United States Solid Waste and
Environmental Protection Emergency Response EPA530-R-94-045
Agency (5305) November 1994
&EPA The Hazardous Waste
Minimization National
Plan
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THE HAZARDOUS WASTE MINIMIZATION NATIONAL PLAN
Executive Summary
The U.S. Environmental Protection Agency (EPA) is committed
to making pollution prevention the guiding principle of the
Agency's environmental efforts. The 1984 Amendments to the
Resource Conservation and Recovery Act and the 1990 Pollution
Prevention Act set in policy the preference for source reduction
over waste management. EPA is reaffirming this commitment. With
the release of the Hazardous Waste Minimization National Ptap on November 18,
1994, EPA outlines its major goals, objectives, and action items
to pave the way toward national reductions in the generation of
hazardous waste.
This Plan focuses on reducing the generation and subsequent
release to the environment of the most persistent,
bioaccumulative, and toxic constituents in hazardous wastes, and
establishes three goals:
1) To reduce, as a nation, the presence of the most persistent,
bioaccumulative, and toxic constituents by 25 percent by the
year 2000 and by 50 percent by the year 2005.
2) To avoid transferring these constituents across
environmental media.
3) To ensure that these constituents are reduced at their
source whenever possible, or, when not possible, that they
are recycled in an environmentally sound manner.
EPA does not expect that each and every generator of
persistent, bioaccumulative, and toxic constituents in hazardous
waste will reduce the generation of these constituents in waste
by the levels and time frames presented above. EPA intends for
these reductions to be achieved nationally by EPA, states, and
generators working together. i
EPA encourages all states and generators of hazardous waste
containing persistent, bioaccumulative, and toxic constituents to
define their own baseline years, set their own goals and target
years for achieving their goals, and track their own progress
toward their goals. This flexibility will allow states and
generators that have already begun source reduction and pollution
prevention to begin measuring their successes from the year they
started, and will give them flexibility in how they contribute to
the national goals.
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EPA sought widespread input from interest groups,Citizens,
industry, the states and federal regulators, and technical
experts, to establish this Plan. Five key message recurred as a
common theme throughout the many discussions and comments from
the public, and the Agency used these to develop the backbone and
five objectives of the Plan. The Plan presents a combination of
voluntary, regulatory, and institutional mechanisms to achieve
these objectives, as described briefly below:
4 obiactive l; Develop a framework for setting national
priorities; develop a flexible screening tool for
identifying priorities at individual facilities;
identify constituents of concern. EPA will prioritize
pollution prevention efforts based on risk. The Agency
will develop a screening tool to help states and
industry set source reduction priorities. It will be
based primarily on the inherent hazard of constituents
but also will be applicable to hazards posed by
management practices. The Agency already has developed
a prototype screening approach addressing metals in
hazardous wastes managed by combustion and metals in
releases from combustion, and will use it to set
initial waste minimization priorities.
In addition, the Agency will use the screening tool to
develop a list of high-priority constituents for source
reduction and recycling, to assist those states and
generators that are not able to apply the screening
tool.
ob-iective 2; Promote multimedia environmental benefits
and prevent cross-media transfers. The Agency will
propose guidance that encourages implementation of
multimedia pollution prevention programs at all
facilities. Pollution prevention often is not applied
cohesively across different departments at facilities
or between EPA or state offices and companies. EPA
will work with states and facilities to incorporate
efforts across media and avoid duplicative and
counterproductive work.
4 objective 3; Demonstrate a strong preference for source
reduction; shift attention to the nation's hazardous
waste generators to reduce hazardous waste generation
at its source. EPA will promote the focusing of
technical assistance on small- and medium-sized
generators of high-priority constituents; promote the
incorporation of waste minimization in inspection,
permit writing, and enforcement programs; develop
demonstration projects focusing on priority
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constituents; and provide EPA Regions and states with
waste minimization training for inspectors, permit
writers, and enforcement officials, among other actions
to achieve this objective.
Objective 4; Clearly define and track progress; Promote
accountability for EPA, states, and industry. EPA will
identify data necessary to evaluate progress in
reducing the most persistent, bioaccumulative, and
toxic constituents. EPA will explore databases that
contain information on hazardous waste quantities and
how they are managed (such as the Biennial Reporting
System (BRS) Database), and on how toxic chemicals are
released to the environment and are managed (the Toxic
Release Inventory (TRI) Database).
Objective 5; Involve citizens in waste minimization
implementation decisions. EPA will continue to
encourage generators of hazardous wastes to share
information with the public and be accountable to the
public. In particular, EPA encourages facilities to
share information on progress towards waste
minimization initiatives that were specifically
identified. EPA will publish guidance to EPA Regions,
states, and industry, identifying how waste
minimization information could be made available to the
public.
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THE HAZARDOUS WASTE MINIMIZATION NATIONAL PLAN
Historical Background
Over the past 20 years, the United States Environmental
Protection Agency (EPA) has made great strides in environmental
protection through the treatment and clean up o;f pollutants. It
has become clear, however, that managing waste only after it is
generated ("end-of-pipe" controls) cannot adequately address the
important environmental issues facing the nation today.
In 1991, approximately 306 million tons of hazardous waste
were generated in the United States . In addition,
approximately 3.2 billion pounds of toxic chemicals were released
into the environment. To reduce hazardous waste generation and
toxic chemical releases to air, water, and land, EPA is committed
to encouraging pollution prevention at the source whenever
possible.
The Resource Conservation and Recovery Act (RCRA), as
amended by the Hazardous and Solid Waste Amendments of 1984
(HSWA), emphasizes a national policy that focuses on source
reduction as the highest priority. With the passage of HSWA,
Congress specifically declared that the reduction or elimination
of hazardous waste generation at the source should take priority
over management (i.e., recycling, treatment, or disposal) of
waste after it is generated.
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In 1990, Congress further confirmed the key role of
pollution prevention in the nation's environmental protection
scheme, by passing the Pollution Prevention Act. In the Act,
Congress essentially codified as law the hierarchy of management
options that mirror those espoused by EPA's waste management
programs, i.e., prevention first, then environmentally sound
recycling, treatment, and disposal.
In her 1993 Earth Day statement, EPA Administrator Carol M.
Browner said "this Administration is committed to making
pollution prevention the guiding principle of all our
environmental efforts." This Waste Minimization National Plan is
a reflection of that commitment. (For definitions of waste
minimization, source reduction, recycling, and pollution
prevention, see Appendix A.)
Based on 1991 Biennial Report Data, United States
Environmental Protection Agency.
Based on "1992 Toxics Release Inventory; Public Data
Release," United States Environmental Protection Agency, EPA 745-
R-94-001, April 1994.
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Previous Releases: Draft Hazardous Waste Minimization and
Combustion Strategy and Draft Waste Minimization National Plan
On May 18, 1993, Administrator Browner released EPA's
Draft strategy on Hazardous Waste Minimization and Combustion.
One of the Strategy's main goals was to reduce the amount of
hazardous waste generated in this country through
establishing a strong preference for source reduction over waste
management. It also called for a better method of encouraging
public participation in setting a national source reduction
agenda. Over the next 12 months, EPA held discussions with
various stakeholders including public interest groups, citizens,
industry, state and federal regulators and technical experts.
These discussions focused on waste minimization and other goals
identified in the Draft Strategy.
Then, in May of 1994, EPA released the Draft Waste
Minimization National Plan. The Draft Plan proposed a series of
waste minimization initiatives to reduce the amount of hazardous
waste destined for combustion, and proposed a longer-term effort
to minimize all hazardous waste generated. EPA again sought
input from stakeholders on the Plan. The Agency held a three-day
focus group meeting with "external stakeholders" and a one-day
meeting with states in September 1994, as well as a meeting with
environmental groups in October 1994. EPA also announced the
Plan and a draft methodology for setting waste minimization
priorities in the Federal Register and invited public comment.
Today7s Release; EPA/s Waste Minimization National Plan
National Waste Minimization Goals .
The National Plan addresses those constituents in hazardous
waste, or compounds they degrade to, that pose potential threats
to human health and the environment, because they are:
4 Persistent, after they are released into the
environment (i.e., they generally do not break down
into other substances once they are released into the
environment;
3 Other goals of the 1993 Draft Strategy on Hazardous Waste
Minimization and Combustion were: strengthening federal controls
governing hazardous waste incinerators and boilers and industrial
furnaces (BIFs); enhancing public participation at the time for
and prior to permitting a facility; assessing multi-pathway risk
at each combustion facility to be permitted and considering the
assessment prior to making a permit decision; and ensuring that
regulatory and permit requirements are vigorously enforced.
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4 Bioaccumulative i.e., they tend to accumulate in plant
and animal tissues); and
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4 Toxic, thereby having the potential to harm the
environment or adversely impact human health (e.g.,
cancer, reproductive, and mutagenic health effects).
The :Plan presents three goals:
1) To reduce the amount and toxicity of the most persistent,
bioaccumulative, and toxic constituents in hazardous wastes
that are generated by 25 percent in the year 2000 and by 50
percent by the year 2005.
2) To avoid transferring persistent, bioaccumulative, and toxic
constituents across environmental media. ',
3) To ensure continual improvement in reducing these
constituents at their source whenever possible, or, when not
possible, that they are recycled in an environmentally sound
manner.
EPA intends for these goals to be achieved by states and
generators working together. However, EPA does not expect that
every generator will reduce the generation of constituents in
wastes by the levels, or time periods specified in the goal;
rather, we expect the national goal to be reached on an
aggregated basis.
Implementation Roles |
Identifying the roles that stakeholders can play in
implementing this Plan is essential to effecting meaningful waste
reduction. Based on stakeholder comments, EPA has outlined
suggested roles for generators, states, and EPA.
It should be noted that one of the major messages that EPA
received from stakeholders in developing this Plan was that the
approaches used to accomplish the objectives in the Plan should
allow states and industry a great deal of flexibility. EPA
recognizes that individual generators have the best information
on which waste minimization alternatives are technically and
economically feasible. (For specific examples of some
generators' recent source reduction and recycling implementation
successes, see Appendix B.) In addition, many states already
EPA will generally use 1991 as the baseline year in
measuring national progress; however, EPA also believes that
generators should be able to select a different base year for
measuring their progress against their own goals and the national
goal, to account for reductions they have already achieved.
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have an effective framework and programs that are resulting in
real reductions in hazardous wastes and emissions. This Plan
serves as a basic framework from which to expand and does not
preclude industry and states from setting their own priorities
and goals, and measuring their own progress. Roles have been
defined in recognition of these facts.
EPA encourages all generators of hazardous wastes containing
persistent, bioaccumulative, and toxic constituents to set their
own goals and target years for achieving their goals, and track
SSiS Jrogress toward their goals. In addition, some generators
began waste minimization activities many years ago and may wish
to measure their progress relative to a different baseline year
than 1991, the year EPA will use to measure the nation s
progress. In setting their own priorities and implementing
source reduction and recycling activities, we expect that
generators will consider factors such as technical and economic
feasibility, product stewardship, and community concerns.
States will contribute to achieving the national goal by
establishing their own goals and priorities. EPA does not
anticipate conflicts between the national goals and state-level
goals.
EPA Headquarters will develop a screening tool that EPA
Regions, states, and industry can apply as a point of departure
in setting their own priorities. EPA will also apply this tool
to develop a national list of priority constituents to assist
states or generators that are unable to apply the screening tool
themselves.
EPA will provide support to generators, states, and EPA
Regions as they implement this Plan. In addition, in the event
that generators and states do not make progress toward the goal
over a certain timeframe, EPA will consider whether a greater
federal role is needed.
Plan Objectives
EPA received many comments during stakeholder discussions
and public review. The National Plan reflects careful
consideration of all of these comments. Five key messages
recurred as a common theme, and these have become the foundation
and objectives of the National Plan.
