United States
Environmental Protection
Agency
Solid Waste and
Emergency Response
(5305)
EPA530-R-94-044
November 1994
a EPA
Strategy for Hazardous
Waste Minimization and
Combustion
Recycled/Recyclable
Printed with Soy/Canola Ink on paperthat
contains et least 50% recycled fiber
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STRATEGY FOR HAZARDOUS WASTE MINIMIZATION
AND COMBUSTION
I.
INTRODUCTION
The Environmental Protection Agency (EPA) is today
announcing its final Strategy for Hazardous Waste Minimization
and Combustion. The Strategy represents a major milestone in
the Agency's ongoing commitment to determine, in the context of
the Resource Conservation and Recovery Act (RCRA), how best to
integrate source reduction and environmentally sound recycling
into the national hazardous waste management program, and how
best to assure the public of safe operation of hazardous waste
combustion facilities. The Strategy is the culmination of 18
months of intensive effort by EPA and other interested parties
under the Draft Strategy on Hazardous Waste Minimization and
Combustion, announced by Administrator Carol M. Browner on Mav
18, 1993. *
^ The Strategy sets forth EPA's fundamental goals and basic
vision with respect to several key areas. First, the Strategy,
in combination with the Hazardous Waste Minimization National
Plan ; also being released today, discusses the role of waste
minimization in the RCRA hazardous waste management program.
Second, the Strategy addresses the role of combustion over the
next 5-10 years. In addition, public involvement in the RCRA
decision-making process, the need for strong compliance and
enforcement, and the role of risk assessment are addressed.
The Strategy also outlines a series of actions (many already
under way pursuant to the Draft Strategy) to foster a broader
range of waste management options that are safe, effective, and
available. The Hazardous Waste Minimization National Plan sets
forth a complementary set of actions, which can and will be
applied to this Strategy, to achieve significant gains in source
reduction and environmentally sound recycling — the two
components of RCRA waste minimization.
II. EPA'S STRATEGIC GOALS
The backbone of EPA's Strategy are eight goals. These goals
address the areas initially covered in the Draft Strategy, as
amplified by the many discussions that have taken place since its
release. These goals provide the policy framework for EPA's
future actions and for reaching the best possible solutions to
This document is a statement of Agency policy and does not constitute a rule. It is not intended, nor
can it be relied upon, to create any rights enforceable by any party in litigation with the United
States.
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the issues that have arisen and will undoubtedly continue to
arise concerning the management of hazardous waste in the United
States. The goals presented below are not in any order of
priority; they are all equally important.
• Public Outreach and EPA-State Coordination: Continue to
facilitate an open and broad national dialogue among all
stakeholders on significant hazardous waste issues. Give
top priority to working with states as co-regulators of
hazardous waste.
• Waste Minimization: Under the Hazardous Waste
Minimization National Plan, reinforce strong preference for
source reduction over hazardous waste management in order to
reduce both the long-term demand for treatment, storage, and
disposal capacity and the quantities of persistent,
bioaccumulative, and toxic constituents that need to be
managed. In partnership with states, industry, and local
communities, pursue aggressive use of waste minimization
measures with primary emphasis on voluntary actions. Afford
members of the public a greater opportunity to become aware
of waste minimization activities in their communities.
• Role of Combustion and Alternative Technologies: Maintain
appropriate role for combustion, and continue to ensure that
combustion and other treatment facilities reduce toxicity,
volume, and/or mobility of hazardous wastes in a manner that
is protective of public health. Foster the commercial
development and use of alternative treatment and other
innovative technologies that are safe and effective in
reducing the toxicity, volume, and/or mobility of RCRA
industrial process and remediation wastes.
• Emission Standards and Controls: Develop and impose more
rigorous controls on combustion facilities based on an
assessment of available technologies and current science.
Develop these controls as a coordinated effort to implement
both RCRA and the Clean Air Act authorities for hazardous
waste combustion facilities. Ensure that hazardous waste
combustion facilities do not pose an unacceptable risk to
human health or the environment.
• Enforcement and Compliance Assistance: Continue aggressive
compliance and enforcement efforts against hazardous-waste
burning incinerators and boilers and industrial furnaces
(BIFs) while working with industry to ensure that EPA's
regulations are understood and followed. Enhance public
confidence in Agency oversight activities and facility
compliance by promoting public understanding of these
activities and increased opportunities for public
involvement in the enforcement process.
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Public Involvement in Permit Process: Enhance public
involvement opportunities in the process for considering
permit applications for combustion facilities-,. Take
; appropriate actions to ensure that local communities are
: fully informed about the RCRA decision-making process
(including waste minimization opportunities) and have an
: opportunity to participate in that process.
,Facility Permitting Priority: Give higher priority to
;those facilities for which a final permit decision would
result in the greatest environmental benefit or the greatest
reduction in overall risk to the public. Give lower
priority to permit decisions on new combustion facilities
|that are not replacing older facilities.
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Risk Assessment: Advance scientific understanding on
icombustion issues and risk assessment, and ensure that
ipermits are issued at facilities in a manner that protects
against unacceptable risks to human health and the
.environment. Use sound science in technical decision-
making.
111 * ; PROGRESS TOWARDS STRATEGIC GOALS OVER LAST 18
A. Draft strategy on Hazardous Waste Minimisation and
Combustion
(May 1993)
;EPA's May 1993 Draft Strategy announced an initial set of
goals and launched a series of steps to maximize reduction of the
amount of hazardous waste generated and to ensure safety and
reliability of hazardous waste combustion in incinerators
boilers, and industrial furnaces. The Draft strategy enabled EPA
to take a leadership role in the broad national dialogue on how
balanced resolution of difficult and controversial waste
The Draft Strategy also served as the focal point for all
interested parties to take a fresh look at how to achieve a fully
integrated waste management program ~ one that has the proper
emphasis on source reduction and recycling and that defines the
appropriate role for hazardous waste combustion. Compliance and
enforcement at incinerators and BIFs also received much attention
during the broad national dialogue, with particular emphasis on
this subject by citizens from local communities in which
hazardous waste facilities are located.
While the Draft Strategy specifically addressed only RCRA-
regulated hazardous wastes, its approaches and principles have
been incorporated in policies covering other areas under EPA's
purview. For example, EPA developed a Superfund policy that
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among other things, adopts public participation and risk
assessment features of the Draft Strategy.
For a detailed summary of significant actions and
accomplishments under the Draft Strategy since May 1993, see
Appendix A.
B. Public Dialogue Following Draft Strategy
Over the past 18 months, members of the public (especially
citizens from the local communities in which hazardous waste
facilities are located), industry, public interest groups, and
state officials have played an essential role in the broad
national dialogue on hazardous waste generation and management.
This dialogue occurred at a 4-day National Roundtable on waste
minimization and combustion held in Washington, D.C. in November
1993, at four Regional Roundtables held in April-May 1994 in San
Francisco, Houston, Chicago, and Atlanta, as well at in the
hundreds of informal meetings with individuals or stakeholder
groups. Summaries of the discussions at the National and
Regional Roundtables have been prepared and made available to the
public upon request through the RCRA Hotline.
These wide-ranging but sharply focused discussions have
provided significant input on many key issues. These issues have
included the need for increased waste minimization, EPA's
approach for upgrading regulatory controls on combustion units,
the desire for flexible means to enhance public participation in
permitting and to address environmental justice concerns, and the
importance of aggressive, credible compliance and enforcement at
combustion facilities.
This public dialogue has made it clear that EPA and other
stakeholders share two fundamental goals: (1) to foster the
maximum amount of source reduction and environmentally sound
recycling for all wastes (not just combustible waste); and (2) to
ensure that any waste management practices, including combustion,
are done in a manner that is protective of human health and the
environment. In that regard, a group of proactive companies and
organizations have come forward voluntarily and worked with the
Agency to meet the objectives of the Draft Strategy even without
regulatory or other mandatory requirements. These voluntary
initiatives, which have the potential for leading to significant
environmental actions, are discussed in Appendix B.
This dialogue has also illustrated that not everything is
known at this time about waste minimization and combustion to the
level of detail that the Agency and the public would wish. As a
result, the best solutions to some issues may not have yet
emerged. Where there still remain unanswered questions, the
Strategy outlines steps to develop the needed information.
During this time, the Strategy and actions under its umbrella
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will provide protection of public health and the environment.
IV. RCRA PROGRAM EVOLUTION AND CURRENT SETTING
A. RCRA Program Evolution
, The RCRA program and hazardous waste management practices
have evolved together in several stages. Before 1980, hazardous
wastes were virtually uncontrolled. Anecdotal information on
prevalent practices suggests that landfilling, deep well
injection, surface impoundments, and incineration were major
avenues of management. From 1980-84, the RCRA regulatory
framework was put into place, and set design and operating
standards for these and other types of waste management
practices. However, the Hazardous and Solid Waste Amendments of
1984! (HSWA) singled out land disposal practices for special
attention and significant restrictions. Free liquids could no
longer be put into landfills, disposal in unlined and unmonitored
landlfills and surface impoundments began to be phased out, and
meeting Best Demonstrated Available Technology (BDAT) treatment
standards prior to land disposal was mandated. Further, under
the Loss of Interim Status or "LOIS" provisions of HSWA,
hazardous waste landfills and surface impoundments; had to file
permit applications within specified time periods and also had to
certify compliance with RCRA groundwater monitoring and financial
responsibility standards in order to remain in ope.ration.
As land disposal BDAT treatment standards were promulgated
through the late 1980's, many were based on levels achievable by
combustion technologies. Management of hazardous waste via
incinerators and BIFs increased, particularly with respect to
orga'nic-bearing waste streams. At the same time, the universe of
incinerators shrunk from 1987-1991 from about 305 facilities to
about 192 facilities (due mainly to permit denials and facilities
that voluntarily closed rather than meet RCRA standards). In
addition, generators were pursuing source reduction and
recycling, at least in part due to rising treatment and disposal
costs and to long-term Super fund liability for waste generators.
These all combined to accelerate the emphasis on source reduction
and recycling as well as the use of combustion.
