentives for continuous improvement. Although industry
favored a voluntary waste reduction program, as well as credit for earlier reductions, representatives
of EPA and a public interest group held that a voluntary program having no provisions for
enforcement would not be effective.
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5.0 WASTE MINIMIZATION ROLE SESSION
Following the breakout and plenary sessions on waste minimization goals, the participants discussed
the roles of stakeholders in promoting waste minimization. The breakout groups were the same as
those in the waste minimization goals session, which include:
• • Hazardous waste management facilities
• Hazardous waste generators
• EPA/state regulators
• Technical assistance centers
• Public interest groups
• Heterogeneous group
Summaries of each breakout session are provided below.
5.1
HAZARDOUS WASTE MANAGEMENT FACILITIES GROUP
The members of the hazardous waste management facilities group developed roles for each of the
stakeholders in implementing waste minimization. The hazardous waste management facilities group
members stressed their role as a service industry focused on providing generators with the best
available technologies and services for the entire waste management hierarchy to help ensure the
protection of human health and the environment. To that end, group members agreed that their role
includes promoting waste minimization options and serving as an information gatherer and
clearinghouse for generators. However, the members of the group were opposed to monitoring and
tracking generators because the generators are their clients, and they would not be willing to play the
role of regulator. On the other hand, the waste management facilities group suggested that such
facilities would be willing to work with EPA regulators to develop and strengthen environmental
standards.
The group also recommended the following roles for regulators, public interest groups, generators,
and technical assistance groups:
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Roles of Regulators:
• Promote consistent, enforceable, and protective standards
• Provide technical assistance in P2, source reduction, and waste reduction
• Assess and eliminate loopholes and disincentives that may diminish P2 efforts
• Devise means of quantification of progress in P2 (measurable indicators)
• Communicate progress in P2 to the public
• Focus on P2, rather than shutting down combustors or any other practicable treatment
technologies; maintain a multi-media outlook and use good science
• Focus on providing more assistance to small and medium-sized generators
Roles of Public Interest Groups:
• Establish consistent dialogue with local generators and TSDFs
• Focus on P2, rather than shutting down combustors or any practicable technologies; maintain
a multi-media outlook and use good science
Roles of Generator:
• Communicate progress in P2 to the public
• Communicate the links between desired consumer products and wastes generated in association
with those products
• Accept the lead role and responsibility for their waste, from cradle to grave
Technical Assistance Center's Roles:
• Focus on smaller generators
• Involve universities more closely (to be initiated by technical assistance groups)
5.2
HAZARDOUS WASTE GENERATORS GROUP
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Generators saw themselves playing a substantial role in working toward waste minimization by
focusing on communication, corporate culture, and planning.
Generators felt they needed to better understand expectations of regulators by developing an active
partnership with EPA. They felt that only through this cooperation can an industry-wide waste
minimization trend be developed. Generators felt the need to communicate opportunities for waste
minimization that are already available. They also saw a need to convince educational institutions to
integrate waste minimization into educational systems. Generators felt they must also develop a
relationship with the public in order to get a perception of the public's expectations and also to
provide visibility and to show the progress being made. The same successes should be shared with
employees within the company to serve as a model.
Generators saw the need for further integration of waste minimization into corporate culture and
business strategy. Generators felt the need to demonstrate corporate commitment and empower every
worker to make a change. They said that management must take steps to install a stated goal
regarding corporate expectations, establish a waste minimization audit program, and implement its
findings. In order to meet these steps, generators must engage in active planning.
Generators felt that planning activities should ensure waste minimization plant-wide, while still
enabling companies to do business. They said that a tracking system should be installed to internally
measure progress by quantity and project status. To do so would entail identifying the real cost and
value of waste streams. Generators thought that priorities should be established for pollution
prevention activities by risk and cost, matching priorities with available resources. They believed that,
through such efforts, industry can develop a long-term waste minimization plan that fosters small
companies' development and takes a creative approach to reducing pollution across all media.
5.3
EPA/STATE REGULATORS GROUP
The breakout session focused on EPA's and state regulators' roles in promoting waste minimization.
The participants, though diverse, voiced concerns that were not dissimilar. During the discussion, the
participants developed 22 ideas. They then voted on the ideas to determine their priority.
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First, the group stressed a consistent multi-media approach that includes combining efforts in the air,
water, and RCRA programs. They agreed that particular efforts should be focused on resolving
inconsistencies currently present among the different programs, for example, in definitions arid
program requirements.
Second, the group discussed the issue of "bean counting." There appears to be a consensus among
the participants on the issue of EPA's and states' inability to measure P2 and successes in P2. The
measurement ability of current "bean counters" HkeTRI reports repeatedly was questioned; generally,
the group identified a need to introduce new measures and delete those that fail to measure success
adequately.
Third, lack of resources to implement P2 tasks was a major concern among the participants. In
addition, they recommended more flexibility in funding.
Finally, P2 planning was discussed. P2 plans should be required for all media, permits, and
generators.
5.4
TECHNICAL ASSISTANCE CENTERS GROUP
The technical assistance centers group began its discussion by discussing the issues set forth in the
discussion document, while suggesting additional issues to be discussed. The group focused primarily
on two issues: 1) technical assistance by regulatory vs. nonregulatory entities, and 2) advantages of
public vs. private operation/funding of technical assistance centers. Additional issues identified
included assistance in regulatory compliance and the appropriateness of providing recommendations to
industry and inspectors.
The group then suggested three major areas for action to help achieve the goal statement previously
identified:
• Provide technical assistance, including facilitating business-to-business interactions; helping
improve competitiveness of businesses through P2, changing the established relationship
between government and industry; participating in and contributing to the National Roundtable
on State Pollution Prevention Programs; and building a national information network.
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• Play a leadership role in effecting change in P2, including fostering relationships with non-
traditional partners; voluntary programs, integrating P2 within state agencies, acting as
champion of P2 within state, supporting P2 legislation; and defending the definition of P2.
• Support funding including maintaining program support and flexibility in funding.
5.5
PUBLIC INTEREST GROUP
The public interest groups began by asking themselves, "What actions could we take to achieve the
group's goals?" and "What can other groups do to support our goals?" The group then developed
suggestions and ideas, most of which reflected such themes as:
• Education
• Access to information
• Legislative and regulatory reform
• Empowerment of the public
Of the approximately 30 ideas that were generated, the group decided that the following are of the
highest priority:
• Improving education
* Establishing labor or citizen committees
• Encouraging product reforms and influence on and access to government decisions
• Bringing site-specific problems to the government's attention
5.6
HETEROGENEOUS GROUP SESSION
Unlike the other breakout groups, the heterogeneous group was made up of representatives of various
stakeholders organizations, including EPA/state regulators, public interest groups, generators,
technical assistance centers, and hazardous waste management facilities. Members were asked to
identify activities the various stakeholders could undertake to achieve the group's goal for a priority-
based approach to reducing the generation and releases of toxic waste. The 30 activities the group
proposed fit into a strategic seven-step plan for waste minimization. That plan is: 1) commit to and
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support the goal of waste minimization, 2) inventory waste streams, 3) .-identify and establish priorities
for waste minimization projects, 4) implement projects in which the benefits justify the use of
resources, 5) measure and report performance, 6) recognize success, and 7) transfer technical
information when possible.
After the group discussed the proposed activities, members ranked the activities according to their
overall importance in achieving the group's goal of waste minimization, regardless of which
organization was responsible for the action. Highly ranked activities, which included both near- and
long-term actions, were:
• Lobby Congress for multi-media legislation (proposed activity for all stakeholders)
• Identify and establish priorities for waste minimization projects (proposed activity for all
stakeholders)
• Close legislative loopholes on recycling to make waste minimization economically
advantageous (proposed activity for EPA/state regulators)
• Implement projects in which the benefits justify the use of resources (proposed activity for
generators and EPA/state regulators)
• Come to final consensus on the definition of waste minimization and pollution prevention
(proposed activity for all stakeholders)
Several stakeholders also pointed out that reaching out to small quantity generators and addressing the
issue of household hazardous wastes are important factors in the success of any waste minimization
program. There was general agreement that the focus of technical and financial assistance should be
to urge small quantity generators to undertake waste minimization efforts.' Although the group did
not reach consensus on whether collection of household wastes is an example of a waste minimization
endeavor, there was strong support for the inclusion of that activity in a long-term strategy to educate
the general public on waste management. Members of the group identified education (of the public,
of industry, and of other affected parties) as a workable tool in successful implementation of a waste
minimization program.
6.0 RANGE OF MECHANISMS TO ACHIEVE WASTE MINIMIZATION GOALS SESSION
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The third group of breakout sessions in the waste minimization session focused on the range of
mechanisms available for achieving waste minimization goals. The participants were again separated
into six groups, but the grouping arrangement was different from that for the previous sessions and
was as follows:
• Nonregulatory mechanisms group
• RCRA federal regulatory mechanisms group (permits and enforcement actions)
• RCRA federal regulatory mechanisms group (generator and LDR regulations)
• General issues group
• Non-RCRA federal regulatory mechanisms group
• State regulatory mechanisms group
A summary of each breakout session is provided below.
6.1 NONREGULATORY MECHANISMS GROUP
Members of the nonregulatory mechanisms group developed recommendations for mechanisms to
achieve waste minimization. The discussion produced numerous recommendations and focused
primarily on information exchange, consumers and market incentives, and possible changes in EPA's
strategy from enforcement to compliance. Although the group did not reach consensus on all issues,
the participants agreed on the following recommendations:
* Technical Assistance Programs:
- Provide funding commensurate with recommendations
- Geographically target efforts
- Integrate already available groups
- Create public and private partnerships
- Provide mentoring, including both large and small companies
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Dissemination of information: -•
- Increase technical assistance resources
- Establish a clearinghouse
- Facilitate development of focus groups
— By chemical used
— By technology
— By status
- Coordinate efforts of industry associations
- Develop P2 curricula for universities
Professional Accountability:
- Provide responsible care
- Encourage establishment of international standards
Economic Incentives:
- Establish a baseline: create tax incentives for P2 loans
- Create incentives for reduction of waste disposal costs by volume
- Recognize economic incentives to reduce costs through waste minimization
- Provide startup funding for P2 businesses
6.2 RCRA FEDERAL REGULATORY MECHANISMS GROUP (PERMITS AND
ENFORCEMENT ACTIONS)
The breakout group on exploring RCRA permit and enforcement mechanisms (as a means of helping
to achieve waste minimization goals) focused more on the use of RCRA permits than enforcement
actions. The discussion generated various ideas that were voted upon by the participants. Those
ideas that were supported strongly are summarized below.
Many participants, particularly the representatives from industry and regulators, believed that RCRA
permits are not the best tool for encouraging waste minimization. The group expressed this concern
through a strong vote in support of the statement that RCRA permits should not be used to achieve
waste minimization goals.
The lack of measurable indicators of P2 progress also was a major concern among the participants.
The participants believed that such measurable indicators should be developed before permit and
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enforcement mechanisms are considered. In addition, the specificity of such indicators also was
discussed, and the group strongly believed that it might be necessary that indicators be tailored to
specific industries.
The group stressed the issue of planning by industry. The group believed that requiring industry to
submit waste minimization plans would be conducive to the goal. Requirements for the submission of
such plans could be a condition of issuing a permit.
Finally, public interest groups, although concerned about the issues, stated that they are not well
informed on the uses and functions of RCRA permits and suggested the need for a deliberate effort to
include the public in the permitting process.
6.3 RCRA FEDERAL REGULATORY MECHANISMS GROUP (GENERATOR AND
LDR REGULATIONS)
The breakout session on exploring RCRA generator and LDR regulatory mechanisms pointed to the
ineffectiveness of certification requirements that have been in place since 1983. Generators saw
"programs in place," however, as a positive step that has proven to work in many states, such as
California. But generators stated that verbal commitment on the part of companies fell short of
effectiveness. Generators believed programs needed to be written and must have demonstrated
progress.
Some generators even suggested EPA require companies to review waste generation annually and
justify continued use of especially harmful chemicals. The focus, however, was on requiring
substantive programs. First, EPA must provide better guidance on what constitutes an acceptable
program, while recognizing the need for flexibility.
Flexibility in regulatory mechanisms was of major concern among generators. To nurture pollution
prevention, generators need flexibility to best reduce pollution affecting all media. Generators should
be able to establish priorities among projects and tailor programs on a plant-to-plant basis. Given this
need for flexibility, command and control is not an appropriate motivator. Not only does it not work,
but arbitrary goals set by command and control regulation also cause underachievement. Economics
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is a more appropriate motivation. Generators must have the ability to pake cost-effective decisions
that will result in substantial reduction of pollution for the least cost. Many aggressive programs are
capital-intensive and unresponsive to these realities.
With regard to implementation, generators felt states should be adequately funded to effectively
review and enforce programs. However, generators warned regulators; in enforcing programs; to
avoid blurring the distinction between enforcement and technical assistance. Generators also believed
competitive business interests should be considered in implementing mechanisms, and small
businesses should be provided with a model.
6.4 GENERAL ISSUES GROUP
The general issues group was made up of representatives of various stakeholder organizations,
including EPA/state regulators, public interest groups, generators, technical assistance centers, and
hazardous waste management facilities. After a quick review of the range of issues related to
mechanisms that had been outlined in the discussion document, members of the group choose to
discuss regulatory and nonregulatory mechanisms for achieving waste minimization. Although the
group developed no official opinion on which of the two mechanisms is most effective,
representatives of several stakeholder organizations favored a balanced regulatory and nonregulatory
approach to waste minimization. Generators pointed out the need to evaluate existing mechanisms
(such as regulations and economic factors) to determine what already has been done and been proven
successful in achieving waste minimization. The recommendation received strong support from other
members of the group. Another recommendation, provided by EPA/state regulators, that drew wide
backing was the linking of enforcement activities with technical assistance.
The most popular recommendations dealt with the need for regulatory agencies to fully commit to,
support, and communicate waste minimization and pollution prevention opportunities. The
importance of regulatory mechanisms for protection of the environment was noted, but the group
recognized that such regulations often inhibit innovation and progress in waste minimization. There
was general agreement that regulatory agencies should:
• Revise regulations that present obstacles to waste minimization
• Ensure that regulations consider current technical knowledge
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Adopt internal goals that demonstrate the principle of pollution prevention
Allocate resources in a way that reflects commitment to pollution prevention
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6.5 NON-RCRA FEDERAL REGULATORY MECHANISMS GROUP
The non-RCRA federal regulatory mechanisms group was interested in two main issues:
• Tracking accounting for materials
• Multi-media issues
The group developed approximately 16 ideas and suggestions. The group then voted on and ranked
each suggestion, with the following four receiving the greatest number of votes:
• Bring academia into planning and research for pollution prevention, with some access accorded
the public
• Develop one single, enforceable permit process
• Bring academia into planning and research for pollution prevention, with full access accorded
the public
• Encourage far-reaching programs (consider phasing in such programs over time)
6.6 STATE REGULATORY MECHANISMS GROUP
The state regulatory mechanisms group began its breakout session by first reviewing two case studies.
One case study pertained to waste generated in painting booths by a car manufacturer, and the second
dealt with a waste minimization program at a manufacturer of wood product coatings. The group
then turned to identifying important issues to be discussed; two priority issues emerged from that
discussion:
• Federal and state issues concerning flexibility
• Organizational and regulatory changes to promote multi-media P2
The following is the list of recommendations developed by the group:
• States need assistance in incorporating P2 into regulatory programs.
• Tradeoffs are needed in state grant work plans to allow EPA grant managers to encourage P2.
• EPA should promote the top of the waste management hierarchy to the states.
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• EPA should learn from the states' P2 programs (for example, California's incinerable waste
project).
• EPA should write regulations so that rules encourage P2, or give states the option to do so.
• EPA should develop a facility wide P2 reporting system as part of a national database (in
cooperation with the states) to replace current media-specific reporting systems.
• EPA should encourage states to move toward multi-media permitting (or consider it in existing
programs), for example:
- Establish state permitting teams
— Eliminates funding conflicts
— Encourages companies to conduct facilitywide P2 efforts
- Streamline permit decisions using multi-media permitting efforts
• Federal laws should give states conditional flexibility based on P2 initiatives (for example,
fundamentally different factors under the CWA).
• Regulations and fee structures should be changed to send a consistent message in support of
P2:
- Fees for permitting
- Generator fee structure based on waste hierarchy (and rebate) as is in place in Oregon and
New Jersey
• All media regulations promote P2 explicitly and not discourage it.
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7.0 BIG PICTURE ISSUES
During the National Roundtable on Hazardous Waste Minimization and Combustion, the participants
in breakout sessions identified and discussed "Big Picture" issues relating to waste minimization.
This summary presents the results of the breakout sessions in order of priority as determined by the
participants.
The three topics identified as the most important were:
• Multi-media impacts
• Measurement of progress
• Waste management hierarchy
Multi-Media Impacts - Many views and opinions were presented concerning this subject. Many of
the comments on multi-media impacts centered on a fundamental restructuring of EPA regulatory
programs. However, no consensus was reached on how to achieve that goal. Some suggested setting
up a multi-media team, which would develop regulatory policies and programs and help shape a
legislative strategy. It was pointed that pollution prevention (P2) currently is limited by the lack of
flexibility in laws and their single-medium nature. Others thought that there is a need for an
enhancement of federal, state, and local organizational structures to promote multi-media approaches,
stating that current EPA and state programs are not focusing on moving up the hierarchy. It was
suggested that there is a need for an all-encompassing definition of P2 and that facilities should be
required to prepare multi-media P2 plans. One group suggested that the current structure of the
multi-media approach is sufficient, stating that another layer of bureaucracy is not desirable. Other
comments included:
• Responses to violations should address all media.
• Regulatory language should be consolidated (lead by the EPA).
• There is a need to break down administrative, technical, economic, and regulatory barriers that
impede success.
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Measurement of Progress - The participants reached no consensus on how to measure progress. A
number of suggestions were produced during the breakout sessions. Some of the groups cited the
need to focus on identifiable, measurable goals, which should be based on a multi-media approach
and targeted to the specific facility or program. The groups believed that instituting waste
minimization requirements for annual approval on a wastestream-by-v/astestream basis is a good idea.
The public interest groups advocated that generators should begin making public reports of toxins in
production. Another group talked about restructuring RCRA reporting requirements for waste
minimization because there is a great disparity in the quality of reports actually being submitted. The
group identified a need for greater consistency among reports in the data submitted and especially in
the definitions of terms used in the reports.
Waste Management Hierarchy - More individual comments were presented on waste management
hierarchy than on any other Big Picture issue. The comments also were very diverse. Some
participants wanted the title of the topic changed to Toxic and Hazardous Materials Hierarchy. Below
are listed a number of the suggestions that were made:
• Use the hierarchy as a flexible framework for continuous improvement to reduce waste
streams.
• Focus on the effects of all constituents at all levels of the hierarchy.
• Focus on the entire hierarchy (energy recovery and recycling should be moved up).
• Exercise preference for pollution prevention and source reduction in general, with other
elements in the hierarchy preferred in specific cases.
• Recognize the role of combustion in the hierarchy.
• Encourage the use of the best available technology (BAT) under the hierarchy.
• Devote Agency resources to the top of the hierarchy.
• Determine how to track reduction of wastes and releases within the hierarchy; expand the TRI
by SIC code and chemical.
• Use facility-specific plans to obtain measurements; confirm those measurements through audits.
According to some groups, the EPA should focus 50 to 80 percent of its resources on clean
production (toxics use reduction/source reduction). They also stated that the use of existing economic
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inducements, coupled with protective regulations, would be an incentive, rather than a disincentive.
One group noted that different programs use different definitions. All groups appeared to agree that
consistent definitions of terms used in the hierarchy must be developed and that currently, too many
problems arise because of the "apples and oranges" problem with definitions. Finally, one group
suggested that the current regulations be changed to make pollution prevention become the higher
authority. In this way, pollution prevention would supersede any current regulations.
Other topics also were discussed including:
• Economics and market mechanisms
• Regulatory issues
Economics and Market Mechanisms - These two topics were considered together because of their
similarity. Many generators listed the appeal of tax incentives for pollution prevention activities and
accomplishments. One group suggested implementation of a program designed to work like the
Malcolm Baldridge award, except that it would be awarded to the company that meets certain criteria
for excellence in pollution prevention. This group felt that just as car companies boast about winning
the Baldridge award, so could the winner of a pollution prevention award. One group identified the
need for waste generation fees, similar to air fees, for all media. One group stated that there is a lack
of understanding of current market forces and that there is a need to identify analogies in other
sectors for harnessing such forces. Overall, everyone agreed that there is a great need to develop
market incentives.
Regulatory Issues - The majority of the participants thought the EPA and local and state governments
could do more than they currently are doing to foster change. There was a strong sense that the EPA
should further commit its resources by:
• Pressing for uniform enforcement of regulations in all Regions and states.
• Allowing direction of resources according to a priority system that focuses on the most serious
environmental problems, with local planning and community involvement.
• Consulting with Congress on changes in environmental statutes and policies, which are behind
the current technology curve.
• Evidencing a clear will and commitment from Administrator Browner and the Clinton
Administration.
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* Providing consistent signals.
• Conducting mini-roundtables in each region of the country.
• Requiring a citizen TRI-type report requirement.
• Correcting current failures to enforce rules and regulations.
• Providing clearer regulatory directions.
• Recognizing that the existing state and federal administration structures are not conductive to
multi-media pollution prevention.
The group came closer to consensus on this issue than on any other. The shared view was evident
that government could do more to foster regulatory and economic change, which in turn, would
stimulate companies' desire to improve upon pollution prevention.
8.0 WASTE MINIMIZATION SUMMARY
At the conclusion of the waste minimization session, Fred Chanania, Project Director for the National
Strategy on Waste Minimization and Combustion, Office of Solid Waste, said he was "pleasantly
surprised at the amount of consensus" and stated that the energies should be focused on those areas.
Mr. Chanania further summarized lessons learned from the session, EPA's direction, and necessary
actions for stakeholders.
Mr. Chanania believed the strongest message was the need for a multi-media, flexible approach.
However, he said that many seemed to question whether EPA and government resources are
significantly engaged. He said that EPA should more effectively communicate its commitment and
provide greater technical assistance to further pollution prevention. Mr. Chanania categorized
barriers to the efforts as administrative, technical, economic, and regulatory. Above all, he stressed
the need for partnerships among stakeholders to overcome these obstacles.
Mr. Chanania said EPA will summarize and digest the ideas generated during the roundtable and then
communicate the information to the public and stakeholders. Mr. Chanania said this purpose will be
accomplished through regional roundtable discussions and other projects that stress public involvement
and continued dialogue. Internally, he noted EPA must show leadership in furthering pollution
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prevention and build on current momentum to show progress. Finally, Mr Chanania said that to be
successful, a multi-media approach must be developed. Goals for EPA in the coming year included
issuing final guidance on waste minimization programs and developing a waste minimization strategy.
This strategy must include goals, process, projects, and barriers. However, Mr. Chanania warned
against building expectations of unachievable results.
In closing, Mr. Chanania stated that all stakeholders have a role in promoting pollution prevention.
He said that TSDFs should develop a positive role and build on current successful models.
Generators should be open to the pollution prevention process by developing information and methods
for sharing it. He said that a first step should be a phase-out of priority persistent toxics. Mr.
Chanania noted that public interest groups should continue the effort to overcome structural barriers
and help to set priorities for concerns related to pollution prevention and toxics. He suggested that
joint lobbying with industry would be a powerful tool. Technical assistance centers are key to
information flow and exchange of technical suggestions on waste minimization. Finally, he suggested
that regulators should show their leadership and commitment and nurture the momentum for pollution
prevention that has developed by continuing efforts to remove barriers and working toward a multi-
media, flexible approach.