This Plan outlines a combination of voluntary, regulatory
and institutional mechanisms to achieve these five waste
minimization objectives. These objectives and the actions EPA is
taking to implement them are described below.
Qb-iective l: Develop a framework for setting national prior it ies;
develop and distribute a flexible screening tool for identifying
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priorities at individual facilities; identify constituents of
concern.
Objective 2; Promote multimedia environmental benefits and
prevent cross-media transfers.
Objective 3; Demonstrate a strong preference for source
reduction; shift attention to the nation's hazardous waste
generators to reduce hazardous waste generation at its source.
Objective 4; Clearly define and track measures of progress.
Promote accountability for EPA, states, and industry.
Objective 5: Involve citizens in waste minimization
implementation decisions.
EPA projects related to each objective that are already
underway or that will be pursued in the future are discussed
below. EPA also will explore the value of implementing other
actions as described in Appendix C.
Ob-iective 1; Develop a framework for setting national priorities;
develop and distribute a flexible screening tool fnr identifying
priorities at individual facilities; identify nnns-hjtuents of
concern. ~
EPA will set priorities for source reduction and
environmentally sound recycling based primarily on the inherent
hazard of constituents and wastes. This approach is particularly
effective in addressing multimedia risks that are "difficult to
predict," such as those that could result from unexpected
failures of waste management practices (e.g., cbmbustion unit
operation "upsets", landfill liner leaks, and transportation
accidents) and from unexpected occupational exposures. This
approach implies a broader role for source reduction and
environmentally sound recycling, addressing "high-hazard"
constituents regardless of how they ultimately are managed. It
is consistent with the statutory language in RCRA and in the
Pollution Prevention Act which strongly promotes source reduction
over waste management.
At the same time, EPA recognizes that there may be
situations where releases from industrial processes and waste
management practices pose significant risks or hazards that could
be addressed by promoting source reduction or environmentally
sound recycling. This may include risks from constituents that
are difficult to manage using certain practices>(e.g., metals,
which are not destroyed by combustion and remain potentially
available to the environment). Consequently, the Agency also
plans to examine, where appropriate, the hazard associated with
for example, Toxics Release Inventory (TRI) releases.
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ACTIONS!
4 EPA will develop a screening tool and a list of high-
priority constituents for source reduction and recyclxng.
EPA's primary objective is to promote source reduction and
the screening tool available (at least in draft) in 1995.
lead to ground water contamination problems.
priorities.
To establish initial national priorities and to assist
perspective.
* EPA will use the results from the prototype screening
approach to set priorities for metals.
FPA has developed a prototype screening tool addressing
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Objective 2: Promote multimedia environmental benefits and
prevent cross-media transfers.
In the Pollution Prevention Act of 1990, Congress made it
clear that pollution prevention must be implemented in a
multimedia framework, even though most environmental statutes are
media specific. The goals in this National Plan are structured
to address this concern. For example, the goals are stated in
terms of reductions of specific constituents within wastes,
rather than reductions of hazardous wastes as a; whole. As a
result, achieving the goal should create benefits for preventing
pollution to all media.
ACTION; !
EPA will propose guidance to encourage the implementation of
multimedia pollution prevention programs at all facilities.
One of the strongest messages from stakeholders in response
to EPA's Draft Waste Minimization National Plan and Guidance to
Hazardous Waste Generators on the Elements of a Waste
Minimization Program in Place was that pollution prevention
planning efforts are often not coordinated across media. This
occurs both within companies, where different departments may
have responsibility for different media pollution control
programs, and between EPA or state offices and a particular
company, where different offices encourage pollution prevention
planning without fully incorporating cross-media impacts. Often,
this results in duplicative, time-consuming, and sometimes
counterproductive efforts.
As a first step toward meeting this objective, EPA will
expand the scope of its Guidance to Hazardous Waste Generators on
the Elements of a Waste Minimization Program in Place to
encourage implementation of multimedia pollution prevention
programs at all facilities. EPA will work closely with all
states, particularly those that have moved forward on multimedia
pollution prevention and permitting programs, since these states'
programs may serve as useful models for the future.
Objective 3: Demonstrate a strong preference for source
reduction; shift attention to the nation's hazardous waste
generators to reduce hazardous waste generation at its source.
In the past, the primary emphasis was placed on ensuring the
safe management of hazardous wastes once they were generated.
The 1984 amendments to RCRA initiated a shift in focus toward the
generation of the waste, requiring generators to certify that
they have a "program in place" to reduce the volume and toxicity
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of their hazardous wastes.
The National Plan continues this shift of attention toward
pollution prevention and hazardous waste generators. Action
items that encourage generators to implement waste minimization
programs are discussed below.
ACTIONS8
4 EPA will implement several VOLUNTARY MECHANISMS, including!
1) Promote focused technical assistance to small- and
medium- sized generators of constituents of concern.
EPA entered into a cooperative agreement with the National
Pollution Prevention Roundtable (NPPR) to develop a strategy for
providing technical assistance to generators of high-priority
constituents. Over 120 state and local pollution prevention
technical assistance centers across the country assist thousands
of waste generators each year. The centers help generators
identify cost-effective waste reduction methods, thereby helping
them to rely less on costly waste management. EPA will work with
the NPPR during 1995 to implement and expand this strategy.
2) Developing outreach and communication mechanisms.
EPA will develop pollution prevention technical guidance
manuals for selected industrial sectors or processes generating
high-priority constituents. The technical guidance manuals will
examine source reduction and environmentally sound recycling
alternatives and assess the technical/economic feasibility and
potential environmental impacts of each alternative. EPA will
set up mechanisms to disseminate this information to regulators,
technical assistance centers, and other stakeholders. In
addition, the Agency will prepare a document that identifies
promising research underway to reduce generation of priority
constituents.
3) Providing guidance to states on incorporating waste
minimization in hazardous waste management planning.
Section 104 (c) (9) of the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) requires
5 Large quantity generators must certify that they have a
"program in place" on manifests when they ship their wastes off-
site (§ 3002(b)); generators who also treat, store, or dispose of
their wastes on-site must certify that they have a "program in
place" (§ 3005(h)). Small quantity generators must certify when
they ship their wastes off-site, but they certify that they are
making a "good faith effort" to reduce their wastes.
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states to assure that adequate capacity exists to manage
hazardous wastes generated over a 20-year period. Failure to
provide this assurance results in denial of Superfund Trust fund
money for remedial actions. To make this showing, EPA has asked
states to submit Capacity Assurance Plans (CAPs) that demonstrate
the state's understanding of current in-state hazardous waste
management, and to develop plans for future management of
hazardous waste.
EPA plans to release a draft waste minimization guidance
document in 1995 to aid states in developing the waste
minimization component of hazardous waste management planning
efforts. The guidance will emphasize flexibility in state
planning of waste minimization activities and cover: data sources
and methods for setting priorities; making projections of future
reductions, and measuring progress; barriers and incentives to
increased use of waste minimization; and state program and
generator success stories. The CAP program will incorporate
comments from states on the draft document, and also plans to
make some grant funding available to states for this voluntary
effort. |
EPA will implement several mechanisms within the RCRA
REGULATORY framework/ including:
1) Developing a program for working with generators to
promote waste minimization
While many companies have made significant progress in waste
minimization over the past ten years, quantitative and anecdotal
data indicate that there are still many companies who have not
taken advantage of the potential hazard reduction and cost
savings benefits of waste minimization planning. Consequently,
EPA's Offices of Solid Waste and Enforcement and Compliance
Assurance will develop during 1995 a program which identifies how
to work with generators that will encourage waste minimization
progress. For example, EPA believes that generators who ship
wastes that are identified as high-priority off-site for
treatment, storage or disposal, and generators who manage their
wastes on-site could complete an analysis of cost effective waste
minimization options. EPA will work with these companies to
encourage completion of such on analysis. EPA will emphasize
flexibility in conducting such analysis. In 1995, EPA and the
States will develop and begin implementing an action specific
plan to enable this to take place.
2) Issuing revised guidance on the use of Supplemental
Environmental Projects (SEPs).
The revised policy will provide greater ease to Regions and
states in constructing viable SEPs as a tool in negotiating
enforcement settlements. This document will provide better
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guidance on appropriate circumstances for their use, as well as
clarifying activities that qualify for inclusion in a SEP. This
guidance will be issued in 1995.
3) Working with EPA Regions and states to provide waste
minimization training for inspectors, permit writers
and enforcement officials.
Many facility stakeholders have expressed concern that
inspectors, permit writers, and enforcement officials do not
adequately understand waste minimization principles from a
production process perspective. To remedy this situation, EPA is
developing a national handbook and training course on the
principles of waste minimization. This training is designed for
inspectors, who must verify that generators have certified that
they have a waste minimization program in place, for RCRA permit
writers, who promote waste minimization conditions in RCRA
permits, and for enforcement officials, who assist in promoting
waste minimization through (SEPs). Several EPA Regions and
states have waste minimization training programs available, and
many others have expressed strong interest in establishing one.
The handbook and training course will build on the waste
minimization inspection programs currently used in EPA Regions
and states, and will network existing training capability in
Regions and states to incorporate waste minimization principles
into inspection, permit writing, and enforcement functions. The
handbook and training curriculum will be developed completed in
1995.
4 EPA will implement several INSTITUTIONAL MECHANISMS, that
will allow the RCRA program to be implemented so as to
encourage the EPA Regional Offices and State environmental
agencies to facilitate generators' waste minimization
actions, including:
1) Incorporating the goals developed in the National Plan
into the RCRA Implementation Plan (RIP)
Both Regions and states use the RIP to focus their RCRA
program activities each fiscal year. The RIP designates national
RCRA priorities for the year and outlines expectations that EPA
Headquarters places on priority actions to be implemented by
Regions and states. For example, in the Fiscal Year 1995 RIP,
EPA outlined a process by which Regions and states could identify
generators of hazardous wastes going to combustion units and use
a variety of tools to encourage these generators to pursue
further waste minimization activities. EPA intends to
incorporate the national goals presented in this Plan into the
RIP for Fiscal Year 1996 and following years. The RIP will be
the primary vehicle for setting EPA's expectations for state
hazardous waste programs to accomplish the national goal, along
with accountability measures for states and Regions to show their
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progress in meeting the national goal (see below).
2) Developing accountability measures and incentives for
the Regions and states to promote accomplishments
toward achieving the national goals.
Under the current hazardous waste program implementation
scheme, there are few incentives for EPA Regions and states to
focus their attention on hazardous waste generators. Most
program activities focus on the treatment, storage, and disposal
facilities managing the hazardous waste that is generated.
Accountability measures, which EPA Headquarters uses to track the
implementation actions of states and Regions, typically focus on
treatment, storage and disposal facilities. In revising the
scheme of accountability measures, EPA intends to put a heavier
focus on hazardous waste generators. EPA is working to develop a
revised scheme for the fiscal years following 1995.
Objective 4; Clearly define and track measures, of progress.
Promote accountability for EPA, states, and industry.
ACTION;
EPA will identify necessary data to evaluate progress in
reducing the most persistent, bioaccumulative, and toxic
constituents
To avoid information collection and processing burdens, EPA
will explore using existing data sources to evaluate national
progress toward the goal. Databases exist that contain
information on hazardous waste quantities and how they are
managed (the "BRS" database), and on how toxic chemicals are
released to the environment or are managed (the "TRI" database).
EPA is reassessing the ability of these and other hazardous waste
information databases (e.g., state databases) for measuring
progress in waste minimization, through the "Measurement Pilot
Projects". EPA has sponsored these Pilot Projects with four
states. Each state will submit to EPA state-level evaluations
and recommendations about collecting data to measure waste
minimization progress. EPA will receive those states'
recommendations in Fall/Winter 1994. In addition, EPA is
taking a comprehensive look at waste information needs, including
data needed to measure waste minimization. ',
Objective 5; Involve citizens in waste minimization
implementation decisions. ;
ACTIONS;
The four states are Alaska, Ohio, Oregon,, and Washington.