In the late 1980's and early 1990's, combustion capacity
significantly exceeded demand, primarily for liquids. Prices for
burning waste dropped substantially (e.g., between 1991-1993, the
price for solids incineration went from about $1225 per ton to
about $900 per ton). Furthermore, waste volumes dropped in
response to waste minimization efforts. Companies consolidated,
and emphasis on affording customer-oriented services and
technologies began to move to the forefront as significant
characteristics of waste management companies. At the same time,
questions about the risks from combustion began to surface with
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greater frequency. The indirect risk pathway (e.g., exposure via
the food chain) was recognized as a particularly important aspect
of assessing the safety of combustion facilities.
B. Current Setting
As discussed in greater detail in Appendix C, there
currently exist 162 permitted or interim status incinerators (28
commercial) and 136 interim status BIFs (38 commercial). An
additional 26 incinerators (5 commercial) and 3 BIFs are proposed
and have applications on file for hazardous waste permits.
Since the Draft Strategy was announced, the universe of
existing and planned facilities has been somewhat dynamic. For
example, 9 commercial incinerators and BIFs have cancelled plans
to burn hazardous waste, but 9 new applications were submitted (2
for commercial units). Three permits were denied by EPA and/or
the states (National Cement in California (on appeal), Marine
Shale Processors in Louisiana (on appeal), and Maybelline
Products in Arkansas) while one permit was issued by Texas
(American Envirotech). Over the coming years, EPA anticipates
that the number of final permit determinations made annually will
be around 20 (but perhaps up to 40) per year. This projection is
based, in part, on EPA's view that the pace of permit decisions
will increase as the EPA regional staff and state personnel gain
more experience and familiarity with the comprehensive risk
assessment procedures introduced over the past year.
EPA estimates that the current universe of 298 permitted
and interim status combustion facilities represent a potential
capacity to burn over 4.8 million tons of waste annually. At the
present time, this represents about 1.2-1.4 million tons of
excess capacity over demand. Most of this excess capacity is for
liquid hazardous waste, perhaps as much as 1.1 million tons.
However, it is important to note that even though excess capacity
may exist on an aggregate national basis, capacity can be limited
in certain regions of the country or for certain types of waste.
For example, due to unusual physical form or particular
constituents, wastes that are explosive or mixed radioactive
waste may require specialized forms of combustion or other
treatment that are not widely available.
In terms of future capacity, the hazardous waste treatment
and disposal market has generally responded in a fashion that has
assured adequate available combustion capacity. The Agency has
found no reason thus far to believe that this will not continue,
even with respect to increased volumes of remediation waste,
which can be generated in substantial amounts over relatively
short time periods with less advance knowledge than most
industrial process wastes.
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V. DEVELOPMENT OF FINAL STRATEGY
A. Role of Waste Minimization
I 1. EPA's Hazardous Waste Minimization National Plan
As discussed in the Draft Strategy, EPA and interested
parties have spent much of the past 18 months examining ways to
best integrate waste minimization into the hazardous waste
management program under RCRA. The dialogue has been fruitful in
many ways, and has served to reinforce the pre-eminence of source
reduction and environmentally sound recycling in the RCRA
hierarchy for hazardous waste. The result of this dialogue has
been development of the final Hazardous Waste Minimization
National Plan, which is also being released today.
EPA's waste minimization approach is presented in detail in
the National Plan. The National Plan has been subject to public
evaluation and debate since its release in draft form in May
1994, This Plan, which will be implemented in concert with the
Strategy, creates the framework for the waste minimization
activities under RCRA and will guide the Agency's efforts to
integrate waste minimization into the other facets of our
national waste management program. Key components of the Plan
include establishment of national goals and priorities for source
reduction and recycling, identification and evaluation of source
reduction and recycling opportunities, mechanisms to achieve the
national goals and measure progress, and implementation steps.
The National Plan indicates that EPA will promote source
reduction and environmentally sound recycling for the waste
constituents that present the greatest potential hazard to human
health and the environment. Efforts to evaluate potential hazard
will continue to center around an analysis of the persistence
toxicity, bioaccumulation, and mass of hazardous constituents in
waste streams. However, within this overall context, EPA will
give an initial implementation priority to actions leading to
removal of high hazard metal constituents from wastes destined
for combustion. This comports with the views expressed by many
parties involved in waste minimization discussions that metals in
combustible waste streams were appropriate toxic and persistent
compounds to focus upon at the outset.
;other noteworthy aspects of EPA's National Plan include:
o 'EPA establishes goals and time frames for waste minimization
iprogress on a national basis. We set as a goal the
reduction of the most persistent, bioaccumulative, and toxic
constituents in hazardous waste by 25% nationally by the
year 2000, and by 50% nationally by the year 2005.
Generators will have the flexibility to set facility-
specific goals and to track their own progress in a manner
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that contributes to the overall national goals.
o The National Plan will be implemented through a mix of
voluntary and regulatory measures to achieve the maximum
amount of source reduction and recycling of the targeted
waste streams containing these constituents, with a clear
emphasis on the voluntary measures during initial
implementation. However, EPA will use the year 2000 as a
benchmark to evaluate whether more aggressive measures are
warranted.
o The National Plan emphasizes the importance of keeping the
public informed and involved. To that end, EPA is including
in its 1991 Biennial Report a list by geographic location of
large quantity generators that were required to certify in
1991 that they had a waste minimization program in place.
This will empower citizens with sufficient information to
determine which facilities are in their vicinity and to
begin the dialogue with, those companies about waste
minimization.
o Measuring success in the waste minimization area raises a
number of difficult questions, such as what data are
necessary, what baseline to use, and how to account for
significant external influences. The National Plan lays out
a flexible process by which the progress on waste
minimization is not delayed by debate over the single best
way to measure progress. Rather, the emphasis will shift to
making progress in an aggregate national manner and to
allowing flexibility for specific facilities to take into
account their unique circumstances within the overall
national picture.
2. Application of Waste Minimization National Plan to
Combusted Hazardous Wastes
Setting Priorities: As discussed above, one of the key
components of the National Plan is setting priorities. In the
Addendum to the National Plan, EPA applies a screening
methodology, based on the persistence, bioaccumulation, toxicity
and mass of constituents in hazardous waste and releases, as a
tool to help set our national priorities for source reduction and
environmentally sound recycling. Based on the screening
methodology, we identify metals in hazardous wastes managed by
combustion as well as metals in releases from combustion
facilities as EPA's initial national priority. This screening
tool is a prototype for a broader screening tool under
development that will address persistent, bioaccumulative and
toxic constituents in a broad spectrum of wastes and releases.
Results from applying the prototype will serve as a point of
departure for EPA Regions, States, and industry in establishing
their own priorities, in the context of this overall Strategy.
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Identification and Evaluation of Waste Minimization
Opportunities: Following the establishment of priorities for
source reduction and recycling as described above,, the next key
aspect of the National Plan is identification and evaluation of
opportunities for source reduction and environmentally sound
recycling. While most of the detailed analysis of technical and
economic feasibility of alternatives will be conducted at a plant
level by generators and/or technical assistance centers, EPA has
information related to feasibility of certain opportunities, at
least on a broad national level. The following discussion
focuses on several general types of waste streams that are being
combusted, and suggests areas that generators and others can
evaluate.
; EPA believes that the hazardous waste regulations enacted
since 1980 have, by themselves, created significant incentives
for waste minimization, due to their alteration of the economics
of waste management. Given this and also the current economic
influences acting upon hazardous waste generators, many of the
obvious waste minimization opportunities yielding short-term cost
savings, particularly for larger businesses, are likely being
investigated and implemented. However, other waste minimization
opportunities may not be sufficiently investigated or
implemented, particularly at smaller size businesses, due for
example to lack of access to information, lack of available
capital, and other factors.
: For hazardous wastes being combusted, there are likely to be
certain waste minimization opportunities which still may not have
been fully explored. Two such candidates are lean waters and
organic liquids. Both lean waters and organic liquids are among
the ;metal-containing waste streams addressed in the Addendum to
the Waste Minimization National Plan.
, Lean waters generally are aqueous liquids lightly
contaminated with organics. EPA's 1991 Biennial Reporting System
(BRS) data indicate that "aqueous wastes with low solvents," a
sublet of lean waters, constitute one relatively high volume
waste stream being managed through combustion. Examples of
potential source reduction alternatives for this waste stream
include switching from chlorinated solvents to mineral spirits or
water-based solvents, improved housekeeping, better inventory
control, and waste stream segregation. We do not know what
factors are influencing generators to send these lean waters to
combustion or how much source reduction is actually possible.
However, some evidence from Ohio supports the ideei that aqueous
wastes offer significant potential for source reduction.
Approximately one quarter of the source reduction reported to the
Ohio EPA for 1991 involved aqueous wastes with low solvent
concentrations. This will likely be an area of further
investigation during implementation of the Hazardous Waste
Minimization National Plan.
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Organic liquids contain higher concentrations of organics
than lean waters. Given that the 1991 BRS data suggest that over
300,000 tons of higher concentration organic liquids are being
managed, these liquids may also present opportunities for source
reduction or, if source reduction alternatives are not feasible,
for significant, environmentally sound recycling. It has been
pointed out to the Agency that a number of factors may influence
whether recycling of organic liquids (e.g., spent solvents) is
feasible. For example, some generators may be inhibited by
potential liability associated with off-site solvent recycling
practices that give rise to releases of hazardous substances.
They appear to believe that combustion offers them more security
from future liability. Another factor that may discourage on-
site recycling is the desire of generators to avoid the cost and
delay of associated permitting (which can take one to three
years). In many cases, the generator would rather send spent
solvent to an industrial boiler or furnace for combustion/energy
recovery. A third example is the situation in which the combined
cost of raw material purchase and waste handling was less for
virgin solvents than for recycled solvents. Under these market
and regulatory conditions, a company would be likely to use
virgin solvent in its production process, and send its used waste
solvent to an industrial boiler or furnace for combustion/energy
recovery.
Other opportunities for waste minimization may exist with
respect to hazardous wastes that are not routinely-generated
process wastes, such as residues from air pollution control
devices, residues from waste treatment systems, and still bottoms
from solvent recovery units. If identified as a high priority
for minimization based on hazard, these wastes would likely
require additional effort to assess the potential for source
reduction and/or recycling.