9.0 INTRODUCTION TO THE SESSION ON TECHNICAL COMBUSTION STANDARDS
After brief opening remarks by Fred Chanania, special assistant to the director of the Office of Solid
Waste, EPA, Sylvia Lowrance, Deputy Associate Administrator, (EPA) welcomed participants to the
session on technical combustion standards with a brief review of the previous day's sessions on waste
minimization. She told participants that their efforts will be helpful to EPA in evaluating the waste
minimization program. She said that the new Administration is committed to a participatory approach
to the issue, citing the scheduling of several regional roundtables for early 1994 as "the beginning of
public participation." Ms. Lowrance stated that the truly difficult issue is whether standards are to
be technology-based or risk-based and that the debate centers on two questions: What is the
increment of risk to be abated? and How good is the science? Looking to the future, Ms. Lowrance
envisioned an expansion by EPA of multi-media "cluster" regulations and a new emphasis on "cross-
program approaches" similar to that already in place in the pulp and paper industry.
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Fred Chanania then provided participants with an overview of the schedule of the session On technical
combustion standards, reminding participants that their efforts will have the attention of the
Administrator of EPA. Mr. Chanania also noted that new guidance soon will be available on public
involvement opportunities and that industry should take a "good-neighbor approach" to regulatory
issues. He also told participants that permit writers soon will have available new guidance on the use
of omnibus permitting authority. Before introducing the general session on technical combustion
standards, Mr. Chanania touched briefly on the scheduled regional rbundtables, noting that their
structure will promote greater participation by interested parties at the local level.
Peter Wise, the lead facilitator, explained the format for the combustion session. The format is
summarized in Table 2.
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TABLE 2
FORMAT FOR THE TECHNICAL COMBUSTION SESSION OF THE NATIONAL ROUNDTABLE ON HAZARDOUS WASTE
MINIMIZATION AND COMBUSTION
DATE
11/17/93
11/18/93
SESSION TYPE
Plenary
Breakout on General
Combustion Issues
Plenary
Breakout on Metals
Controls
Breakout on
Organics Controls
Plenary
Breakout on Other
Combustion Issues
SESSION PESCR1PTION
Welcoming address by Sylvia Lowrance, Deputy Associate Administrator, Office of Solid Waste
(OSW); meeting overview by Fred Chanania, special assistant to the director of the Office of Solid
Waste (OSW); Introduction to the Technical Combustion Session by Peter Wise, SAIC.
Five separate groups discussed general combustion issues. The groups were composed of a
mixture of representatives from all of the stakeholder organizations that were present at the
roundtable. Each breakout group had owners or operators of TSDFs, generators, regulators (state
and federal), public interest groups, and technical assistance center staff. Each breakout groups
also had a facilitator, a recorder, and between 12 and 20 participants. Several observers attended
each breakout session.
A representative from each breakout session presented the general combustion issues generated by
their breakout group.
Five separate groups discussed metals controls issues. The composition of the groups was identical
to the previous breakout groups on general combustion issues.
Five separate groups discussed organics issues. All groups were mixed with representatives from
all stakeholders that participated in the previous breakout groups. All groups had 12 to 20
participants, a facilitator, a recorder, and several observers.
A representative from each breakout session presented the organics issues generated by their
breakout group.
Five groups each discussed other combustion issues generated by which issues were the most
important to the group. All groups were mixed with representatives from every stakeholder. All
groups had 12 to 20 participants, a facilitator, a recorder and several observers.
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DATE
11/18/93
(continued)
SESSION TYPE
Plenary
Closing Remarks
SESSION DESCRIPTION
A representative from each breakout session presented the other combustion issues generated by
their breakout group.
Closing remarks by Matthew A. Straus, Director of the Waste Management Division of OSWER.
1 The sessions are listed in the order that they occurred on each date.
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10.0 GENERAL COMBUSTION ISSUES
The following summarizes the discussions that occurred during five breakout groups arid a plenary
session on general combustion issues. Each breakout group had similar mixtures of various
stakeholder representatives at the Roundtable and each group began their discission with the same set
of issue topic areas. Groups were allowed to raise additional issues. These issue topic areas
included:
• Technology compared with risk-based standards
• Siting requirements
• Siting restrictions
• Exemption for "non-toxic" hazardous waste
• Future incineration capacity
The following subsections present the major points that were raised by various stakeholders across the
five breakout sessions on general combustion issues.
10.1 TECHNOLOGY-BASED COMPARED WITH RISK-BASED STANDARDS
Many representatives of public interest groups held that incineration is not an appropriate technology
because of unacceptable risks posed by emissions (no risk is acceptable) and the inability to determine
the actual composition of products of incomplete combustion (PICs). Many public interest groups
also held that risk assessments should address risks posed to the environment, as wells as those posed
to human health. Many of these groups also believe that risk assessments are not an appropriate tool
because existing levels of hazardous substances in the environment and in humans have not been
determined (lack of epidemiological studies). Many of these groups also believe that, whatever risk
assessment standard is accepted, there should be zero discharge of toxic, persistent compounds and
the standards should be protective of human health and the environment. Some representatives of
public interest groups said that standards should focus on pollutants of concern, not surrogates. Many
public interest groups representatives also believe that risks associated with removal actions should be
considered carefully.
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Representatives of public interest groups and EPA/state regulators stated that regulations and
standards should ensure that generators and treatment facilities have a written plan for pollution
prevention and waste minimization. Public interest groups also stated that metals and chlorinated
wastes should not be incinerated. Although acknowledging some of the problems that metals and
halogens can pose, industry representatives questioned what noncombustion alternatives were available
to treat metal and halogen-bearing wastes effectively and safely.
Many industry representatives and EPA/state regulators agreed that technology-based performance
standards should be developed, with risk assessment as a check, and that regulations should compel
better and better technology. These participants generally agreed that use of risk assessments alone is
not appropriate for determining emission standards because of the uncertainties that inherently result.
Rather, many believed that risk assessments should be used to supplement technology-based standards.
In this regard, many EPA/state regulators and industry representatives agreed that EPA should
develop better risk assessment science. Further, many agreed that some form of site-specific risk
assessment (i.e., screening assessment or comprehensive assessment) should be conducted to help
ensure that the technology-based standards are protective. In addition, representatives from all three
groups held that the science of risk assessment should be simplified and fine-tuned and that the public
does not trust the results of risk assessments. Many representatives of on-site facilities support a risk-
based alternative to technology standards because; 1) many on-site facilities are smaller and have
lower mass emission rates which can mean a lower risk level, and 2) many of the on-site
representatives believe EPA should consider dollar values when establishing standards that are more
stringent than called for under risk assessment. All groups agreed that resources should be committed
to enforcement and that EPA should establish a level playing field for all facilities.
Industry representatives and EPA/state regulators held that EPA should develop and use joint RCRA,
Clean Air Act, and Clean Water Act standards. Industry representatives and EPA/state regulators
believed strongly that, if existing facilities could not meet the standards, they should be closed or
upgraded. However, some industry representatives and EPA/state regulators thought that costs should
be considered in establishing technology-based standards (e.g., for existing facilities and small
facilities), assuming that the technology-based standards result in emission levels more stringent that
those that would be dictated by the use of risk assessment alone.
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10.2 SITING REQUIREMENTS
Representatives of some public interest groups stated strongly that no additional incinerators (or BIFs)
should be sited. All groups agreed that existing loading in humans and the environment and the
presence of other sources of emissions (for example, existing incinerators) should be considered
carefully when siting new BIFs or incinerators. Industry representatives stated that siting
requirements should be defined clearly and limits on siting established. They said that a time frame
and schedule for implementation of requirements should be established. Industry representatives also
stated that uniform guidelines for siting requirements should be established.
Industry representatives and EPA/state regulators supported periodic review of existing facilities.
Industry representatives and EPA/state regulators maintained that, in developing standards, EPA
should allow flexibility for current state requirements for buffer zones, as well as site-specific
situations. Some industry representatives stated that siting requirements should be applied equally to
existing facilities, and others believed that different siting requirements should be developed for
existing facilities. The majority of the members of each group considered the effects of combustion a
national issue that is not addressed by siting requirements.
10.3
SITING RESTRICTIONS
Many of the breakout sessions did not include discussion of this issue. Most groups that did discuss
the issue agreed that environmental equity should be considered when developing siting restrictions.
These groups also agreed that such factors as environmental loading and proximity to schools, flood
plains, residences, and sensitive environments should be considered. Industry representatives and
EPA/state .regulators believed that, in such cases as new commercial incinerators, siting regulations
should address populations already exposed to contaminants, as well as other environmental receptors.
The representatives of public interest groups held that siting restrictions should be applied to
remediation wastes. In siting decisions, risk from handling materials and the existing air quality also
should be considered. Others stated that requirements should be the same, regardless of the waste
streams being managed.
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10.4
EXEMPTION FOR "NONTOXIC" HAZARDOUS WASTE
During this discussion, many points were made about emissions from fossil fuels and from hazardous
waste fuels. A study completed by California EPA revealed that hazardous waste fuel burns cleaner
than fossil fuels. The representatives of public interest groups did not want to allow any exemptions
for burning "clean" hazardous waste fuels. EPA and state regulators held that exemptions for
hazardous ignitable wastes should meet specific conditions. Regulators and industry representatives
have problems with exemptions because enforcement and implementation are difficult. Both groups
also believed that waste characterization and halogen content of wastes are issues.
10.5
FUTURE INCINERATION CAPACITY
The representatives of public interest groups held that excess incinerator capacity is a disincentive to
waste reduction and that waste reduction should limit the need for additional incinerators. They said
that there are alternative treatment technologies that are more effective than incineration in destroying
the wastes. (Many industry representatives questioned whether there were, in fact, noncombustion
treatment methods available for most of the wastes currently combusted that have been shown to be
effective and safe.) Many representatives from public interest groups expressed the view that
incineration is not an acceptable technology because emissions from incineration pose unacceptable
risk. The group maintained that policies and regulations should discourage incineration and move
toward its eventual phase-out. Industry representatives and EPA/state regulators stated that that
market should be the primary determinant of capacity and that EPA should not determine the market.
They stated that the market would be determined by economics, need, cleanup requirements; and
regulatory requirements. EPA and state regulators stated that capacity should be considered on a
regional and national level. Some commenters felt that the state capacity assurance guidelines should
be changed so that states that do not have large incineration capacity do not lose Superrund money.
They also held that capacity limits would affect economics adversely and are a disincentive for
industry to upgrade control technologies (for example, such limits discourage recovery of energy from
high-BTU wastes). Regulators maintained that hazards associated with the transportation of hazardous
waste should be considered when examining capacity. Public interest groups and regulators held that
excess capacity should be avoided and waste reduction emphasized. Industry representatives held that
there always will be a need for waste management and that incineration is one of the safest
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technologies available. They said that a more cohesive, focused approach to permitting is needed, so
that industry and the market can react to changes. There was no consensus among or within groups
on current incineration capacities. However, industry representatives stated that there is not sufficient
capacity for some types of wastes (for example, nerve gas, explosives, and mixed waste). Several
industry representatives noted that EPA relys on incineration as a preferred treatment technology
under the Land Disposal Restrictions.
11.0. METALS COMBUSTION ISSUES
The following summarizes the discussions that occurred during five breakout groups and a plenary
session on metal combustion issues. Each breakout group had similar mixtures various stakeholder
representatives that were at the Roundtable and each group began their discussion with the same set of
issue topic areas; These issue topic areas included:
• Limits on particulate matter (PM)
• Limits on individual metals
• Need for controls on both PM and metals
• Waste minimization considerations
The following subsections present the major points that were raised by various stakeholders across the
five breakout sessions on metal combustion issues.
11.1
LIMITS ON PM
The overwhelming majority of breakout group participants thought that particulate matter (PM) is not
an effective surrogate for metals. Thus, real-time monitoring and the PM standard were not discussed
in detail. A few participants felt that PM can be a good surrogate for metals and that, if the PM
standard was more stringent, and if continuous monitoring of PM was feasible, then periodic stack
testing for metals might be enough to control metals emissions.
11.2
LIMITS ON INDIVIDUAL METALS
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Representatives of many public interest groups' believed that metals should not be fed to incinerators
or BIFs in any form or volume. Some industry representatives noted, however, that combustion may,
in fact, be the safest and most effective way to treat many organic wastes containing metals. Industry
and EPA/state regulators believed that limits should be set for individual metals. Some industry
representatives suggested the use of maximum achievable control technology (MACT) to set a
concentration-based emission standard and to use risk assessment (either on a generic, national level,
or on a site-specific basis, or both) as a check on the MACT. Some industry representatives and
EPA and state regulators also suggested mass emission limits as well to limit the total amount of
metals emitted. Other general group suggestions included establishing limits for metals and halogens
fed to the system and requiring that risk assessments consider indirect exposure and site-specific
background concentrations. Additional suggestions and comments regarding limits for individual
metals are presented below according to the subtopic areas that were presented for the metals limits
issue in the EPA Roundtable discussion document.
11.2.1
Forms of Control
The public interest groups believed that control of metals should pertain to both the emissions and the
other residues (and products) generated by combustion devices. Some participants thought that limits
should be placed on both mass emission rates and stack gas concentration. Many participants
believed that, even if continuous monitoring of metals is feasible, some monitoring of feed streams
should continue and that operating controls should continue to apply (e.g., maximum temperature in
the combustion chamber and at the air pollution control device (APCD), APCD operating parameters)
to ensure good operating practices.
11.2.2
Variability in Metal Feed Rate
Some industry representatives suggested that flexibility in permitting and applicability of standards
should be considered to address those facilities that have no metals or very low levels of metals in the
waste streams.
11.2.3
Generic vs. Source-Specific Limits
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Many representatives from public interest groups believed strongly that everyone should be required
to meet the same standard. Industry representatives were divided on this idea. Some commenters
believed that all units should meet the same standard, while others thought that separate standards
should be written for the various types of combustion devices (e.g., cement kilns, incinerators), for
small facilities, and for existing facilities. In addition, industry representatives held that some units
should be exempt from certain standards if no metals are present in the hazardous waste burned.
11.2.4
Continuous Emissions Monitoring
In general, the participants believed that the technology is not yet available for continuous emissions
monitors (CEM) for metals. The public interest groups held that if continuous monitors are not yet
available then perhaps semi-continuous monitoring of metals can be conducted (basically more
frequent stack sampling). They did state, however, that the CEM for metals should be pursued.
Industry representatives from a Department of Energy (DOE) facility noted that a CEM for metals is
required by one of their permits but that the device is not yet available. In addition, few CEMs can
handle the extreme environments in some stacks (for example, those with high concentration of
nitrates).
Industry was divided on whether a CEM for metals should be further pursued. Some commenters
(generally representing small, on-site burners) stated they would rather continue the waste feed
analysis approach to metals monitoring. Many representatives from public interest groups were not
satisfied with current waste feed analysis methods of monitoring metals. They felt that these methods
do not properly account for real world operations where upsets occur. Industry representatives stated
that the automatic waste feed cutoff system would take care of any upsets that occurred, but the public
interest groups did not share that confidence. The industry representatives also pointed out that
individual metal compounds sometimes cannot be distinguished by a CEM. The EPA/state regulators
believed that development of a CEM for metals should be pursued actively.
11.3
NEED FOR CONTROLS ON BOTH PM AND METALS
Many industry representatives believe that both metals and PM limits are needed. The representatives
of industry believed that the Clean Air Act is a driving force for the PM limit and soon will be such
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for metals. They did think, however, that the limits should be tempered by the relative hazards posed
by the individual compounds. Some industry representatives predicted that once the metals controls
are decided upon, the PM controls would then be in place; they felt mat if you have a metals limit
then the PM limit would be unnecessary. The EPA/state regulators felt strongly that limits should be
required for both PM and metals. Reasons in support of that position included concern about toxic
organics adsorbed onto PM, and that the PM per se is a health hazard (e.g., the PM10 issue). An idea
developed by the group was that the list of metals should be reexamined and updated, according to
current lexicological data.
11.4
WASTE MINIMIZATION CONSIDERATIONS
Public interest group representatives generally believed that metals should not be fed to combustion
devices. They felt the only acceptable level of feed and emissions of metals is zero. They believed
that incinerators and BIFs should be used for true resource recovery. They felt that units burning
metal-bearing wastes are operating outside the original intent of RCRA because the metals going into
these units (other than metal recovery furnaces) are not being used as a resource (such as a fuel) nor
are they being recovered. The public interest groups held felt that EPA should prohibit blending of
metal-bearing wastes destined for combustion. In addition, they stated that EPA should use a strategy
for the reduction of toxics use, rather than a waste minimization approach, to eliminate metals from
the feed streams to incinerators and BIFs.
The industry representatives generally agreed that there were definitely some wastes with very high
concentrations of metals that should not be fed to incinerators or BIFs. However, they were divided
on whether to completely disallow metals in the feeds to these units. They stated that there are many
organic waste streams that have trace levels of metals for which incineration is probably the most
effective and safest treatment. Pretreatment to remove the metals is sometimes feasible, while under
other circumstances, such pretreatment is not possible or not cost effective. Some industry
representatives noted that pretreatment can cause severe health and safety concerns (for example, at
DOE facilities). Industry felt that if EPA wishes to encourage reclamation of metals, incentives
should be provided to encourage that activity.
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The EPA/state regulators thought that some metal-bearing wastes definitely should not be incinerated,
and that perhaps a ban should be placed on these streams. They also believed that a multi-media
approach should be taken to better assess the big picture of effects of metals on the environment.
In general all stakeholders believed that minimization of metal-bearing wastes is the preferred path.
They also believed that recovery of metals is preferred to burning them, and that more research and
development should be conducted to assess alternative recovery technologies. In addition, many
representatives stated that more research should be conducted on the behavior of metals in combustion
systems to evaluate the need for reduction of the quantities of metals in the feed to incinerators and
BIFs.
12.0 ORGANICS CONTROLS
The following .summarizes the discussions that occurred during five breakout groups and a plenary
sessions on organic compound combustion issues. Each breakout group had similar mixtures of
stakeholder representatives and each group began their discussions with the same set of issue topic
areas. These issue topic areas included:
• Controls on dioxins
• Controls on other organic emissions.
The following subsections present the major points that were raised by stakeholders across the five
breakout sessions on organic compound combustion issues.
12.1 CONTROLS ON DIOXIN
Four subissues concerning controls on dioxins were discussed. These subissues included:
Limits on dioxins
Controls on total congeners versus toxicity equivalents
Exemption for non-chlorinated wastes
Effects of waste minimization
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Major points raised during discussions on these subissues are presented below.
12.1.1
Limits on Dioxins
Consensus was not reached on the standard that should be used for control of dioxin. Some
participants supported the adoption of the standard proposed by the European Community (EC). At
the same time, concern was raised about the need for clarification of the derivation of the EC
standard. In terms of setting numbers for the standard, representatives of public interest groups held
that the limit on emissions of dioxin should be zero, but most of the rest of the group felt that a
technology-based performance standard should be developed that would be risk-checked. Many
industry representatives and EPA/state regulators held that the formation and emission of dioxins
could be reduced by the use of good combustion practice, stack gas temperature controls, and the use
of air pollution control equipment. Representatives of public interest groups suggested that the
identification of the best achievable technology (BAT) and maximum achievable control technology
(MACT) should be updated every three to five years.
Industry representatives identified a need for full-scale testing to better understand the formation of
dioxin and its control, identification of sources of dioxin and furans to determine whether other
controls are needed, and the conduct of more accurate mass balance calculations. Representatives of
public interest groups agreed to some degree with those recommendations but believed strongly that
all sources of halogens should be identified and eliminated. Representatives from several stakeholder
groups stated that metals and halogens in waste streams must be identified, and wastes with high
levels of metals and halogens should not be blended with wastes that are to be burned.
Representatives of public interest groups also recommended that the existing levels of dioxin in the
environment be determined and the health effects resulting from current dioxin emissions levels be
evaluated.
12.1.2
Controls on Total Congeners vs. Toxicity Equivalents
In general, many participants thought the TEq approach was acceptable for several reasons. Industry
representatives generally supported TEq because they believed that TEq is more protective and
provides a more appropriate evaluation from the point of view of a risk assessment. Industry
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representatives also pointed out that TEq is easier to use because of its wide acceptance. Some EPA
and state regulators thought that the TEq approach should be adopted until better approaches become
available, because they felt that the total congeners approach can be improved to better estimate risks.
Some participants supported development of a total congener evaluation, with risk evaluation as a
check.
12.1.3
Exemption for Nonchlorinated Wastes
There was substantial disagreement as to whether facilities burning hazardous waste with
nondetectible levels of chlorine should be exempt from dioxin controls. Several participants noted
that chlorine from other sources (e.g., fuels such as coal, or raw materials) could react with products
of incomplete combustion from burning hazardous waste to form dioxins. Some EPA and state
regulators recommended that EPA consider reduced requirements (e.g., reduced stack testing) for
facilities that handle nonchlorinated wastes.
12.1.4
Effects of Waste Minimization
Many participants believed that the goal should be reduced use and eventual elimination of chlorinated
feedstocks and emphasized that industry should make a commitment in this area. Representatives of
public interest groups felt that all potential sources of dioxin, including halogen containing materials,
should be identified and eliminated, but industry representatives did not feel that that recommendation
was realistic. Industry representatives emphasized that the complexity of the roles of chlorinated
compounds in the manufacturing industry should be recognized. For a more realistic
recommendation, industry representatives stated that a tight dioxin standard would ensure
implementation of the best technology and protection of public health, and encourage waste
minimization because the cost of meeting the standard would be passed back to generators.
12.2
CONTROLS ON OTHER ORGANIC EMISSIONS
F.our subissues concerning controls on other organic emissions were discussed. These subissues
included:
• Risk from dioxins versus other organics
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• Surrogates for other organics
• Effects of waste minimization
• Quantifying emissions for risk assessments
These subissues are presented below.
12.2.1
Risk from Dioxin vs. Other Organics
In general, participants believed it is necessary to control other toxic organics, as well as dioxin. The
EPA and state regulators emphasized the importance of good combustion design and operating
practices that lead to better control of organics. Many EPA and state regulators and industry
representatives believed that stack monitoring and testing when burning chlorinated wastes should be
more frequent. However, some industry representatives suggested that EPA should focus on controls
on dioxin because those individuals believed that addressing dioxin also would control other organics.
12.2.2
Surrogates for Other Organics
Representatives of public interest groups voiced concern that the use of surrogates may not ensure
adequate control of organic emissions. However, many industry representatives stated that carbon
monoxide (CO) remains a good indicator of combustion and suggested that EPA review the existing
database for CO information and trial burn data and conduct more frequent stack testing of specific
compounds to verify the appropriateness of the use of surrogates.
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12.2.3
Effect of Waste Minimization
The group agreed that waste minimization is a valid way to reduce chlorine and other halogens in
feedstocks, and provide an alternative strategy to emissions control.
12.2.4
Quantifying Emissions for Risk Assessments
EPA and state regulators recommended consideration of both the toxicity and the quantity of
emissions of other organics. Industry representatives believed that enforcement should be directed
based on risk and toward bad actors. Representatives of public interest groups stated that not enough
is known about what is coming out of stacks. Many participants agreed that stack sampling and risk
modeling procedures need to be better validated. Public interest groups also recommended that EPA
require that data from emissions monitoring be disclosed to the public. The public interest groups
held that risk assessments should be completed before construction of a facility begins. The group
developed agreed that it would be helpful for EPA to collect all test data from the Agency, industry,
academia, and other sources and make the information available in a user-friendly format.
Representatives of public interest groups held that more research is needed to better characterize
emissions. Several industry representatives also agreed that research and development (R & D)
regarding the characterization of emissions should be apriority, including bench-, pilot-, and full-
scale testing. Representatives of public interest groups emphasized that funds for R & D should be
used for pollution prevention and that industry should pay for such R & D.