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4 EPA will continue to encourage generators of hazardous
wastes to share waste minimization priorities and
initiatives, and be accountable to the public.
As part of the Biennial Report, EPA has just published a
list of large quantity generators of hazardous waste (using 1991
data), that were required to certify that they had a Waste
Minimization Program in Place. By putting this information up on
the Internet and the RTKNet, EPA expects that the list will reach
a much wider audience than has been possible using only paper
publications. This information is one tool for the general
public to use in better understanding the source reduction and
environmentally sound recycling efforts of hazardous waste
generators. Members of the general public who are most directly
affected by hazardous waste can also become more familiar with
hazardous waste generation patterns as a result of publication of
this list. The publication of the list also will enable them to
pursue further sources of information.
t EPA will publish guidance to Regions, states, and industry,
identifying when and how waste minimization information
should be made available to the public during the permit
process.
EPA is planning to publish a final rule in the summer of
1995 on "RCRA Expanded Public Participation and Revisions to
Combustion Permitting Procedures" (see June 2, 1994 proposal,
published at 59 FR 28680). In addition to the final rule, EPA
plans to develop guidance, in fall 1995, that focuses
specifically on § 124, Subpart B of RCRA procedures applicable to
RCRA permits. This guidance reflects EPA's desire for the public
to understand and comment on waste minimization.
This guidance to EPA Regions and states will include
information such as:
Procedures for highlighting pollution prevention
information in any public notices.
« Instructing permit writers to acquire facility-specific
waste minimization information and make it available to
the public. Facility specific information that may be
highlighted includes:
Historical TRI information for facilities in
question, (highlighting chemical generation,
recycling, treatment, transfers and releases, and
pollution prevention activity).
Historical Biennial Report data, highlighting
waste generation, waste management, and waste
minimization activities.
Any previous 3002(b) or 3005(h) waste minimization
program in place certifications signed by
facilities and any publicly available non-CBI
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supporting documentation facilities may have on
file.
A summary of any State or local pollution
prevention requirements (e.g., requirements for
pollution prevention facility plans), and a copy
of facility-specific publicly available
documentation (e.g. , a facility-rspecif ic pollution
prevention facility plan).
A list of technical assistance contacts that have
information on pollution prevention opportunities.
Pollution prevention contacts at facilities.
Procedures for arranging pollution prevention
meetings with facilities if citizens identify this
as a need.
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Appendix A - Definitions of Terms
In this document, EPA is using terms such as "waste
minimization," "source reduction," "recycling," "environmentally
sound recycling," and "pollution prevention." There has been and
continues to be much debate over what activities can be
classified as waste minimization, for example, or as source
reduction.
For the purposes of the RCRA Waste Minimization National
Plan, EPA is reiterating its previous explanation, published in
the May 28, 1993 Federal Register at 58 FR 31115, which explained
and defined these terms as follows:
EPA believes that waste minimization, the term employed
by Congress in the RCRA statute, includes (1) source
reduction, and (2) environmentally sound recycling. (See
later discussion for further clarification of which types of
recycling are not waste minimization.)
The first category, source reduction, is defined in
section 6603(5)(A) of the Pollution Prevention Act, 42
U.S.C. 13102(5)(a), as any practice which (i) reduces the
amount of any hazardous substance, pollutant, or contaminant
entering any waste stream or otherwise released into the
environment (including fugitive emissions) prior to
recycling, treatment, or disposal; and (ii) [r]educes the
hazards to public health and the environment associated with
the release of such substances, pollutants, or contaminants.
The term includes equipment or technology
modifications, process or procedure modifications,
reformulation or redesign of products, substitution of raw
materials, and improvements in housekeeping, maintenance,
training, or inventory control. j
EPA believes this definition is appropriate for use in
identifying opportunities for source reduction under RCRA.
The second category, environmentally sound recycling,
is the next preferred alternative for managing those
pollutants which cannot be reduced at the source. In the
context of hazardous waste management, there are certain
practices or activities which the hazardous waste
regulations define as "recycling." The definitions for
materials that are "recycled" are found in Title 40 of the
Code of Federal Regulations, § 261.l(c). A "recycled"
material is one which is used, reused, or reclaimed. A
material is "used or reused" if it is (i) employed as an
7 40 CFR 261.l(c)(7).
A-l
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ingredient (including use as an intermediate) in an
industrial process to make a product (for example,
distillation bottoms from one process used as feedstock in
another process)* * * or (ii) employed in a particular
function or application as an effective substitute for a
commercial product.* * *
A material is "reclaimed" if it is "processed
recover a usable product, or if it is regenerated."
Some readers of [the May 28, 1993 Federal Register
notice] may question whether certain types of recycling are
within the concept of waste minimization. EPA believes that
recycling activities closely resembling conventional waste
management activities do not constitute waste minimization.
Transfer of hazardous constituents from one
environmental medium to another also does not constitute
waste minimization. For example, the use of an air stripper
to evaporate volatile organic constituents from an aqueous
waste only shifts the contaminant from water to air.
Furthermore, concentration activities conducted solely for
reducing volume does not constitute waste minimization
unless, for example, concentration of the waste is an
integral setup in the recovery of useful constituents prior
to treatment and disposal. Similarly, dilution as a means
of toxicity reduction would not be considered waste
minimization, unless dilution is a necessary step in a
recovery or a recycling operation.
Several questions have been raised regarding whether EPA
considers burning a hazardous waste for energy recovery a form of
recycling that is "waste minimization." As stated in the May 23,
1994 Draft RCRA Waste Minimization National Plan (p.2) and in the
RCRA/Superfund Hotline Monthly Report for July 1994, EPA does not
consider burning hazardous wastes for energy recovery to be
"waste minimization." Burning the hazardous waste for its energy
value closely resembles incineration, a conventional waste
management activity, because in both burning for energy recovery
and in incineration, constituents are either destroyed by the
burning process or are emitted into the air.
8 40 CFR 261.l(c)(5).
9 40 CFR 261.1(C) (4) .
A-2
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Appendix B - Examples of Successful Waste Minimization Actions
Described below are examples of seven hazardous waste
generators' waste minimization activities; these examples outline
process and waste information, results, and cost savings the
generators achieved. i
1.0 HEADLINE: Raw Material Substitution and Process Modification
at an Electronic Component Manufacturing Facility
2.0 SIC CODE: Electronic Components & Accessories/SIC 3674
3.0 NAME & LOCATION OF COMPANY: Siltec Silicon; i 1351 Tandem Avenue
N.E.; Salem, OR 97303; Murray McCareary, 503/371-0041
!
4.0 CASE STUDY SUMMARY: |
4.1 Pollution Prevention Program Description:
Siltec, a 600 employee company, recently eidopted a total
quality management (TQM) approach to doing business. Among the
benefits of this approach, Siltec has been able to continuously
improve its environmental quality program. Siltec's Board of
Directors and shareholders approved a resolution to make safety
and environmental projects first priority when making decisions
about capital investments and projects.
Siltec established priorities, plans, and goals around four
major themes:
Reducing or eliminating the use of toxic substances;
Minimizing or eliminating the generation of hazardous
wastes;
Practicing resource conservation; and
Establishing strong internal environmental systems to
ensure ongoing prevention and protection.
Siltec's first goal was to completely eliminate use of
chlorofluorocarbons (CFCs) and Halons. The second goal was to
eliminate the use of 1,1,1-trichloroethane (TCA) and
trichloroethylene (TCE). Subsequent goals addressed eliminating
acetone, ammonium hydroxide, hydrogen peroxide, and chromic acid.
In general, Siltec viewed those chemicals being used in the
greatest volume as the best opportunities for waste reduction.
After investigating immediate waste reduction opportunities
based on chemical inputs, Siltec addressed waste reduction
opportunities based on energy and water conservation and
recycling.
4.2 Process & Waste Information: i
B-l
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TCE and TCA were used in the production processes to remove
wax from process equipment. By changing the wax used and
utilizing an industrial wax stripper in combination with hot
caustic, the need for both solvents was eliminated. The
replacement chemicals are commonly used and present a low degree
of environmental hazard. Fire fighting Halon-based systems were
replaced with water sprinklers and carbon dioxide or dry chemical
fire extinguisher.
Acetone presented employees with an unacceptable safety
hazard. Through careful study and trials, Siltec identified
isopropyl alcohol as an acceptable substitute. Looking to
subsequently minimize the generation of waste isopropyl alcohol,
Siltec purchased two industrial boilers that could be fueled by
alcohol or natural gas. The alcohol, whose use is being phased
out completely, will be used to fire the boilers. Once the
alcohol is eliminated, the boilers will be fired with natural
gas.
Ammonium hydroxide and hydrogen peroxide were eliminated
from process operations through modification of the process
operations. These changes resulted in reduced material
purchasing and handling, simplified storage, and lower waste
treatment and related costs.
Chromic acid is used in an etching process. Process
modifications have resulted in substantially reduced waste
chromic acid. However, an acceptable alternative that will
eliminate the use of chromic acid is still being sought.
Siltec has implemented several recycling and recovery
programs:
waste process heat recovery;
water conservation;
paper recycling;
scrap "poly" recycling;
shipping pallet reuse;
scrap metal recycling; and
used drum reuse.
4.3 Scale of Operation: Facility wide
4.4 State of Development: Fully implemented
4 5 Level of commercialization: Techniques and measures
are broadly applicable across other industrial sectors
utilizing comparable technologies and processes.
4.6 Balances & substitutions:
B-2
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CHEMICAL/
RESOURCE
Freon TF
Freon 23
Freon 116
Trichloroeth
ane
Trichloroeth
ylene
Acetone
Ammonium
Hydroxide
Hydrogen
Peroxide
Isopropyl
Alcohol
Chromic Acid
Waste
Heat Energy
Water
Waste Paper
Scrap Poly
Empty Drums
UNITS
OF
MEASURE
Pounds "
Cylind
ers
Cylind
ers
Pounds
Pounds 3
Gallon
s
Pounds5
Pounds9Z
Gallon 3
s
Gallon
s
KWH/yr
NA
Pounds
Pounds
Drums
1989-
1990
USAGE
3,815
1
2
432
8,937
100
2,703 4:
3,696 63
1,064
8,721
NA
NA
NA
NA
NA
1990-
1991
USAGE
0
0
0
0
0
0
5,893
0,916
o10
5,967
NA175,
NA
NA 29,
NA255,
NA 2
REDUCTION
100% 12
100%
100%
100%
100% 1
100%
23% 9
34% 20
100%
32%
900 /yr
12-15%
000 /yr
000/yr
0/week
ANNUAL
SAVINGS
($)
9,501
1,679
2,725
695
1,174
610
5,340
3,660
NA
2,052
NA
NA
NA
NA
NA
NA = Not Available
5.0 ECONOMICS:
Less than $150,000 has been spent for process changes and
opportunity assessments. Labor costs have not been carefully
monitored and instead have been absorbed into general overhead
costs.
10
The isopropyl alcohol has been converted to a fuel.
1991, Siltec used 11,420 gallons of isopropyl alcohol.
In
B-3
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In 1989, Siltec instituted a five-year pro-active
environmental effort to upgrade all existing facilities and
systems. As of 1992, over $9 million have been invested towards
completion of this plan.