In assessing waste minimization opportunities over the next
5-10 years, it is also relevant to consider several potential
future trends affecting quantities and characteristics of wastes
going to combustion:
o Establishment of LDR treatment standards that have or may,
in the future, be based on levels achieved by combustion
(e.g., Phase II rule (just issued), the Phase III rule
(1996), the Phase IV rule on industrial surface impoundments
(1997-1998), new waste listings (1996-2005), and remediation
wastes). Very preliminary estimates are that new waste
listings could introduce approximately 100,000 to 400,000
tons of hazardous waste per year going to combustion.
Depending on the nature of these listings, industry may be
encouraged to investigate source reduction opportunities.
o More rigorous emissions standards for combustion units, now
scheduled for finalization in late 1996, may increase waste
management costs for generators, encourage further waste
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: minimization efforts, and ultimately reduce some of the
demand for combustion.
o , AS generators extend the period of use and reuse of organic
! and aqueous-based solvents to avoid treatment and disposal
costs, solvent wastes will have a higher solids content.
1 Still bottoms from solvent recovery may also have a higher
solids content as solvent recovery operations; are pushed to
; increase recovery rates.
i
o ; Some special waste streams (e.g., radioactive mixed waste,
waste explosives, and chemical munitions) may continue to
' warrant incineration and would not be expected to change in
character. However, sufficient capacity will be needed only
in particular times frames for certain of these wastes, for
; example, 10 years for chemical munitions due to treaty
limitations.
i These factors as well as many others (such as regulatory
barriers, capital availability, and technological innovation)
make! it difficult to predict the feasibility of future source
reduction and environmentally sound recycling opportunities for
wastes destined for combustion. The Hazardous Waste Minimization
National Plan provides an overall program framework for
identifying those opportunities as they arise and for providing
sufficient flexibility to use various mechanisms in pursuing
those opportunities.
B.
Role of Combustion and Potential Alternatives
i In assessing the respective roles of combustion and
potential alternatives, several key elements need to be
evaluated. These include: (1) ability to achieve permanent
reductions in waste volume, toxicity and/or mobility; (2) ability
to treat or manage organic fluids, solids, and sludges in a safe
manner; (3) timely availability of the technology for the amounts
of hazardous wastes being generated; and (4) risks; posed by
residuals from the process or from long-term management.
1 From a technical standpoint, combustion of hazardous waste
is a> single, stand-alone process that substantially and
permanently reduces the toxicity and volume of virtually all
organic-bearing waste streams, principally by destroying organic
compounds. In addition, unlike many other waste treatment
processes, combustion in incinerators and BIFs can accommodate a
wide variety of waste matrices — liquids, solids, and sludges.
Residues from combustion are generally amenable to land disposal,
often more so than the original waste streams. Finally,
combustion is a demonstrated and commercially available
technology for which considerable design and operational
experience exists.
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Despite these technical attributes, a great deal of
controversy has arisen over the use of combustion for hazardous
waste. Combustion facilities emit trace levels of toxic organic
compounds that are not fully destroyed during combustion, or that
may be formed downstream of the combustion chamber. Trace levels
of metals may also be emitted. The controversial issues fall
primarily in two major categories: (1) ensuring proper
treatment/destruction through good combustion and ensuring that
facility emissions do not exceed regulatory limits, and (2) more
fully characterizing the risks from combustion emissions.
First, EPA seeks to ensure that the combustion chamber is
operated in a manner that represents "good combustion," i.e.,
proper destruction of organic compounds. Because of current
technical difficulties of measuring destruction in the combustion
chamber itself, EPA's approach is to monitor various parameters
(e.g., temperature, CO or O2) that are indicators of how well the
waste is being combusted. Thus, the first category of technical
issues contains questions related to selecting and using the best
parameters as indicators of combustion efficacy. To address this
issues, EPA is committed, among other things, to: (1) reviewing
trial burn procedures to ensure that they result in fully
protective operating conditions, and (2) developing emission
monitors that sample and analyze emissions continuously. Other
actions are detailed in Section VI below.
Second, there are questions about air emissions for which we
do not have complete answers. These issues revolve primarily
around an understanding of the full suite of pollutants (e.g.,
products of incomplete combustion or "PICs") emitted by hazardous
waste combustors and of the indirect exposure pathways. For
example, only limited PIC testing has been done at full-scale
facilities. Lab-scale and full-scale testing has been
initiated, but will take the next several years to provide us
with complete and verified answers that can be the basis of
specific regulatory limits. The current approach relies, if
actual emissions data are unavailable, upon conservative
assumptions about operating conditions (e.g., waste feed) in
conducting facility risk assessments to ensure that the facility
can be operated in a protective manner. However, in light of the
public concern about this approach, it is advisable to conduct
further analysis on the nature and toxicity of combustion
emissions and their contribution to overall risk. In that
regard, EPA will be taking steps (as detailed in Section VI.
below) to: (1) better characterize organic emissions (including
PICs), and (2) use multi-pathway risk assessment procedures.
These steps are consistent both with the Agency's overall efforts
pursuant to the Dioxin Reassessment as well as with the efforts
of the Office of Solid Waste (OSW) and the Office of Research and
Development (ORD) to better assess indirect risks from both toxic
metals and organics, particularly from hazardous waste combustion
facilities.
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; Alternative treatment and other innovative technologies
afford significant opportunities for addressing hazardous wastes
particularly in the remediation context in which many of these '
alternatives have been developed. Some of the alternative
treatment technologies reduce toxicity or volumes of hazardous
waste streams, a key point of comparison for RCRA wastes that
would otherwise be combusted in incinerators and BIFs. Other
innovative technologies can help achieve source reduction and/or
environmentally sound recycling.
, However, of the limited alternative treatment technologies
commercially available today or those expected to be available
over the next 5-10 years, none have been shown provide a
stand-alone alternative that is entirely comparable to combustion
in the degree of toxicity reduction, process efficiency
permanence, and adaptability to a wide variety of waste matrices
A few existing technologies provide some of these
characteristics, but not all. Hence, a primary benefit of these
alternative treatment technologies over the next 5-10 years may
be as pretreatment to reduce the volume of wastes that would be
combusted, for example by separating organic constituents from
more complex_waste matrices. EPA is making a commitment in this
Strategy to identify and explore ways to address barriers that
stand in the way of commercial development and use of safe and
effective alternative technologies, including both those that
reduce toxicity and/or mobility of waste as well as those that
would promote source reduction and/or recycling of waste. EPA
will also emphasize with technology developers the need to
properly characterize actual and potential releases of hazardous
constituents when testing out innovative treatment technologies.
Source reduction and recycling will certainly be pursued
under the Hazardous Waste Minimization National Plan, but cannot
be expected to eliminate the need to combust certain wastes over
the next 5-10 years, particularly organic-bearing waste streams.
Apart from alternative treatment technologies, the alternative
conventional management options for organic-bearing waste streams
now going to combustion are limited — increased landfilling
(with liquid wastes being containerized and held with sorbents),
deep; well injection, release to wastewaters, and perhaps some
landfarming. Long-term storage in concrete vaults, as advocated
by some, is not an acceptable alternative both from a risk
perspective (due to containment failure and increased threat to
groundwater) as well as from an implementation standpoint (due to
immediate legislative change required that would allow such long-
term; storage). In addition, although these alternative
conventional management options may avoid some of the air-based
inhalation and indirect risks from combustion, they would add
long-term soil and ground water-based risks to the equation.
Furthermore, to the extent that organics are land disposed in
lieu! of being combusted, the overall risk from volatilization
from land-based management units would be increased over current
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risk levels. In sum, virtually all of these alternative
management options (including long-term storage) would involve a
reversal of current practices that seek permanent solutions
through treatment to reduce toxicity and mobility (and
bioaccumulation potential at the same time). EPA does not
believe that such a reversal is proper.
As a result, the degree to which toxic emissions from
combustion facilities are controlled is the single most
significant factor in comparing the risks from
combustion-oriented waste management against those from
alternative management scenarios. EPA recognized in the Draft
Strategy that the emissions standards should be upgraded. In
addition, State and federal agencies need to ensure that
combustion facilities are in compliance with all regulatory
standards, both from the standpoint of assuring protection of
human health and the environment and from the standpoint of
having public confidence that their health is being properly
protected. If properly designed and operated in compliance with
tough regulatory standards, combustion is a technology that
provides sound management of hazardous waste and, to varying
degrees, recovery of energy values. However, to remain an
integral part of the national waste management program, EPA
believes that combustion facilities must be operated in the best
possible manner and be equipped with the protective_air pollution
control and real-time monitoring devices. In addition, the
barriers to commercial development and use of safe and effective
alternatives to combustion (including innovative technologies to
reduce hazardous constituents in waste) need to be identified and
addressed, so that broader choices are available for the RCRA
industrial waste universe in the future.
VI. IMPLEMENTATION OF EPA'S STRATEGIC GOALS
EPA has already undertaken a number of actions to implement
the goals of the Strategy, and will be initiating others. The
sections that follow provide both a brief and selective recap of
EPA's actions to date and a more detailed picture of EPA's plans
for achieving each of the Strategic Goals.
[NOTE: A more detailed summary of EPA actions to date is
contained in Appendix A.]
A. Public Outreach and EPA-State Coordination;
EPA has held one national and four regional roundtables (in
addition to hundreds of individual meetings) on source reduction,
recycling, combustion, public participation, enforcement and
other issues over the last 18 months. In response to citizen
requests for greater availability of information on the Draft
Strategy, EPA has made key documents available on electronic
14
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networks and has begun a Strategy Update newsletter. The
Newsletter is currently mailed to over 3000 people who have
attended any Agency meeting on the Strategy or who have otherwise
made, their interest known (e.g., via telephone calls, letters
etc.). '
EPA and the States have also created an EPA-State Steering
Committee on Hazardous Waste Management to discuss significant
policy issues, including source reduction, recycling, public
participation, and combustion. State representatives are being
included on all EPA workgroups that are pursuing particular
projects in these areas.
;To continue our commitment to broad public outreach and to
EPA-State coordination, EPA will take the following actions:
o !Actively solicit the public and stakeholders group opinions
and factor them into Agency decision-making in a manner that
provides for broad and open dialogue.
o Provide an enhanced level of information to the public and
stakeholder groups through the Newsletter and electronic
media. EPA will also explore use of information outreach
programs and technical assistance to local communities.
o Continue to involve members of the EPA-State Steering
Committee on significant policy and technical issues.
o Bring state representatives into EPA planning efforts and
work groups early in these processes.