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13.0 OTHER COMBUSTION ISSUES
The following summarizes the discussions that occurred during five breakout groups and a plenary
session on other combustion issues. Each breakout group had similar mixtures of all of the various
representatives and each group began their discussions with the same topic areas of issues that were
included in the EPA discussion document for combustion sessions that was provided to all the
Roundtable participants. These issue topic areas included:
• Fuel blenders
• Trial burns
• Campaign burning
• Sampling of feed streams
• Record keeping
• State regulations
• Dump stacks
• Stack gas sampling
The following subsections present the major points that were raised be stakeholders across the five
breakout sessions on other combustion issues.
13.1 FUEL BLENDERS
Some of the groups did not discuss fuel blending. All groups agreed that fuel blending should be
conducted only at RCRA-regulated units with no exemptions. The representatives of public interest
groups held that blending of high metal and halogen wastes with other wastes to produce suitable
fuels should be prohibited. Industry representatives and many EPA and state regulators held that
specifications for waste-derived products should be developed. There was considerable discussion
about whether wastes containing less than 5,000 BTU per pound should be sent to fuel blenders.
Many industry participants believed that wastes with lower heating value can provide significant
energy to a BIF which is fully regulated. In addition, some industry participants believe that lower
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heating value wastes should be allowed in industrial furnaces even if they are not considered fuels
provided that they do not have high levels of metals that could partition to the product at levels that
could pose a hazard.
13.2
TRIAL BURNS
Many of the groups spent a lot of time discussing trial burns. Representatives of many public interest
groups believed that trial burns are not adequate for establishing realistic operating conditions because
emissions during a trial burn are not representative of normal operations. In addition, the
representatives of the public interest groups stated that background environmental monitoring and
community health surveys are needed to provide baseline data. EPA/state regulators and industry
representatives agreed that such data would be helpful. The public interest group representatives and
some of the EPA and state regulators held that surrogates should not be used. Both groups held that
there are problems in the selection of principal organic hazardous constituents (POHC) and that trial
burns are not conducted consistently. The representatives of public interest groups also believed very
strongly that the use of emergency relief stacks (i.e., bypass or dump stacks) on incinerators should
be prohibited. They said that research is needed on whether dump stacks are necessary (engineering
controls) and on the constituents contained in dump stack emissions. Further, they said that CEMs
should be developed for all types of pollutants and that the use of CEMs should be required. Stack
analysis for polyhalogenated dioxin also should be required. The representatives of the public interest
groups also held that the frequency of trial burns should be increased and that trial burns do not
represent day-to-day operations.
Some incineration representatives believed that dump stacks could not be eliminated but that the
number and duration of dump stack openings could be limited. Many industry representatives held
that surrogates are a useful tool for establishing operating parameters for combustors and meeting the'
requirements for the trial burn without posing significant threats to human health and the
environment. Many industry representatives held that trial burns are a valid basis for determining
combustion operation and that they are useful for establishing limits on feed rates and operational
controls. Those representatives also held that representation of day-to-day operations is influenced
mainly by the initial characterization of waste streams. Both representatives of industry and EPA and
state regulators stated that research is needed on analytical detection limits for stack emissions. The
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representatives of the public interest groups were opposed to any government funding for such
research (they held that industry should fund the research). They believed that government funding
should be used for waste minimization and pollution prevention.
Some EPA and state regulators and industry representatives proposed a phased approach to trial
burns, using both surrogates and real wastes during trial burns. They also held that there should be
consistent guidance on trial burns.
13.3
CAMPAIGN BURNING
Many of the groups did not discuss campaign burning. No comments were obtained from the
representatives of public interest groups. Industry representatives held that trial burns are not set up
as campaign burns, and they did not support campaign burns. EPA and state regulators were divided
on this issue.
13.4
SAMPLING OF FEED STREAMS
Industry representatives wanted additional guidance on sampling of feed streams and the frequency of
such sampling. They said that the guidance should be rigorous and uniform nationally, but flexible.
They held that EPA should address mixed waste (SW-846 methods do not apply).
13.5
RECORDKEEPING
The representatives of public interest groups held that records of operations at BIFs and incinerators
should be made available to the public. The records should include: sources of wastes, name of the
industry and its destination, name of incinerator or BIF, identification of the waste to burned, number
of dump stacks, background information on the company, documentation of communications with
regulatory agencies, and number of violations and citations and information on each such violation.
Several industry representatives also held that such information would be helpful. The public interest
groups held that community advisory groups should be formed and that a structure for involving
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public participation is needed. More standardization of recordkeeping procedures would be helpful to
the public (approaches are different among some permitting agencies).
Industry representatives held that there are inconsistencies in the manner in which data are stored.
They also held that information repositories in libraries do not work well because information often is
removed from them or lost. They suggested the information be computerized.
13.6
STATE REGULATIONS
Representatives of public interest groups held that states do not always adequately enforce their
regulations. Industry representatives held that there are vast differences between state regulations.
They also held that mixed waste must be addressed specifically. States also have less expertise and
fewer resources and may need more oversight. Industry wanted to know whether authorized states
will enforce the new combustion strategy, using omnibus provisions under RCRA. They also wanted
to know what EPA will do if states do not take the lead. EPA and state regulators and industry
representatives held that states seeking authorization should be involved from the beginning in local
siting issues.
13.7
DUMP STACKS
All groups that discussed this issue did so in conjunction with trial burns.
13.8
STACK GAS SAMPLING
Several EPA and state regulators and industry representatives questioned the accuracy of dioxin
measurements. They questioned whether all data should be adjusted for spike recoveries before being
used for risk assessments or for other purposes. The representatives of public interest groups held
that a precautionary principle should be adopted in the regulation to offset difficulties in measurement.
14.0 CONCLUDING REMARKS
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Matt Straus, director of EPA's Waste Management Division, Office of Solid Waste, concluded the
roundtable by highlighting its accomplishments. Mr. Straus said that, as EPA had hoped, the
conference began dialogue and built perspective among all stakeholders involved in the waste
minimization effort. He said that the much-appreciated participation of public interest groups was
especially insightful.
Mr. Straus also addressed concerns about the voting procedure that v/as employed during the breakout
sessions. He stressed that EPA is examining issues, not the number of votes. He stated that common
concerns became evident during the four-day session. More important, however, he said EPA will be
exploring all the ideas that were brought out. He noted that pollution prevention initiatives will begin
early in 1994; those initiatives will take these ideas and concerns into account. Mr. Straus further
encouraged participants to actively explore this arena and continue cooperative communication.
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CONTENTS (continued)
Page
APPENDIX A
PLENARY SESSION SLIDES
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Section
CONTENTS (continued)
Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Hazardous Waste Management Facilities Group
Page
HAZARDOUS WASTE MANAGEMENT FACILITIES
Focus on P2 in all aspects of waste management recognizing the need for a multi-media
approach and flexibility in management options
Redefine the waste minimization/combustion strategy by reorganization into a P2 strategy that
considers all management approaches
Source reduction
Waste minimization
Recycling
Reuse
Treatment
LDRs
Waste minimization should be viewed as a concept that extends beyond the generator, and
involves the actions of waste generators, recyclers, and treaters
No relaxation of standards in the name of waste minimization
VI
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Section
CONTENTS (continued)
Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
EPA and State Regulator Group
Page
The national goal is at least a 50% reduction of multi-media pollutants through source reductioin by
the year 2000
Sub-Goal
To demonstrate maximum source reduction that is technically and economically
feasible at specific sites «
Important Concepts
Multi-media
Flexible and accountable
Eliminate "bad incentives" - create "good incentives"
Public involvement and empowerment
Adjusted for output
Credit for prior achievements
vn
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Section
CONTENTS (continued)
Slides
Plenary Sessions on Waste Minimization Goals
November 15, 1993
Public Interest Group
Page
GOAL
To empower "grassroots" and other environmental groups and people in implementing a RCRA
strategy to:
Reduce toxic chemical use and hazardous waste generation through P2,
Phase out production and release of persistent toxics, organochlorines and heavy
metals, and
Eliminate combustion of such wastes.
GOAL SHORTHAND
Local input
EPA action based on input
Phase out persistent toxics
TUR/Source Reduction Planning and materials accounting
Eliminate combustion (toxic waste incinerators)
Vlll
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Section
CONTENTS (continued)
Slides
Plenary Sessions on Waste Minimization Goals
November 15, 1993
Technical Assistance Centers Group
Page
GOAL - FOCUS ON THE PROBLEM NOT ON THE SYMPTOMS
• Re-orient EPA to make pollution prevention a real priority
Consolidate single-media programs into a multi-media program with focus on
Prevention
Compliance Assurance
• Require all EPA managers to be accountable for P2 and to facilitate state and local P2
activities.
Remove or change non-P2 beans
Factor P2 needs into allocation of grants to states
Include P2 flexibility in all regulations
Establish goals for P2 to be included in compliance agreements (25% by '95, 50% by
'96)
Coordinate federal research and development and technical assistence activities to
support P2 (i.e. DOD, DOE, NIST, SBA)
• Provide technical assistance through universe of existing providers at the federal, state, and
local level.
• Provide incentives and adequate resources causing continuous action to reduce waste to a
minimum through multi-media source reduction.
• No uniformity, promote flexibility.
• Clearly identify P2 expectations to industry.
• Move to multi-media reporting systems which allow measurement of P2 progress.
• Level the playing field.
JUST DO IT!
IX
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CONTENTS (continued)
tier
Page
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Section
CONTENTS (continued)
Slides
Plenary Session on Waste Minimization Goals
Identification of Goals
November 15, 1993
Hazardous Waste Generator Group
Page-
CONSENSUS
ELEMENTS OF RISK GOAL
Risk Driven (goals, priorities)
Voluntary - Self implementing
- Goal of 100% participation
- Broad but flexible
Multi-media
Cost-effective
Public involvement-dialogue
Use heirarchy to drive
Positive incentives
Remove barriers
Systematic planning
Flexible protocol
Use existing data, public scorecards
TRI and hazardous waste and nonhazardous waste
Corporate openness
Participation of public in dialogue - local level
Tracking, reporting
xi
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Slides
Plenary Session on Waste Minimization Goals
Identification of Goals
November 15, 1993
Hazardous Waste Generator Group (continued)
XII
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Slides
Plenary Session on Waste Minimization Goals
Identification of Goals
November 15, 1993
Hazardous Waste Generator Group (continued)
1.
POINTS OF CONCERN
100% Corporate Participation is a Goal
Small Firms
Commercial Firms
2. Public Participation at Local Level is a Goal
Small Sites
Low Waste Volume
3. Scope of 11/15-16 Discussion
Waste Min -> RCRA
Integrate into National P2 Strategy
4. Must Attack Risk Broadly
Wastes/Releases
Employee Safety
Community Safety
XIII
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group
The goal for waste
minimization should be
toward a prioritized
approach for the reduction
of generation and releases
of toxic waste, including
persistent toxics.
The focus should be on the generators of products with emphasis on:
Health and the environment
Regionalization/localization
Elimination of multi-media shifting of releases
Cost effectiveness
An interim milestone of 50% voluntary reduction of hazardous waste generation should be achieved
bv 2005.
Impact on incineration and combustion
Would not close down
Would reduce waste available for combustion
Would increase the already evident effect:
"Waste minimization is driven by cost."
xiv
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Expected Reaction of Specific Stakeholders:
Industry
Will want details
Fear of/concern
Hazardous waste management facilities
Incineration business concern
Recyclers may see increases and decreases
New business opportunities
Regulators
May not understand its impact on them
Vague and not enforceable
Technical assistance Centers
Need to keep separate from regulatory programs
Public interest groups
Not enough, need more front-end efforts
Vague, meaningless
xv
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Slides
Plenary Session on Waste Minimization Roles
November 16, 1993
Hazardous Waste Management Facilities Group
OWNERS, OPERATORS OF TSDFs
1. Partnering (not mandates)
a. Work with generators in pursuit of P2
1. Already a role for many
2. Limitations
CBI
Large generators/multiple TSDFs
b. Particular emphasis on small, medium quantity generators.
2. Information Gathering/Clearinghouse
a. P2 methods, techniques
b. LDRs/disposal, treatment requirements
3. Whether on- or off-site, provide BAT to generators
a. Recycling, treatment, transportation, disposal
b. Minimize toxic components
c. Ensure residuals management is protective of human health and the environment
i.e., pollution prevention
4. Working with state and federal regulators
a. Develop, strengthen environmental standards
b. Close loopholes
c. Protect human health and the environment
xvi
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
1.
OTHER STAKEHOLDERS' ROLES
Generators
a. Communicate progress in P2
b. Recognize/accept lead role in cradle — > grave system
Public Interest Groups
a. Emphasis on P2, not merely shutting down combustion or other viable waste
management tool
b. Promote use of good science, mutli-media approach
c. Establish a constructive linkage in the dialogue between generators TSDFs and their
resident communities
Technical Assistance Center
a. Focus on small generators
b. Greater university/academia involvement
EPA/State Regulators
a. Multi-media, good science
b. Eliminate loopholes and disincentives that may diminish P2
c. Devise system of measurable indicators to assess P2
d. Promulgate and consistently enforce standards protective of human health and the
environment
e. P2 technical assistance
XVH
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Slides
Plenary Session on Waste Minimization Roles
November 16, 1993
EPA and State Regulator Group
A) Improve Measures of Success
(What we measure)
Compliance
Pollution prevention in permits
B) Regulatory Reform
• Regulators take responsibility for resolving inconsistencies
goals and priorities
definitions
reporting
pilot for specific industries
* Develop requirements for P2 plans for all media permits and generators - flexible and
accountable
C) Resources
More resources
More flexibility with existing resources (50%)
D) Reform Information Reporting System
(How we track)
efficient
effective
better measures of progress
E) Create Incentives/Address Barriers
xvin
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
F)
Common Threads
Multi-media
Flexible and Accountable
Preference for source reduction (TQI)
Recognize Waste Management Hierachy
Public involvement/dialogue/empowerment (consumer)
Real resources (EPA/state/company)
Improved measures (both what & how)
Recognize difference and needs of different groups
regulations
technical assistance
Priorities should be based on environment and human health/considerations and
goals/risks
xix
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Slides
Plenary Session on Waste Minimization Roles
November 16, 1993
Public Interest Group
1. Education
information on pollution prevention progress
materials accounting data
destination of wastes
clearinghouse for alternatives
2. Labor/citizen committees
3. Product reform
4. Develop/support legislation
5. Bring site-specific problems to attention of government
6. Citizen suits
7. Prevent siting
8. Federal procurement
xx
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
OTHER STAKEHOLDERS
Data
Pollution prevention plans, including public goals and plan summaries and
publicly available materials accounting data (generators, regulators)
information on where wastes are going and what they are (generators,
regulators)
access to compliance and monitoring data (generators, regulators, owners and
operators)
Develop a national plan for phasing out persistent toxics, especially chlorine compounds and
heavy metals (EPA).
Shift to "precautionary principal" - chemicals are guilty until proven innocent
and develop clean tech (regulators, generators)
Contribute % of profits to fund for safer alternatives review and P2 research
and/or tax off-site shipments to fund P2 programs (regulators, generators,
owners and operators).
Establish mechanisms for greater labor and public involvement in P2
(generators, EPA).
Technical assistance programs should involve citizens as well as industry
(technical assistants centers).
Regulators need to get away from end-of-pipe mentality need to close
loopholes in existing regulations that promote shifting toxics between
environmental media.
Regulators should help develop one-stop shopping for transition to P2 and
sustainable technologies.
EPA set goal for reducing combustion capacity, including kilns and on-site
burning.
XXI
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
xxn
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Slides
Plenary Session on Waste Minimization Goals
November 15j1993
Heterogeneous Group (continued)
Slides
Plenary Session on Waste Minimization Roles
November 16, 1993
Technical Assistance Centers Group
PROVIDE TECHNICAL ASSISTANCE
Make business competitive through P2
Change established relationships between government and industry
Facilitate business-to-business interactions
Build information networks
Should be located where best for state
REDUCE WASTE
LEADERSHIP
Foster relationships with non-traditional partners
Support internal integration of P2 within state agencies
Influence legislation advocating P2
Risk taking/creative solutions
Watchdog state regulations to avoid barriers to P2
Support voluntary programs
Defend definition
CHAMPION
xxiii
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
XXIV
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
FUNDING
Need continued support for state P2 programs
Core grant funding
Enforcement agreements
Industry sources
Other
1. Generators
Focus on continuous improvements
2. Hazardous waste management facilities
Direct customers to state technical assistance programs
3. Regulators
Require hazardous waste management facilities to require P2 plans from
customers
4. Public interest groups
xxv
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Slides
Plenary Session on Waste Minimization Roles
November 16, 1993
Hazardous Waste Generators Group
THE ROLE OF WASTE GENERATORS IN PROMOTING WASTE MINIMIZATION
• Waste minimization Is happening
• 3 tiers of a waste minimization/P2 program
• Element of a successful waste minimization/P2 program
Business Roundtable Benchmaking Study
Group identified 22 elements and crudely ranked them
Does not represent a cook book!
Elements
• Integrate waste minimization into business strategy
Must have a corporate commitment
• Establish a tracking system to measure progress (internal)
More than tracking pounds
Includes project status
• Empower every employee in company
• Establish a stated goal and install it as a corporate expectation
Once established though do not micromanage implementation
* Develop a waste/emissions inventory and assign responsibility and accountability for progress
• Communicate achievements to public
• Prioritize P2/waste minimization activities by risk and cost, matching priorities with available
resources
* Establish waste minimization/P2 audit program - obtain commitment by management to
implement findings
xxvi
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Conduct active advocacy to retain flexibility in achieving waste minimization/P2
xxvn
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Slides
Plenary Session on Waste Minimization Roles
November 16, 1993
Heterogeneous Group
ACTIVITIES
Lobby Congress for multi-media approach/regulations to allow for multi-media waste reduction, (all
groups)
Identify and prioritize projects or action items and ensure alignment with goal, (all groups)
Close recycling loopholes to make waste minimization economy-driven, (regulators)
Implement projects where benefits justify resources, (generators and EPA)
Define/settle definition of waste minimization and pollution prevention, (all groups)
PROCESS
Commitment and support for goal
Inventory waste streams
Identify and prioritize projects
Implement projects where benefits justify resources
Measure and report performance (internal and external)
Recognition of success
Technology transfer where possible
xxvi 11
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Slides
Plenary Session on Waste Minimization Goafs
November 15, 1993
Heterogeneous Group (continued)
Slides
Plenary Session on Mechanisms to Achieve Waste Minimization
November 16, 1993
General Issues Group
I. GENERAL ISSUES
1. EPA/States should set waste minimization goals for themselves
"Beans" do not relate to pollution prevention (need to fix)
OSW behind the curve on P2 (may be the problem)
AAs should have a regular dialogues on P2 (and be consistent in approaches)
2. Evaluate existing regulations and economic factors to determine what is being done (now)
Implementation executive order on regulatory reform
3. We have in industry's attention need to provide technical/regulatory advice to "complete" P2
get out of system
Link enforcement and technical assistance
xxix
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Slides
Plenary Session on Mechanisms to Achieve Waste Minimization
November 16, 1993
RCRA Federal Regulatory Group (Permits and Enforcement)
II. RCRA PERMITS/ENFORCEMENT
Permits
20 mechanisms identified
TOP IDEAS
Require P2 planning
Don't use permits requirement as the mechanism to drive (multi-media) waste
minimization.
EPA should develop means indicators of P2 progress prior to using
permit/enforcement mechanism.
Seek statutory clarification of clarify 3005(h) (certification)
EPA should develop industrial sector - specific indicators of P2 progress.
Deliberate effort to include the public in permit process (increase)
Increase general inspections to improve general waste minimization performance.
Violations should be settled via Supplemental Environmental Projects
Expand RCRA permits to consider multi-media (air, water)
EPA should use omnibus authority to impose waste minimization permit conditions.
Citizen provision and inspections (encourage)
Multi-media so'urce reduction performance standards.
xxx
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Slides
Plenary Session on Mechanisms to Achieve Waste Minimization
November 16, 1993
RCRA Federal Regulatory Group (Generator and LDR Requirements)
REGULATORY MECHANISMS FOR IMPLEMENTING WASTE MANAGEMENT
CERTIFICATIONS
Section 3002(b) - certification for large quantity generators
Revision of LDRs to promote other recycling techniques
la. Program in place needs to be in writing
b. P2 should demonstrate progress
c. EPA should enforce the waste minimization certification but recognize flexibility
d. EPA should focus on requiring "real" programs and not just paper plans
2. Don't pursue command and control
3. Allow goal setting to be facility specific allowing for prioritization
4. EPA needs to speak with one voice addressing all media
5. EPA should ensure adequate funding to states to provide or aid in the review process
6. Recognize that some projects are capital intensive and cannot be done immediately
7. Recognize other existing land already on the books
XXXI
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Slides
Plenary Session on Mechanisms to Achieve Waste Minimization
November 16, 1993
Non-RCRA Federal Regulatory Group
IV. NON-RCRA REGULATORY MECHANISMS
Create incentives and remove decintives for Tier III & IV P2
Mandate goals
Information Network
"Waiver" for Promising projects
Multi-Media/Facility wide Permit/Compliance/Enforcements
P2 is not an Add-on. It is changing how you do what you (EPA) do
P2 PLANS
Less Central command and control
Multi-media/Facility wide
Risk-based - Tradeoffs in Facility bubble
Confidence in Plan Quality - Certified Planners
Trade Secrets
Use Information Reporting
xxxn
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Slides
Plenary Session on Waste Minimization Goals
a November 15, 1993
Heterogeneous Group (continued)
Slides
Plenary Session on Mechanisms to Achieve Waste Minimization
November 16, 1993
State Regulatory Group
V. Promote multi-media P2
Organization change
Regulatory change
(1) Develop facility-wide P2 reporting system as part of national database (with states) to
replace current reporting media-specific systems
(2) EPA should write regulations with P2 so that rules push P2 or give states option to
push P2
(3) EPA should encourage states to move toward multi-media permitting (or consider it in
existing programs)
For instance:
State permitting teams should be established to:
Eliminate funding conflicts
Encourage companies to make whole-facility pollution prevention
Multi-media permitting should help stream-line and for permit decisions
(4)
EPA should learn from the states' P2 programs (e.g., California incinerables)
EPA should promote top of hierarchy to states
Need to be,tradeoffs in state grant workplans to allow grant managers to push P2
States need assistance on How to incorporate P2 into regulatory programs
"Foster the long view"
(5)
XXX1I1
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Federal Laws should give conditional states based on State Pollution Prevention initiatives
(e.g., fundamentally different factors in Clean Water Act.)
xxxiv
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Slides
Plenary Session on Mechanisms to Achieve Waste Minimization
November 16, 1993
Non-Regulatory Group
VI.
1.
NON-REGULATORY MECHANISMS
Economic
Tax incentives for P2
Incentives structure for costs by Volume
Inherent economic inc through waste minimization/P2
2.