Costs savings due to particular measures are described in
Section 4.0
6.0 DATE CASE STUDY WAS PERFORMED: 1992
7.0 CONTACTS & CITATION
Commendation, Second Annual Oregon Governor's Award for Toxics
Use Reduction, 1992
Oregon Waste Reduction Assistance Program
Oregon Department of Environmental Quality
811 S.W. Sixth Avenue
Portland, OR 97204
Sandy Gurkewitz 503/229-5918, Department of Environmental
Quality
B-4
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1.0 HEADLINE: Process Modification and Material Substitution at
a Steel Mill
2.0 SIC CODE: Primary Metals/SIC 3312 i
3.0 NAME & LOCATION OF COMPANY: Oregon Steel Mills; 1000 S.W.
Broadway, Suite 2200; Portland, OR 97205; Mark Rowsell,
503/223-9228 ]
4.0 CASE STUDY SUMMARY:
4.1 Pollution Prevention Program Description:
Oregon Steel Mills, Inc. (OSM) is committed to environmental
improvements in their procedures and practices as is evidenced by
their Corporate Environmental Policy Statement. The goal is to
reduce air emissions, toxics use, and hazardous waste generation,
and incorporate recycling activities into operations. As part of
the company's commitment, they joined EPA's 33/50 program in
1989. Under this program, OSM will attempt to reduce hazardous
waste generation by 33 percent by the end of 1993 and by 100
percent by 1995.
This policy applies to all facilities owned and operated by
OSM, but each facility has also developed site-specific policies
as well as employee involvement in waste reduction programs. OSM
established an Environmental Committee to address all issues and
review all chemical and equipment purchases and any process
changes. In 1992, OSM implemented a hazardous materials tracking
system enabling them to track materials from purchase to
disposal. This allows the Environmental Committee to identify
and implement ongoing toxic use and waste reduction programs
throughout their operations. i
j
4.2 Process & Waste Information:
OSM uses an electric arc furnace that produces a dust that
is a listed hazardous waste (K061). OSM developed a glass
manufacturing technology known as Classification , which
recycles this dust along with other materials to make a
commercial glass product. The result is complete elimination of
the hazardous waste. Approximately 7,000 tons per year of the
dust is reused in the glass production in addition to the
conservation of natural resources (e.g., iron ore), which is
normally required in the glass production.
i
Another effort of OSM involved changing from atomizing to
non-atomizing nozzles in their paint spray equipment. This
change resulted in a 15 percent reduction in paint waste residues
and allowed the use of a paint that is lower in solvents.
B-5
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In 1992, OSM voluntarily eliminated PCBs from its plant by
replacing three PCB-containing transformers with non-PCB
transformers. The company also replaced their chromium
refractory brick with the Dolometic type used for lining ladles.
The inert materials from non-chromium bricks pose little harm to
the environment by reducing exposure to chromium particulates and
contain no leachable constituents.
4.3 Scale of Operation: Facility-wide
4.4 State of Development: Fully implemented
4.5 Level of Commercialization: Techniques and measures
are broadly applicable across other industrial sectors
utilizing comparable technologies and processes. OSM
predicts that within the next few years, nationwide use
of Classification will eliminate 250,000 tons of
hazardous waste from treatment or land disposal.
4.6 Balances & Substitutions:
CHEMICAL/
RESOURCE
K061
PCB oils
chromium
refractory
bricks
UNITS
OF
MEASURE
Tons
Gallon
s
Bricks4
1993
USAGE
7,000
4,000
0,000
1994
USAGE
7,000 lOO:
0
0
REDUCTION
; recycled
100%
100%
ANNUAL
SAVINGS
($)
NA
NA
NA
NA « Not Available
5.0 ECONOMICS:
An estimated revenue of $6,384,000 per year should yield an
approximate 4 year pay back for the Classification process. An
additional savings of $1,820,000 results from decreased disposal
costs.
Elimination of chromium refractory bricks resulted in a
financial savings of $2,300,000 per year in purchasing costs.
Additional savings from hazardous waste disposal, transportation,
and handling costs were not estimated.
By eliminating all PCBs from the facility, OSM reduced
future financial and environmental liabilities.
6.0 DATE CASE STUDY WAS PERFORMED: 1992
B-6
-------
7.0 CONTACTS & CITATION
Winner, Oregon Governor's Award for Toxics Use Reduction,
1993.
Oregon Waste Reduction Assistance Program
Oregon Department of Environmental Quality
811 S.W. Sixth Avenue i
Portland, OR 97204
Sandy Gurkewitz 503/229-5918, Department of Environmental
Quality
B-7
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1.0 HEADLINE: Material Substitution and Process Change at a
Trucking Company
2.0 SIC CODE: Trucking/SIC 42
3.0 NAME & LOCATION OF COMPANY: Consolidated Freightways; P.O. Box
3420; Portland, OR 97208; Larry Stub, 503/499-3281
4.0 CASE STUDY SUMMARY:
4.1 Pollution Prevention Program Description:
The Portland shops of Consolidated Freightways Motor Freight
have formed a Hazardous Waste Reduction Committee made up of all
levels of personnel. The responsibilities of the Committee
include studying, testing, and recommending substitute chemicals
and processes for hazardous waste streams at these facilities.
They also provide training and help personnel as they adjust to
new chemicals or processes. The Committee implemented a
materials substitution in the company's dust abatement equipment
in an effort to reduce hazardous waste.
4.2 Process & Waste Information:
The company used dust abatement equipment when performing
brake relining on their vehicles. Use of water soluble chemicals
eliminated the need for stoddard solvent. This new process only
required building new pumping units to hold the liquid for this
process, but resulted in a reduction of 631 pounds per week in
the production of hazardous waste. In addition, this has reduced
employee exposure to stoddard solvent along with reducing the
amount of waste to dispose.
4.3 Scale of operation: Facility-wide
4.4 State of Development: Fully implemented
4.5 Level of Commercialization: Techniques and measures
are broadly applicable within the automotive/trucking
industries.
5.0 ECONOMICS:
An initial investment of $6,000 was required to build and
implement the new equipment. A cost savings of approximately
$7,400 per year resulted in a payback period of less than one
year.
6.0 DATE CASE STUDY WAS PERFORMED: 1991
7.0 CONTACTS & CITATION
Co-winner, Oregon Governor's Award for Toxics Use Reduction,
1991.
Oregon Waste Reduction Assistance Program
Oregon Department of Environmental Quality
B-8
-------
811 S.W. Sixth Avenue
Portland, OR 97204
Sandy Gurkewitz 503/229-5918, Department of Environmental
Quality
B-9
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1.0 HEADLINE: Process Modification at an Electronic Component
Manufacturing Facility
2.0 SIC CODE: Electronic Components & Accessories/SIC 3674
3.0 NAME & LOCATION OF COMPANY: Intel Corporation; 5200 NE Elam
Young Parkway; Hillsboro, OR; John Harland, 503/642-6479
4.0 CASE STUDY SUMMARY:
4.1 Pollution Prevention Program Description:
Intel Corporation is committed pollution prevention which
has been institutionalized and made a goal at all levels of the
company. Intel has established priorities, plans, and goals that
include:
Eliminating the use of CFCs by 1992;
« Tieing executive bonuses to environmental performance;
Creating the Environmental, Health, and Safety
Department (EHS); ' .
« Committing to reduce chemical volumes and toxicity with
each new process;
Requiring EHS approval for all new chemical purchases;
Requiring EHS approval for all process equipment
installations;
Recognizing individual employees and Divisions for
toxic use reduction;
Participating in the EPA 33/50 program; and
« Providing approximately 3,720 hours of EHS training
(1991).
This commitment is seen through four projects which Intel
completed in 1991. These projects resulted in major reductions
in chemical use and waste generation.
4.2 Process & Waste Information:
(1) Attaching components to printed circuit boards using
sophisticated surface mount technology required use of CFCs.
Intel decided to redesign the process so the use of CFCs was
completely eliminated. The new design uses water soluble surface
mount pastes, fluxes, and final assembly techniques. All
chemical cleaning steps have been removed and only hot water is
used where cleaning is required. Over 75,000 Ibs/yr of ozone
depleting Freon 113 were eliminated and greater efficiency
allowed the process to expand operations to 24 hours a day.
(2) Acetone is used to clean photoresist application
equipment. By installing controls that allow variable volume and
frequency dispensing rather than automatic dispensing,
consumption was reduced by 60,000 Ibs/yr (30 percent). Less
chemicals are handled and fewer air emissions occur.
B-10
-------
(3) An innovative filtration process was installed that
reduced sulfuric acid consumption by 9,400 Ibs/yr (43 percent)
while also improving acid purity and increasing product yield.
(4) Wastewater laden with phosphates results from
phosphoric acid used in the manufacturing process. In an attempt
to avoid contributing phosphates to a nearby river, Intel
researched alternative manufacturing methods. After determining
that consumption of phosphoric acid could not be sufficiently
reduced and all wastewater treatment options involved the use of
more chemicals, Intel began searching for a use for the used
phosphoric acid. As a result 100,000 gallons per year of
phosphoric acid that previously was managed as a waste is
collected and sold for use by fertilizer manufacturers. No
phosphate waste is generated, reducing the phosphate load to the
river by 18%. In addition, Intel stopped using 120,000 Ibs/yr of
caustic to treat the waste.
4.3 Scale of Operation: Facility-wide I
4.4 State of Development: Fully implemented
4.5 Level of Commercialization: Techniques and measures
are generally applicable to other electronic
manufacturers and other industrial sectors utilizing
comparable technologies and processes;.
4.6 Balances & Substitutions:
CHEMICAL/
RESOURCE
Freon 113
Acetone
Sulfuric
acid
Phosphate
Caustic
UNITS
OF
MEASURE
Pounds "/
Pounds2 (
Pounds :
GallonlC
s
PoundslS
1990
USAGE
5,000
0,000 14
1,850 :
0,000
0,000
1991
USAGE
0
0,000
2,450
0
0
REDUCTION
100% 14
30%
43%
1QO% 16
100% 1
ANNUAL
SAVINGS
($)
0,000
NA
NA
0,000
2,000
NA = Not Available
5.0 ECONOMICS : !
An estimated $2.2 million was spent for process changes and
research in order to put the four projects in place. This
translates to 0.121 Ibs of toxic use reduction per year per
dollar spent and 0.461 Ibs of waste prevented per year per dollar
spent.
The payback period is unclear, however through reductions in
B-ll
-------
disposal" costs, purchase costs, and environmental liability, a
payback of the initial investment will be realized.
6.0 DATE CASE STUDY WAS PERFORMED: 1992
7.0 CONTACTS & CITATION
Winner, Second Annual Oregon Governor's Award for Toxics Use
Reduction, 1992.
Oregon Waste Reduction Assistance Program
Oregon Department of Environmental Quality
811 S.W. Sixth Avenue
Portland, OR 97204
Sandy Gurkewitz 503/229-5918
B-12
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1.0 HEADLINE: Process Modification at a Liquid and Solid
Propellant Propulsion Systems Manufacturer
2.0 SIC CODE: Fabricated Metal Products/SIC 34
i
3.0 NAME & LOCATION OP COMPANY: Aerojet Propulsion Division;
Sacramento, CA 95813; Keith Pearce
4.0 CASE STUDY SUMMARY:
4.1 Pollution Prevention Program Description:
Aerojet Propulsion Division, a 3,300 employee company, has
implemented a Waste Reduction Program. The three person staff
assists in identifying and implementing waste reduction projects
wherever possible.
Aerojet identified three categories as drivers for waste
reduction:
Inventory reporting;
Emission reporting; and
Employee exposure.
In July 1987, a vapor degreasing pollution prevention
project was implemented in anticipation of solvent use
restrictions along with concerns over employee exposure. Since
that time, the cost of halogenated hydrocarbon solvent has also
provided a compelling reason for change.
4.2 Process & Waste Information:
In producing its propulsion systems, Aerojet uses several
processes to clean metal parts for the liquid propellant engines
(e.g., a bonding process). Water soluble machine tool coolant is
the primary contaminant being removed. Two vapor degreasers were
used that did a good job of removing contaminants, but a large
amount of energy was required and 80% of the perchloroethylene
and 100% of the Freon were lost to the atmosphere.
An emulsion cleaning system was adopted and has proven to be
beneficial from both an environmental and economic view. No
incinerable waste is produced by this cleaning process and hydro
testing of hardware after cleaning no longer results in
generation of hazardous waste.