B. Waste Minimization;
EPA's public dialogue on waste minimization goals,
approaches, and implementation has not only included the national
and regional roundtables, but has recently occurred in the
context of focus groups assembled to discuss the Draft Hazardous
Waste Minimization National Plan, released in May 1994. This
dialogue has resulted in significant advances during development
of the final National Plan, which is being released today as the
framework for future actions to reduce the persistent,
bioaccumulative, and toxic constituents in hazardous waste.
EPA continues to place emphasis on waste minimization in our
waste management thinking. EPA will take the following actions:
o Issue and, with EPA Regional and State lead, aggressively
implement the Hazardous Waste Minimization National Plan
Under the National Plan, EPA will:
!
Focus efforts on industrial sectors and processes
; 15
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producing waste streams that contain persistent,
bioaccumulative and toxic constituents that represent
the highest risk, with an initial emphasis on toxic
metals in combustible waste streams.
— Look closely at other waste streams that contain
persistent, toxic, and bioaccumulative constituents
(e.g., those with halogenated organics) in the near
future.
Implement measures to achieve the overall goals for
source reduction and environmentally sound recycling
and for generator participation set forth in the
National Plan.
Provide for sufficient individual company flexibility
to harness the creative thinking of American industry
in finding source reduction opportunities.
Maximize use of voluntary partnerships and programs
among industry, the public, and regulatory agencies in
implementing the National Plan.
Issue final "Waste Minimization Program in Place"
guidelines.
Enforce the RCRA waste minimization certification
requirements at large quantity generators and TSDFs, and
continue to encourage facilities to make their waste
minimization programs available to the public.
Revisit after several years the mechanisms used to pursue
waste minimization under the National Plan to determine
whether satisfactory progress in source reduction and
environmentally sound recycling is being made.
Provide technical assistance on waste minimization issues.
Provide opportunities for widespread public recognition of
industry success in source reduction of hazardous wastes.
C. Role of Alternative Technologies:
Over the past 18 months, EPA and interested parties have
explored the appropriate role for combustion and, to a lesser-
degree, alternative treatment and other innovative technologies,
in our national hazardous waste program. This has been
accomplished in the national and regional roundtables as well as
in numerous individual meetings.
The dialogue among stakeholders has made it very clear that
combustion facilities must be designed and operated in the best
possible manner and be equipped with the most protective air
pollution control technologies feasible. Alternative treatment
16
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wastes to reduce toxicity
will
effort an examination of the potential role
0le
take
Siskin ?h^ p?p?rmine h°W bSSt t0 address barriers that may
exist in the RCRA program (and possibly elsewhere) aaainst
commercial development and use of alternative treit22SJ and
So^-inn°Vatl^e techn°l°gies that can reduce the Sxicit?
mobility, persistence, bioaccumulation, and/or volume of
hazardous constituents in a safe and effective way™ Ml
will also emphasize the need to properly characterize actual
Sel-?™611^ reieases of hazardousPconsti?uen?s whJn ^
testing out treatment and other innovative technologies.
Ensure better cooperative work on gathering data and
assessing alternative treatment technologies among EPA
offices and with outside parties. *mong WA
Take better advantage of energy recovery opportunities
through EPA' s workgroup efforts considering evelopmSnt of a
"clean fuel specification," which could potential!? modi?J
the management practices applicable to some wastes that dn
not warrant the current full set of regulator? controls"
D- Emission Standards and Controls:
'AS the ^rsult of both the national dialogue on technical
Sgar n? P^°Per controls f0^ hazardoul waste comSus?ion
and a significant amount of EPA technical work over the
last 18 months EPA released for public review in MaJ 199? its
preliminary analysis of achievable emission levels for dioxinS
"
s?andl?t°? CETRED' a"f Wil1 f°CUS °n the devlopnent
standards for sources that are burning hazardous waste, such as
17
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incinerators, cement kilns, light-weight aggregate kilns,
boilers, halogen acid furnaces, and other types of industrial
furnaces.
In addition, over the past 18 months, EPA regions and states
have examined pending facility permit applications to determine
whether use of the RCRA omnibus permit authority to apply
additional permit controls beyond those required under the
current regulations is necessary to ensure that emissions ofr
hazardous constituents do not pose an unreasonable risk to human
health and the environment.
in the Draft Strategy, the Agency identified 30 ng/dscm of
dioxins and furans and 0.015 gr/dscf particulate matter (PM) as
goals and targets until upgraded technical standards were
adopted Since then, the Agency has done additional analysis on
achievable dioxin and PM levels. For example, CETRED identifies
0?1 ng TEQ/dscm dioxin and 0.005 gr/dscf PM as levels that have
been achieved by existing hazardous waste combustors. By way of
nersoective, the proposed emissions guidelines for existing
municipal waste combSstors (MWCs) are 0.5 ng TEQ/dscm dioxin and
0 012 gr/dscf PM for large MWCs, and 1.0 ng TEQ/dscm dioxin and
0 030 ar/dscf PM for small MWCs. Proposed new performance
standards for both large and small MWCs are 0.2 ng TEQ/dscm
dioxin and 0.007 gr/dscf PM.
EPA's basic goal remains to have hazardous waste combustion
facilities achieve low emission levels that protect human health
and the environment. Until the technical standards rulemaking is
proposed, the EPA and state permit writers should use risk
assessments and RCRA omnibus authority in developing permit
conditions to limit emissions on a case-by-case basis as
necessary to ensure protection of human health and the
environment, and should work with facilities to develop and use
best operating practices to achieve low emission levels.
To continue to ensure that hazardous waste burning
incinerators and BIFs are well-operated in a manner that Protects
human health and the environment, EPA will take the following
actions:
Continue to build on its technical data base on emissions
from hazardous waste combustion devices, including the use
of coordinated governmental and industry testing and, if
necessary, through the use of compulsory data-gathering
mechanisms.
Develop and promulgate rules that impose more rigorous
controls on combustion facilities based on>an assessment of
available technologies and most current science. The
proposed rule is scheduled for September 1995, with a final
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rule scheduled for December 1996. Our intent is to develop
this rule in a coordinated manner under both RCRA and the
Clean Air Act authorities.
After the proposed rule to upgrade emission standards is
published, in appropriate permit actions, implement the
proposed emission standards and controls through use of
omnibus permit authority as necessary to protect human
health and the environment. Encourage all combustion
facilities to implement the proposed standards to reduce
emissions as quickly as possible.
Implement final rule in a manner that achieves the greatest
possible immediate reduction in dioxins, furans, and metal
emissions at all hazardous waste combustion facilities,
including consideration of whether and how to reopen and
modify existing permits as appropriate.
Enhance current efforts, both inside and outside EPA, to
test continuous emission monitors for toxic organics and
metals and to stimulate their commercial availability within
the shortest possible time. Explore how these CEMs can be
installed at hazardous waste combustion facilities as soon
as possible and in a manner that affords public access to
the monitoring results.
E. Enforcement and Compliance Assistance;
To enhance compliance by hazardous waste incinerators and
BIFs with regulatory requirements, since May 1993, EPA has
undertaken three major enforcement initiatives in conjunction
with the States. The initiatives involved 51 complaints and 43
settlements, all of which addressed hazardous waste combustion
violations. The enforcement actions proposed over $31.5 million
in new civil penalties, while collecting nearly $6 million in
settlement of ongoing actions.
In addition, EPA and the States inspected 255 combustion
facilities between March 1, 1994 and September 30, 1994. Of
these inspections, 115 were at BIFs and 140 at incinerators.
Many facilities have been inspected a number of times.
The three enforcement initiatives complement other steps EPA
has taken, or is the process of undertaking, to work with
industry to ensure that EPA's regulations are understood and
followed. As part of the national dialogue and rouridtables on
combustion, EPA and the States heard from community groups and
individual citizens that better opportunities should be afforded
for public information and involvement in compliance assistance
and enforcement activities. In addition, industry also
demonstrated a willingness to engage in preventive, compliance-
19
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oriented activities with the Agency.
To enhance such opportunities, EPA has held compliance
workshops with industry groups, and will seek to increase the
public's understanding of, and involvement in, the hazardous
waste regulations and the enforcement process. For example, in
October 1994, EPA released an OSW memorandum explaining the
regulatory requirements for intermediate waste treatment/fuel
blending operations that handle combustible and other wastes.
To continue these efforts, EPA will take the following
actions:
o Continue to target hazardous waste handling and combustion
facilities for inspections, and aggressively enforce against
violators to promote deterrence and return facilities to
compliance. EPA also intends to reevaluate how best to
address facilities with a record of repeated violations,
including the use of legal authorities enabling EPA to shut
down such facilities.
o Provide enhanced compliance and enforcement training for
Regional and State enforcement personnel, including the
development of user-friendly computer-based video training
materials by FY 1996. These materials will also be provided
as appropriate to the regulated community.
o Continue to reassess and, as appropriate, revise current
policies and procedures to maximize facility compliance.
EPA plans to develop user-oriented guidance documents as
well as clearer regulations and permit provisions. These
would foster and maximize proactive facility compliance.
One of these documents, a draft Guidance on Waste Analysis
Plans for BIFs, will be released in late November or
December 1994 for public review and comment. When
finalized, this document is expected to help combustion
facilities to better characterize their wastes prior to
burning.
o Another compliance assistance tool being developed by EPA
for release in December 1994 or early 1995 is the transcript
from the joint CMA/EPA BIF Workshop. The transcript
contains answers to specific questions on compliance raised
by CMA members regarding the BIF rules.
o Increase public confidence in Agency oversight activities
and facility compliance by enhancing public understanding of
these activities and promoting public involvement. EPA will
consider: (1) including provisions in hazardous waste
settlement agreements to establish citizen advisory
committees or to create publicly accessible, real-time "on-
line" compliance monitoring systems; and (2) expanding the
20
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use of pollution prevention and waste minimization
strategies in consent agreements through compliance
requirements and Supplemental Environmental Projects (SEPs).
A "Plain Language Guide to EPA Administrative Enforcement"
is being prepared to better inform the public how EPA's
administrative enforcement process works, the rights and
responsibilities of the parties involved and the public, and
the factors EPA considers under the statute and the RCRA
Civil Penalty Policy in proposing penalties and settling
cases. This Guide is currently scheduled for release in
early 1995.