Technical Assistance
Improve funding
Target geographically
Openess to participation
Integrate into available groups (Public & Private)
Mentoring Large/Small; Knowledgeable/Not Knowledgeable
3. Professional Accountability
Responsible Care
International Standard setting
4. Information Dissemination
On Technical Assistance Resources
Strengthen Clearinghouse lead
Education
School Curricula
Focus Group Facilitation
by chemical usage
by technology
by status
Industry Association Coordination
5. Consumers
Clean product promotion
labeling
xxxv
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
6. Voluntary Programs
Improvement to existing programs
Identify and Use Multiple Steakholders
xxxvi
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Slides
Plenary Session on "Big Picture" Issues
November 16, 1993
Group 1
WASTE MANAGEMENT HIERARCHY
Consider actual effects on human health and the environment across media
Waste management hierarchy needs to be considered across the board
Use existing economic drivers coupled with protective regulations
Focus on promotion of toxics use reduction/reduction in waste generation
Use hierarchy as a flexible framework for continuous improvement to reduce waste releases
EPA to focus 80 percent of resources on clean production (toxics use reduction/source
reduction)
Consistent signals from regulators
EPA waste management policies based on preventing pollution, not hierarchy
Focus on impacts of all constituents at all hierarchy levels
P2/source reduction is preferred in general - other elements in hierarchy in specific cases
Current EPA & state programs are not focusing on moving up hierarchy
Focus on entire hierarchy, energy recovery and recycling needs to be moved up
Rename it "Toxic & Hazardous Materials Hierarchy"
Drop combustion from hierarchy
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
MEASURE PROGRESS
Need to focus on identifiable, measurable goals
or
Goals & measures should be multi-media and facility- and/or program-specific
Institute waste minimization requirements for annual approval on wastestream by wastestream
basis
Be creative! Perhaps GNP-type measure
Generators are not publicly reporting toxics in production. Should begin reporting.
PROBLEM/SOLUTIONS
How to track "reducing" waste & releases within hierarchy? Expand TRI by SIC code and
chemical .
Too many lists and attendant reports. Need to clearly and consistently identify potential
pollutants of concern across media
How do you establish baseline?
Flexible systems? Toxic use clusters?
Facility specific plans needed for valid measures. Confirm with audits, protective standards
needed for materials balancing
xxxvin
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Slides
Plenary Session on "Big Picture" Issues
November 16, 1993
Group 2
WASTE HIERARCHY
EPA needs to define "clean fuels."
Clean fuels that are burned for energy recovery are not waste and do not belong in the
hierarchy.
EPA needs to define
Waste minimization
P2
Recycling
"Dirty fuel" that is blended with other fuels and burned for energy recovery is "treatment"
What do we consider "dirty fuel" that is treated and now becomes a "clean fuel" that is
burned for energy recovery? recycling? waste minimization? treatment?
MULTI-MEDIA
EPA should develop a consistent list of constituents to be regulated Under all media, using
highest standard appropriate.
Consistent definition of "terms" under each program.
Develop all allowable emission/release/discharge levels based on risk.
Allow facility to make waste management decisions based on risks.
Revise current media regulations to allow P2 to take place that reduces risk or develop P2
regulations that "Trump" media regulations.
xxx ix
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Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
xl
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
LIMITING FACTORS
Improve material safety data sheets
Better product labeling; benefits:
Allows facility to make appropriate P2 decisions or waste management
practices/worker safety
Allows consumer to select products based on toxicity that will reduce pollution
Technical assistance to small generators
Maintain high treatment standards (LDR) and close all regulatory loopholes that act as
disincentives
xli
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Slides
Plenary Session on "Big Picture" Issues
November 16, 1993
Group 3
I. WASTE MANAGEMENT HIERARCHY
Recognize role of combustion in hierarchy
Concentrate efforts to reduce impacts to human health and the environment
industry flexibility
encourage use of BAT under hierarchy
Devote agency resources to the top of the hierarchy
II. MULTI-MEDIA
Responses to violations should be able to be responded to across all media
Enhance state, federal and local organizational structures to promote multi-media
approaches
Consolidate language (lead by EPA) (Congress is the culprit)
III. MARKET MECHANISMS
Tax incentives for P2 activities and accomplishments
Waste generation fees (similar to air fee) for all media
Require citizen TRI-type reporting
xlii
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Slides
Plenary Session on "Big Picture" Issues
November 16, 1993
Group 4
1. Limiting Factors
2. Environmental Justice
3. Measuring Progress
4. Remediation Wastes
BIG PICTURE
LIMITING FACTORS: ADMINISTRATIVE
Need clear will and commitment from EPA Administrator and Clinton Administration
Current structure, multi-media solutions/approach (don't need another layer of bureaucracy)
EPA needs to talk to Congress to change environmental statutes/policy
* Focus on consensus evident here
Develop momentum
REGULATORY
P2 limited by lack of flexibility in laws and their single-media nature.
* EPA tends to focus on end-of-pipe solutions
Lack of Congressional mandate
xliii
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Slides
Plenary Session on Waste Minimization Coals
November 15, 1993
Heterogeneous Group (continued)
xliv
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Slides
Plenary Session on Waste Minimization Goals
November ISj 1993
Heterogeneous Group (continued)
ECONOMICS
Lack of resources at EPA and small firms
Haven't tapped market incentives
Limit capacity (create disincentive)
Lack of understanding of market forces
xlv
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Slides
Plenary Session on "Big Picture" Issues
November 16, 1993
Group 5
A. MULTI-MEDIA IMPACTS
1. Fundamental restructuring of EPA regulatory programs
set up multi-media team
develop regulatory policies and programs; P2 as driver
develop legislative strategy
2. Remember to factor in economic impacts when evaluating technologies, with
preference for those that have additional benefits
3. Don't focus just on waste - look upstream to raw materials u&e, energy use, etc.
B. MEASURING PROGRESS
1. Restructure reporting requirements (big gap between what we want and get)
TRI as starting point
• timeliness
• baseline
• streamline
• user-friendly (e.g., electronic)
• additional data - to address gaps (e.g., materials going into facilities)
Normalization of data, for comparison
2. Report progress via (qualitative) pollution prevention plans
3. Statistical sampling
xlvi
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
xlvii
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Slides
Plenary Session on "Big Picture" Issues
November 16, 1993
Group 6
TOPICS TO CHOOSE FROM
Measuring progress
Multi-media impacts
Waste management capacity
Remediation wastes
Waste management hierarchy
Limiting factors
Environmental justice
Resource allocation (what to do)
TOPIC CATEGORIES SELECTED
1. Resource Allocation
A. Require written multi-media P2 plans
Promote P2 by establishing a framework that catalyzes facility efforts without
overly specific regulations
Establish accountability
B. Need more all-encompassing definition of wastes released to the environment (multi-
media focus)
C. Allow resources to be directed based on priority system that focuses on most serious
environmental problems with local planning and community involvement
NON-CONSENSUS
A. Continue to develop stringent environmental protection goals (e.g., LDRs)
xlviii
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
B. Press for uniform enforcement of regulations across regions and states.
xlix
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
OTHER ISSUES
Multi-Media
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Slides
Plenary Session on Technical Combustion General Issues
November 17, 1993
Group 1
TECHNOLOGY COMBUSTION STANDARDS
Summary of General Issues
Technology- vs. risk-based standards
Future incineration capacity
Exemption for "nontoxic" hazardous wastes
Federal bad actor law
Siting requirements/restrictions
TECHNOLOGY VS. RISK-BASED STANDARDS
Must use best technology available (with technology standard), then look at risk on
site-by-site basis -* MACT Standards
AA for OSWER should work closely with AA for air to address all air toxics issues
(look at air emissions beyond hazardous waste)
Technology-based standards are starting point - cost effective control, then risk-based
to make sure it is protective
Risk assessment should be rejected until all stack emissions are quantified
Need good combustion/operating practices
li
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Difference exists between theory and practice of combustion
combustion
must show need for
Hi
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
FUTURE INCINERATION CAPACITY
Is there a need for additional hazardous waste incinerators in the U.S.?
• Future needs should be market-driven, EPA should not regulate capacity
• EPA should strive to develop a level playing field for incinerators (in terms of
technologies, costs, etc.) and then let market drive future capacity.
• New capacity generally is better technology
• Not enough capacity for some types of wastes (nerve gas, mobile capacity)
EXEMPTION FOR "NONTOXIC" HAZARDOUS WASTE
Valid concept but implementation is difficult (for example, defining "clean" fuel)
If "clean" fuels then technical standards should handle issue
Should be able to reach an acceptable definition of "clean" fuel
Halogen and metals content is issue in defining "clean" fuel
Waste characterization is issue
liii
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Slides
Plenary Session on Technical Combustion General Issues
November 17, 1993
Group 2
I. RISK ASSESSMENT/HEALTH
A. Don't ship off-site unless there is a clear benefit
No Risk is acceptable if it is avoidable
Consider need for risk management as well as risk assessment
B.
C.
D.
F.
G.
H.
I.
J.
K.
L.
M.
Zero discharge of all persistent or bioaccumulative toxic substances. This should also
include all Superfund facilities, TSDFs and federal facilities
Citizen's health should be paramount priority - standard should be no health risk.
"Acceptable Risk" concept has created the current animosity between industry,
regulators, and communities
Serious lack of data to support risk assessment
Consider whether combustion and generation of waste is cost effective
Risk assessment should consider accident scenario (transportation)
Emissions standards should apply to all combusters
Phase out of all organochlorines use. Substitutes are available for chlorine in these
areas:
Total U.S. Chlorine Use
Pulp/Paper
PVC
Polyurethane
14%
32%
12%
Evolution of new risk assessment that considers alternatives to production and
treatment of waste
liv
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Slides
Plenary Session on Waste Minimization Goals
November 15f 1993
Heterogeneous Group (continued)
Iv
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Slides
Plenary Session on Waste Minimization Goals'
November 15, 1993
Heterogeneous Group (continued)
II. TECHNOLOGY- VS. RISK-BASED STANDARDS
A. There should be no single technical standard - this leads to off-site treatment. Tailor
standard to facility.
B. Emission controls should be technical standards with risk assessment as a back-up;
cost vs. reduction.
C. Technology-based standards/superior to risk-based standards - cost should not be a
factor - install the best!
D. Coordinate with CAA standards
in. EPA RESPONSIBILITY
A. Develop rules fairly and openly before implementation
Determine what is safe and good science - then stand behind it
Serious lack of data supporting risk assessment
Determine what is safe and technology can achieve it
B.
C.
D.
E.
Severe lack of data on MACT, BACT, and LAER - Develop data and make data
accessible
F. All combustors should be addressed:
High temperature metals recovery
Smelting
Thermal desorbers
Have no standards - but high volume of hazardous waste
IV. CAA - TYPE STANDARDS MUST
Ivi
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A.
B.
Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Consider unit type
Standards based on BACT, MACT, or LAER, then stick to them
Ivii
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
FUTURE INCINERATION CAPACITY
A. 45% overcapacity
B. Move toward eventual elimination of incineration
C. Look at existing evidence of exposure around operating facilities
D. Focus on source and waste reduction so no increase in capacity is needed
E. LDR program should be taken into account; capacity variances are still being given
inconsistently
F. Expanding economy and accelerating clean-ups- may dictate expansion of capacity
G. Option to burn on-site
H. Effective planning for long-term management of wastes
I. LDR program should be taken into account
J. Permitting extra capacity could be disincentive to reduce
K. Limiting capacity - disincentive for industry to upgrade
Iviii
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Plenary Session on Waste Minimization Goals
November 15,1993
Heterogeneous Group (continued)
Slides
Plenary Session on Technical Combustion General Issues
November 17, 1993
Group 3
REPORTER DID NOT USE SLIDES
lix
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Slides
Plenary Session on Technical Combustion General Issues
November 17, 1993
Group 4
GENERAL ISSUES
Conduct study on comparative risk for all treatment technologies before setting limits
Siting does not address national effects
Establish/articulate compliance goals
Enforce existing standards
Planned phase-out of incineration
SITING REQUIREMENTS
Existing facilities have options of addressing siting requirements with "other" controls
(risk-based)
Siting regulations must be applied equally to existing facilities
SITING
Siting should be based on risk of materials handled not on commercial or non-
commercial standards
Siting regulations need to address all human and environmental effects, including
"other" environmental effects (background exposure)
Ix
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
TECHNOLOGY- AND/OR RISK-BASED STANDARDS
Technology-based standards should be used with a risk-based safety net. Standards
goals:
a) Restrict nonburnable wastes, e.g., metals
b) Maximize thermal destruction
c) Minimize emissions
Technology-based standards to focus on pollutants of concern, not surrogates which
ties in with source reduction and waste minimization
Prioritize resources based on comparative risk
Develop standards commensurate with risk (technologically feasible and cost
effective)
Both risk-based and technology-based standards should have zero discharge of
persistent toxics
CONSENSUS ITEMS
1) Standards should protect human health and environment
2) Compliance and enforcement of standards (present and future)
3) Establish time frame or schedule for implementation
Ixi
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
DOES COMBUSTION MERIT EPA'S PRESENT EMPHASIS?
Q'ing Combustion
Accepting combustion as viable
SITING STANDARDS UNIFORMITY?
a) New vs. existing
b) Commercial vs. noncommercial
c) Differentiation by material
d) Local vs. national
Ixii
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Slides
Plenary Session on Technical Combustion General Issues
November 17, 1993
Group 5
2 GROUPS
Public Interest, Groups
Other Stakeholders
2 ISSUES
Capacity/Need
Standards - Technology-based vs. Risk-based
CAPACITY
PUBLIC INTEREST GROUPS
Available capacity is a disincentive to waste reduction
EPA policies/regulations should discourage incineration (and move toward eventual
phase-out)
EPA should prioritize alternatives which do not result in releases (of persistent toxics)
to communities
In the meantime, look at capacity on national level
Ixiii
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
CAPACITY
OTHER STAKEHOLDERS
1. Capacity needs driven by market forces and regulatory requirements
• Let the market drive capacity needs but remember that other forces (rules,
state/federal statutes; like CERCLA) have impact
2. Incineration should be compared to other waste treatment technologies in terms of
efficiency, environment and health protection. This is EPA's responsibility!
3. We (EPA & states) need to look at capacity issues on a state-wide and region-wide
basis
• There is not over-capacity in all areas of country
• For example, California will lose Superfund monies because of a lack of
incineration capacity.
4. Continued need for waste management; incineration is one of the safest technologies
available
Ixiv
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
OTHER STAKEHOLDERS
RISK-BASED VS. TECHNOLOGY-BASED STANDARDS
1. Regulations should drive best technology standards, then use risk assessment as a
check
2. Same standards of review applied to incineration ought to be applied nationally to
other waste treatment technologies
• Danger in lowering other standards (LDRs) to encourage innovative
technology over incineration
3. All sources of contaminants (cars, power plants, incinerators) ought to be considered
equally — whether standards are based on risk assessment or technology
4. EPA needs to take lead in developing better risk assessment science; simplify
application
5. All facilities (new and existing) ought to meet same standards - no "grandfathering"
RISK-BASED VS. TECHNOLOGY-BASED STANDARDS
PUBLIC INTEREST GROUPS
Risk assessment does not reflect reality. It is based on incomplete information and is
therefore inappropriate as a tool to determine safety (may be a role to prioritize if tool
is appropriate on past not future problems). EPAs first question must be: Is this risk
avoidable"? No risk is acceptable if it is avoidable. Risk-based vs. technology-based
questions are secondary.
Ixv
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Slides
Plenary Sessions on Organics Control Issues
November 18, 1993
Group 1
DIOXIN/FURAN EMISSIONS
EPA adopt APHA position on banning chlorine
MACT standards - no exceptions based on good operating
practices and risk assessment
PM should not be used a surrogate
Regulating on TEq makes most sense from risk assessment
viewpoint - start with EC standards
Minimize chlorinated compounds as a valid alternative strategy
Should not be an exemption for non-chlorinated waste
Do know what all sources of dioxin/furan are
Need mass balance
7 pts.
(public interest)
16 pts.
13 pts.
11 pts.
6 pts.
6 pts.
8 pts.
OTHER ORGANICS EMISSIONS
Support phase out of halogen compounds/look at other
emissions
Feel EPA surrogates currently close to mark - however, need
to conduct more frequent stack gas testing to speciate
emissions and verify appropriateness of surrogate usage
Important that we require good combustion/operating
6 pts.
(public interest)
32 pts.
15 pts.
Ixvi
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
practices; thru regs. need to limit upsets before EPA takes
further action
EPA needs to push for better CEMs for organics thru
regulations
13 pts
Ixvii
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Slides
Plenary Session on Organics Control Issues
November 18, 1993
Group 2
CONTROLS ON DIOXINS/FURAMS
- No Consensus -
Public..Interest Group Comments
• Entire discussion based on premise that allow some amount of dioxins; don't accept this
premise.
• Need to move toward elimination of organochlorines.
• No dioxin is safe.
• All wastes burned should be screened for dioxins.
• Do not study any longer, do something now.
Other Stakeholder Comments
- No Consensus -
A.
TEo vs. Total Congeners
Several supporters of TEq approach, although do not know what numerical limit
should be. Some supporters of European standard.
Consider non-detectable for tetra congener plus TEq; should be stricter than municipal
waste combustion standards.
Total limit & TEq may be needed because TEq does not capture some congeners.
Need to establish a safe limit based on wealth of existing scientific and health data.
Ixviii
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Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
• From regulatory standpoint, TEq may be necessary for utilization of omnibus
authority.
• Any standard still needs to be backed up by site-specific, multi-pathway risk
assessment.
Ixix
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
CONTROLS ON DIOXINS/FURANS (continued)
B. Formation Mechanisms
• Presence of chlorine alone does not mean dioxin formation; particulate, air pollution
control temperature are also factors.
• EPA & public need to work with industry re: gathering more data on formation
mechanisms and source of TEq vs. total.
• Dioxin formed in all combustion sources (fireplaces, diesel, etc.).
• Control front-end wastes burned, coupled with combustion at high efficiency.
C. "Exemptions"
• Some support for limited exemptions, possibly like B1F approach.
• No exemption for no-chlorine wastes.
• EPA needs to develop a safe technology to address existing dioxin stockpile.
CONTROLS ON OTHER ORGANICS
- No consensus -
Public Interest Group Comments
"Being trapped into giving opinions on issues that are not relevant."
• Chlorinated & other halogenated waste should be a top priority for waste reduction efforts.
• Need continuous monitoring of all wastes burned for PICs.
• Due to complexity of combustion & potential for direct releases, monitor for all PICs (no CO
surrogate).
Ixx
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Given that regulatory controls do not work, Carol Browner should extend her moratorium and
shut down all incinerators.
Ixxi
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Other Comments
** Dioxin control is not adequate for other organic control (dioxin controls focus on post-
combustion)
• Health estimates on dioxins may over-estimate risk, but other organics pose different health
risks by other pathways & need to be assessed.
• Cannot monitor organics or dioxins on a real-time basis.
HC/CO/PIC Controls
• Use HC/CO CEMs to continuously monitor combustion efficiency w/stack testing for organics
on a periodic basis (2 years).
• Should not have to identify PICs if CO < 100 ppm; if CO > 100 ppm identify PICs under
"worst-case" conditions. Need guidance from EPA re: "worst-case." Use SVOST/VOST.
• CO/HC not appropriate indicators of combustion efficiency in some devices (cement kilns
with organics in raw materials).
• During trial burn, require testing for 30 priority chemicals. They are not common & public
may be reassured.
• During trial burn, need to identity all PICs listed in the 9/24/93 Denit memo. Allow no
exemptions, because boilers had some of the highest levels (based on CO).
• Combustion of organic wastes in industrial boilers is an excellent way to manage these wastes
in a cost effective manner.
Ixxii
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Slides
Plenary Sessions on Organics Control Issues
November 18, 1993
Group 3
DIOXINS
ALTERNATE OPINION
NO LEVEL OF DIOXINS EMITTED IS ACCEPTABLE. ALTERNATE DISPOSAL METHODS
OR STORAGE UNTIL ACCEPTABLE ALTERNATE METHODS DEVELOPED FOR CHLORINE
BEARING WASTES. ABSOLUTE PHASE-OUT OF ORGANIC HALOGENS
DIOXIN LIMITS
Use European Standard
But How Was It Based?
Actual Experience in Germany - Need to Understand Better
Use TEq
Use Both
Use Total Congeners
EXEMPTION FOR NON-CHLORINATED WASTES
Potential for formation with almost any level of Cl but may not occur with specific
wastes/specific processes
Consider relief if test data indicates no dioxin emissions of concern
Relief - long term testing with demonstration of no dioxin production or no
production
Ixxiii
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Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Ixxiv
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
TRIAL BURNS
Education need - To educate public on risk issues
Research need - To identify PICs - measurement devices; quantification/toxicity
QUANTIFYING EMISSIONS
Who does risk assessments?
EPA/States/Generators/Facil ity?
1-phase or 2-phase
Before trial burn & After
Is there an alternate to DRE?
Risk analysis
Ixxv
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Slides
Plenary Sessions on Organics Control Issues
November 18, 1993
Group 4
CONSENSUS POINTS
1) Fund/research/establish on-line monitoring system for halogens/PICs
2) 17/1 (almost consensus)
Identify halogens in waste stream
ISSUES RAISED FOR DISCUSSION
Controls on dioxins/furans
Controls on other emissions
Avoid possibility of dioxin generation in air pollution control equipment
Avoid possibility of generation by control of combustion process
On-site operations vs. commercial
known & unknown wastes
degree of variability or knowledge of the waste
Validation and/or limitation of current quantification methods
Eliminate halogen-containing products
Ixxvi
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
RECOMMENDATIONS: CONTROLS ON DIOXINS/FURANS
Prioritize and focus national resources on key areas
Start with tight dioxin standard to enable implementation of best technologies for waste
minimization and chlorine limits
Identify and eliminate all sources of dioxin
Consider other sources of dioxin in assessing whether other controls are needed
Disallow exemptions
Adopt toxicity equivalents approach rather than a total congeners approach
RECOMMENDATIONS: CONTROLS ON OTHER EMISSIONS
Review existing database for existing information and trial burn data
Use CO, total hydrocarbon, HC£, and particulate CEM in addition to oxygen
Continue to control and measure other toxic organics
Consider using extractable organic matter methods as indicators of organics for trend analysis
Ixxvii
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Slides
Plenary Sessions on Organics Control Issues
November 18, 1993
Group 5
Move toward reduction/elimination of use of chlorinated feed stocks
solvents
pulp and paper
Progress is being made - encourage continued progress
industry commitment
recognize complexity of roles of Cl
R&D should be a priority
combustion
dioxin
PIC
Fundamental, pilot- and full-scale R&D dollars need to do. Prevention as well.
Funding - more dollars need to be spent
No consensus on EPA/industry funding
Needs to be addressed
Ixxviii
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Technology-based with risk evaluation as check
Should be a performance standard (technology-based)
Risk assessment should only be used to make controls more stringent or relax them
Cost must be taken into consideration in developing technology-based standards
Dioxin controls adequate? No. Practice good combustion design and operating practices and will
control organics
Trial burns should not focus just on dioxins, but on broad range of organics
Surrogate may not be representative of the waste
Need stronger enforcement directed toward risk and bad actors (disagreement)
better QA/QC on feed
more frequent trial burns
level of controls tailored to type of burner
O2 should be included in regulations, continuously monitored & recorded.
O2 cutoff limits should be established in all permits based on trial burn
Ixxix
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Slides
Plenary Session On Other Combustion Issues
November 18, 1993
Group 1
TRIAL BURNS
T.B. represents worst case scenario - therefore, effective tool
Value of T.B. is in setting operating conditions - therefore, more appropriately termed
"performance test"
Burn what you are permitted to burn at representative volumes and speciate stack emissions
Need more frequent validation of T.B. operating conditions
more frequent performance testing with real wastes
stack testing during normal operating conditions
ambient air monitoring
P.C. output
FUEL BLENDERS
Some fuel blenders are operating without permits - all blenders should have permits and
standards
Fuel blending should be prohibited
Metals waste and low-BTU waste should not blended
low-BTU waste does not necessarily = high metals
Need to control waste-derived products from health perspective
Failure to have minimum specifications for hazardous waste fuel has created an unlevel
playing field between BIFs and incinerators
Part of T.B. is establishing good operating practices, including adequate oxygen, under worst-
case scenarios + operator certification
Ixxx
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
T.B. is only mass balance testing performed on any waste management technology today
Tailor T.B. requirements to take into account consistency of waste burned
Need clear procedures to deal with T.B. failures
Energy recovery vs. destruction
Ixxxi
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Slides
Plenary Session On Other Combustion Issues
November 18, 1993
Group 2
PUBLIC PARTICIPATION GOAL:
Make certain that citizen views are considered throughout the permitting process, implementation,
operation, and enforcement
1.