4.3 Scale of Operation: Facility-wide
4.4 State of Development: Fully implemented
4.5 Level of Commercialization: Fully applicable to
comparable parts cleaning operations
B-13
-------
4.6 Balances S Substitutions:
CHEMICAL/
RESOURCE
Freon 113
Perchloroeth
ylene
s===^=
UNITS
OF
MEASURE
Tons
Tons
=
1987
USAGE
69
102
-~
1988
USAGE
0
0
__ -^^?
=s^=^==
REDUCTION
100%
100%
ANNUAL
SAVINGS ($)
$195,000
from
the
process
chanae
5.0 ECONOMICS:
The purchase and installation of the new emulsion cleaning
system was $300,000. Removal of the old equipment cost $100,000.
The annual operating and maintenance costs for the new system are
$72,000, resulting in an annual savings of $203,000 from the
reduced operating costs of the previous system.
A payback period of 1.5 years for the initial capital was
determined based on the fact that some of the existing equipment
was to be replaced at a cost of $110,000. This cost was avoided
with the installation of the new system. Many intangible
benefits from the reduction in waste are not quantified.
6.0 DATE CASE STUDY WAS PERFORMED: 1991
7.0 CONTACTS & CITATION
California Incinerable Hazardous Waste Minimization
Workshops, 1991
Aerojet Propulsion Division
Sacramento, CA 95813
Keith Pearce, Aerojet
B-14
-------
1.0 HEADLINE: Reduced Raw Material Use and Process Modification
at a Stainless Steel Manufacturing Facility
2.0 SIC CODE: Stainless Steel Manufacturing/SIC 33
3.0 NAME & LOCATION OF COMPANY: Carpenter Technology Corporation;
Reading, PA. Michael Wise, Manager, Environmental
Engineering. 610/208-2570
4.0 CASE STUDY SUMMARY:
4.1 Pollution Prevention Program Description:
Carpenter Technology Corporation manufactures stainless
steel for customers in the medical, aerospace, and oil drilling
industries. Some of the chemicals used in the steel
manufacturing facility are acid and solvents, including 1,1,1-
trichloroethane (TCA), mineral spirits, and perchloroethylene
(PERC). Acid is used in the manufacturing process to pickle the
steel and various organic solvents are used to degrease the
stainless steel.
TCA is known for its ozone depleting properties. PERC was
listed as a potential cancer causing agent in the 1980s. Due to
this, Carpenter Technology decided to adjust a number of their
processes to reduce raw material usage, which resulted in
decreased raw material purchases and waste disposal costs. Their
goal is to eliminate TCA usage.
4.2 Process & Waste Information:
Carpenter Technology Corporation implemented the following
pollution prevention measures:
1. Instead of routinely disposing of acid baths, acid
solutions are tested by chemical titration and
stabilized. Acids are only disposed when determined to
be unusable.
2. Substitution of mineral spirits in most of the parts .
washing stations. ,
3. Closing of containers when not in use decreased TCA
consumption by 95 percent.
4. Two large PERC degreasers had to be retained, but they
were modified to reduce emissions of volatile organic
compounds.
5. Coolant wastes were reduced by prolonging coolant life
through relatively simple laboratory tests to control
additions of coolant and chemicals.
4.3 Scale of Operation: Facility-wide
B-15
-------
4.4 State of Development: Fully implemented
4.5 Level of Commercialization: Fully applicable to
industries employing similar processes.
B-16
-------
4.6 Balances & Substitutions:
CHEMICAL/
RESOURCE
Acid
1,1,1 TCA
Coolant
UNITS
OF
MEASURE
Pounds ,
Gallon
s
Gallon
s
1991 USAGE
000,000
25,000
NA
1992
USAGE
NA
1,600
NA
REDUCTION
NA
:94%
NA
ANNUAL
SAVINGS
($)
NA
NA
NA
NA = Not Available
5.0 ECONOMICS:
Between $150,000 and $200,000 were spent to develop and
implement all of the changes. In addition, annual operating
costs will be approximately $150,000 and $200,000. A savings of
over $1.5 million per year is realized by avoiding the cost of
solvents and acid purchases, hazardous waste disposal, and
coolant disposal. Benefits with no assigned dollar value include
the decreased risk of environmental liability, increased employee
safety, and ease in complying with additional environmental
regulations.
6.0 DATE CASE STUDY WAS PERFORMED s 1993
7.0 CONTACTS & CITATION
Winner, Pennsylvania Governor's Waste Minimization Award
Program, 1993.
Pennsylvania Department of Environmental Resources
Source Reduction Section
P.O Box 8472
Harrisburg, PA 17105-8472
Meredith Hill 717/787-7382, Pennsylvania Department of
Environmental Resources
B-17
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1.0 HEADLINE: Safety-Kleen Customers Minimize Waste Solvent
Volumes
2.0 SIC CODE: 4953
3.0 NAME & LOCATION OF COMPANY: Safety-Kleen
1000 North Randall Road
Elgin, IL 60123-7857
4.0 CASE STUDY SUMMARY:
4.1 Pollution Prevention Program Description:
In 1994, Safety-Kleen Corp. introduced a waste minimization
parts cleaning machine for its customers who use decreasing
solvents to clean dirty metal parts used in automotive and
industrial businesses. This new system will introduce an
environmentally improved solvent which will allow tens of
thousands of mostly small businesses to maintain the same level
of cleaning while reducing solvent use by 12 million gallons a
year. This reduced volume of solvent will be recycled and reused
in a closed loop process.
4.2 Process & Waste Information:
The new parts cleaning machine which the firm calls the
"Green Machine," includes a cyclonic separation system which more
than doubles the solvent's useful life. A new solvent has also
been formulated for use in the cyclonic unit. The solvent is less
flammable (flash point of 150 degrees F.), has less odor, and has
lower air emissions than previously used solvents. The new
solvent is non-chlorinated and does not contain any ozone
depleting compounds.
4.3 Scale of Operation: Fully Operational
4.4 State of Development: Fully implemented
4.5 Level of Commercialization: This "Green Machine" is
used by service stations, auto dealers, and a large
variety of other industries. By 1994, approximately 40%
of the company's parts washer units (over 100,000
units) will have switched to the new waste minimization
machine. By the end of 1995, the Company forecasts that
90% of its parts washer units (over 230,000 units) will
have been converted over to the "Green Machine".
B-18
-------
4.6 Balances & Substitutions: In 1993, customers using the
firm's parts cleaning machine generated approximately
25,000,000 gallons of waste solvent. For 1994, the firm
estimates that these customers will generate
approximately 18,600,000 gallons of waste solvent for a
reduction of 6,900,000 gallons of waste due to the
introduction of the "Green Machine". For 1995, it is
estimated that the volume will be reduced to about
13,400,000 gallons, nearly 12,000,000 gallons less than
1993. It is important to note that over 90% of these
reductions will be realized by small generators. The
system and cleaning agents are being continuously
improved as the company works with customers to further
reduce environmental impacts of their operations.
5.0 ECONOMICS: Minimum cost savings to customers.
6.0 DATE CASE STUDY WAS PERFORMED: 1994
7.0 CONTACTS & CITATION: Safety Kleen
1000 North Randall Road
Elgin, IL 60123-7857
Bill Constantelos - 708/468-2217, fax 708/468-8535
-------
-------
Appendix C - Supplemental Actions EPA Is Investigating
This section describes several additional actions which EPA
is exploring, and if appropriate, will make plans to implement.
They are listed according to the objectives in the National Plan.
Objective 2
EPA will evaluate the cross-media impacts of source
reduction and recycling activities for specific
constituents.
The Agency wants to encourage stakeholders (in particular,
state technical assistance centers, academic institutions, and
industrial facilities) to examine the potential "life cycle"
impacts from adoption of source reduction and recycling
alternatives, as their resources permit. EPA plans to support
this effort by evaluating potential impacts of selected source
reduction and recycling alternatives for constituents that are a
high-priority from a national standpoint.
In the near term, EPA plans to examine the potential effects
of source reduction and recycling alternatives for a couple of
selected industrial sectors generating high-priority metal
constituents, based on the results presented in the Addendum to
the Plan. This examination would address potential cross-media
transfers, as well as impacts on energy and water usage.
* EPA will explore the relationship between the goals of
reducing persistent, bioaccumulative, and toxic constituents
identified in this Plan with the goals of each Common Sense
Initiative Sector that the Agency is pursuing.
The Common Sense Initiative has three goals: 1) to eliminate
problems caused by focusing too narrowly on a single pollutant or
environmental medium (thereby resulting in cross-media
transfers); 2) to stop the practice of making policy in response
to emergencies; and 3) to try to bridge the gap separating
environmentalists and industry by holding regular meetings with
EPA and interested parties to discuss differences and reach
agreement on major issues. This Waste Minimization National Plan
has been developed with very similar principles.
Although this Plan does focus on constituents, it attempts
to understand which industrial sectors and processes result in
the generation of these constituents in wastes, and then proceeds
to focus on those processes for which source reduction and
recycling opportunities may exist.
EPA will look at the relationship of the persistent,
bioaccumulative, and toxic constituents in this Plan to the six
industries that the Common Sense Initiative is focusing on (i.e.,
iron and steel, electronics and computers, metal plating and
finishing, automobiles, printing, and oil refining). In
particular, EPA will share information on processes within these
C-2 :
-------
sectors that generate wastestreams containing these persistent,
btotclumulative, and toxic constituents and any "formation on
source reduction and recycling opportunities that may exist, or
that should be developed that would result in a reduction of
these constituents.
Although there has been little formal discussion in"this
context, the Common Sense Initiatives could serve as a vehicle to
pilot many of the concepts that are presented in this National
pian? Such as the use of a screening tool to identify source
reduction and recycling priorities; the use of a combination of
voluntary, regulatory, and organization mechanisms to achieve
reductions; optimization of flexibility to both States and
industry to get real reductions; and effective partnerships that
lead to efficient, effective, and innovative implementation of
actions ?o achieve waste minimization goals stated here today.
Ob-iective 3
* EPA will investigate whether activities already underway can
aid in accomplishing the goals stated in this Plan.
Possible opportunities to investigate include:
o Potential expansion of the 33/50 Program and other EPA
initiated voluntary programs to incorporate priority
constituents identified through the screening tool
described under Objective #1.
o Developing or expanding an already existing
Leadership/Recognition Program to support both State
and industry source reduction efforts aimed at priority
constituents.
EPA will be investigating the value of using existing
vehicles, such as the Environmental Leadership Program, to get
further movement in reductions of constituents of concern. Many
generators have been proactive and responsible in their efforts
to reduce the use of toxic substances through source reduction
reduce releases of toxics to the environment, and increase their
use of environmentally sound recycling. EPA wants to see an
increase in the trend toward industry's commitment to preventing
pollution.
Objective 4
EPA will investigate measurement techniques for evaluating
progress toward the national goal.
After identifying the necessary data and defining the level
of detail needed to assess national progress toward the goal, EPA
will investigate measurement techniques (including defining
appropriate data collection approaches and mechanisms) to
evaluate the progress. The recommendations from the four state
pilot projects described in the National Plan will be one^
Starting point for developing these measurement techniques. EPA
C-3
-------
anticipates reviewing the usefulness of measurement methods that
have already been developed by States and industry to measure
progress.
EPA will explore establishing a process by which Regions,
States, and industry are accountable to the public in
continually improving their reductions in hazardous
constituents.
Regardless of the mechanisms that are used to achieve the
stated goals, there is a need for industry, States, and EPA to
document progress towards these goals, and to be accountable to
the public on their intentions in setting their own priorities
and meeting their own stated goals, and how these do or do not
complement the national priorities and goals. EPA expects that a
process will be needed to communicate the Regions', States', and
industry's progress to the general public.