Explore means to have continuous emission monitors (CEMs)
installed at combustion facilities as soon as CEMs are
commercially available. The Agency intends to do so in a
manner that ensures prompt and open public access to
facility compliance information.
F. Public Involvement in Permit Process;
As noted in many places in this Strategy, perhaps the
primary cornerstone of EPA's approach has been to ensure that
local communities and citizens are heard — both in the
discussions on national policy as well as in individual facility-
related activities. EPA published a major proposal in May 1994
to revise the RCRA rules to ensure that the public has a greater
opportunity to participate in the permitting process and to
better address limiting operations at facilities that fail trial
burns conducted during interim status. EPA also directed Regions
and States to begin immediate implementation of this proposal to
the extent legally permissible.
In addition, EPA's Office of Solid Waste convened a task
force in early 1994 to explore avenues to address a number of
environmental justice and facility siting concerns that had
arisen, including at the 1993-94 national and regional
roundtables on the Draft Strategy. The work of this task force
has led to the initiation of a number of additional activities
that complement the proposed changes to RCRA permitting rules
contained in the May 1994 proposal.
, Enhancing public involvement opportunities remains one of
the Agency's highest priorities for all of its activities. With
respect to the areas addressed in this Strategy, EPA will take
the following actions:
o By summer 1995, finalize rule to enhance general public
involvement opportunities in process for considering permit
applications for combustion and other RCRA facilities, and
21
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to better address limiting operations at facilities that
fail trial burns during interim status.
Continue to work with regions and states to implement
measures designed to maximize community-based public
involvement in RCRA permitting and compliance/enforcement
decisions, consistent with EPA Assistant Administrator Laws'
memorandum of May 1994 about immediate implementation of
some portions of proposed rule to enhance public involvement
in permitting.
Continue to implement recommendations of the OSWER
Environmental Justice Task Force in a manner consistent with
the overall Agency approach to environmental justice and
public involvement concerns. In particular, EPA will
continue efforts of a recently-initiated RCRA siting work
group to explore an upgrade to current RCRA facility
location standards. EPA will also continue work on the
Office of Solid Waste study on demographics around hazardous
waste incinerators and BIFs.
G. Facility Permitting Priority;
The Regions and States have now called in all permit
applications for commercial BIFs that are currently operating
under interim status. These permit applications have received
high priority for review and processing. In addition, Regions
and States have begun to call in some applications for the
remaining non-commercial facilities as time and resources allow.
At the same time, some existing permits for incinerators have
reached the end of their permit term and are in the process of
renewal evaluation. Permit applications and actions for new
facilities and expanded capacity at existing facilities have been
given low priority over the last 18 months if those new
facilities would not replace existing combustion capacity.
Appendix C contains details on the universe of hazardous waste
incinerators and BIFs and the permitting activity in this
universe over the last 18 months.
In general, EPA expects that permitting for existing interim
status combustion facilities will continue to be given higher
priority and permitting of new, non-replacement capacity will
continue to be given lower priority. We also wish to afford
flexibility to the Regions and States that would allow them to
give priority to other permit applications (e.g., for permit
renewals) that would result in the greatest environmental
benefits or the greatest reduction in overall risk to the public.
To implement this approach, EPA will take the following actions:
o Assist regions and states in giving higher priority to those
facilities for which a final permit decision would result in
22
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the greatest environmental benefits to the surrounding
community or the greatest reduction in overall risk to the
public. Permit renewals may be considered within the high
priority category if they meet these priority criteria.
Maintain current policy of low priority for work on
applications involving new, non-replacement combustion
facilities.
Recommend to Regions and States that the call-in of all
outstanding permit applications be consistent with the
permitting priority approach of this Strategy to avoid the
triggering of permitting time requirements that may divert
resources away from high priority permit actions. However,
the Agency's overall goal is to have Regions and States call
in all combustion permit applications within the shortest
possible time.
H. Risk Assessments
The Draft Strategy established the general policy that risk
assessments, which include indirect exposure pathways, should be
performed prior to final permit determinations for all hazardous
waste combustion facilities. At this point, about 10 risk
assessments have been reviewed by EPA headquarters and regional
experts and about another 30-40 are under way at individual
facilities. To assist in this effort, EPA published two
significant technical documents — a draft Addendum to the 1990
ORD indirect risk guidance and a draft OSW combustion facility
risk assessment guidance (including a risk screening protocol)
Thesse documents incorporated the latest information pertinent to
performing risk assessments, particularly with respect to
indirect exposure pathways, which the draft Dioxin Reassessment
and ; other documents have shown to be very significant'in
connection with combustion facilities.
EPA remains committed to the goal of advancing scientific
understanding on combustion issues and risk assessment. EPA will
take the following actions:
o ; Continue the current policy that risk assessments should be
completed prior to making final permit determinations.
o , Release by early 1995 an updated version of the OSW
implementation guidance, which takes into account regional
,; and state experience and comments over the last 6-12 months.
! EPA will also develop a user-friendly spreadsheet for the
risk screen procedure as a future supplement to the
guidance.
o Continue availability of HQ-Regional Risk Assessment Review
23
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Team in scoping, performing, and/or reviewing risk
assessments for the near future until the Regions have more
experience and familiarity with the risk assessment process
for combustion facilities.
X. CONCLUSION
EPA remains committed to the principle that the best
approaches to hazardous waste minimization and management will be
most easily found and implemented in a spirit of cooperation and
partnership among the interested parties. To that end, EPA will
continue to serve as a chief catalyst for broad and open
discussions among all interested parties and, in particular, to
foster a full and open relationship between RCRA facilities and
their surrounding communities.
As stated in the Draft Strategy, EPA is keenly aware that,
ultimately, we serve the public. Our mission under RCRA, and
that of the authorized states, is explicit — we must assure
protection of human health and the environment. However,
generators of hazardous waste and facilities that store, treat or
dispose of hazardous waste should continue to improve
relationships with their communities. Members of the public must
be assured — not just by word but also by deed — that their
well-being is of paramount concern to those that have
responsibility for managing hazardous waste safely.
24
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APPENDIX A
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Appendix A — Strategy for Hazardous Waste Minimization and Combustion
ACCOMPLISHMENTS IN PUBLIC OUTREACH AND EPA-STATE COORDINATION
OVERALL GOALS
+ ; Continue to facilitate an open and broad national dialogue
among all stakeholders on significant hazardous waste issues.
j Give top EPA priority to working with states as co-regulators
-, of hazardous waste.
EPA ACTIVITIES
j
• ; Agency commitment in May 1993 to engage the widest range of
i interested parties in a broad national dialogue on waste
• minimization and combustion issues.
• ! Creation of the EPA-State Steering Committee on Hazardous
'• Waste Management, which meets to discuss significant policy
issues related to waste minimization, combustion, public
; involvement, and other issues in the Draft Strategy.
« Press Advisory (September 1993) and Environmental Fact Sheet
• (October 1993) released to identify for the public the planned
! events and actions associated with the Draft Strategy and to
I identify opportunities for public involvement.
• • Four-day National Roundtable on Hazardous Waste Minimization
i and Combustion convened in the Washington, D.C. area November
, 15-18, 1993. The meeting drew over 200 participants and
observers and brought out the views of a broad spectrum of
' interests.
• ; A series of four one-day Regional Roundtables on the Draft
i Strategy and related topics held in San Francisco, Houston,
: Chicago, and Atlanta in April-May 1994. Approximately 500
; participants and observers provided their views to EPA on a
broad range of issues including pollution prevention,
; combustion standards, permitting, compliance and enforcement,
, environmental justice, siting, and risk assessment.
• I Initiation of a quarterly newsletter (the "Strategy Update")
; in September 1994 devoted to keeping interested parties
I informed of on-going activities connected with the Draft
! Strategy. The Newsletter is currently sent to over 3000
people.
• \ Released for public review and comment in May 1994 a draft
; Combustion Emissions Technical Resource Document (CETRED) that
preliminarily identified emission levels of dioxins, furans,
I and particulate matter (PM) from existing hazardous waste
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Appendix A — Strategy for Hazardous Waste Minimization and Combustion
combustion facilities using the best control technologies and
operating practices. CETRED and the comments received on the
document will be included as part of the regulatory
development process that will culminate, under the current
schedule, in a proposed rule in September 1995 covering at
least hazardous waste incinerators, cement kilns, and light-
weight aggregate kilns.
A four-day focus group meeting in September 1994 was held in
Washington, D.C. to discuss the framework of and issues
associated with developing the RCRA Hazardous Waste
Minimization National Plan. Results of the discussions were
integrated into the final National Plan.
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Appendix A — Strategy for Hazardous Waste Minimization and Combustion
ACCOMPLISHMENTS IN WASTE MINIMIZATION - SOURCE REDUCTION AND
RECYCLING
OVERALL GOALS
+ Under the Hazardous Waste Minimization National Plan,
reinforce strong preference for source reduction over
hazardous waste management in order to reduce both the long-
term demand for treatment, storage, and disposal capacity
; and the quantities of persistent, bioaccumulative, and toxic
constituents that need to be managed. In partnership with
states, industry, and local communities, pursue aggressive
use of waste minimization measures with primary emphasis on
voluntary actions. Afford members of the public a greater
opportunity to become aware of waste minimization activities
in their communities.
EPA ACTIVITIES
• Released EPA's guidance on what constitutes a Waste
; Minimization Program-in-Place in May 1993.
• Conducted a two-day session on waste minimization (source
reduction and recycling) of hazardous waste, with particular
focus on combustible wastes as part of the four-day National
Roundtable in November 1993.
* In November 1993, Administrator Browner sent letters to
, approximately 22,000 large quantity generators of hazardous
waste that were required to certify that they had a waste
minimization program in place in 1991. Letters were also
; sent to approximately 12,000 chief executive officers of the
parent corporations of those generators. The letters
referenced current requirements on having waste minimization
programs and encouraged the companies to make those programs
! available to the public.
• Conducted public dialogue on waste minimization at the four
Regional Roundtables (San Francisco, Houston, Chicago and
; Atlanta) in April-May 1994.
• Released in May 1994 EPA's Draft RCRA Hazardous Waste
Minimization National Plan, which focuses on a number of
specific goals, including reducing the amount and toxicity
of hazardous waste that is generated, particularly when such
; reductions benefit more than one environmental! medium. EPA
i released the Waste Minimization Plan in draft form in order
to have further broad and open discussions with various
stakeholders before finalizing the Plan.