Meaningful dialogue has to involve public from very beginning
2. Need clear pathway for involving stakeholders upfront
3. Regional forums need to be in Regions where there are many combustors
4." Stop talking about health effects - go measure them in the surrounding communities
5. Need better communication between state, federal, local environmental offices
* "A regulation that is not enforced is no good."
6. Establish an on-site or convenient public site that is publicly accessible with full set of
permitting and compliance data (e.g., releases, communication with government, manifests,
etc.)
7.
8.
SKIPPED
Need guidance on how to maintain good public participation. This goes beyond the
permitting process
9. Involve community early. Develop representative advisory committees.
Public needs to be educated on purpose/design of units and how they operate. Percepti
old data still being used out of context.
10.
ion of
11.
i. - t- —
being used out of context.
Public interest want to see the hard-core data •• not boiled down
Local repository of facility information needs a facility representative who is knowledgeabl
and accessible to public. Should not be a PR person.
Ixxxii
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued).
12. Increase/improve public notice/announcement of pending regulation development/proposal
Ixxxiii
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Slides
Plenary Session on Waste Minimization; Goals
November 15, 1993
Heterogeneous Group (continued)
PUBLIC PARTICIPATION GOAL (continued):
The FRN process is not user friendly. Give guidance on how to submit comments
Facility should sponsor repository upkeep
Define what is "publicly available" info for public.
Need ways to condense and rapidly convey data
Education needs to go both ways. Small groups are important.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
Public information meetings needed for all BIFs, not just Class III permit modifications -
these are productive
Public skepticism due to negative experiences. Need to overcome this for "meaningful public
participation."
Public notices are not posted in optimal, prominent, or consistent places.
Prior to public information meeting re: new permits & modification, need to have a public
meeting devoted to actual health effects from incineration.
Public notice should reach the radius around the facility.
Meetings need to be accessible to the public.
Permits are modified after public hearing without additional public input
Public participation is lacking in the capacity assurance plan process. EPA should guarantee
public access in future
Need 1-800 number for quick access to regulators re: local issues
Need flexible approaches to tailor public participation to different cases and areas (urban vs.
rural)
28. Options for repository: on-site reading room, community college, library, others
Ixxxiv
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Slides
Plenary Session oh Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Ixxxv
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
FUEL BLENDING
Need closer scrutiny
Move to removal of metals & Cl sources
Permitting process needed for blending operation
Transportation blending operations banned.
Waste-derived product specifications
Difficult to define waste characterization procedures during permit process because of variety
and volume of wastes
Blender must have permit and must comply with manifest systems both ways.
Fixing M/D rule would help
Blending important to provide uniform feed to unit.
<5000 BTU/lb wastes must be tracked, in order to comply with LDR standards for products
applied to land. Ban on blending <5000 BTU/lb wastes since the ability to track is lost.
Regulations need clarification of difference between mixing & blending
Ixxxvi
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Slides
Plenary Session On Other Combustion Issues
November 18, 1993
Group 3
TRIAL BURNS
Approach - (Legitimacy) Public interest groups feel data not complete. Want broader,
more realistic test covering all conditions.
Industry groups: real waste, worst conditions
Frequency - Surprise vs. best-day data
- Surprise would not push envelope like existing burns
Some sort of confirmation test site-by-site
Goals - Performance standards, operating conditions
Shakedown - Maybe > than 720 hours needed. Need operating restrictions •. i
Results - > 90 days needed
Mechanism to extend
FEEDSTREAM SAMPLING FREQUENCY
SW-846 equivalent methods for mixed waste need to be identified
Address parity between cement kilns & incinerators. Blended fuel issues.
Develop guidance - rigorous and uniform vs. flexible.
Ensure cement kilns used for resource conservation. Limit fuel to clean fuels. Pull back.
All waste combustors should meet same performance and operational standards.
Disagreement over ability
Ixxxvii
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
CAMPAIGN BURNING
Disagreement. Regulators liked.
RECORDKEEPING
Bottom line, so that it can't be tampered with. Standardization would be good.
Public Interests Groups - publicly available, raw data & correspondence. FOIA may not do
it.
STATE REGULATIONS
Will authorized states regulate under new combustion strategy using omnibus or will EPA
overfile? Answer needed.
States should work with EPA the whole way through process beginning with siting
Ixxxviii
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Slides
Plenary Session On Other Combustion Issues
November 18, 1993
Group 4
BROAD ISSUES
1. Trial Burns
2. TME vs DRE vs DE
3. Recordkeeping
4. Feed Stream Sampling Frequency
5. All Other Waste Combustors
6. Clean Fuels/Fuel Blending
7. Ash Quality
8. AWFCO Frequencies
9. Role of Public
3 or more votes
RECOMMENDATIONS: TRIAL BURNS
EPA review current trial burn protocols & evaluate public concern & then respond to those
concerns (on low concentration)
Work together to develop strategies to minimize dump-stack openings
Phase surrogate and waste trial tests together
Eliminate dump stacks
Ixxxix
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Utilize surrogates in concentrations similar to wastes of concern
4 or more votes
xc
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
RECOMMENDATIONS: (continued)
almost consensus:
• Collect & analyze more data before eliminating use of DRE
• Conduct DREs with total organic feed minus total organic left in the ash
xci
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Slides
Plenary Session On Other Combustion Issues
November 18, 1993
Group 5
TRIAL BURNS:
Basis for determining combustion operation
Strengthen by expanding, # of POHCs, PIC's, frequency of testing,
new tech available
Useful for establishing feed limits & operational controls
Not representative of day-to-day operation
Effective for establishing metals partitioning
Need environmental monitoring of area background
Need community health survey
Need baseline for both above
T.B. should not use surrogates
T.B.'s not adequate for real operating conditions
T.B. fuel should only use actual waste to be burned
T.B.'s to establish operating parameters are best tech today
Day-to-day operations mainly influenced by initial waste characterization
Should be consistent guidance on TBs
xcn
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Problems with selection of POHCs
TBs not in fact being carried out consistently by regulators
xcin
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
TRIAL BURNS (continued): »
• DREs better than risk assessments
because risk assessments are voodoo science
• Real wastes are used in TBs after initial one
• Unclear whether DREs necessary/informative are tracking significant PICs and doing risk
assessment on them
• TB needs to be tailored to task of burner (simple/complex); number of PICs of interest
Stack Gas Sampling
Accuracy in measuring dioxins
Parts-per-trillion difficult to analyze
not real-time
need outside labs
Should all data be adjusted for spike recoveries before being used for risk assessment or other
purposes?
Given measurement difficulties, should we adopt a precautionary principle?
FEEDSTREAM SAMPLING FREQUENCY
YES - industry wants guidance; CMA BIF workshop?
CAMPAIGN BURNING
No Sunnort
xciv
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Slides
Plenary Session on Waste Minimization Goals
November IS, 1993
Heterogeneous Group (continued)
Trial burns aren't done on campaign basis
Real operational difficulties
xcv
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Slides
Plenary Session on Waste Minimization Coals
November 15, 1993
Heterogeneous Group (continued)
RECORDKEEPING
• Guidance on identifying primary data source as point of regulation for TBs and ongoing
operation (e.g., computer output vs. strip chart)
• Public needs access to records (manifests) on where waste is coming from
• Form community advisory groups community-run*, independent resource base
- selected membership
• Information on number of violations/citations & number of dump-stack events
• Information on company/agency communication
* or partnership with industry & regulators
xcvi
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
APPENDIX B
AGENDA
xcvn
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
AGENDA
National Roundtable on Waste Minimization
and Combustion
Session on Waste Minimization
Monday, November 15
7:30 am On-Site Registration Begins
8:30 Welcome
Matthew A. Straus, Director
Waste Management Division
U.S. EPA
8:40
9:15
10:30
10:45
11:15
Overview of Waste Minimization and Combustion Strategy
Elliot Laws, Assistant Administrator
Office of Solid Waste and Emergency Response
U.S. EPA
Panel Discussion: Waste Minimization and Combustion Strategy
Break
Waste Minimization Session Overview
Breakout Sessions: Waste Minimization Goals1
12:00 pm Lunch (on your own)
1:15
2:00
Breakout Sessions: Waste Minimization Goals (continued)
Plenary Session: Waste Minimization Goals2
1 The breakout sessions are small group discussions with facilitators. Lists of participants by
breakout room will be provided at registration.
xcvm
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
3:00
3:15
4:45
Break
Breakout Sessions: Roles of Stakeholders in Promoting Waste
Minimization
Adjourn
2 The plenary sessions are for discussion of small group findings.
xcix
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
AGENDA
National Roundtable on Waste Minimization
and Combustion
Session on Waste Minimization
Tuesday, November 16
8:30 am Welcome and Summary of First Day Activities
8:45 Plenary Session: Roles of Stakeholders in Promoting Waste Minimization
Break
9:45
10:00
11:30
Breakout Sessions: Range of Mechanisms to Achieve Waste Minimization
Goals
Plenary Session: Range of Mechanisms to Achieve Waste Minimization
Goals
12:30 pm Lunch (on your own)
1:45
3:15
3:30
4:30
5:00
Breakout Sessions: "Big Picture" Issues
Break
Plenary Session: "Big Picture" Issues
Waste Minimization Session Summary
Adjourn
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
AGENDA
National Roundtable on Waste Minimization
and Combustion
Session on Technical Combustion Standards
Wednesday, November 17
7:30 am On-Site Registration Begins3
8:30
Welcoming Address
Sylvia Lowrance, Associate Deputy Administrator
U.S. EPA
8:45
Introduction to the Technical Session
Fred Chanania, Project Director
Waste Minimization and Combustion Strategy
U.S. EPA
9:15
9:45
11:45
12:45pm
Meeting Overview
Session 1: General Issues
Small Group Discussions with Facilitators
Lunch (on your own)
Session 1: Plenary Discussion
3 Coffee is available in the hotel at your expense.
ci
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2:00
Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
Session 2: Metals Controls
Small Group Discussion with Facilitators
4:00
5:15
Session 2: Plenary Discussion
Adjourn
cu
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
AGENDA
National Roundtable on Waste Minimization
and Combustion
Session on Technical Combustion Standards
Thursday, November 18
8:30 am Welcome and Meeting Overview
8:45
10:45
1:15
3:15
4:30
4:45
Session 3: Organics Controls
Small Group Discussion with Facilitators
Session 3: Plenary Discussion
12:00 noon Lunch (on your own)
Session 4: Other Issues
Small Group Discussion with Facilitators
Session 4: Plenary Discussion
Concluding Remarks
Adjourn
cm
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
APPENDIX C
DISCUSSION DOCUMENTS
civ
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Slides
Plenary Session on Waste Minimization Goals
November 15, 1993
Heterogeneous Group (continued)
EPA/530/R-93/020
DISCUSSION DOCUMENT
FOR
ROUNDTABLE SESSION ON WASTE MINIMIZATION
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE
NOVEMBER 15 & 16, 1993
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INTRODUCTION
As announced in the Administrator's Draft Hazardous Waste Minimization and
Combustion Strategy, EPA is seeking to stimulate the widest range of involvement and
comment from all stakeholders to assist EPA and the States in developing, among other
things, a national waste management strategy that will better integrate waste minimization
into the national hazardous waste management program under the Resource Conservation and
Recovery Act (RCRA). EPA is convening a National Roundtable on Waste Minimization
and Combustion to bring together groups that have a stake in the discussion of hazardous
waste minimization and how it relates to hazardous waste management in the United States.
Immediately following the Roundtable Session on Waste Minimization will be the Roundtable
Session on Hazardous Waste Combustion, at which interested parties will discuss technical
combustion issues pertaining to managing hazardous wastes in incinerators, boilers, and
industrial furnaces.
The scope of the Roundtable Session on Waste Minimization is not limited to
hazardous wastes that are managed in combustion units. It is also a vehicle to discuss
minimization of other, non-combustible hazardous wastes that are managed by a variety of
waste management techniques.
EPA has several specific expectations for this Roundtable Session, and believes that
stakeholders will have their own expectations as well. EPA's expectations are to discuss:
• waste minimization goals;
• the current or potential roles of the various stakeholder groups in achieving the goals;
• the range of mechanisms to achieve the goals; and
• issues that EPA is aware of, and that stakeholders raise during the Roundtable, related
to goals, the roles of stakeholders, the range of mechanisms for promoting waste
minimization, and other aspects of waste minimization.
This discussion document is structured around the expectations listed above, and the agenda
for the Waste Minimization Session of the Roundtable will be similarly structured around
these expectations. EPA has identified, for discussion, the issues on the following pages;
Roundtable participants may have other issues as well.
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1. Goals
The Pollution Prevention Act of 1990 states in § 6602(b) (42 U.S.C. 13101) that it is
national policy that "pollution should be prevented or reduced at the source whenever
feasible; pollution that cannot be prevented should be recycled in an environmentally safe
manner, whenever feasible; pollution that cannot be prevented or recycled should be treated
in an environmentally safe manner whenever feasible; and disposal or other release into the
environment should be employed only as a last resort and should be conducted in an
environmentally safe manner." EPA's "Pollution Prevention Policy Statement: New
Directions for Environmental Protection" (June 15, 1993), goes a step further by providing a
number of objectives to build pollution prevention into EPA's mission to protect human
health and the environment (such as regulatory/compliance mechanisms, State and local
partnerships, private partnerships, Federal partnerships, public information/the right to know,
technological innovation, and, where justified, new legislation). Many of these objectives
relate to the regulatory and non-regulatory mechanisms that could potentially be used to
promote waste minimization.
The national policy stated in RCRA § 1003(b) (42 U.S.C. 6902(b)), is that
"...wherever feasible, the generation of hazardous waste is to be reduced or eliminated as
expeditiously as possible. Waste that is nevertheless generated should be treated, stored, or
disposed of so as to minimize the present and future threat to human health and the
environment." In addition to the national policy, Congress stated (among several RCRA
objectives):
The objectives of this Act are to promote the protection of health, [sic] and the
environment and to conserve valuable material and energy resources by--...(6)
minimizing the generation of hazardous waste and the land disposal of hazardous
waste by encouraging process substitution, materials recovery, properly conducted
recycling and reuse, and treatment... "4
The draft Waste Minimization and Combustion Strategy (May 1993) presented five
specific goals related to waste minimization and combustion:
• to establish a strong preference for source reduction over waste management, and
thereby reduce the long-term demand for combustion and other waste management
facilities;
• to better address public participation in setting a national source reduction agenda, in
evaluating technical combustion issues, and in reaching site-specific decisions during
the waste combustion permitting process;
4 RCRA § 1003(a); 42 U.S.C. 6902(a).
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to develop and impose implementable and rigorous state-of-the-art safety controls on
hazardous waste combustion facilities by using the best available technologies and the
most current science;
to ensure that combustion facilities do not pose an unacceptable risk, and use the full
extent of legal authorities in permitting and enforcement; and
to continue to advance scientific understanding with regard to waste combustion
issues.
Issues
Should we prioritize our pollution prevention and waste minimization efforts at
a national level? If so, how? For example, should EPA set a national waste
minimization or capacity reduction goal for combustible wastes, or should we
focus on broader goals, such as reduction in all hazardous waste generation,
pollution prevention across all media, or human health and ecological risk
reduction? If established, what are the advantages and disadvantages of
expressing a goal in quantitative terms (e.g., percentage reduction by a target
year)?
How should our RCRA waste minimization goals relate to and be integrated
into Agency pollution prevention goals (articulated in the Pollution Prevention
Act and in related pollution prevention policy statements)?
Roles of Stakeholders in Achieving Goals
Role of Hazardous Waste Generators
• Hazardous waste generators are likely to be in the best position to minimize
waste through adjusting production processes, changing operating practices, or
substituting raw materials,. Should generators be considered the primary group
for society to focus on to reduce the volume and toxicity of wastes produced?
If so, how?
• What factors drive generators', decisions to source reduce, recycle, or treat?
What factors drive generators' decisions to conduct pollution prevention plans
or waste minimization audits to look for source reduction opportunities?
• How important is the potential for cost savings in driving generators' waste
minimization decisions? Are generators considering the total costs of waste
handling in their cost accounting systems? For example, do generators take
long-term costs into account in their decision-making?
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• Would it be more productive to lower the barriers that generators encounter as
they attempt to minimize their wastes? Or would it be more efficient to
strengthen incentives that hazardous waste generators have to minimize their
hazardous wastes?
Role of Hazardous Waste Management Facilities
• Are there financial (or other) reasons why waste management facilities would
have an incentive to work in partnership with generators to minimize wastes?
Although from a short-term perspective such partnerships may appear not to be
in the best financial interest of the waste management facilities (e.g., waste
management facilities earn greater revenues from managing more waste), with
a longer-term perspective would such partnerships make sense?
« Should waste management facilities track or monitor their customers' (i.e.,
hazardous waste generators') waste minimization efforts? Should this tracking
or monitoring, if any, be limited to checking the generator's compliance with
waste minimization certifications? Would this affect the concept of
"partnership?" Do waste management facilities have the technical expertise to
go beyond simple checks of compliance status?
• Are there specific wastestreams that pose particular administrative or
environmental problems to treatment and disposal facilities (e.g., risk,
compliance, and cost) to such an extent that treatment/disposal facilities would
welcome waste minimization? For example, could reducing the concentrations
of particular constituents (e.g., toxic metals) present in hazardous wastes
managed in a combustion unit improve the waste management facility owner
or operator's ability to comply with regulatory requirements, or reduce the
owner or operator's liability?
Role of EPA and States
• Should EPA and States continue with their respective regulatory, enforcement,
research and development, data collection, and technical assistance roles?
Should EPA and States place more emphasis on one or another of these roles?
Are there still other roles that EPA and States should adopt? For example:
- Are there certain conflicts when EPA or a State
regulatory/enforcement agency also performs "technical assistance"
functions?
- In what situations should an EPA or State inspector share general
waste minimization practices observed at competing facilities?
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- Should the primary focus of EPA and States be collecting, processing,
and making publicly available the data that would allow society to
gauge progress toward waste minimization goals?
- Should the role of EPA and States be primarily to concentrate on
eliminating barriers and/or increasing incentives for pollution
prevention and waste minimization?
• How can EPA better empower States to engage in pollution prevention and
waste minimization efforts? What incentives can EPA provide for this purpose
(e.g., more flexibility in RCRA core grants)?
• Should there be national uniformity amongst EPA Regions and/or States in the
regulatory and non-regulatory mechanisms used to achieve pollution prevention
and waste minimization goals? What are the advantages and disadvantages of
promoting uniformity in mechanisms?
• Several commenters on the October 5, 1990 Federal Register notice5
requesting comments on waste minimization issues believed that technical
assistance functions are of greater benefit to small businesses than larger ones.
Do EPA and States need to address the issues of small businesses in a different
manner than the issues of larger businesses?
Role of Technical Assistance Centers
• Commenters on the October 5, 1990 Federal Register notice varied in their
opinions on whether EPA and state regulatory agencies are best suited for
providing technical assistance, with some commenters believing that technical
assistance provided by a non-regulatory entity (such as a university) is more
appropriate. What role could/do technical assistance centers play in promoting
waste minimization? Are there advantages to public vs. private operation
and/or funding of such centers? Are the centers more valuable to particular
industries or sizes of businesses than to others? What should the role of EPA
and States be in encouraging these centers?
Role of Public Interest Groups
• Is there a role for the general public to play in placing pressure on other
stakeholders, so that the nation's hazardous wastes are minimized? If so,
would this role include public scrutiny of actions that other stakeholders take
and progress that these groups make in minimizing hazardous waste
generation? What else might it include?
55 FR 40881, October 5, 1990.
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• If consumers are to play a more active role in promoting waste minimization,
how would they most effectively obtain the information necessary for them to
make the connection between their purchasing decisions and hazardous waste
generation rates and composition? Would having the information affect
consumers' purchasing decisions?
Roles of Other Stakeholder Groups
• What role should trade and industry associations play in minimizing
hazardous wastes?
• Are there other stakeholder groups not identified above, which could play a
role in minimizing hazardous wastes?
3. Range of Mechanisms to Achieve Goals
General Issues
• What is the appropriate balance between regulatory mechanisms (e.g., a
regulation requiring generators to reduce hazardous waste volume by a certain
percentage6) and non-regulatory mechanisms (e.g., technical assistance) to
promote waste minimization? How effective are regulatory vs. non-regulatory
approaches?
• Should generators be held accountable for meeting specific waste minimization
goals? If there are goals and accountability, then how much flexibility should
the generators have in determining and achieving the goals?
• How would/could goals benefit or detract from our efforts to maintain national
economic competitiveness? What effect could the Basel Convention have on
pollution prevention and waste minimization efforts?
RCRA Federal Regulatory Mechanisms — Permits
• EPA has not yet adopted a general interpretation concerning the extent of
RCRA Section 3005(h) authority for certification requirements for hazardous
waste management facilities. Is it desirable to interpret the statute as requiring
permittees to maintain written descriptions of their "programs in place" to
minimize hazardous waste generated on the premises? Is it desirable to
interpret the statute as requiring evidence that the permittee is making progress
in minimizing wastes? Or would it be desirable to seek a clearer statement of
Congressional intent (via a statutory amendment) before interpreting Section
6 This is not a current Federal regulatory requirement.
6
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3005 (h) in this manner? Are there other mechanisms that can be used to
encourage the permittee to make progress in minimizing wastes?
• How much flexibility should the permittees have in determining for themselves
which waste minimization actions to take, and how much oversight should
those decisions be subject to?
• Should omnibus permitting authority under RCRA section 3005(c)(3) be used
to impose specific waste minimization permit conditions? If so, under what
circumstances?
RCRA Federal Regulatory Mechanisms — Generators' Waste Minimization
Certifications
• EPA has not yet adopted a general interpretation concerning the extent of
RCRA Section 3002(b) authority for certification requirements for large
quantity generators who ship hazardous wastes off-site using a manifest. Is it
desirable to interpret the statute as requiring generators to maintain written
descriptions of their "programs in place" to minimize hazardous waste? Is it
desirable to interpret the statute as requiring evidence that the generator is
making progress in minimizing wastes? Or would it be desirable to seek a
clearer statement of Congressional intent (via a statutory amendment) before
interpreting Section 3002(b) in this manner? Are there other mechanisms that
can be used to encourage the generator to make progress in minimizing
wastes?
o Is there overlap between Federal certification requirements and State pollution
prevention plans? Is one more effective than the other? If so, in what ways is
it more effective?
• What might be the advantages and disadvantages of abandoning a "command
and control" approach to mandate a "program in place," and instead placing
emphasis on providing technical assistance to hazardous waste generators, and
informing them of the economic benefits that they can enjoy through
minimizing their waste?
RCRA Federal Regulatory Mechanisms — Land Disposal Restrictions Requirements
• How could EPA emphasize revising the land disposal restrictions requirements
to include more recycling techniques, either as options or mandatory Best
Demonstrated Available Technologies? Should the land disposal restrictions be
structured to require (at least as an alternative) source reduction in some cases?
Would a BDAT approach that mandates the use of a specific source reduction
or recycling technology preclude generators from undertaking additional
pollution prevention and waste minimization activities? Would a BDAT
approach based on performance standards provide greater flexibility?
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RCRA Federal Regulatory Mechanisms — Enforcement Actions
• Should EPA develop and use enforceable minimum standards to require
facilities that are unwilling to pursue voluntary activities or technical assistance
to minimize their wastes, or should EPA concentrate its resources on
noncompulsory efforts to help those willing to voluntarily reduce their waste
streams? Can EPA pursue both avenues concurrently, and if so, how?
