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.
     i
      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

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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

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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

                                 18

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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-

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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

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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

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       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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