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Appendix A — Strategy for Hazardous Waste Minimization and Combustion
Released in 1994 for public comment EPA's Draft Methodology
Document for Setting Priorities for Hazardous Waste
Minimization. This methodology is a key component of EPA's
National Plan.
A four-day focus group meeting in September 1994 was held in
Washington, D.C. to discuss the framework of and issues
associated with developing the RCRA Hazardous Waste
Minimization National Plan. Results of the discussions were
integrated into the final National Plan.
Release today of final Hazardous Waste Minimization National
Plan in concert with Final Strategy announcement. The
National Plan provides the framework within which EPA will
conduct its waste minimization activities.
OSW distributed to the Regions and States an Addendum to the
RCRA Implementation Plan (RIP) for FY '95 discussing how
source reduction and recycling can be integrated into the
existing program (e.g., permits, enforcement agreements) and
can be pursued in non-regulatory initiatives, such as
technical assistance, training, and outreach. The approach
in the RIP also seeks to take advantage of opportunities
arising from the permitting and inspection of combustion
facilities, as affected by the Draft Strategy.
As part of the 1991 RCRA Biennial Report released in
November 1994, EPA has included a list of large quantity
generators who were required to certify that they had a
waste minimization program in place in 1991.
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Appendix A — Strategy for Hazardous Waste Minimization and Combustion
ACCOMPLISHMENTS REGARDING ROLE OF COMBUSTION AND
ALTERNATIVE TECHNOLOGIES
OVERALL GOALS
4 Maintain appropriate role for combustion, and continue to
ensure that combustion and other treatment facilities reduce
; toxicity, volume, and/or mobility of hazardous wastes in a
manner that is protective of public health. Foster the
| commercial development and use of alternative treatment and
, other innovative technologies that are safe and effective in
reducing the toxicity, volume, and/or mobility of RCRA
; industrial process and remediation wastes.
EPA!ACTIVITIES
• EPA's Technology Innovation Office (TIO) was established to
; accelerate the development and application of innovative
hazardous waste remediation technologies. Emergence of cost
; effective, on-site remediation alternatives such as Soil
. Vapor Extraction (SVE), have eliminated some of the demand
for off-site incineration capacity for remediation wastes.
A number of innovative alternatives (e.g., low temperature
thermal desorption, solvent extraction and soil washing) are
volume reduction technologies that have reduced, but not
eliminated, the quantity of materials which might otherwise
. require incineration.
• EPA efforts to create a hospitable environment for
; technology development and commercialization include:
: - The Superfund Innovative Technology Evaluation (SITE)
program provides a venue for promising remediation
technologies to receive technical assistance and
' objective third-party evaluation. A number of
; technologies in the SITE program have potential
applicability to newly- generated wastes.
; - A grant to WASTECH, a multi-organization cooperative
| project managed by the American Academy of
; Environmental Engineers, to publish a series of 8
: monographs on the state-of-practice of innovative
| treatment technologies
1 - Establishment the Vendor Information System for
Innovative Treatment Technologies (VISITT) data base,
which contains vendor-supplied information on
technology performance and availability.
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Appendix A — Strategy for Hazardous Waste Minimization and Combustion
The Office of Solid Waste (OSW) has begun a comparative
analysis of alternative treatment technologies. This
analysis will be coordinated with TIO and will provide a
basis for beginning the identification and evaluation of
barriers to the commercial development and use of
alternative treatment technologies that can reduce the
toxicity, mobility, bioaccumulation, and mass of hazardous
constituents.
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Appendix A — Strategy for Hazardous Waste Minimization and Combustion
ACCOMPLISHMENTS IN EMISSION STANDARDS AND CONTROLS
OVERALL GOALS
+ ; Develop and impose more rigorous controls on combustion
facilities based on an assessment of available technologies
, and current science. Develop these controls as a
| coordinated effort to implement both RCRA and the Clean Air
j Act authorities for hazardous waste combustion facilities.
• Ensure that hazardous waste combustion facilities do not
; pose an unacceptable risk to human health or the
i environment.
EPA ACTIVITIES
« Entered into settlement agreement in litigation on 1991 BIF
; regulations, which obligates EPA to propose upgraded
I emission standards for all hazardous waste burners under the
• following schedule:
* t- Phase I: Includes hazardous waste incinerators, cement
kilns, light-weight aggregate kilns, and smelter furnaces.
i Propose: by September 1995
Promulgate: by December 1996
t» Phase II
furnaces.
Includes boilers and certain other industrial
; Propose: by September 1998
• Promulgate: by December 1999
: Conducted a two-day session on upgrading technical standards
! as part of the four-day National Roundtable in November
1993.
Conducted public dialogue on combustion issues at the four
i Regional Roundtables (San Francisco, Houston, Chicago and
; Atlanta) in April-May 1994.
; Initiated technical studies to determine Best Operating
i Practices (BOPs) and emission levels for the best-controlled
i existing hazardous waste combustion facilities. The first
phase focused on dioxins, furans, and particulate matter,
; and has led to the development of the Combustion Emission
' Technical Resource Document (see below). The second study
i phase will focus on metals and other hazardous air
, pollutants, and is being conducted during 1994 and early
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Appendix A — Strategy for Hazardous Waste Minimization and Combustion
1995.
Release in May 1994 of the draft Combustion Emissions
Technical Resource Document (CETRED) that preliminarily
identifies emission levels of dioxins, furans, and
particulate matter (PM) that have been achieved at existing
hazardous waste combustion facilities using available
control technologies and operating practices. CETRED uses
an approach to determining these emission levels that is
derived from the MACT process under the Clean Air Act;
however, the levels identified in CETRED are not MACT
determinations. CETRED also contains an extensive review of
the combustion technologies in use today and of their
various performance characteristics. The dioxin level
identified as being achieved by the best-controlled
hazardous waste combustors is 0.1-0.2 TEQ ng/dscm. The PM
level identified is 0.005 gr/dscf.
CETRED is the first preliminary analysis addressing
technology-based emission levels for hazardous waste
combustion facilities and the Draft Strategy. Following
release of CETRED, EPA provided for public review and
comment on the data base and the analytical process used in
the document. In fall 1994, EPA began work on determining
achievable metal levels by the best-controlled sources.
Both CETRED and the later findings of achievable metals
levels will be considered in the regulatory development
process that will culminate, under the current schedule, in
a proposed rule in September 1995 covering at least
hazardous waste incinerators, cement kilns, and light-weight
aggregate kilns.
In May 1994, EPA released a statement of policy under the
Land Disposal Restrictions (LDR) program, which clarifies
that combustion of certain inorganic, metal-bearing
hazardous waste streams may not represent adequate treatment
and therefore can violate the LDR dilution prohibition.
EPA's Office of Solid Waste (OSW) and the Office of Air
Quality Planning and Standards (OAQPS) continue to
coordinate efforts in the development of proposed rules to
set emission standards for hazardous air pollutants under
both RCRA and CAA authorities. These rulemakings will cover
sources that are burning hazardous waste, such as
incinerators, cement kilns, light-weight aggregate kilns,
boilers, halogen acid furnaces, and other types of
industrial furnaces.
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Appendix A — Strategy for Hazardous Waste Minimization and Combustion
]ACCOMPLISHMENTS IN ENFORCEMENT AND COMPLIANCE ASSISTANCE
OVERALL GOALS
* i Continue aggressive compliance and enforcement efforts
against hazardous-waste burning incinerators and boilers and
| industrial furnaces (BIFs) while working with industry to
I ensure that EPA's regulations are understood and followed.
1 Enhance public confidence in Agency oversight activities and
! facility compliance by promoting public understanding of
these activities and increased opportunities for public
< involvement in the enforcement process.
EPA ACTIVITIES
• Since May 1993, EPA and the States have undertaken three
major enforcement initiatives targeted at BIFs and hazardous
waste incinerators, the first in September 1993, the second
': in February 1994, and the third on November 15, 1994. The
1 enforcement actions resulted in 51 complaints and 43
• settlement agreements proposing over $31.5 million in new
civil penalties, while collecting nearly $6 million in
, settlement of ongoing actions.
• , As part of the February 1994 initiative, the Department of
'• Justice filed the United States government's first judicial
j BIF complaint against Neville Chemical Company located in
Neville Island, Pennsylvania. Neville had reported that its
hazardous waste feed stream contains carcinogenic metals.
; Because Neville Chemical Company's failure to properly
: monitor and control its hazardous waste feed rates, the
| violations could have posed a significant ris;k to human
i health and the environment. The U.S. is seeking up to the
: statutory maximum penalty of $25,000 per day for each
! violation.
\
• ; In the September 1993 initiative, a $3 million action was
filed by the State of Illinois against Chemical Waste
| Management, Inc.'s hazardous waste incinerator located in
! Sauget, Illinois. The State's complaint cites the facility
for uncontrolled fugitive emissions, including vapor, ash,
; and smoke, from the burning of hazardous waste.
• From March 1994 through September 1994, EPA and the States
-; inspected 255 hazardous waste combustion facilities, or 77%
of the total universe of facilities. Of the 255 inspected
• facilities, 115 were BIFs and 140 were incinerators. Some
| facilities have been inspected a number of times. According
; to data on BIFs supplied by EPA's Regions and incinerator
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Appendix A — Strategy for Hazardous Waste Minimization and Combustion
data from EPA's RCRIS database, the inspectors noted
potential violations at 77 BIFs and 47 incinerators.
In October 1994, an OSW memorandum to EPA regions provided a
comprehensive discussion of the permitting, LDR, and other
related requirements applicable to intermediate transfer,
storage, and/or treatment facilities that, among other
things, may blend waste fuels for combustion.
In September 1993, EPA completed a three-day workshop for
State and Regional compliance and enforcement staff on
inspections at hazardous waste BIFs. Similar BIF compliance
and enforcement workshops were also held for Alabama and
Missouri personnel in spring 1994. The Agency's compliance
and enforcement office anticipates continuing its intensive
training efforts on inspection and compliance at hazardous
waste combustion facilities.
On March 29-30, 1994, EPA compliance, enforcement, and
permitting personnel held a compliance assistance workshop
with the Chemical Manufacturers Association to answer
specific questions raised by CMA members on the BIF
regulations. EPA will release a transcript of the workshop
in December 1994 or early 1995.