• Should EPA and States use enforcement of mandatory requirements (e.g.,
through a consent order) to bring about the desired changes in behavior?
• To what extent should EPA and States settle alleged violations of regulatory
provisions (other than waste minimization provisions) through negotiating an
agreement for the respondent to conduct a Supplemental Environmental Project
(SEP)?7
Non-RCRA Federal Regulatory Mechanisms
• What authorities and mechanisms are available under Federal statutes other
than RCRA (e.g., the Clean Air Act, the Clean Water Act, the Toxic
Substances Control Act, the Superfund Amendments and Reauthorization Act,
the Pollution Prevention Act, the Safe Drinking Water Act, and the Federal
Insecticide, Fungicide, and Rodenticide Act) that could be used in a
complementary fashion to further promote pollution prevention and waste
minimization? Should these complementary mechanisms be used?
• Would/does a Best Available Technology (BAT) approach that mandates the
use of a specific source reduction technology preclude generators from
undertaking additional pollution prevention and waste minimization activities?
Would a BAT approach based on performance standards provide greater
flexibility?
• To what extent do authorities and mechanisms related to pollution prevention
under RCRA and other statutes currently overlap?
• HoW could multi-media permitting and enforcement foster pollution prevention
and waste minimization? How would this affect incentives and barriers for
pollution prevention and waste minimization?
7 In these projects, the respondent may undertake specific source reduction or recycling
activities that provide environmental benefits in exchange for a reduction in the assessed
penalty.
8
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• Would techniques such as expanded use of citizen's suits against organizations
that are not in compliance, product bans, or use restrictions on products that
contain certain constituents be effective in promoting waste minimization?
State Regulatory Mechanisms
• Should pollution prevention and waste minimization be integrated into State
permits and enforcement actions? If so, how? Are States currently taking this
approach? How does it differ from Federal approaches?
• How should potential conflicts between Federal waste minimization
requirements and guidance and current State waste minimization or pollution
prevention requirements be resolved?
• Can/do requirements for pollution prevention plans and waste minimization
audits contribute significantly to pollution prevention and waste minimization
efforts?
Non-Regulatory Mechanisms
• Are waste minimization partnerships between generators and treaters a
problem or are they in the long-term interest of the generators and
treatment/disposal industry?
• If there is a role for the general public to play in placing pressure on other
stakeholder groups, such as evaluating generators' progress in minimizing
wastes, then what is the most effective way for the public to have access to the
information they would need (e.g., through product labeling)? How would
confidential business information be protected?
• Should economic incentives (e.g., grants, loans, and subsidies) be used to
promote waste minimization? How effective are they? Must there be other
mechanisms in place concurrently?
• How could core grants in different media programs be used to promote waste
minimization initiatives? How can EPA and states reallocate resources to
promote pollution prevention and waste minimization?
• Have there been non-regulatory initiatives or mechanisms that have been
particularly effective in changing generator behavior?
• .What motivates generators to participate in voluntary challenge programs?
4. "Big Picture" Issues
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Measuring Progress
• How should progress toward waste minimization goals be measured or
determined? How should we take into account progress that has already been
made?
• Do we need to obtain an accurate multi-media perspective on chemical use,
generation, release, and/or management? If so, how?
• Are the current data reporting requirements (e.g., Biennial Reporting System
and Toxics Release Inventory) adequate for measuring waste minimization and
pollution prevention progress or should we re-evaluate these requirements
based on measurement goals? What are the best indicators of progress to use?
• Can/do pollution prevention plans and waste minimization audits contribute
significantly to measuring the progress of pollution prevention and waste
minimization efforts?
Multi-Media Impacts
• One of RCRA's stated objectives is to minimize the generation of hazardous
wastes; in contrast, requirements under other environmental laws (such as the
Clean Air Act and the Clean Water Act) may result in removing contaminants
from the air and water, thereby producing "pollution control" wastes that are
managed under RCRA. Are there fundamental conflicts between the RCRA
hazardous waste program and these other laws? In what specific instances do
other environmental laws' requirements and RCRA hazardous waste
minimization requirements conflict, and how could these conflicts be
addressed?
• Could source reduction and recycling techniques for "process wastes" (wastes
that result from production processes and general facility operations)
inadvertently result in transfers of contaminants to other environmental media
(e.g., air and water)? If so, how can we minimize potential cross-media
impacts resulting from promotion of waste minimization?
• Can/should multi-media pollution prevention and compliance objectives be
accomplished through combining single-media programs into multi-media
organizations or through better coordination between the single-media
programs?
Waste Management Capacity
• How do we promote waste minimization as a potential solution to waste
management capacity shortfalls identified in the capacity assurance planning
process?
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Remediation Wastes
Could restricting waste management options, while functioning to promote
waste minimization, also impede remediation activities?
What are our waste minimization goals, in the context of remediation
activities? Do we have opportunities to promote waste minimization through
our choices of remediation technologies (e.g., in-place treatment of
contaminated soil, versus excavation and off-site treatment/disposal)? Could
innovative technologies play a role in minimizing remediation wastes?
To what extent do remediation wastes create demand for waste management
capacity (e.g., demand for incineration capacity)? If remediation wastes create
a significant demand, could minimization of either the remediation wastes or
"process wastes" reduce demand for that waste management capacity?
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Waste Management Hierarchy
• In the May 28, 1993 Federal Register publication of the Interim Final
Guidance to Hazardous Waste Generators on the Elements of a Waste
Minimization Program, EPA defined "waste minimization" to include source
reduction (as defined in the Pollution Prevention Act) and environmentally
sound recycling. EPA does not consider certain types of recycling to be in the
"waste minimization" category. Is this definition appropriate? Should it be
modified? If so, in what way?
• Are certain forms of recycling (and even treatment) as environmentally
beneficial as source reduction? Conversely, does source reduction sometimes
cause unintended environmental effects? Can life cycle analysis illuminate the
potential tradeoffs of relying on source reduction vs. other management
techniques (e.g., recycling and burning for energy recovery)?
• With combustion, do the fuel substitution benefits and destruction of harmful
constituents make it an appropriate management technique for some wastes?
Does the answer depend in part on the extent to which waste minimization is
already occurring or on the potential risk reduction achieved?
• Should burning for energy recovery, because of its resource conservation
benefits, be considered waste minimization?
• Is there a limit to how much source reduction can ultimately be achieved? If
so, should we then encourage recycling?
Limiting Factors
• What is the role for market forces to dictate the balance between burning for
energy recovery and materials recovery? If solvent recovery is more
environmentally sound than burning for energy recovery, should government
intervene in the market (through regulatory or other means) to promote solvent
recovery?
• What are the regulatory barriers to pollution prevention and waste
minimization? What are non-regulatory barriers?
• To what extent does the lack of available technologies, or knowledge of
available technologies, limit pollution prevention and waste minimization?
• Are options more limited for small businesses in conducting pollution
prevention and waste minimization (e.g., in gaining access to capital to make
process changes)?
12
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Environmental Justice
• What implications do pollution prevention and waste minimization have for
environmental justice concerns?
13
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EPA NATIONAL ROUNDTABLE ON HAZARDOUS WASTE MINIMIZATION AND
COMBUSTION (Nov. 15-18, 1993)
DISCUSSION DOCUMENT: TECHNICAL COMBUSTION SESSIONS
General Issues
1. Technology vs Risk-Based Standards
• Questions with Risk-Based Standards. Given the questions raised with risk-
based standards, should risk assessment be used as the primary decision factor
in the regulatory program? Questions include: (1) risk assessment tools do not
consider ecological impacts or long-range transport of pollutants; (2) risk-
based standards allow dilution of emissions rather than removal of pollutants
and can also prolong the use of less efficient, older technologies; (3) lack of
knowledge regarding background levels of toxic chemicals; and (4) risk-based
standards are difficult to implement.
• Use of Risk Assessment in Rulemaking. Rather than basing emission limits
solely on risk assessment, should the rules require the use of "best
demonstrated technology", and use risk assessment to: (1) document that the
generic technology-based standards are protective in most cases; and (2) ensure
on a site-specific basis that the technology-based standards are protective.
Rather than requiring a site-specific risk assessment in all cases, should EPA
establish criteria that identify situations that can pose a particular hazard (e.g.,
poor dispersion conditions, high risk exposure scenarios) and require risk
assessment only when a criterion is exceeded?
• Development of Technology-Based Standards. If technology-based standards
are used, how should they be developed?
What are the pros and cons for EPA establishing standards for
hazardous waste burners under RCRA using the same procedures it
uses for developing maximum achievable control technology (MACT)
standards for controlling hazardous air pollutants under the Clean Air
Act Amendments (CAAA)?
What are the pros and cons for EPA promulgating technology-based
standards for hazardous waste burners under joint authority of RCRA
and the CAAA?
• Consideration of Cost-Effectiveness. Generic risk assessments of reasonable,
worst-case scenarios may indicate that technology-based emissions limits are
more than adequate for protection of human health. If so, is it appropriate to
14
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2.
consider cost-effectiveness in establishing such technology-based standards,
and if so how? Are there key factors to be considered, including cost-
effectiveness impacts on: (1) existing vs new facilities; (2) small vs large
facilities; and (3) facilities that are achieving emissions levels close to the
technology-based limit.
Siting Requirements: Buffer Zone. Given that accidents could happen at a hazardous
waste combustion facility that could pose an immediate hazard to persons in the
vicinity, are siting restrictions needed to provide a buffer zone between the facility
and residential areas or other types of land use (e.g., commercial or industrial areas)?
* Applicability to Existing Facilities. Should siting restrictions apply to existing
as well as new facilities, and if so how? If an existing facility cannot comply
with a restriction for reasons beyond its control: (1) should the facility be
exempt from the restriction (i.e., "grandfathered"); or (2) when the facility's
permit is due to be reissued, should EPA deny the reissuance; or (3) should
the facility be allowed to take measures to minimize the hazard posed under a
process that ensures public involvement? Are there other options regarding
existing facilities?
• Degree of Hazard. Should siting restrictions attempt to consider the degree of
hazard posed by the facility by considering factors such as size of the facility,
treatment of on-site vs off-site waste streams, and hazards already posed by
nearby facilities? Are there other relevant factors? Is such tailoring of siting
requirements practicable considering the subjectivity that may be involved in
developing and implementing the requirements?
Siting Restrictions: Environmental Equity. Should facilities be allowed to locate in
areas that already have high ambient levels of pollutants because of other sources?
Exemption for "Nontoxic" Hazardous Waste. Some generators assert that their
wastes are hazardous solely because they are ignitable and that the wastes do not
contain Appendix VIII, Part 261, toxic constituents. These generators claim that
these wastes are fuels that can be burned with less environmental impact than normal
fossil fuels. Although both the incinerator and BIF regulations have exemptions for
such wastes, the exemption process nonetheless requires a permit and compliance with
corrective action procedures. The Agency's work on "clean fuels" as a part of the
"Definition of Solid Waste" effort is addressing this issue, in part. An issue is
whether and how EPA could establish a definition of "clean fuels" and implement the
controls absent the oversight provided by the permitting process?
If a definition of "clean fuels" is established, can or should the levels of
toxic compounds in fossil fuels be used as a benchmark?
If so, which fossil fuels should be used (e.g., grade of fuel oil, grade
of coal), and what statistical method (e.g., 50th percentile level, 75th
15
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5.
percentile highest (or lowest) level) is most appropriate for
characterizing the level of toxic compounds in the fossil fuel?
!"
Should the Agency's risk assessment methodology be used in
identifying acceptable levels of toxic compounds in "clean fuels?"
Future Incineration Capacity. Is there a need for additional commercial hazardous
waste incinerators in the United States?
6. Federal Bad Actor Law. Is there a need for a Federal Bad Actor Law to help ensure
that facility owners and operators are reputable and competent?
Controls on Emissions of Toxic Metals
1. Limits on PM. Are particulate matter (PM) emissions an effective surrogate for
emissions of toxic metals?
• Can PM emissions be monitored on a real-time basis to determine compliance
with a limit in the range of 0.015 to 0.03 gr/dscf?
• If real-time monitoring is not currently feasible, can PM be sampled
continuously and analyzed periodically to help ensure compliance with a PM
limit? What is a reasonable averaging period and how quickly can
determinations be made after the sampling period ends?
• Are there metals or classes of metals (e.g., nonvolatile) more suitable to a PM
monitoring approach than others?
2. Limits on Individual Metals.
metals, and if so how?
Should EPA establish limits on individual toxic
Form of the Controls. What form should the controls take: (1) concentration limit
in stack gas (mg/dscm); or (2) mass emission rate(g/hr); or (3) system removal
efficiency (1 minus the ratio of the mass emission rate to the mass feed rate,
considering metal partitioning to bottom ash (or product) and metal removed by the
air pollution control system)?
How to Consider Variability in Metal Feed Rate. In establishing an emission rate
limit, how should variability of metal feed rate (i.e., variability of metal
concentration in the waste, and variability of waste feed rate) be considered? An
option would be to consider current industry practice for waste feed rate and the
50th, 75th or 90th percentile highest metals concentration in combustible waste.
Alternatively, to minimize metals emissions, a lower emission limit could be
established by considering that a waste with the 75th or 90th percentile lowest
metals concentration is burned. Would this opportunity create an incentive for waste
minimization or pretreatment to remove metals?
16
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• Generic vs. Source Category-Specific Limits. Should metals limits be established
separately for specific source categories (e.g., incinerators, cement kilns, coal-fired
industrial boilers) considering feasibility of control technologies and other factors, or
should generic metals limits, be established for all hazardous waste combustion
devices? Given that BIFs do not have to burn hazardous waste fuels in lieu of fossil
(or other) fuels, would it be appropriate to establish metal emission limits based on
the performance of the best facilities irrespective of the type of device? What would
be the pros and cons of such an approach?
• Continuous Emissions Monitor rCElvD. What is the status of development for a
real-time monitor for emissions of individual metals? What is the status of
development of a continuous sampler for metals that could provide samples for
periodic metal determinations so that emission rate determinations could be made on,
for example, an hourly-average basis and reported promptly after the sample has
been taken?
If a metals CEM could be developed to document continuous compliance with
emissions limits, are regulatory controls on operating conditions (e.g.,
maximum temperature at the inlet to the control device; limits on key operating
parameters of the air pollution control device) also appropriate to ensure that the
facility is operating according to best operating practices?
If a metals CEM is developed, is it appropriate to consider cost-effectiveness in
determining whether to require its use at small facilities?
3- Need for Both PM and Metals Controls. If EPA establishes metal-specific emission
limits, is a limit on PM also needed? If not, how would the following issues be
dealt with or do they need to be addressed: (1) control of those metals (for which .
EPA has not specified emission limits) that can have adverse ecological impacts
(e.g., copper); (2) control of metals that may pose a hazard to human health even if
the Agency does not have adequate health effects data at this time to warrant specific
emission limits; or (3) control of toxic organic compounds that are adsorbed onto
PM?
4- Waste Minimization Considerations. Is combustion an appropriate treatment
technology for metal-bearing wastes? If not, are waste minimization efforts to
reduce the quantity of metal-bearing wastes useful in reducing emissions of toxic
metals?
Controls on Emissions of Toxic Organic Compounds
1. Controls on Dioxins/Furans
• Dioxin Limits. Should EPA adopt the dioxin standard recently proposed by the
European Community (EC)? This standard would impose a limit of 0.1 ng/dscm of
toxic equivalency at 11% oxygen, which equates to 0.14 ng/dscm at 7% oxygen.
17
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(EPA's hazardous waste combustion standards are corrected to a stack gas oxygen
concentration of 7 %.)
Controls on Total Congeners Vs Toxicity Equivalents. Should EPA establish limits
on chlorinated dioxins and furans based on total tetra- through octa- congeners, or
on the basis of toxicity equivalents? What are the pros and cons for each method,
considering level of protection provided, technical feasibility, cost, and
implementation factors?
Exemption for Nonchlorinated Wastes. Should EPA control dioxin emissions from a
facility if the hazardous waste burned does not contain detectable levels of chlorine?
Should EPA control under RCRA authority dioxins that may be formed by
interaction of organic compounds derived from burning nonchlorinated hazardous
waste with chlorine derived from other fuels (e.g., coal)?
Effects of Waste Minimization. Can chlorine present in hazardous waste contribute
significantly to formation of chlorinated dioxins? If so, are waste minimization
efforts to reduce the quantity of chlorinated wastes useful in reducing emissions of
dioxins?
Controls on Other Organic Emissions
Risk from Dioxins Vs Other Organics. If dioxin emissions are controlled, is it
necessary to control other toxic organic emissions in order to protect human health
and the environment? Is it appropriate to assume that risk assessments typically
estimate that the risk from dioxin emissions to be much higher that the risk from
other emissions?
Surrogates for Other Organics. Is there a better approach to control other organic
emissions than limiting bulk gas surrogates such as carbon monoxide (CO) and
hydrocarbons (HC)? Can emissions of individual organic compounds be monitored
on a real-time basis? If not, what is the state of technology and the prospects for
the future? Which organic compounds can appropriately serve as surrogates for
emissions of toxic organic compounds?
Effect of Waste Minimization. Can chlorine present in hazardous waste contribute
significantly to formation of toxic chlorinated organic compounds? If so, are waste
minimization efforts to reduce the quantity of chlorinated wastes useful in reducing
emissions these compounds?
Quantifying Emissions For Risk Assessment. For purposes of site-specific risk
assessment, how should organic emissions be quantified?
- Which compounds should be quantified during trial burns? Are there some (or
combinations) that are more useful than others?
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How should emissions during the trial burn be used in the risk assessment? For
example, for facilities that conduct trial burn tests under varying conditions,
should the test conditions that result in the highest emissions be used for the risk
assessment?
Other Issues
1.
2.
Fuel Blenders. Hazardous waste fuels are generally supplied to cement and light-
weight aggregate facilities by fuel blenders that obtain wastes from generators and
process the wastes (e.g., by grinding, blending, decanting, settling, suspension of
solids in liquids) to meet the burner's fuel specifications. Two questions have been
raised: (1) are fuel blenders operating under RCRA permits; and (2) given the
controls provided by the BIF rule, should EPA still be concerned about the as-
generated heating value of wastes that are destined for use as fuel in these devices.
• Blender Permits. Fuel Blenders require a RCRA permit for any hazardous
waste fuel or any waste destined for use as fuel. Are blenders operating without
a RCRA permit? If so, is it because of confusion over the applicability of the
regulations?
• Heating Value Restrictions. Once a BIF certifies compliance with emissions
standards under §266.103(c), it may burn hazardous waste irrespective of its
heating value. Thus, BIF certification of compliance supersedes the "sham
recycling" policy that wastes with a heating value of (generally) less than 5,000
Btu/lb, as-generated, cannot be burned in a BIF unless the BIF has an
incinerator permit.
Although certification of compliance supersedes the sham recycling policy,
burning listed wastes with less than (generally) 5,000 Btu/lb, as-generated,
subjects products that are applied to the ground (e.g., clinker (cement),
light-weight aggregate) to regulation as hazardous waste. Such waste-
derived products must be managed as hazardous waste unless they meet
land disposal restrictions standards for the waste burned.
Is this appropriate because of concern that metals in low heating value
wastes (e.g., electroplating sludges) may partition to the product and pose a
hazard to human health or the environment during transportation or use in
commerce?
Are there problems with implementing this approach (i.e., restricting the as-
generated heating value of wastes burned in devices that produce products
applied to the ground)? Is there a better approach to ensure that metals do
not partition to the product at levels that could pose a hazard?
Trial Burns. How effective are trial burns at: (1) ensuring that the facility can
comply with emissions standards; and (2) establishing operating controls that ensure
19
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continued compliance with the standards? How representative is the trial burn of
actual day-to-day operations? Are there improvements that can be made?
3. Campaign Burning. Given that analyzing heterogeneous waste streams to document
composition is problematic and that it can be difficult to maintain steady-state
operations when burning heterogenous wastes, what are the pros and cons of
requiring facilities to segregate wastes that have similar properties into batches or
"campaigns?"
4. Feedstream Sampling Frequency. Is guidance (or regulatory revisions) on
feedstream sampling frequency needed to assist regulated facilities in complying with
the regulations?
5. Recordkeeping. Is guidance needed on how to electronically maintain records so
that they can be retrieved quickly (e.g., for inspectors)?
6. State Regulations. Are state regulations at least as strict as the federal minimum
standards? Should EPA provide further oversight to ensure that state regulations
meet federal criteria?
7. Emergency Safety Vents. Should an incinerator be allowed to burn hazardous waste
if it is equipped with an emergency safety vent that, when open, allows combustion
gases to by-pass the air pollution control system? If they can serve a useful
function, what restrictions should apply to their use (e.g., maximum number of
openings per month; requirements for redundancy in critical systems that can trigger
an opening)?
20
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APPENDIX D
LIST OF PARTICIPANTS
21
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LIST OF PARTICIPANTS
Joann Almond
Scotch
George Anderson
National Association of Chemical
Recyclers
Beth Antley
U.S. EPA Region IV
345 Courtland Street, NE
Atlanta, GA 30365
Mike Balchunas
Systech Environmental
245 North Valley Road
Xenia, OH 45385
Phone: (513) 372-8077
Fax: (513) 372-8099
Ronald E. Bastian
Focus Environmental, Inc.
9050 Executive Park Drive, Suite A-202
Knoxville, TN 37923
Phone: (615) 694-7517
Fax: (615) 531-8854
Sharon Baxter, Manager
VA Department of Environmental Quality
Pollution Prevention Program
101 North 14th Street
Monroe Building, 14th Floor
Richmond, VA 23219
Phone: (804) 371-8712
Fax: (804) 371-0193
Doug Beason
State of Florida Department of
Environmental Protection
2600 Blair Stone Road
Tallahassee, FL 32399-2400
Phone: (904)488-9730
Fax: (904) 488-2439
Mike Benoit (Chairman, CKRC Executive
Committee)
Vice President, Environmental Affairs
Cedence Energy Recovery
2172 Plainfield Pike
Greene, RI 02827
Phone: (401)392-0151
Fax: (401) 392-3890
Faye Beuby
Romic Chemical Corporation
2081 Bay Road
East Palo Alto, CA 94303
Phone: (415) 324-1638 x 390
Fax: (415) 324-2965
William W. Bilkovich
Environmental Quality Corporation
259 Timberlane Road
Tallahassee, FL 32312-1542
Phone: (904)386-7740
Fax: (904) 386-6131
Gil Black
Organizations United for the Environment
209 S. 4th Street
Lewisburg, PA 17837
James Brennan
Hazardous Waste Treatment Council
750 Holiday Drive
Pittsburgh, PA 15220
Phone: (412) 642-3502
Fax: (412) 642-2318
Andy Bellina
U.S. EPA Region II
Jacob K. Javits Federal Building
26 Federal Building
New York, NY 10278
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Barbara Bush
American Petroleum Institute
1220 L Street, NW
Washington, DC 20005
Phone: (202) 682-8235
Fax: (202) 682-8031
James V. Callier
U.S. EPA Region VII
WSTM/RCRA/IOWA
726 Minnesota Avenue
Kansas City, KS 66101
Phone: (913)551-7646
Fax: (913) 551-7521
Dave Cameron
Ross Environmental Services, Inc.
36970 Giles Road
Grafton, OH 44044
Phone: (216)748-2200
Fax: (216) 748-1399
Robert L. Campbell
Pollution Control Industries, Inc.
3317 Chicago Road
S. Chicago Heights, IL 60411
Phone: (800)388-7242
Fax: (708) 754-7125
Fred Chanania
U.S. EPA - Office of Solid Waste
2800 Crystal Drive
Arlington, VA 22202
Samuel Coleman, P.E.