I
EPA will investigate the use of the Biennial Report, the
Capacity Assurance Plan process, the Waste Minimization Program
in Place Certification, and the Toxics Release Inventory, as
viable and defensible mechanisms for demonstrating progress and
being accountable to the public.
C-4
-------
-------
ADDENDUM
APPLICATION OP WASTE MINIMIZATION NATIONAL PLAN
TO THE
COMBUSTION UNIVERSE
-------
-------
ADDENDUM: APPLICATION OF WASTE MINIMIZATION NATIONAL PLAN
APPROACH TO THE COMBUSTION UNIVERSE
Background
In this addendum to the Waste Minimization National Plan,
EPA applies a screening tool and sets initial national priorities
for metals contained in hazardous wastes treated by combustion
facilities and metals in releases from combustion facilities.
This approach serves as a point of departure for EPA Regions,
States, and industry in establishing their own priorities.
In applying the screening tool, the Agency has chosen to
focus on metals at combustion facilities because they are not
destroyed by combustion and are therefore potentially available
to the environment following management. The Agency believes
that promotion of source reduction and environmentally-sound
recycling for these metals will contribute in important ways to
managing risks from combustion, consistent with the goals of the
Waste Minimization and Combustion Strategy.
EPA is not currently applying this approach to halogenated
organic compounds in wastes treated by combustion facilities or
halogenated organics in releases from these facilities, as was
proposed in the Draft Waste Minimization National Plan. EPA
plans to address halogens in a broader array of wastes and
releases using a broader screening tool, as discussed below and
in the Waste Minimization National Plan. EPA plans to address
dioxins from hazardous waste combustion facilities specifically
as part of the Agency's on-going Dioxin Reassessment.
The screening tool described in this addendum is a prototype
for a broader screening tool, to be developed, that will focus
primarily on an "as-generated" approach to prioritizing
constituents in wastes and in TRI transfers to off-site
management. The broader screening tool will also be supplemented
by an "as-managed" approach for TRI releases to address those
situations where certain industrial sources and waste management
practices may pose significant hazards. The core of the broader
screening tool will be the assessment of hazard based on the
persistence, bioaccumulation, and toxicity of constituents,
weighted by constituent mass.
It will take additional time to develop the broader
screening tool, based on the many comments already received on
EPA's draft methodology. EPA expects to make the screening tool
available (at least in draft) in 1995.
In the near term, EPA will begin to implement its Plan by
applying its prototype screening methodology to! metals in
combustion facility wastes and releases. EPA plans to use these
results to set initial national priorities for source reduction
-------
and environmentally-sound recycling in the context of the Waste
Minimization and Combustion Strategy.
For this application of the prototype methodology, EPA is
using elements of the draft methodology outlined in the document
"Setting Priorities for Hazardous Waste Minimization," July 1994
(draft report). This methodology set priorities for combusted
hazardous wastes "as generated," based on the persistence,
bioaccumulation, toxicity, and mass of constituents in the
wastes. Two primary modifications were made to the draft
methodology for this application: (1) EPA is using the draft
methodology to assess the hazard of metals only (rather than both
metals and halogens) in wastes, and (2) EPA is also applying the
draft methodology to TRI releases reported by combustion
facilities.
It should be noted that this application is based on
national-level data on wastestreams and TRI releases.
Application of this type of tool to the wastes and releases at a
state or facility level could result in a different ordering of
priorities (e.g., a different relative ranking of metals), since
the metal content of wastes and releases is likely to vary
significantly from state to state and facility to facility.
Methodology
Revisions to Draft Methodology for Prioritizing Hazardous Wastes
EPA prioritized metals in combusted hazardous wastes using
the same data sources and applying the same general methodology
described in "Setting Priorities for Hazardous Waste
Minimization," July 1994 (draft report). As discussed in Chapter
2 of this report, Biennial Reporting System data reported in 1991
were used to characterize waste generation and management. Data
from a variety of sources were used to develop estimates of
constituent content and concentrations in about 150 large-
quantity "wastestream combinations" representing approximately
50 percent of routinely-generated hazardous wastes going to
combustion.
1 This type of methodology could also potentially be applied
to transfers reported in the TRI (e.g., off-site transfers to
publicly-owned treatment works, treatment facilities, and
recycling facilities), using the same basic approach as for
wastes "as generated." Due to time constraints, EPA has not
applied the methodology to TRI transfers in this addendum.
2 EPA created "wastestream combinations" by combining
combusted wastestreams that were identical in terms of the RCRA
hazardous waste codes; the generator's Standard Industrial
Classification and source (or process); and waste form.
-------
As discussed in Chapter 3 of this report, the draft
methodology uses a waste characteristics scoring component from
Superfund's Hazard Ranking System (HRS), with some modification.
The methodology determines hazard as generated based on
persistence, bioaccumulation, toxicity, and/or mobility for four
primary pathways (air, surface water, ground water, and soil) and
weights the result by constituent mass. The highest pathway
score for a given constituent is used to represent the
constituent's hazard, and the highest constituent score for a
given.wastestream is used to represent the wastestream's hazard.
One of the key differences of the application in this
addendum from the draft methodology is the focus here on
prioritizing metals only. The waste characterization work
described in Chapter 2 and in Appendix 6 of the report was
modified for this application by removing halogens and other non-
metal constituents from the top 150 wastestream combinations.
This was done to avoid the "masking" of metals by non-metals.4
This left 80 wastestream combinations containing metals. Once
non-metals had been removed, hazard scores were added across
wastestreams by metal to determine "high-hazard metals."
Application of Draft Methodology to TRI Releases from Combustion
Facilities
One of the other key differences of the application in this
addendum from the work presented in the draft report is the use
of the methodology to assess the relative hazard of TRI releases.
The Agency recognizes that there are a variety of TRI-based
screening approaches (as well as other non-TRI-based approaches)
already in use or under development that could be used as
alternatives to the approach employed here. As discussed in the
Waste Minimization National Plan, the Agency plans to examine
these alternative approaches in developing the broader screening
tool for sett-ing priorities for source reduction and
environmentally-sound recycling. However, to demonstrate how TRI
data might be used along with waste data in setting priorities,
the Agency has started with the HRS-based approach, which could
be readily employed and is internally consistent with the current
All of the constituent mass in the wastestream is assumed
to be available to any of the pathways.
4
Only the score for the "hazard-driving constituent" in
each wastestream (see Exhibit 3-4 in "Setting Priorities") was
used in the draft methodology to tally the total hazard score by
constituent and determine which were the most tuizardous
constituents across all wastestreams. If a halogen in a
particular wastestream had a higher hazard score than a metal in
that wastestream, the metal score was not tallied -(i.e., was.
masked).
3 ;
-------
approach for ranking constituents in wastes.
In assessing the hazard of TRI metal releases from hazardous
waste incinerators and from boilers and industrial furnaces
(BIFs), the Agency started with a recent estimate of the universe
of these combustion facilities. Based on May 1994 data, there
were 265 facilities that were incinerators and/or BIFs, including
55 commercial facilities and 210 non-commercial facilities. The
Agency used the EPA ID numbers of these facilitiesgto identify
the 35 facilities with thermal treatment processes reporting
releases of metals in the 1992 TRI. Only a small subset of
combustion facilities currently report metals releases under TRI
because they do not manage metal-bearing wastestreams in
combustion units, they do not meet reporting thresholds, or they
do not fall within the industrial sectors required to report
under the TRI.
In the TRI, facilities separately report their releases to
air, land, underground injection, and water. For each metal, EPA
added release quantities across the 35 facilities to obtain
estimates of total national releases by release type (e.g., EPA
estimated the total releases of cadmium to air from point and
non-point sources at the 35 facilities).
Once national estimates had been derived of the mass of each
metal by release type, EPA applied one or more of the pathway
algorithms from the HRS-based draft methodology to each release
type, as shown in Exhibit 1. For example, for releases to air,
all four HRS-based pathways (air, surface water, ground water,
and soil) were applied, since releases to air could potentially
result in exposures via any of these pathways. The highest
scoring pathway was then used to obtain the hazard score for a
given metal and release type. For each metal, EPA then added
hazard scores across release types to obtain an aggregate hazard
5 This includes facilities reporting incineration/thermal
treatment (F) codes or energy recovery (U) codes in the TRI.
6 Facilities falling in Standard Industrial Classification
codes 20-39 are required to report under TRI.
7 The air pathway algorithm from the HRS-based draft
methodology was modified slightly in applying it to TRI air
releases, by assuming that the "mobility" factor for air equals 1
(i.e., the pathway score for air is based on toxicity alone).
This was done since the mobility factor for air, based on vapor
pressure, is more an expression of the potential for constituent
release to air than of constituent movement once in air. TRI
releases reflect constituents already present in air; therefore
the mobility factor was not needed.
-------
score (e.g., EPA added the hazard score for cadmium released to
air to the hazard score for cadmium released to water, etc. to
obtain the total hazard score for cadmium).
Results
Revisions to Draft Screening Results for Hazardous wastes
Focusing just on metal constituents present in combusted
hazardous wastes, hazard ranking results parallel the results
presented originally in Exhibit 3-5 of "Setting Priorities for
Hazardous Waste Minimization." As shown below in Exhibit 2, the
top-ranking constituents are cadmium, lead, mercury, selenium,
and copper. Cadmium is responsible for approximately three
quarters of the overall hazard score, followed by lead with 12
percent, and mercury with 8 percent.
Although EPA intends to focus primarily on constituents,
rather than wastes, in setting priorities for source reduction
and environmentally-sound recycling, it is useful to understand
which wastestreams the priority constituents are present in and
which industrial sectors and sources generate the wastes, in
order to identify source reduction and recycling opportunities.
Exhibit 3, below, is a revised version of Exhibit 3-4 from
"Setting Priorities," which shows the large-quantity wastestream
combinations that EPA characterized and the metal that was the
highest-hazard constituent for each wastestream combination.
Exhibit 4, a revised version of Exhibit 3-7 from the draft
report, shows the ranking of industrial sectors; and sources based
on the hazard of the wastestreams they generate. Exhibit 5, a
revised version of Appendix 9 from the draft report, shows which
Regions and States the wastestream combinations were generated
in. (Please note that the hazard scores shown in Exhibits 3, 4,
and 5 do not represent any absolute measure of the magnitude of
hazard or risk; only the relative difference between scores is
significant.)
Results of Application of Draft Methodology to TRI Releases
Based on the application of the HRS-based ranking
methodology to the TRI metal releases reported by the 35
hazardous waste combustion facilities, the highest-hazard metals
are lead, copper, mercury, and silver. The hazard rankings for
8 The hazard score for each metal was obtained by adding
hazard scores across pathways (rather than selecting the highest-
scoring pathway)'to account for the total mass of the constituent
released to the environment. This parallels the approach used
for estimating the hazard of wastes, where all the mass of a
constituent was assumed to be available when estimating each of
the pathway scores.
-------
these and other metals in TRI releases are shown in Exhibit 6.
As shown, lead accounts for about three quarters of the total
hazard score for metals, and copper accounts for 20 percent.
Overlap Between Waste and Release Results
The top-scoring metals present in TRI releases (shown in
Exhibit 6) overlap to a limited extent, on a national basis, with
the top-scoring metals present in hazardous wastestreams (shown
in Exhibit 2). One constituent that appears prominently on both
lists is lead; mercury also appears near the top of both lists.
The limited overlap in high-ranking metals is not
surprising, for at least two reasons:
o The constituent content of wastes may or may not be related
to the constituents present in TRI releases, depending on
the industrial processes and waste management practices
employed at facilities and on"the physical and chemical
properties of the constituents.
o The TRI metals releases at the 35 combustion facilities
reporting releases may not be representative of the releases
at the overall universe of 265 facilities receiving
hazardous wastes.
At a facility level, where this type of screening tool would
most often be applied in practice, the overlap between metals in
releases and wastes may be somewhat stronger (for facilities both
generating waste and reporting releases).