10
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Appendix A — Strategy for Hazardous Waste Minimization and Combustion
ACCOMPLISHMENTS IN PUBLIC INVOLVEMENT IN PERMITTING PROCESS
AND ENVIRONMENTAL JUSTICE
OVERALL GOALS
4- Enhance public involvement opportunities in the process for
considering permit applications for combustion facilities.
Take appropriate actions to ensure that local communities
are fully informed about the RCRA decision-maiking process
; (including waste minimization opportunities) and have an
| opportunity to participate in that process.
EPA 'ACTIVITIES
• EPA's Office of Solid Waste met with representatives of
various stakeholder groups in October 1993 to discuss
: possible changes to RCRA permitting regulations to enhance
; opportunities for earlier and more effective public
! involvement.
i
• ; Administrator Browner issued a memorandum on March 16, 1994
i to EPA's Environmental Appeals Board (EAB) directing that
j the EAB give highest priority to review of Regional permit
; decisions that deny a final permit for an interim status
i incinerator or BIF. The memorandum further directs the EAB
; to render a decision to the extent practicable within 90
; days after the appeal is filed.
• Conducted public dialogue on permitting and public
involvement at the four Regional Roundtables (San Francisco,
| Houston, Chicago and Atlanta) in April-May 1994.
« | Publication on June 2, 1994 of EPA's proposal to change its
; RCRA permitting regulations to provide for earlier and more
; effective public involvement in the RCRA permit process.
: The proposal also contained changes to permit, procedures to
better address facilities that fail trial burns during
; interim status. In addition, EPA also issued a memorandum
; to the Regions at that time encouraging them to immediately
, implement the provisions to the maximum extent legally
' permissible. This memorandum will afford the public
, expanded opportunities for involvement in the; permit
decision-making process prior to time the rulemaking is
: finalized.
1 The proposed rule has two major themes: 1) earlier and
expanded public involvement, and 2) strengthening the
1 permitting procedures, particularly for combustion
i facilities.
11
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appendix A — Strategy for Hazardous Waste Minimization and Combustion
Public Involvement — Key components of the expanded
opportunities for public involvement in all RCRA permits
include: (1) facility required to hold a pre-application
meeting with the affected community prior to submitting
their RCRA permitting application; (2) notice of receipt of
permit application by the permitting authority; (3) EPA may
require permit applicants and permittees to establish public
information repositories in close proximity to the facility
site; and (4) public notice of trial burn conditions and
scheduling would be required.
Permitting Improvements — Key components of the
strengthened permitting procedures for incinerators and BIFs
include: (1) agency approval of the trial burn plan for
interim status units prior to the actual burn; (2) limiting
post-trial burn operations to only those conditions that the
facility successfully passed; (3) narrowing the opportunity
to operate based on submittal of data in lieu of performing
a trial burn; and (4) providing clearer regulatory authority
on denial of a permit application if the facility cannot
pass its trial burn. Note that the trial burn failure
guidance, which dovetails with this portion of the proposed
rule, was released in July 1994.
As part of overall Agency task force to address
environmental justice issues, OSWER Assistant Administrator
Elliott Laws convened a RCRA-CERCLA-UST task force in 1993.
After working closely with representatives from all ten EPA
regions, as well as members, from environmental justice
community groups, labor unions, academic institutions and
industry groups, the OSWER Environmental Justice Task Force
in April 1994 completed a draft final report recommending
various approaches to identify and address environmental
justice issues.
In April 1994, OSWER Assistant Administrator Elliott Laws
established an inter-office Siting Task Force to identify
the options available for addressing various concerns
related to siting of RCRA hazardous waste facilities. The
Task Force explored options that ranged from setting
technical location standards to enhancing public information
and input as a matter of increased environmental justice.
The Task Force reported to the OSWER AA in August 1994 with
respect to its findings. Following the report, the OSWER AA
directed work to begin on a proposal to upgrade the RCRA
location standards. The Task Force continues to meet and to
report progress in developing other siting options to the
OSWER AA.
OSW is in the early stages of developing a methodological
12
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Appendix A — Strategy for Hazardous Waste Minimization and Combustion
approach or approaches for assessing the racial and ethnic
makeup and income levels of neighborhoods around facilities
that represent several industrial sectors. The results of
this effort are expected to provide tools that will help OSW
identify various aspects of environmental justice issues in
its future regulatory and non-regulatory projects.
OSW is also exploring, in conjunction with EPA's Office of
Environmental Justice, means by which the dialogue with
Native American tribes can be enhanced and facilitated
regarding their environmental justice concerns.
13
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Appendix A — Strategy for Hazardous Waste Minimization and Combustion
ACCOMPLISHMENTS IN FACILITY PERMITTING PRIORITY
OVERALL GOALS
+ Give higher priority to those facilities for which a final
permit decision would result in the greatest environmental
benefit or the greatest reduction in overall risk to the
public. Give lower priority to permit decisions on new
combustion facilities that are not replacing older
facilities.
EPA ACTIVITIES
• Incinerator Universe — EPA's latest census as of November
1, 1994 shows 162 permitted and interim status incinerators
in the hazardous waste combustion universe. An additional
26 proposed facilities (including 7 demilitarization and 2
remedial units) are also potentially in the universe.
Since May 1993, 8 non-commercial onsite incinerators
withdrew from the universe of permitted facilities (most
units had not been built); 8 commercial facilities withdrew
plans to add capacity, and 4 interim status facilities (1
commercial and 3 non-commercial) decided to close. In
addition, 7 facilities submitted new incinerator
applications (1 commercial, 4 non-commercial, 1 remedial,
and 1 demilitarization). One permit was issued by Texas for
the American Envirotech facility. In September 1994, EPA
denied the permit application for Marine Shale Processors in
Morgan City, LA (now on appeal).
• BIF Universe — EPA's latest census as of November 1, 1994
shows 136 interim status boilers and industrial furnaces in
the hazardous waste combustion universe.
Since May 1993, 22 interim status BIF facilities have
withdrawn from the universe of hazardous waste combustors (6
commercial cement kilns, 2 commercial boiler, 13 onsite
boilers, and 1 smelter). In March 1994, EPA denied the BIF
permit application submitted by National Cement in Lebec, CA
(now on appeal). Also in 1994, Arkansas denied a permit
application submitted by Maybelline Products.
• In addition, on April 4, 1994 in response to a petition
filed by the Hazardous Waste Treatment Council et al., EPA
determined that: 3 facilities had never qualified for
interim status (Gage Products in Ferndale, MI; ESSROC in
Speed, IN; and Marine Shale in Morgan City, LA); 3 kilns at
Lafarge Cement in Alpena, MI had never qualified for interim
14
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Appendix A — Strategy for Hazardous Waste Minimization and Combustion
I status; Holnam Cement in Ada, OK had qualified for interim
1 status; and River Cement in Festus, MO complied with the
certification of compliance requirements and could continue
to burn hazardous waste. Boxcrow in Midlothian, TX, also
discussed in the April determination, has since indicated
i its intent not to burn hazardous waste or to assert
\ authority to operate under interim status.
! Since May 1993, all EPA Reqions and many States have qiven
hiqhest priority to proceedinq towards final permit
; determinations for operatinq interim status combustion
I facilities not yet under permit controls. Risk assessments
! at 18 incinerators and 13 BIFs are currently underway.
• By May 1994, the Reqions and States called in permit
i applications for all commercial BIFs that are currently
i operatinq under interim status.
i
; In May 1994, EPA distributed additional guidance to Reqions
on trial burn procedures (particularly with respect to
; obtaininq representative PIC levels needed for risk
! assessments) to assist the Reqions and states in
implementinq the Strateqy and in making final permit
: determinations.
i Continued examination of each facility permit application to
; determine whether use of the RCRA "omnibus permit authority"
I to apply additional permit controls beyond those required
; under the current regulations is necessary to ensure that
1 emissions of hazardous constituents do not pose an
; unreasonable risk to human health and the environment.
15
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Appendix A — Strategy for Hazardous Waste Minimization and Combustion
ACCOMPLISHMENTS IN RISK ASSESSMENT
EPA GOALS
4 Advance scientific under-standing on combustion issues and
risk assessment, and ensure that permits are issued at
facilities in a manner that protects against unacceptable
risks to human health and the environment. Use sound
science in technical decision-making.
EPA ACTIVITIES
• Since May 1993, Regions and States have been advised of
EPA's policy, as stated in the Draft Hazardous Waste
Minimization and Combustion Strategy, that the permitting
process for hazardous waste combustion facilities should
include a full risk assessment that covers indirect as well
as direct exposure pathways.
• In November 1993, EPA released for review, by the public and
the Science Advisory Board, the Draft Addendum to update the
Agency's 1990 guidance document on conducting indirect
exposure risk assessments. Public and SAB comments are
being considered at the present time, and the Agency is
working to revise the full guidance document (including the
Addendum) in light of those comments.
• In May 1994, EPA released its current implementation
guidance for conducting risk assessments for RCRA combustion
facilities. The document provides specific, detailed
methodologies for conducting risk screening assessments as
well as a revised list of hazardous constituents to be
evaluated. In addition, the guidance also contains revised
information on how to plan and conduct trial burns in light
of the information needed to conduct the indirect risk
assessments called for by the Draft Strategy. The Agency
plans to issue a revised version of the risk screening
methodology by early 1995.
• OSW has constituted a risk assessment technical group to
assist Regions and states in conducting risk assessments at
RCRA combustion facilities. This technical assistance group
is comprised of risk assessment experts from EPA's Office of
Research and Development (ORD), the Office of Solid Waste,
and Regional offices.
• OSW and ORD have participated with the Regions in reviewing
several of the initial risk assessments performed after
announcement of the Draft Strategy in May 1993.
16
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APPENDIX B
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Appendix B — Strategy for Hazardous Waste Minimization and Combustion
VOLUNTARY INITIATIVES IN RESPONSE TO DRAFT STRATEGY
The Draft Strategy on Hazardous Waste Minimization and
Combustion posed a challenge to industry. After its announcement
EPA asked companies to step forward and meet the objectives of the
Draft Strategy even without regulatory or other mandatory
requirements. In particular, industry was challenged to create
opportunities for potentially significant environmental actions.