U.S. EPA - Office of Waste Programs
Enforcement
401 M Street, SW (OS-520)
Washington, DC 20460
Phone: (202)260-8115
Mary Ellen Connally
CLEAN (South Carolina)
664 Connolly Road
York, SC 29745
Phone: (803) 684-6519
Fax: (803) 927-7663
Paul Connert
Waste Not
Chemistry Department
St. Lawrence University
Canton, NY 13617
Phone: (315)379-5853
Jamie Conrad
Chemical Manufacturers Association
2501 M St., NW
Washington, DC 20037
Phone: (202) 887-1353
Fax: (202) 887-1237
Pat Costner
Greenpeace
P.O. Box 548
Eureka Springs, AR 72632
Phone: (501)253-8440
Eugene P. Grumpier, Jr.
U.S. EPA - Office of Air Quality Planning
and Standards
U.S. EPA (MD-13)
Research Triangle Park, NC 27711
Phone: (919) 541-0881
Fax: (919) 541-5600
Becky Cuthbertson
U.S. EPA
2800 Crystal Drive
Arlington, VA 22202
Phone: (703) 308-8447
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Carl Daly
U.S. EPA Region VIII
999 18th Street
Denver, CO 80202
Phone: (303)293-1500
Vivian Daub
U.S. EPA - Office of Water
401 M Street, SW
Washington, DC 20460
Kevin Dick, Manager
Nevada Small Business Development
Center
Business Environmental Program
University of Nevada - Reno
Reno, NV 89557-0100
Phone: (702)784-1717
James W. Dolen, Jr., P.E.
New York State Department of
Environmental Conservation
Bureau of Hazardous Waste Facility
Compliance
Division of Hazardous Substances
Regulation
RCRA Permit Section 2
50 Wolf Road
Albany, NY 12233-7252
Phone: (518)457-7269
Craig Doolittle
Dow Chemical Company
Environmental Services
1261 Building
Midland, MI 48667
Phone: (517)638-3863
Fax: (517) 638-7142
Larry Eastep
IL Environmental Protection Agency
Bureau of Land Management
2200 Churchill Road
P.O. Box 19276
Springfield, IL 62794-9276
Phone: (217) 524-3305
Fax: (217) 524-3291
Tracy Easthope
Ecology Center
417 Detroit Street
Ann Arbor, MI 48104
Phone: (313)663-2400
BillEberle
NY State Department of Environmental
Conservation
50 Wolf Road
Albany, NY 12233-8010
Eli D. Eilbott, Deputy General Counsel
Hazardous Waste Treatment Council
915 15th Street, Fifth Floor
Washington, DC 20005
Phone: (202)783-0870
Fax: (202) 737-2038
Gary Elliot
Systeh Environmental
245 North Valley Road
Xenia, OH 45385
Phone: (513)372-8077
Fax: (513) 372-8099
Brian Engel
USPCI
515 West Green Road, #500
Houston, TX 77607
Phone: (713)775-7849
Fax: (713) 775-7845
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Patti Everitt
Texas Water Commission
P.O. Box 13087
Austin, TX 78711-3087
Phone: (512)475-4580
Fax: (512) 475-4599
Andrea Farrell
Pollution Prevention Program
DNREC
P.O. Box 1401
Dover, DE 19903
Phone: (302)739-3822
Fax: (302) 739-5060
Gregory Ferguson
Arkansas Peace Center
204 Beachwood
Little Rock, AK 72205
Phone: (501)661-9622
Susan Ferguson, Director
TX Natural Resources Conservation
Commission
Industrial & Hazardous Waste Division
P.O. Box 13087
Austin, TX 78711
Phone: (512) 908-2334
Fax: (512) 908-2550
Dominic Forcella, Executive Officer
CT Hazardous Waste Management Service
900 Asylum Avenue, Suite 360
Hartford, CT 06105-1904
Phone: (203)244-2007
Fax: (203) 244-2017
David Ferrell
Texas Natural Resouce Conservation
Commission
P.O. Box 13087
Austin, TX 78701-3087
Richard C. Fortuna
Hazardous Waste Treatment Council
915 15th Street, Fifth Floor
Washington, DC 20005
Phone: (202)783-0870
Fax: (202) 737-2038
Gregg P. Franklin
Expanded Shale Clay and Slate Institute
P.O. Box 228
Ashland, VA 23005
Phone: (804)798-7981
Fax: (804) 752-6310
Harry Freeman
U.S. EPA - Risk Reduction Engineering
Laboratory
26 West Martin Luther King Drive
Cincinnati, OH
Phone: (513)569-7529
Shiva Garg
U.S. EPA - Office of Solid Waste
2800 Crystal Drive
Arlington, VA 22202
Phone: (703)308-8459
Kevin F. Gashlin
Hazardous Substance Management
Research Center
New Jersey Institute of Technology
University Heights
Newark, NJ 07102
Phone: (201)596-5864
Fax: (201) 802-1946
Don Gebhardt
Ashland Oil, Inc.
P.O. Box 391
Ashland, KY 41114
Phone: (606) 329-3070
Fax: (606) 329-4296
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Ken Gigiello
U.S. EPA - Office of Waste Programs
Enforcement
401 M Street, SW
Washington, DC 20460
Robert Giraud
Dupont (L-13W07)
Engineering Department
655 Papermill Road
P.O. Box 6090
Newark, DE 19714
Phone: (302) 366-6906
Fax: (302) 366-4123
Chris Goebel
National Association of Chemical
Recyclers
1200 G Street, NW, Suite 800
Washington, DC 20005
Hillel Gray
National Environmental Law Center
29 Temple Place
Boston, MA 02111
Phone: (617) 422-0880
Fax: (617) 422-0881
Charles Griffith
Ecology Center
417 Detroit Street
Ann Arbor, MI 48104
Phone: (313) 663-2400
Gary Gross
U.S. EPA Region III
541 Chestnut Street
Philadelphia, PA 19107
Robert E. Hall
U.S. EPA
Air and Energy Engineering Research
Laboratory
Combustion Research Branch (MD-65)
Research Triangle Park, NC 27711
Phone: (919)541-2477
">
Eric Hansen (Chairman CKRC Technical
Committee)
Vice President and Technical Director
Ash Grove Cement
8900 Indian Creek Parkway
P.O. Box 25900 (66225)
Overland Park, KS 66210
William Gerald Hardy
Alabama Department of Environmental
Management
1751 Cong Dickinson Drive
Montgomery, AL 36130
John R. Hart, P.E.
California Environmental Protection
Agency
Department of Toxic Substances Control
Region 1
Facility Permitting Branch
10151 Croydon Way, Suite 3
Sacramento, CA 95827
Phone: (916)255-3615
Fax: (916) 255-3595
Joan F. Hartley
South Carolina Department of Health and
Environmental Control
2600 Bull Street
Columbia, SC 29201
Phone: (803) 734-5167
Fax: (803) 734-5199
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David Hartley, Chief, Technology
Clearinghouse
Office of Pollution Prevention and
Technology Development
Department of Toxic Substances Control
P.O. Box 806
Sacramento, CA 95812-0806
Phone: (916)324-1815
Fax: (916) 327-4494
Carolyn Hartmann
U.S. Public Interest Research Group
215 Pennsylvania Avenue, SE
Washington, DC 20003
Phone: (202)546-9707
Fax: (202) 546-2401
Thomas Hassell
E.I. Dupont DeNemours
Engineering Department
P.O. Box 6090, L3370
Wilmington, DE 19714-6090
Phone: (302)366-4343
Fax: (302) 366-6205
Laurie C. Haws, Ph.D.
Texas Natural Resource Conservation
Commission
Effects Evaluation Section/Office of Air
P.O. Box 13087, Bldg C
Austin, TX 78711
Phone: (512)908-1000
Teresa Hay, Administrator
IA Department of Natural Resources
Waste Management Division
900 East Grand Avenue
Henry A. Wallace Building
Des Moines, IA 50319-0034
Phone: (515)281-8975
Fax: (515) 281-8895
Daniel W. Heintz
Southdown, Inc.
1200 Smith Street, Suite 2400 _,,.
Houston, TX 77002
Phone: (713) 653-6956
Fax: (713) 653-8567
Tom Hein
Eli LiLly & Company
Lilly Corporate Center
Indianapolis, IN 46285
Phone: (317)276-1815
Fax: (317) 276-1800
Michael B. Heiser
WINCO
P.O. Box 4000 MS-3202
Idaho Falls, Idaho 83403
Phone: (208)526-3317
Fax: (208) 526-5465
Bob Hellang
U.S. EPA - Office of Solid Waste
A. Judson Hill
Westinghouse
One Church Street, #801
Rockville, MD 20850
Phone: (301)762-0181
Fax: (301)762-6115
Rick Hine
Greenpeace
1436 U Street, NW
Washington, DC 20009
Phone: (202)319-2505
Fax: (202) 462-4507
Dwight Hlustick
U.S. EPA - Office of Solid Waste
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Bob Holloway
U.S. EPA - Office of Solid Waste
2800 Crystal Drive
Arlington, VA 22202
Phone: (703) 308-8461
Bill Honker, Chief
EPA Region 6
RCRA Permits Branch (6H-P)
1445 Ross Avenue
Dallas, TX 75202
Phone: (214)655-6770
Fax: (214) 655-6460
Ed Hopkins
Citizen Action
1120 19th Street, NW, Suite #630
Washington, DC 20036
Phone: (202) 775-1580
Fax: (202) 296-4054
Mark Hopkins
American Petroleum Institute
Gary Hunt, Director
North Carolina Department of
Environment, Health, and Natural
Resources
Pollution Prevention Program
Office of Waste Reduction
P.O. Box 27687
Raleigh, NC 27611-7687
Phone: (919)571-4100
Robert Hukill
Hukill Chemical Corporation
7013 Krick Road
Bedford, OH 44146
Phone: (216)232-9400
Fax: (216) 232-9477
John lannotti, Director
Department of Environmental
Conservation
Pollution Prevention Unit
Office of Environmental Quality
50 Wolf Road
Albany, NY 12233-8010
Phone: (518)457-7267
Fax: (518) 457-2570
Tom Jacob
Dupont, EA-N9527
1007 Market Street
Wilmington, DE 19898
Phone: (302)774-6873
Ellis Jacobs
Greene Environmental Coalition
211 South Main Street, Suite 300
Dayton, OH 45402
Phone: (513) 228-8088, 8888
Rex Jameson (CKRC Technical
Committee)
Corp. President, Corp. Development
Holnam, Inc.
6211 North Ann Arbor (48131)
P.O. Box 122
Dundee, MI 48131
Phone: (313)529-2411
Fax: (313) 529-2719
Tom L. Jones
Union Carbide Chemicals and Plastics
Company Inc.
Taft Plant, P.O. Box 50
Hahnville, LA 70057
Phone: (504) 468-4738
Fax: (504)783-2943
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R. Stan Jorgensen
ENSCO, Inc.
415 N. McKinley, Suite 890
Little Rock, AR 72205
Phone: (501)664-0020
Fax: (501) 664-5005
Ed Junia
Systech Environmental
245 North Valley Road
Xenia, OH 45385
Phone: (513)372-8077
Fax: (513) 372-8099
Ronald O. Kagel, Ph.D.
Environmental Consultant
4 Hannah Court
Midland, MI 48642
Phone: (517)631-4477
Satish Kastury
State of Florida Department of
Environmental Regulation
Division of Waste Management
Bureau of Solid and Hazardous Waste
2600 Blair Stone Road
Tallahassee, FL 32399-2400
Phone: (904)488-0300
Fax: (904) 922-4939
Michael Kelley
OH Environmental Protection Agency
Office of Pollution Prevention
P.O. Box 1049
1800 WaterMark Drive
Columbus, OH 43266-0149
Phone: (614)644-3969
Fax: (614) 644-2329
James D. Kilgroe
U.S. EPA
Y.J. Kim
U.S. EPA Region IX
Hazardous Waste Management Division
Mail Code H-3-3
75 Hawthorne Street
San Francisco, CA 94105
Phone: (415)744-2058
John Klepeis
Rhone Poulenc
P.O Box 881
Shelton, CT 06484
Phone: (203)925-3481
Fax: (203) 925-3659
Scott Kuhn
Laidlaw Environmental Services, Inc.
220 Outlet Point Boulevard
Columbia, SC 29210
Phone: (803)798-2993
Fax: (803) 551-4202
Robert LaBoube
Chemical Waste Management, Inc.
2000 South Batavia Road
Geneva, IL 60134
Phone: (708) 513-4500
Fax: (708) 513-0680
Haile B. Mariam
U.S. EPA
2800 Crystal Drive
Arlington, VA 22202
Phone: (703) 308-8439
Tita Lagrimas
Pollution Control Industries, Inc.
4343 Kennedy Avenue
E. Chicago, IN 46312
Phone: (219)397-3951
Fax: (219) 397-6264
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Richard Lavoie
Safety-Kleen Corporation
1000 North Randall Road
Elgin, IL 60123
Phone: (708)468-2014
Fax: (708)468-8507
Denise Lee
Blue Ridge Environmental Defense League
Route 2, Box 286
Wadesboro, NC 28170
Phone: (704) 826-8116
K.C. Lee
Union Carbide
3200 Kanawha Turnpike
P.O. Box 8361, Building 770/344
South Charleston, WV 25303
Phone: (304)747-5221
Fax: (304) 747-5430
Mark Lemons
The Upjohn Company
Mail Stop 6602-306-1
7171 Portage Road
Kalamazoo, MI 49001
Phone: (616)329-9159
Fax: (616) 329-5056
Lawrence H. Liden
Baltimore Gas and Electric Company
Environmental Programs Section
7609 Energy Parkway, Suite 101
Baltimore, MD 21226
Phone: (410)787-5107
Fax: (410) 787-5199
Jo Ann S. Lighty, Ph.D.
University of Utah
2254 Merrill Engineering Building
Salt Lake City, UT 84112
Phone: (801)581-5763
Joe Lindsly
The Dow Chemical Company
2030 Dow Center
Midland, MI 48674
Phone: (517) 636-1215
Fax: (517) 636-9933
Jim Lounsbury
National Roundtable of State Pollution
Prevention Programs
P.O. Box 7219
Silver Spring, MD 20910
Phone: (301)495-9278
Fax: (301) 589-7068
Doug MacMillan
National Solid Waste Management
Association
Cheryl Maggio
U.S. Army Chemical Material Destruction
Agency
AttmSFILCDEP
Aberdeen Proving Grounds, MD 21010-
5401
Phone: (410) 671-1455
Fax: (410) 671-3782
Eric Males
Chemical Manufacturers Association
2501 M Street, NW
Washington, DC 20037
Phone: (202) 887-1270
Fax: (202) 887-1237
Catherine Massimino
U.S. EPA Region X
1200 6th Avenue
Mail Code HW 106
Seattle, WA 98101
Phone: (206)553-4153
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Mark McCorkle
Arkansas Department of Pollution Control
& Ecology
Little Rock, AR 72210
Phone: (501)562-7444
Brian McHenry
(CKRC Technical Committee)
Vice President, Environmental &
Regulatory Affairs
Cemtech, Inc.
One West Brook Corporate Center
Suite 500
Westchester, IL 60154
Phone: (708)947-2770
Fax: (708) 947-2756
Mark Mercer
U.S. EPA
Ray Mendelsoki
DuPont/Chemical Manufacturers
Association
Elizabeth H. Mikols
Lehigh Portland Cement Company
7660 Imperial Way
Allentown, PA 18195
Phone: (215)366-4753
Fax: (215) 366-4684
Gary Miller
Illinois Hazardous Waste Research
Information Center
1 East Hazelwood Drive
Champaign, IL 61820
Phone: (217)333-8942
Fax: (217) 333-8944
Peter A. Molinaro
Union Carbide Corporation
801 Pennsylvania Avenue, N.W., Suite
230
Washington, DC 20004
Phone: (202)383-3211
Fax: (202) 347-1684
Dr. Albert Montague
U.S. EPA Region III
Regional Solid Waste Manager
841 Chestnut Street
Mail Code 3HW50
Philadelphia, PA 19107
Phone: (215)597-1613
Pat Moran
Rohm & Haas
P.O. Box 32260
4300 Camp Ground Road
Louisville, KY 40232
Phone: (502)449-5258
Fax: (502) 449-5256
Jim Mueller
55 Ridge Trail
Joplin, MO 68404
Phone: (417) 623-8407
Fax: (417) 781-4501
Warren Muir
Hampshire Research Associates, Inc.
9426 Forrest Haven Drive
Alexandria, VA 22309
Phone: (703)780-7474
Fax: (703) 648-7704
Bernard M. Nee, Jr.
Eastman Kodak Company
1100 Ridgeway Avenue
Rochester, NY 14652-3615
Phone: (716)722-1337
Fax: (716) 722-3695
10
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Lee Otis
U.S. EPA Region X
1200 6th Avenue
Mail Code HW107
Seattle, WA 98101
Phone: (206)553-1099
Rick Page
UT Department of Environmental Quality
Division of Solid & Hazardous Waste
288 North 1460 West
Salt Lake City, UT 84114-4880
Phone: (801)538-6170
Fax: (801) 538-6715
Don Patterson
Beveridge and Diamond
Clyde Peeling
Organizations United for the Environment
Donna Perla
U.S. EPA
2800 Crystal Drive
Arlington, VA 22202
Phone: (703)308-8402
Fax: (703) 308-8433
Lynn Persson, Coordinator
WI Department of Natural Resources
Hazardous Waste Minimization Program
Bureau of Solid & Hazardous Waste
Management
P.O. Box 7921
Madison, WI 53707
Phone: (608)267-3763
Fax: (608) 267-2768
Michael Poetzsch
U.S. EPA, Region II
Jacob R. Javits Federal Building
26 Federal Building
New York, NY 10278
Milton P. Polakovic
New Jersey State Department of
Environmental Protection
Division of Environmental Quality
401 E. State Street
CN027
Trenton, NJ 08625
Phone: (609) 984-3027
Jim Power
Edison Electric Institute
Jane Powers
U.S. Department of Energy/EH-231
1000 Independence Avenue, SW
Washington, DC 20912
Phone: (202)586-7301
Fax: (202) 586-3915
Mitch Press
Dupont
Engineering Department
655 Papermill Road
P.O. Box 6090
Newark, DE 19714
Phone: (302)366-6986
Fax: (302) 366-4123
Randy Price
DuPont
Maple Run, 2024
P.O. Box 80721
Wilmington, DE 19880
Phone: (302) 999-4128
Fax: (302) 999-3099
John Pruden
Organizations United for the Environment
10701 Lake Avenue
Ossineke, MI 49766
Phone: (517) 471-2747
11
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Robert Robatine
ENSCO
100 Trislate International, Suite 260
Lincolnshire, IL 60069
Phone: (708)945-5700
Fax: (708) 945-5918
Jan Radinsky
CA Department of Toxic Substances
Control
Hazardous Waste Management Program
P.O. Box 806
Sacramento, CA 95812-0806
Phone: (916)324-1819
Fax: (916) 327-4495
Mark Ralston
U.S. EPA - Office of Solid Waste
2800 Crystal Drive
Arlington, VA 22202
John Ramirez
U.S. Department of Energy
656 Quince Orchard Road, Suite 270
Gaithersburg, MD 20878
Phone: (301)427-1542
Fax: (301) 427-1541
Dennis Redington
Monsanto (A3NA)
800 North Lindbergh Boulevard
St. Louis, MO 63167
Phone: (314)694-6503
Fax: (314) 694-8957
Phil Retallick
Rollins Environmental Services, Inc.
One Rollins Plaza
P.O. Box 2349
Wilmington, DE 19899
Phone: (302)426-3948
Fax: (302) 426-3553
James Roewer
Edison Electric Institute
701 Pennsylvania Avenue, NW
Washington, DC 20004-2696
Phone: (202)508-5645
Ken Rota
U.S. EPA Region I
Department of Environmental Protection
JFK Federal Building
One Congress Street
Mail Code HB.WCAN-3
Boston, MA 02203
Phone: (617)573-5757
Manik Roy, Ph.D.
Environmental Defense Fund
1875 Connecticut Avenue, NW
Washington, DC 20009
Phone: (202)387-3500
Fax: (202 234-6049
David Rozell
OR Department of Environmental Quality
Hazardous Waste Policy & Program
Development
Waste Management and Cleanup Division
811 S.W. Sixth Avenue
Portland, OR 97204-1390
Phone: (503)229-5278
Fax: (503) 229-6977
Alan Rubin
U.S. EPA - Office of Water
Ed Sadler
Missouri Department of Natural Resources
Program Director
Hazardous Waste Program
205 Jefferson Street
P.O. Box 176
Jefferson City, MO 65102
Phone: (314)751-3176
12
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Joseph J. Santoleri
Four Nines, Inc.
400 Stenton Avenue
Pylmouth Meeting, PA 19462
Phone: (215) 834-0490
Fax: (215) 834-1469
Michael Santoro
3M Corporation
Environmental, Engineering and Pollution
Control
P.O. Box 33331
Building 21-2W-05
St. Paul, MN 55133-3331
Phone: (612)778-4089
Fax: (612) 778-7203
Sonya Sasseville
U.S. EPA - Office of Solid Waste
2800 Crystal Drive
Arlington, VA 22202
Dale Scherger
Rollins Environmental Services, Inc.
One Rollins Plaza
P.O. Box 2349
Wilmington, DE 19899
Phone: (302) 426-3578
Fax: (302) 426-3553
Jim Schermbeck
Texans United
2101 South Edgefield
Dallas, TX 75224
Phone: (214)942-6300
Bob Schreiber (CKRC Executive
Committee)
Vice President
Industrial Waste Management
271 Wolfner Drive
St. Louis, MO 63026
Phone: (314)349-8300
Fax: (314) 349-8384
Karl Sheaffer
Pennsylvania Department of Environmental
Resources
Division of Hazardous Waste Management
P.O. Box 2063
Harrisburg, PA 17105
Ron Shipley
Chemical Manufacturers Association
2501 MSt.,NW
Washington, DC 20037
Phone: (202) 887-1160
Fax: (202) 887-1237
Garth Shipman
Organizations United for the Environment
P.O. Box 193
Allenwood, PA 17810
Phone: (717)538-1313
Peter R. Siebach
U.S. Department of Energy
EM-323 (TREVION II)
Washington, DC 20585
Phone: (301)903-7128
Fax: (301) 903-7168
Steve Silverman
U.S. EPA - Office of General Council
John Smith
U.S. EPA Region VII
WSTM/RCRA/PRMT
726 Minnesota Avenue
Kansas City, KS 66101
Phone: (913)551-7845
Fax: (913) 551-7947
13
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Patricia Deese Stanton
Assistant Commissioner
MA Department of Environmental
Protection
Bureau of Waste Prevention
One Winter Street, 7th Floor
Boston, MA 02108
Phone: (617)292-5765
Fax: (617) 656-1049
Randal W. Steger
Idaho Department of Health and Welfare
Division of Environmental Quality
1410 North Hilton
Boise, ID 83706-1253
Phone: (208)334-5879
Jerome Strauss
Versar
6850 Versar Center
Springfield, VA 22151
Phone: (703)750-3000
Sally Swanson
U.S. EPA Region V
77 West Jackson Boulevard
Mail Code HRM-7J
Chicago, IL 60604
Phone: (312)353-8510
Terri Swearington
Tri-State Environmental Council
Road #1
Box 365
Chester, WV 26034
Phone: (304)387-0574
Nancy D. Tammi
Beverridge and Diamond, P.C.