Conclusions and Recommendations for Implementation
EPA applied the prototype screening methodology to national-
level data on metals contained in combustion wastes and in
releases from combustion facilities in order to set initial
national priorities and begin to implement the Waste Minimization
National Plan. This application is also meant to illustrate how
a broader screening tool could potentially be applied to other
constituents in wastes and releases and how it could be applied
to State or facility-level data.
Consistent with EPA's emphasis on the hazard of wastes as
generated as the primary basis for setting priorities, the
results for ranking of metals in hazardous wastes as generated
should serve as the starting point for setting Regional, State,
and industry priorities. Results for ranking of TRI releases of
metals should be used to reinforce waste-based priorities (where
there are common high-priority constituents between wastes and
releases) and to identify releases of other metals that may also
be of potential concern and good candidates for source reduction
or recycling activities.
-------
The screening results provided here for the top-ranking
metals, the wastestreams containing the metals, and the
industrial sources generating the wastestreams (augmented by
results for top-ranking metals in TRI releases) serve as a
starting point for setting national source reduction and
recycling priorities. These initial results will be incorporated
in RCRA program activities for 1995-6. However, these results
should hot preclude Regions, States, and industry fr.om:
conducting more detailed characterization of these and other
wastestreams (or releases) containing metals; applying
alternative prioritization approaches, when appropriate, to the
metals; and modifying these initial national-level priorities
accordingly.
Limitations of Screening Approach
i
In interpreting the results presented above, it is important
to consider the following points.
o Results for hazardous wastes reflect 1991 Biennial Reporting
System data, current as of March 1994 (the most data at the
time the analysis for "Setting Priorities" was conducted).
These data do not reflect more recent State updates of the
BRS data (as part of the Capacity Assurance Planning
process). However, these updates did not significantly
change overall waste quantities and should therefore not
alter the basic national-level results reported here.
o Results for hazardous Wastes are based on best estimates of
average waste characteristics for the top-volume wastestream
combinations representing approximately 50' percent of the
routinely-generated combusted waste universe. More detailed
characterization of these wastestreams and/or
characterization of the other 50 percent of the universe
could alter the draft national results repiorted above.
o Results for TRI releases assume that the entire mass of the
releases is potentially available to the environment. The
approach .does not consider reductions in availability of
mass due to controls or treatment (e.g., liners in landfills
or stabilization of metals).
o TRI data indicate which facilities conduct, thermal treatment
processes but do not indicate which specific releases result
from these processes (i.e, releases are not unit-specific).
The metal release numbers could reflect releases from other
sources or processes in addition to releases from combustion
units. The estimates of constituent mass released therefore
serve as upper bound estimates of releases from thermal
treatment units.
o In the TRI, metals can be reported as elemental metals or as
7 i
-------
"metal compounds." EPA assumed that the entire mass
reported of a metal compound was present in the form of the
elemental metal. This assumption could result in either an
understatement or overstatement of toxicity and hazard.
As discussed in the Waste Minimization National Plan, EPA is
developing a broader screening tool. With application of
the broader tool, these initial results for metals in wastes
and releases could change.
8
-------
Exhibit 1. HRS-Based Pathways Applied to TRI Release Types
Type of TRI Release
Highest Scoring Among
Following HRS-Based
Pathways Was Used to
Estimate Hazard of
Release
Rationale
Air (point and non-
point)
Air, surface water,
ground water, and
soil pathways
Air releases could result in direct
exposures via air; could be deposited to
surface wat!er, and, once in surface
water, could contaminate ground water;
could be deposited onto land
Land (landfill,
surface impoundment,
land application,
other)
Air, surface water,
ground water, and
soil pathways
Releases to land could be transported to
air, surface water, ground water, or
soil
Underground injection
Ground water and
surface water (ground
water to surface
water) pathways
Releases to underground injection could
be transported to ground water, and,
once in ground water, could enter
surface water; however releases could
not directly enter surface water
Water
Air, surface water,
ground water, and
soil pathways
Releases to surface water could be
transported to air, ground water, or
soil
-------
Exhibit 2.
Hazard Ranking of Metals in Large-Quantity
Combusted Hazardous Wastestreams
Metal
Cadmium
Lead
Mercury
Selenium
Copper
Beryllium
Silver
Chromium
Nickel
Percent of
Overall Metal
Hazard Score
77
12
8
1
1
<1
<1
<1
<1
10
-------
EXHIBITS
TOP 80 METAL-CONTAINING WASTESTREAM COMBINATIONS, RANKED BY HAZARD SCORES
Rank
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
Wastestream Combination
D002D006
F003 F005
D001 D008 F003 F005
K002
D001 D005 D006 D007 D008 D018 D026 D035 F001 F002
D001 D002
D001 F001 F002 F003
D001 D008
K048 K049 K051
F003 F005
D001 F003 F005
D001 D004 D005 D006 D007
K051
D001 D004 D005 0006-0007 0008 0009 0010 001 1 0016
0001 F003 F005
0001 D004 0005 0006 0007 0008 0009 0010 001 1 0018
0001 0005 0006 0007 0008
0001 0004 0005 0006 0007 0008 0009 0010 0016 F001
0001 0002 0003 0008 0018 D023 0024 D025 0026
0001 0002 0003 0004 0005 0006 0007 0008 0009 0010
0001 0004 0005 0006 0007 D008 0010 001 1 0018 0035
0001 0005 0006 0007 0008
0001 0005 0006 0007 0008 0009 0019 F001 F002 F003
001 8 F037 F038 K048 K049 K050 K051
0001 0004 0005 0006 0007
0005 0006 0008 F001
0001 0007 0008 0018
DOOT D005 D006 D007
0001 F001 F003 F005
0001 D007 0008 0018 0022 D026 0027 0028 D033 0036
0001 0005 0006 0007 0008 F003 F005
0001 0002 0005 0006
0001 0006 0008 F002
F001 F002 F003 F005
0001 0005 0006 0007 0008 0011 0022 0035 0039 F001
0001 0028 F037 F038
D001 0002 0007 0008 0018 0035 F001 F003 F005 U009
0008
0001 0007 0008 F001 F002 F003 F005
0001 0018 K048 K049
0001 F004
SIC
Code
2833
4953
2865
2869
2821
2819
2911
7389
7389
2869
4953
2899
3221
2911
4953
2911
9999
2821
4953
2911
2869
9999
2911
2821
Source
Code
A32
A73
A33
A31
A33
A
A89
A89
A71
A33
A99
A89
A54
A75
A89
A99
A73
A89
A37
A33
Form
Code
B207
B219
B203
B203
B219
B207
B204
B602
B
B203
B204
B603
B202
B204
B202
B204
B219
B219
B114
B204
B407
B407
B206
B603
B407
B204
B204 .
B206
B204
B204
B219
B602
B204
B403
B204
B205
B219
B202
B204
B602
Volume
(Tons)
3724
17218
4880
6554
31348
3873
10782
13395
3393
6101
5692
22251
6217
6591
8747
5565
10883
4743
18825
4564
4531
7826
2999
7914
10580
4509
4348
8564
84191
3775
5956
7001
3410
3295
3168
6975
3124
6785
5679
5357
4866
3669
3990
Hazard- Driving
Constituent
Cadmium
Mercury
Lead
Lead
Cadmium
Copper
Selenium
Lead
Mercury
Lead
Lead
Cadmium
Lead
Mercury
Lead
Mercury
Cadmium
Mercury
Lead
Mercury
Mercury
Cadmium
Mercury
Lead
Lead
Cadmium
Cadmium
Lead
Lead
Cadmium
Selenium
Lead
Cadmium
Cadmium
Cadmium
Selenium
Cadmium
Lead
Lead
Lead
Lead
Lead
Beryllium
Wastestream
Combination
Score
3.72E+13
2.58E+12
2.43E+12
6.54E+11
6.26E+11
5.80E+11
5.38E+11
5.35E+11
5.08E+11
4.57E+11
4.54E+11
4.44E+11
2.92E+11
2.63E+11
2.62E+11
2.22E+11
2.17E+11
1.89E+11
1.88E+11
1.82E+11
1.81E+11
1.56E+11
1.20E+11
1.18E+11
1.06E+11
9.00E+10
8.68E+10
8.54E+10
7.56E+10
7.53E+10
7.43E+10
6.98E+10
6.80E+10
6.57E+10
6.32E+10
6.26E+10
6.23E+10
5.75E+10
5.67E+10
5.34E+10
4.85E+10
3.66E+10
3.18E+10
Cum.
Percent
73.2
78.3
83.1
84.4
85.6
86.8
87.8
88.9
89.9
90.8
91.7
92.5
93.1
93.6
94.2
94.6
95.0
95.4
95.8
96.1
96.5
96.8
97.0
97.3
97.5
97.6
97.8
98.0
98.1
98.3
98.4
98.6
98.7
98.8
98.9
99.1
99.2
99.3
99.4
99.5
99.6
99.7
99.8
Volume
Flank
125
34
98
79
17
121
55
44
134
84
90
25
83
78
60
92
53
103
27
. 106
107
68
144
67
57
108
111
61
5
124
86
71
133
136
138
73
140
75
91
95
99
126
119
11
-------
EXHIBIT 3
TOP 80 METAL-CONTAINING WASTESTREAM COMBINATIONS, RANKED BY HAZARD SCORES
tank
44
AC.
*t3
46
47
48
AQ
*ty
50
51
co
D£
53
54
55
56
C7
wf
CO
DC
CQ
Ow
er
uL
61
CO
\J£.
63
R4
Dfc
65
fifi
DO
K7
DJ
68
RQ
U!
7fl
/u
7-
f
72
/ t
T
i \
7A
/*
75
76
77
1 >
.78
79
80
Wastestream Combination
D001 F001 F002 F003
nnni
L/uu I
F001 F002 F003
D001D011D018D021D022
D001 D002 D003 D004 D005 D006 D007 D008 D009 D010
K048
D001 F003 F005
D00.1 D002 D007
\fr\AQ
i\u*jy
D001 D005 D006 D007 D008 F001 F002 F003 F004 F005
D001 D002
D001 D002 D007
D001 D002 D003
nnn°
L/WU£
nrvni
UUvJl
nnfM
\j\j\j i
nnm
UUUI
D001 D002 D007 D018 D021 F002 F003 F005
K022
D001 D002 D007 D018 D021 F002 F003 F005
D001 D002
D001 D002 D003 D007 D018 D019 D021 D022 D028
KD99
I\U£.£
K022
D001 D002 D019 00320033 D034 D039 F002
D001 D002
nnm no??
U\J\J t L/V^Ci
D001 D002
0001 D002
D001 D002
Kn99
IVJ££
D001 D002 F003
D001 D002U008U113
K027
K027
D001 K013 U003
D018D038K022K083
Total
SIC
Coda
2899
2512
3861
2869
2911
3053
2869
2911
7389
2869
2869
2879
2869
2869
2822
2869
2865
2865
2865
2819
2869
2869
2865
2869
2869
9999
2869
2821
2869
2819
2869
2865
2865
2869
2865
Source
Code
A89
A92
A49
A33
A75
A56
A33
A75
A71
A35
A33
A37
A09
A35
A35
A31
A33
A34
A37
A33
ASS
A35
ASS
A37
A
ASS
A49
A33
A
A33
ASS
ASS
ASS
A
rorm
Code
B204
B403
B204
B105
B503
B403
B602
B202
B206
B219
B219
B102
B207
B219
B207
B204
B602
B204
B219
B212
B606
B602
B219
B202
B
B219
B102
B219
B
B101
B409
B403
B219
B
Volume
(Tons)
5825
4322
4822
9390
13182
19996
3465
36709
3316
3518
95042
16099
27247
8001
12842
3068
10732
4781
9432
4316
15997
2900
23281
4609
3866
3477
3414
2969
7412
2868
10846
5323
189524
11123
4457
5554
17303
Hazard-Driving
Constituent
Selenium
Lead-
Selenium
Silver
Cadmium
Lead
Lead
Chromium
Mercury
Lead
Copper
Chromium
Selenium
Copper
Mercury
Mercury
Lead
Chromium
Cadmium
Chromium
Copper
Chromium
Mercury
Cadmium
Lead
Lead
Lead
Lead
Copper
Lead
Cadmium
Mercury
Chromium
Nickel
Nickel
Lead
Nickel
Wastestream
Combination
Score
2.91E+10
2.59E+10
2.41 E+10
9.37E+09
6.58E+09
5.99E+09
4.32E+09
3.66E+09
3.31 E+09
3.16E+09
1.90E+09
1.61 E+09
8.16E+08
7.98E+08
6.41 E+08
6.12E+08
5.35E+08
4.77E+08
4.71 E+08
4.31 E+08
3.19E+08
2.89E+08
2.32E+08
2.30E+08
1.93E+08
1.73E+08
1.70E+08
1.48E+08
1.48E+08
1.43E+08
1.08E+08
1.06E+08
1.89E+07
4.44E+05
1.78E+05
1.66E+05
3.45E+04
5.08E+13
Cum.