; While a number of companies and organizations explored
different options, several stand out from the rest in terms of an
early commitment to take significant environmental steps. These
include:
American _ Portland Cement Alliance CAPCA) and the Cement Kil
Recycling Coalition (CKRC)
: The APCA and CKRC are cooperating with the Agency on a project
to provide data and information on several issues pertinent to
establishing emissions standards for hazardous air pollutants for
cement kilns. Under this project, testing and data gathering would
begin in winter 1994-95. In addition, the CKRC has agreed to
undertake an information-gathering effort from its members
regarding, among other things, the concentrations of metals in
waste streams being combusted as fuel in cement kilns. Contact-
Craig Campbell, 202-789-1945.
Ash Grove Cement
; Ash Grove Cement is cooperating with the Agency in a testing
program to evaluate the effectiveness of reducing dioxin and furan
emissions by rapidly controlling kiln-off gas temperature by air
andiwater quenching. The tests will also measure dioxin and furan
emissions at the kiln exit (i.e., as well as in the stack) to
determine the extent of dioxin/furan formation in the kiln itself
rather than downstream in the ducting and particulate matter
control device. This testing is scheduled for January-February
1995. Contact: Eric Hansen, 913-451-8900.
Continental Cement Company. Inc.
_ ^Continental Cement has investigated approaches to reduce
dioxin and furan emissions. Continental has replaced its previous
source of shale raw material with a source that contains much lower
leve;ls of organic matter, and has substantially reduced emissions
of both total hydrocarbons and dioxins/furans. The Company has
also performed emissions testing to evaluate various approaches to
further lower dioxin/furan emissions, including rapid quenching of
the kiln off -gas temperature and injection of material to inhibit
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Appendix B — Strategy for Hazardous Waste Minimization and Combustion
the post-combustion formation of dioxin/furans. Additional testing
is planned for fall-winter 1994. Contact: Ron Powell, 314-221-
1740.
ECOVA
ECOVA has developed an innovative community involvement
approach in connection with its facility in Kimball, Nebraska, and
proposed to make this available to another combustion facility
seeking to modify and upgrade its units, with the objective of
providing an improved model for all other facilities to use in
enhancing the level of public information and involvement at the
community level. Contact: Elliott Cooper, 303-279-9712.
Eli Lilly and Company
Eli Lilly and Company proposes to upgrade an incinerator unit
at a facility in Indiana with new air pollution control devices
that would meet prospectively more stringent EPA standards well in
advance of their final promulgation. Testing of the upgraded unit
against an otherwise identical unit would be conducted to develop
data on the degree of emission controls. Strengthened waste
minimization efforts (to reduce incinerator loadings) would also be
included. Contact: Ron Pitzer, 317-276-6196.
Lafarge Corporation
Lafarge has had preliminary discussions with the Agency
regarding cooperating in a testing program at a cement facility.
The testing would include evaluating and sharing data on: (1) the
effectiveness of reducing dioxin and furan emissions by rapidly
cooling kiln-off gas temperature and by injecting materials that
may inhibit post-combustion formation; (2) the relationship between
chlorine levels in feed streams and dioxin/furan emissions; and (3)
emissions of organic compounds to characterize the emissions as
completely as reasonably possible. Contact: David Carroll, 703-
264-3652.
National Association of Chemical Recvclers fNACR)
NACR undertook a comprehensive data-gathering effort to
determine the life-cycle flow of metal-bearing waste streams from
generation .through treatment ultimately to combustion. In
addition, the NACR membership developed and adopted a detailed plan
to implement their Responsible Recycling principles. Contact:
Chris Goebel, 202-434-8740.
Rollins Environmental Services
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Appendix B — Strategy for Hazardous Waste Minimization and Combustion
i Rollins is cooperating with the Agency in a testing program to
evaluate alternative control devices to lower emissions of toxic
metals and particulate matter (PM) at a commercial incineration
facility in concert with achieving low dioxin emissions. The air
pollution control system currently in place at Rollins' facilities
uses a variety of wet scrubbers that effectively control dioxin (to
less than 0.1 ng. TEQ) and acid gas emissions, but does not control
PM 6r metals to comparable levels. Testing of continuous emissions
monitors for PM is also planned as part of the testing program.
The i testing is scheduled for January 1995. Contact: Phillip
Retallick, 302-426-3948.
S outhdown. Inc.
Under the leadership of Southdown, Inc., a consortium of
private companies have joined together in a non-profit venture to
work with EPA to expedite development and commercial availability
of reliable continuous emission monitors (CEMs) for metals, an
important technical advancement that should significantly improve
real-time emission monitoring capability. Contact: Edgar Marston,
7134650-6200.
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APPENDIX C
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Appendix C — Strategy for Hazardous Waste Minimization and Combustion
BACKGROUND FOR EPA'S STRATEGIC GOALS — HAZARDOUS WASTE
GENERATION AND MANAGEMENT
I. Hazardous Waste Managed in RCRA System
Based on 1991 Biennial Report Survey (BRS) data, of the 306
million tons of hazardous waste reported as generated in 1991,
294 million tons were managed as follows:
TABLE 1. Hazardous Waste Management Practices in the United States
(based on 1991 BRS data)
MANAGEMENT METHOD
Aqueous Treatment
Other: Treatment (e.g.,
neutralization, settling,
evaporation)
Deep Well Injection
Solvent Recovery
Combustion (Incinerators and
BIFs)
!
Landfill and Land Treatment
Other; (e.g., metal and other
recovery, sludge treatment,
stabi lization)
TONS OF WASTE MANAGED (Millions)
206
32
23
4
3
2
24
PERCENTAGE OF TOTAL
70%
11% :
8%
1%
1%
1%
8%
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Appendix C — Strategy for Hazardous Waste Minimization and Combustion
II. Current Volumes of Hazardous Waste Being Combusted
Combustion of hazardous waste is currently an integral and
controversial component of hazardous waste management in the
United States. It has reached this position as the nation moved
away from land disposal in the 1980's and into an era of
treatment to reduce waste volume and toxicity. According to 1991
BRS data, approximately 3.4 million tons of hazardous waste are
combusted in incinerators and BIFs, and another 0.6 million tons
are burned in metal recovery and smelting furnaces. The types of
wastes going to these devices can be broken down as follows:
TABLE 2.
BIFs,
Quantities of Hazardous Waste Managed in 1991 in Incinerators,
and Other Industrial Furnaces (in tons)
CURRENT MANAGEMENT
METHOD
Metal Recovery and
Smelting
Incineration
BIFs
Total
ORGANIC LIQUIDS
54,000
520,000
1,200,000
1,774,000
ORGANIC SOLIDS AND
SLUDGES
6,000
110,000
340,000
456,000
AQUEOUS LIQUIDS
5,000
800,000
1,000
806,000
INORGANIC SOLIDS
AND SLUDGES
490,000
105,000
5,000
595,000
These numbers do not contain the amount of waste sent to combustion from small quantity generators.
2
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Appendix C — Strategy for Hazardous Waste Minimization and Combustion
III.I Universe of Hazardous Waste Incinerator and BIF Facilities
The RCRA combustion facility universe , as of November 1,
1994;, can be broken down as follows:
TABLE 3.
RCRA Combustion Facility Universe (as of November 1, 1994)
Facility Type
Commercial Incinerator
Non-Commercial Incinerator
Commercial BIF
Non-Commercial BIF
Remedial
Chemical Munitions
Incinerator
Permitted
21
120
0
0
0
2
Interim
Status
7
14
38
98
0
0
Proposed
5
21
1
2
2
7
Total
(Potential
Universe)
33
155
39
100
2
9
This universe has been somewhat dynamic since the Draft
Strategy was released. The following changes have occurred over
the last 16 months. Some of the key changes that have occurred
include:
Incinerators
o 8 permitted on-site incinerators (non-commercial) have
withdrawn from the universe.
o 7 commercial and 1 demilitarization incinerators have
• cancelled plans to develop new capacity.
o 4 interim status incinerators decided to clos.e (1
; commercial; 3 non-commercial).
o j 7 new incinerator applications were submitted (1
: commercial; 4 non-commercial; 1 remedial, 1
. demilitarization).
o i authorized state incinerator permit was issued (American
Envirotech in Texas).
o 1 incinerator permit application was denied (Marine Shale
2 This universe does not contain any figures for mobile incinerators or those being used as on-site units
at Superfund remediation sites.
^ Although shown separately in this row, these facilities are included in the incinerator numbers shown
above in the chart.
Although shown separately in this row, these facilities are included in the incinerator numbers shown
above in the chart.
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o
o
o
Appendix C — Strategy for Hazardous Waste Minimization and Combustion
Processors in Louisiana, now on appeal).
BIFs
o 22 interim status BIFs withdrew from universe (6 commercial
cement kilns; 2 commercial boilers; 13 onsite boilers; 1
smelter).
1 commercial cement kiln cancelled plans to burn hazardous
waste.
1 commercial boiler and 1 non-commercial industrial furnace
submitted new applications.
1 cement kiln permit application was denied (National Cement
in California, now on appeal), and 1 on-site BIF application
denied (Maybelline Products in Arkansas).
A number of upcoming permit actions and other changes are
anticipated. However, because many of these permit
determinations involve risk assessments being conducted in
authorized states, it is difficult to develop an accurate
estimate of the number of final permit determinations that will
occur within given time frames. EPA estimates that around 20
(but perhaps up to 40) permit determinations will be made
annually over the next several years. Also at this point, EPA
has information from states indicating that some 30-40 risk
assessments are under way. However, no trial burn plans have
been approved by the regions or the states within the last year.
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Appendix C — Strategy for Hazardous Waste Minimization and Combustion
IV.: Combustion Capacity Based on Universe of Current and
I Proposed Facilities
; Based on 1991 BRS data and other information (e.g., joint
EPA-rindustry surveys), EPA estimates that about 3.4-3.6 million
tons of hazardous waste are being burned annually. In assessing
the total combustion capacity that could be made available, EPA
estimates that about 3 million tons of off-site commercial
capacity exist. Unfortunately, EPA does not have reliable and
complete information on the amount of on-site combustion
capacity, but we do know that about 1.8 million tons are being
burned on-site. Using this 1.8 million tons as representing
total capacity (a conservative approach), then the total annual
combustion capacity would be 4.8 million tons at a minimum.
Sin
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