1350 I Street, NW, Suite 700
Washington, DC 20005
Phone: (202)789-6000
Fax: (202) 789-6190
Lynn Thorp
Greenpeace
Janice Tirpack
BASF Corporation
8 Campus Drive
Parsippany, NJ 07054
Phone: (201) 397-4691
Fax: (201) 397-4520
James M. Turek
The Upjohn Company
7000 Portage Road
Kalamazoo, MI 49004
Phone: (616)323-6490
Fax: (616) 329-5056
Jim Turpin
American NuKEM
454 S. Anderson Road
BTC 532, Suite 304
Rock Hill, SC 29730
Phone: (803)329-9690
Gary Victorine
U.S. EPA Region V
77 West Jackson Boulevard
Mail Code HRP-8J
Chicago, IL 60604
Phone: (312) 886-1479
Don Warren
American Cyanamid
Box 817
Hannibal, MO 63401
Phone: (314)769-2011
Fax: (314) 769-3178
Ed Weiler
U.S. EPA
401 M Street, SW
Washington, DC 20460
Phone: (202)260-2996
14
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J. Brad Willett
American Cyanamid
State Route 168 and JJ Spur
Box 817
Hannibal, MO 63401
Phone: (314)769-2011
Fax: (314) 769-3178
Todd Williams
General Motors
Argo A-250
485 W. Milwaukee
Detroit, MI 48202
Phone: (313)556-7608
Fax: (313) 556-76296
Betty C. Willis
Agency for Toxic Substances and Disease
Registry
Executive Park, Building 33
1600 Clifton Road, E-56
Atlanta, GA 30333
Phone: (404) 639-6068
Fax: (404) 639-6075
Bill Wilson
U.S. EPA Region IX
Waste Minimization Coordinator
Hazardous Waste Management Division
Mail Stop H1W
75 Hawthorne Street
San Francisco, CA 94105
Phone: (415)744-2153
Fax: (415) 744-1044
Tyler J. Wilson
U.S. Chamber of Commerce
1615 H Street, NW
Washington, DC 20062
Phone: (202)463-5500
Henry Winders
Continental Cement
Highway 79 South
Hannibal, MO 63401
Phone: (314)221-1740
Fax: (314) 221-1689
Mark Woodall
Sierra Club
P.O. Box 185
Woodland, GA 31836
Phone: (706) 846-3838 (H)
Fax: (706) 846-2281 (W)
Martin S. Wright
Food and Drug Administration, CFSAN
200 C Street, SW
Washington, DC 20204
Phone: (202)205-4281
Gerald Wrye
Eastman Chemical
Environmental Affairs
P.O. Box 1993 (FANB4)
Kingsport, TN 37760
Phone: (615) 229-2834
Fax: (615) 229-4864, 3966
Stephen Yee
U.S. EPA Region I
JFK Federal Building
One Congress Street
Boston, MA 02203
Phone: (617)573-9644
Vic Young
Waste Reduction Resource Center
EPA Region IV
3825 Barrett Drive
Raleigh, NC 27609
Phone: (800)476-8686
15
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Marie Zanowick
U.S. EPA Region VIII
999 18th Street
Denver, CO 80202
Phone: (303)294-1065
Fax: (303) 293-1724
Ken Zarker
TX Natural Resource Conservation
Commission
William J. Ziegler
Thermalkem, Inc.
454 S. Anderson Road, ETC 532
Rock Hill, SC 29730
Phone: (803)329-9690
Fax: (803) 329-5830
16
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APPENDIX E
LIST OF OBSERVERS
17
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LIST OF OBSERVERS
Clayton D. Allen
Dow Chemical Company
2020 Dow Center
Midland, MI 48674
Phone: (517)636-0529
Fax: (517) 638-9621
Harvey Alter
U.S. Chamber of Commerce
Phone: (202)463-5531
Robin Anderson
U.S. EPA
T. J. Appleman
Radian Corporation
2455 Horsepen Road, Suite 250
Herndon, VA 22071
Phone: (703)713-1500
Fax: (703) 713-1512
Tom Appleman
Radian Corporation
2455 Horsepen Road
Herndon, VA 22071
Phone: (703)713-1500
Dr. Sharla Barber
Westinghouse-APTUS
11600N. AptusRd.
Aragonite, UT 84029
Phone: (801)531-4200
Fax: (801) 531-4394
Jesse Baskir
Research Triangle Institute
Center for Environmental Analysis
Hobbs Building
P.O. Box 12194
Research Triangle Park, NC 27709-2194
Phone: (919)541-5882
Fax: (919) 541-7155
Frank Behan
U.S. EPA - Office of Solid Waste
2800 Crystal Drive
Arlington, VA 22202
Phone: (703)308-8476
Jim Bell
AETC
Gold Mine Road
Flanders, NJ 07836
Phone: (201)347-7111
Fax: (201) 691-7343
Eugene Berman
Molten Metal Technology
51 Sawyer Road
Waltham, MA 02154
Phone: (617)487-7622
Fax: (617) 487-7870
Betty Black
209 S. 4th Street
Lewisburg, PA 17837
Thomas R. Blank
Hager Sharp, Inc.
1090 Vermont Avenue, NW, 3rd Floor
Washington, DC 20005
Phone: (202) 842-3600
Fax: (202) 842-4032
Mike Bonaventure
Ethyl Corporation
451 Florida Boulevard
Baton Rouge, LA 70810
Phone: (504)388-7740
James M. Bonk
Lafarge Corporation
11130 Sunrise Valley Drive, Suite 380
Reston, VA 22090
Phone: (703)264-3664
Fax: (703) 264-0632
18
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Larry Bross
American Cyanamid
Incinerator Op.
3125 Rendlen
Hannibal, MO 63401
Cyndy Bryck
Chemical Manufacturers Association
2501 M Street, NW
Washington, DC 20037
Ron V. Bumpers
Eastman Chemical Company
P.O. Box 3283
Kingsport, TN 37662
Phone: (615)299-2256
Barbara Bush
American Petroleum Institute
1220 L Street, NW
Washington, DC 20005
Phone: (202)682-8235
Fax: (202) 682-8031
Kerry Callahan
Association of State and Territorial Solid
Waste Management Officials
444 N. Capitol Street, NW, Suite 388
Washington, DC 20001
Phone: (202) 624-5828
Fax: (202) 624-7875
Craig Campbell
Cement Kiln Recycling Coalition
1212 New York Avenue, NW, Suite 500
Washington, DC 20005
Phone: (202)789-1945
Fax: (202) 408-9392
Elizabeth W. Cannon
Environmental and Governmental
Relations Consultant
11402 Fairway Drive
Reston, VA 22090
Phone: (703) 709-4137
Fax: (703) 709-2287
Robert E. Cassell, Jr.
Eastman Chemical Company
Tennessee Eastman Division
P.O. Box 1993
Kingsport, TN 37662-5393
Phone: (615)229-5312
Fax: (615) 224-7213
Dorothy A. Cauter, Ph.D.
U.S. EPA - Office of Solid Waste and
Emergency Response
Mail Code 5101
401 M Street, SW
Washington, DC 20460
Phone: (202)260-3100
Emily Chow
U.S. EPA - Office of Waste Programs
Enforcement
RCRA Enforcement Division
401 M Street, SW
Washington, DC 20460
Scot D. Cidzik
Eastman Kodak Company
Rochester, NY 14652-3615
Phone: (716)477-5584
Fax: (716) 722-3695
Mary Clark
Olin Corporation
P.O. Box 248
Charleston, TN 37310
Phone: (615)336-4579
Fax: (615) 336-4505
Raoul Clarke
Department of Environmental Protection,
Hazardous Waste Management Section
2600 Blair Stone Road
Tallahassee, PL 32399-2400
Phone: (904)488-0300
Fax: (904) 922-4939
19
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David W. Coy, P.E.
Research Triangle Institute
Center for Environmental Analysis
P.O. Box 12194
Research Triangle Park, NC 27709-2194
Phone: (919)541-6940
Fax: (919) 541-5945
Rhonda Craig
U.S. EPA
2800 Crystal Drive
Arlington, VA 22202
Phone: (703)308-8771
Gordon Davidson, President
Capital Environmental
1299 Pennsylvania Avenue, NW
Washington, DC 20004
Phone: (202)238-7446
Fax: (202) 383-6610
John Day
Rollins Environmental Services
1 Rollins Plaza
Wilmington, DE 19899
Phone: (302)426-3166
Fax: (302) 426-3553
John C. de Ruyter
DuPont Energy Engineering
P.O. Box 6090
Newark, DE 19714-6090
Phone: (302)366-6442
Fax: (302) 366-6205
Hiroshi A. Dodohara
U.S. EPA - OPPT
Mail Code 7404
401 M Street, SW
Washington, DC 20460
Phone: (202)260-3959
John Dombrowski
U.S. EPA - Office of Waste Programs
Enforcement
RCRA Enforcement Division
401 M Street, SW
Washington, DC 20460
Phone: (202)260-7834
Fax: (202) 260-4100
C.A. "Bud" Douthitt
The MILSOLV Companies
Box 444
Butler, WI 53007
Phone: (414)252-3550
Fax: (414) 252-3961
R.H. Dreith
Shell Oil Company
One Shell Plaza
P.O. Box 4320
Houston, TX 77510
Roderick T. Dwyer
American Mining Congress
1920 N Street, NW, Suite 300
Washington, DC 20036
Phone: (202) 861-7530
Bill Eby
Ethyl Corporation
451 Florida Street
Baton Rouge, LA 70801
Phone: (504)388-7251
Sherry L. Edwards
SOCMA
1330 Connecticut Avenue, NW, Suite 300
Washington, DC 20036
Phone: (202) 822-6760
Fax: (202) 659-1699
Eli Eilbott
Hazardous Waste Treatment Council
915 15th Street, NW, Fifth Floor
Washington, DC 20005
Phone: (202)783-0870
20
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Fax: (202) 737-2038
Scott Elinger
U.S. EPA - Office of Solid Waste
Scott Ellis
Cadence Environmental Energy Inc.
Cadence Park Plaza
Michigan City, IN 46360
Phone: (219) 873-3113
Steve Fan
USPCI
8960 N. Hwy 40
Lake Point, UT 84074
Phone: (801)252-2045
Fax: (801) 252-2075
Jim Fain
Anistech Chemical Corporation
Sandra Farrell
U.S. EPA
John P. Fillo
ENSR Consulting & Engineering
1001 Liberty Avenue, 9th Floor
Pittsburgh, PA 15222
Phone: (412)261-2910
Fax: (412) 765-1421
John D. Fognani
Gibson, Dunn & Crutcher
1801 California Street, Suite 4200
Denver, CO 80202-2694
Phone: (303)298-5737
Fax: (303) 296-5310
Steven Fotis
Van Ness, Feldman, and Curtis
1050 Thomas Jefferson St., NW, 7th Floor
Washington, DC 20007
Phone: (202)298-1800
Fax: (202) 338-2416
Brent Fryrear
National Paint & Coatings Association
Courtaulds Coatings Inc.
400 S. 13th Street
Louisville, KY 40203
Phone: (502)588-9792
Fax: (502) 588-9371
Mike Fusco
Rollins Environmental Services
1 Rollins Plaza
Wilmington, DE 19899
Phone: (302)426-3948
Fax: (302) 426-3553
Mike Fusco
Rollins Environmental
Curt Gardner
American Cyanamid
P.O. Box 817
Hannibal, MO 63401
Phone: (314)769-2011
Tony Germinario
American Cyanamid Company
One Cyanamid Plaza
Wayne, NJ 07470
Phone: (201) 831-4968
Paul Gorman
Midwest Research Institute
425 Volker Boulevard
Kansas City, MO 64110
Phone: (816) 753-7600
Gary C. Grover
Elf Atochem North America, Inc.
900 First Avenue, P.O. Box 1536
King of Prussia, PA 19406-0018
Phone: (215) 337-6893
Fax: (215) 337-6670
21
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David L. Gustafson
DPRA
E-1500 First National Bank Building
St. Paul, MN 55101
Phone: (612)227-6500
Fax: (612) 227-5522
Heidi Halik
Sierra Club
408 C Street, NE
Washington, DC 20002
Phone: (202)675-6274
Martin Hall
Concord Resources Group
5990 Richmond Hwy. #111
Alexandria, VA 22303
Phone: (703)329-9644
Fax: (703) 329-9645
Edward F. Harrington
Westvaco, Chemical Division
P.O. Box 836
DeRidder, LA 70634-0836
Phone: (318)462-4222
Fax: (318) 462-2441
Lisa Harris
U.S. EPA - OPPT
401 M Street, SW
Washington, DC 20460
Floyd Hasselras
American Society of Mechanical Engineers
Karen Henty
Karch and Associates, Inc.
Phone: (202)463-0400
Jeff Hooker
Eastman Chemical Co.
P.O. Box 511 B-248
Kingsport, TN 37662
Samantha Hopkins
U.S. EPA, Office of Water
Mail Code 4303
401 M Street, SW
Washington, DC 20460
Phone: (202)260-7149
Norris Johnson
Lone Star Industries
2524 South Sprigg Street
Cape Girardeau, MO 63701
Phone: (314)335-5591
Fax: (314) 334-3522
Davis Jones
U.S. EPA - Office of Waste Programs
Enforcement
401 M Street, SW
Mail Code 5503
Washington, DC 20460
Phone: (202)260-5033
Fax: (202) 260-4100
Randall A. Jones, PE
Molten Metal Technology, Inc.
51 Sawyer Road
Waltham, MA 02154
Phone: (617)487-7614
Fax: (617) 487-7870
Leida Vasquez-Jorge
Merck & Company, Inc.
1 Merck Drive
Whitehouse Station, NJ
Phone: (202)302-7811
Fax: (302) 302-0050
Ron Joseph son
U.S. EPA
401 M Street, SW
Washington, DC 20460
Phone: (202)260-6715
22
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Melvin Keener
Laidlaw
655 15th Street, NW (#300)
Washington, DC 20005
Phone: (202)639-4130
Fax: (202) 347-6109
Becky Keogh
CH2M Hill
523 S. Louisiana, Suite 203
Little Rock, AR 72201
Phone: (501)372-6060
Richard Kinch
U.S. EPA
2800 Crystal Drive
Arlington, VA 22202
Phone: (703)308-8434
Rebecca King
U.S. Chamber of Commerce
1615 H Street, NW
Washington, DC 20062
Phone: (202) 463-5495
Jim Knepper
Miles
Stephen Kroner
U.S. EPA
Mail Code 5304
401 M Street, SW
Washington, DC 20460
Phone: (202) 260-5219
Fax: (202) 260-0225
Leon Kuchinski
Pennsylvania Department of Environmental
Resources
Division of Hazardous Waste Management
P.O. Box 8472
Harrisburg, PA 17105-8472
Phone: (717) 787-6239
Fax: (717) 787-0884
Marianne Lamont
RCRA Policy Forum
1701 Pennsylvania Avenue, NW
Washington, DC 20006
Phone: (202) 879-2693
Fax: (202) 879-2697
Steve Lanier
EER Council Corporation
Joe LaSala
USPCI
515 West Green Rd. #500
Houston, TX 77607
Phone: (713) 775-7835
Fax: (713) 775-7910
Diane M. Leber
Ciba-Geigy Corporation
444 Saw Mill River Road
Ardsley, NY 10502
Phone: (914)479-2159
Fax: (914) 479-2332
Guy Leeds
American Cyanamid
3404 S. 36th
Quincy, IL 62301
Kara Levin son
Halliburton NUS Corporation - EPC
910 Clopper Road
Gaithersburg, MD 20878
Phone: (301)258-8650
Fax: (301) 258-2568
Dave Levy
U.S. EPA, Office of Solid Waste
Waste Management Division
2800 Crystal Drive
Arlington, VA 22802
Phone: (703) 308-8479
23
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Martha Lindover
Cement Kiln Recycling Coalition
1212 New York Avenue, NW, Suite 500
Washington, DC 20005
Phone: (202)789-1945
Fax: (202) 408-9392
Richard L. Lobb
Waste Minimization and Combustion
Coalition
1301 Connecticut Avenue, NW
Washington, DC 20036
Phone: (202) 828-8833
Chris Logein
Westinghouse/Hazardous Waste Treatment
Council
750 Holiday Drive
Foster Plaza
Pittsburg, PA 15228
Phone: (412)973-4161
Laura Lopez
U.S. EPA
2800 Crystal Drive
Arlington, VA 22202
Phone: (703)308-8482
Jim Lund
U.S. EPA - Office of Water
401 M Street, SW, Mail Code 4301
Washington, DC 20460
Phone: (202)260-7811
Fax: (202) 260-5394
Michelle Lusk
Cement Kiln Recycling Coalition
1212 New York Avenue, NW, Suite 500
Washington, DC 20005
Phone: (202)789-1945
Fax: (202) 408-9392
William H. MacNair, Jr.
Air Products and Chemicals, Inc.
7201 Hamilton Boulevard
Allentown, PA 18195-1501
Phone: (215)481-5967
Fax: (215) 481-8051
Jim Mahony
JWR Associates
5103 Moorland Lane
Bethesda, MD 20814
Phone: (301)652-3239
Michael Marlow
Laidlaw
P.O. Box 210799
Columbia, SC 29221
Phone: (803)798-2993
Fax: (803) 551-4202
Bob Martin
U.S. EPA - OSWER
401 M Street, SW
Washington, DC 20460
Phone: (202)260-9361
Frank McAlister
U.S. EPA
2800 Crystal Drive
Arlington, VA 22202
Phone: (703)308-8196
Alexander McBride
U.S. EPA
Soonya W. McDavid
National Paint & Coatings Association
1500 Rhode Island Avenue, NW
Washington, DC 20005-5597
Phone: (202)462-6272
Fax: (202)462-8549
Karen Medlin
American Trucking Association
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Ray L. Mendelsohn
Louviers Building
P.O. Box 6090
Newark, DE 19787-6090
Jim Michael
U.S. EPA, Office of Solid Waste
Assistance Branch
Mail Code 5303W
2800 Crystal Drive
Arlington, VA 20202
Larry A. Miller, P.E.
Eastman Chemical Company
Tennessee Eastman Division
P.O. Box 511
Kingsport, TN 37662
Phone: (615)229-5590
Fax: (615) 224-0172
Roger Miller
Pesticide and Toxic Chemical News
Ian Moar
Coalition for Responsible Waste
Incineration
Lee Moraglio
Van Ness, Feldman, and Curtis
1050 Thomas Jefferson St., NW, 7th Floor
Washington, DC 20007
Phone: (202)298-1800
Fax: (202) 338-2416
Lisa Mullings
National Association of Chemical
Recyclers
1200 G Street, NW, Suite 800
Washington, DC 20005
Phone: (202)434-8740
Celeste Murphy
U.S. EPA
John F. "Jack" Murray
Thermal Fluids Council
1330 Connecticut Avenue, NW, Suite 300
Washington, DC 20036-1791
Phone: (202) 822-6757
Fax: (202) 659-1699
Darla W. Neeley
EG&G Idaho, Inc.
P.O. Box 1625
Idaho Falls, ID 83415
Phone: (208)526-4859
James A. Newburn
Thermatrix Inc.
3590 N. First Street, Suite 310
San Jose, CA 95134
Phone: (408)944-0220
Fax: (408) 944-0292
Lori Nudo
Stevens Publishing
1170 National Press Building
Washington, DC
Albert E. Nugent
Midwest Research Institute
409 12th Street, SW, Suite 710
Washington, DC 20024
Phone: (202)554-3844
Fax: (202) 484-1096
Sean O'Holleran
USPCI-Union Pacific
555 13th Street, NW, #450W
Washington, DC 20004
Phone: (202) 662-0160
Fax: (202) 662-0199
Don Oberauker
U.S. EPA
Les Otte
U.S. EPA, Office of Solid Waste
2800 Crystal Drive
Arlington, VA 22202
Phone: (703)308-8480
25
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Diana Pape
ICF
9300 Lee Highway
Fairfax, VA 22031
Nick Paugaro
ENSR Consulting and Engineering
Phone: (508)635-9500
Stephen K. Pavel
Consultant
Nine Greenway Plaza, Coastal Tower
Houston, TX 77046-0995
Phone: (713) 877-3377
Fax: (713) 877-3874
Gary Perket
Environmental Information/ET Digest
4801 West 81st Street 119
Minneapolis, MN 55939
Phone: (612) 831-2473
Fax: (612) 831-6550
John Perrin
American Cyanamid
Pat Pescacreta
U.S. EPA
2800 Crystal Drive
Arlington, VA 22202
Phone: (703)308-8605
C.L. Pettit
Institute of Chemical Waste Management
1730 Rhode Island Avenue, NW, Suite
1000
Washington, DC 20036
Phone: (202)659-4613
George T. Phillips
Sipi Metals Corp.
1720 Elston Avenue
Chicago, IL 60622
Phone: (312)276-0070
Fax: (312) 276-7014
Terrance Pierson, Ph.D.
Research Triangle Institute
P.O. Box 12194
Research Triangle Park, NC 27709-2194
Phone: (919)541-7406
Fax: (919) 541-5945
John P. Pilney
3M Chemolite Center
Building 47
P.O. Box 33131
St. Paul, MN 55133-3131
Phone: (612)458-2039
Fax: (612) 458-2017
Robley F. Piper
RR2 Box 227A
Hannibal, MO 63401
Dr. Suellen Pirages
Karch and Associates, Inc.
1701 KSt.,NW, Suite 1000
Washington, DC 20006
Amy Porter
BNA - Daily Environmental Report
1231 25th Street, NW
Washington, DC 20037
Phone: (202)452-4106
Jan Power
OHM Corporation
305 Whispering Oaks Lane
Davidsonville, MD 21035
Phone: (301)261-7074
Fax: (301) 261-7074
Brenda Pulley
Cement Kiln Recycling Coalition
1212 New York Avenue, NW, Suite 500
Washington, DC 20005
Phone: (202)789-1945
Fax: (202) 408-9392
Terry F. Quill
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Beveridge & Diamond
1350 I Street, NW, Suite 700
Washington, DC 20005
Phone: (202) 789-6061
Fax: (202)789-6190
Anne Randolph
EPA - OROSLR
WSM
West Tower 326, Mail Code 1502
401 M Street, SW
Washington, DC 20460
Karen Randolph
U.S. EPA
2800 Crystal Drive
Arlington, VA 22202
Phone: (703)308-8651
Scott Rarenzahn
U.S. EPA
2800 Crystal Drive
Arlington, VA 22202
Steve Roebuck
ALCOA
Patricia Rooney
Newan and Holtzinger
Jeffrey L. Roop
Tennessee Eastman Company
Power and Services Division
P.O. Box 511
Kingsport, TN 37662
Phone: (615)229-6945
Larry Rosengrost
U.S. EPA
Anne Rowland
U.S. EPA Region VII
Office of Regional Counsel
726 Minnesota
Kansas City, KN 66101
Mark Thomas Schaefer
BDM International, Inc.
12850 Middlebrook Road, Suite 300
Germantown, MD 20874
Phone: (301)601-1383
Fax: (301) 601-1396
Nellina Scheuer
CH2M Hill
625 Herndon Parkway
Herndon, VA 22070
Martina B. Schlauch
Association of American Railroads
Environmental and Hazardous Materials
Research Division
50 F Street, NW
Washington, DC 20001
Phone: (202)639-3280
Fax: (202) 639-2285
David B. Schnelzer
Miles Inc.
Mobay Road
Pittsburgh, PA 15205-9741
Phone: (412)777-2431
Fax: (412) 777-3063
Tracey E. Schreft
Fleishman-Hillard, Inc.
1301 Connecticut Avenue, NW
Washington, DC 20036
Phone: (202) 659-0330
Fax: (202)296-6119
Colleen Schu
Inside EPA
1225 Jefferson David Highway, Suite 1400
Arlington, VA 22202
Phone: (703) 892-8518
Herbert Schumaun
STEAG
1050 Thomas Jefferson St., NW, Suite
700
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&ERA
United States
Environmental Protection Agency
(5305)
Washington, DC 20460
Official Business
Penalty for Private Use
$300
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