Percent
99.9
99.9
99.9
99.9
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
Volume
Rank
112
101
59
45
26
131
14
135
129
4
36
19
65
47
142
56
102
58
113
37
148
24
105
122
130
132
146
70
149
54
96
49
110
93
33
12
-------
EXHIBIT 4
SIC/SOURCE CODE COMBINATIONS, RANKED BY HAZARD SCORES
Rank
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
SIC Code Description
Medicinal Chemicals and Botanical Products
Refuse Systems
Cyclic Organic Crudes and Intermediates, and Organic Dyes and Pigments
Industrial Organic Chemicals, N.E.C.
Plastics Materials, Synthetic Resins, and Nonvulcanizable Elastomers
Industrial Inorganic Chemicals, N.E.C.
Petroleum Refining
Business Services, N.E.C.
Chemicals and Chemical Preparations, N.E.C.
Industrial Organic Chemicals, N.E.C.
Business Services, N.E.C.
Refuse Systems
Refuse Systems
Glass Containers
Petroleum Refining
Nonclassifiable Establishments
Plastics Materials, Synthetic Resins, and Nonvulcanizable Elastomers
Industrial Organic Chemicals, N.E.C.
Nonclassifiable Establishments
Petroleum Refining
Wood Household Furniture, Upholstered
Photographic Equipment and Supplies
Gaskets, Packing, and Seating Devices
Industrial Organic Chemicals, N.E.C.
Pesticides and Agricultural Chemicals, N.E.C.
Industrial Organic Chemicals, N.E.C.
Synthetic Rubber (Vulcanizabte Elastomers)
Cyclic Organic Crudes and Intermediates, and Organic Dyes and Pigments
Cyclic Organic Crudes and Intermediates, and Organic Dyes and Pigments
Industrial Inorganic Chemicals, N.E.C.
Cyclic Organic Crudes and Intermediates, and Organic Dyes and Pigments
Plastics Materials, Synthetic Resins, and Nonvulcanizable Elastomers
Cyclic Organic Crudes and Intermediates, and Organic Dyes and Pigments
Total
.SIC
Code
2833
Unk.
4953
2865
2869
2821
2819
2911
7389
2899
2869
7389
4953
4953
3221
2911
9999
2821
2869
9999
2911
2512
3861
3053
2869
2879
2869
2822
2865
2865
2819
2865
2821
2865
Source Code Description
Product filtering
Solvents recovery
Product distillation
Product rinsing
Product distillation
Other pollution control or waste treatment
Other pollution control or waste treatment
Other pollution control or waste treatment
Product distillation
Filtering/screening
Other
Oil changes
Wastewater treatment
Other .
Solvents recovery
Spent process liquids removal
Routine cleanup wastes
Other non surface preparation processes
Discontinue use of process equipment
By-product processing
Spent process liquids removal
Clean out process equipment
Product rinsing
Product solvent extraction
Spent process liquids removal
By-product processing
Other non-surface preparation processes
Source
Code
A32
Unk
A73
A33
A31
A33
Unk
A89
A89
A89
A33
A71
A99
Unk
A54
A75
A99
A73
A37
Unk
Unk
A92
A49
A56
A35
A37
A09
Unk
A31
A34
A37
A35
A49
Unk
Hazard
Score
3.72E+13
6.75E+12
2.43E+12
6.54E+11
5.80E+11
5.66E+11
4.57E+11
4.35E+11
2.17E+11
2.10E+11
2.01 E+ 11
1.92E-M1
1.82E+11
1.53E+11
1.18E+11
1.15E+11
6.98E+10
6.80E+10
5.68E+10
4.87E+10
3.66E+10
2.59E+10
9.37E+09
4.32E+09
3.07E+09
8.16E+08
7.98E+08
6.12E+08
4.77E+08
4.31 E+08
3.19E+08
2.30E+08
1.43E+08
3.45E+04
5.07E+13
% Hazard
Score
73.2
13.3
4.8
1.3
1.1
1.1
0.9
0.9
0.4
0.4
0.4
0.4
0.4
0.3
0.2
0.2
0.1
0.1
0.1
0.1
0.1
0.1
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
Cum. %. Of
Haz. Score
73.2
86.5
91.3
92.6
93.7
94.9
95.8
96.6
97.0
97.5
97,9
98.2
98.6
98.9
99.1
99.4
99.5
99.6
99,7
99,8
99.9
100.0
100.0
100.0
100.0
100.0
100.0
100,0
100,0
100.0
100.0
100,0
100,0
100.0
13
-------
EXHIBIT 5
TOP 80 RANKED WASTESTREAM COMBINATIONS WITH GENERATING
STATES AND REGIONS
}ank
1
2
3
4
5
6
7
8
c
10
11
RCRACode , .
D002 D006
F003 F005
F003 F005
F003 F005
F003 F005
F003 F005
F003 F005
F003 F005
D001 D008 F003 F005
K002
D001 D005 D006 D007 D008 D018 D026 D035 F001 F002
D001 D002
D001 F001 F002 F003
D001 F001 F002 F003
D001 F001 F002 F003
D001 F001 F002 F003
D001 F001 F002 F003
D001 F001 F002 F003
D001 D008
K048 K049 K051
K048 K049 K051
F003 F005
D001 F003 F005
D001 F003 F005
D001 F003 F005
D001 F003 F005
D001 F003 F005
D001F003F005
D001 F003 F005
D001 F003 F005
D001 F003 F005
SIC
Code
2833
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
4953
2865
Unk.
2869
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
2821
Unk.
Unk.
2819
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Source
Code
A32
Unk
Unk
Unk
Unk
Unk
Unk
Unk
A73
A33
Unk
A31
Unk
Unk
Unk
Unk
Unk
Unk
A33
Unk
Unk
Unk
Unk
Unk
Unk
Unk
Unk
Unk
Unk
Unk
Unk
rorm
Code
B207
B219
B219
B219
B219
B219
B219
B219
B203
B203
B219
B207
B204
B204
B204
B204
B204
B204
B602
Unk.
Unk.
Unk.
B203
B203
B203
B203
B203
B203
B203
B203
B203
Hazard
Score
3.7E+13
2.6E+12
2.6E+12
2.6E+12
2.6E+12
2.6E+12
2.6E+12
2.6E+12
2.4E+12
6.5E+11
6.3E+11
5.8E+11
5.4E+11
5.4E+11
5.4E+11
5.4E+11
5.4E+11
5.4E+11
5.3E+11
5.1E+11
5.1E+11
4.6E+11
4.5E+11
4.5E+11
4.5E+11
4.5E+11
4.5E+11
4.5E+11
4.5E+11
4.5E+11
4.5E+11
Volume
(Tons)
3724.88
20.25
1325.1
613.95
248.59
45.05
14.67
17.81
4880.02
6554.5
31348.19
3873
1.88
745.82
0.92
1553.42
1482.27
6.61
13395.7
1612.8
1626.38
320.42
5.91
5.62
101.51
70.48
55.59
34.49
6.08
3.68
704.15
State
CT
CT
MA
NJ
NY
PA
VA
WV
KY
LA
Ml
VA
FL
KY
IN
OH
Wl
IA
KY
OH
LA
TN
CT
MA
ME
NJ
NY
MD
PA
VA
AL
EPA
Region
1
1
1
2
2
3
3
3
4
6
5
3
4
4
5
5
5
7
4
5
6
4
1
1
1
r
f
f
\i
f
\.
f
\.
i
14
-------
EXHIBIT 5
TOP 80 RANKED WASTESTREAM COMBINATIONS WITH GENERATING
STATES AND REGIONS
Rank
12
13
14
15
RCRACode
D001 F003 F005
D001 F003 F005
D001 F003 F005
D001 F003 F005
D001 F003 F005
D001 F003 F005
D001 F003 F005
D001 F003 F005
D001 F003 F005
D001 F003 F005
D001 F003 F005
D001 F003 F005
D001 F003 F005
D001F003F005
D001 F003 F005
D001 D004 D005 D006 D007
D001 D004 D005 D006 D007
D001 D004 D005 D006 D007
K051
D001 D004 D005 D006 D007 D008 D009 D010 D01 1 D016
D001 F003 F005
nnm pnns pnn*
D001 F003 F005
D001 F003 F005
D001 F003 F005
D001 F003 F005
D001 F003 F005
D001 F003 F005
D001 F003 F005
D001 F003 F005
D001 F003 F005
SIC
Code
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
2911
Unk.
Unk.
Up.k.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Source
Code
Unk
Unk
Unk
Unk
Unk
Unk
Unk
Unk
Unk
Unk
Unk
Unk
Unk
Unk
Unk
Unk
Unk
Unk
A89
Unk
Unk
1 Inlf
- -^^| || \
Unk
Unk
Unk
Unk
Unk
Unk
Unk
Unk
Unk
Form
Code
B203
B203
B203
B203
B203
B203
B203
B203
B203
B203
B203
B203
B203
B203
B203
B204
B204
B204
B603
B202
B204
B204
i*** wnr
B204
B204
B204
B204
B204
B204
B204
B204
B204
Hazard
Score
4.5E+11
4.5E+11
4.5E+11
4.5E+11
4.5E+11
4.5E+11
4.5E+11
4.5E+11
4.5E+11
4.5E+11
4.5E+11
4.5E+11
4.5E+11
4.5E+11
4.5E+11
4.4E+11
4.4E+11
4.4E+11
2.9E+11
2.6E+11
2.6E+11
O CCj.'M
' ba*Wh» III
2.6E+11
2.6E+11
2.6E+11
2.6E+11
2.6E+11
2.6E+11
2.6E+11
2.6E+11
2.6E+11
Volume
(Tons)
10.49
151.51
2.2
52.93
11.87
13.01
66.24
9.66
1.04
5.23
1.71
1.4
9.4
1.29
9.51
503.37
662.1 1
21086.04
2530.88
6591
72.04
M no
ww«ww
7.82
10.96
5.14
65.49
1716.23
10.4
51.77
6.82
26.53
State
FL
MS
NC
SC
TN
IN
Ml
MN
OH
LA
KS
MO
CO
ND
CA
TN
IN
Ml
TX
MO
NJ
VA
w r~\
WV
KY
IL
IN
Ml
OH
MO
NE
CA
EPA
Region
4
4
4
4
4
5
5
5
5
6
7
7
3
8
9
4
5
5
6
7
2
O
w
3
4
5
5
5
5
7
7
9
15
-------
EXHIBIT 5
TOP 80 RANKED WASTESTREAM COMBINATIONS WITH GENERATING
STATES AND REGIONS
lank
icu irv
16
17
18
19
20
21
22
23
n A
24
25
26
27
28
or
29
30
RCRA Code
D001 D004 D005 D006 D007 D008 D009 D010 D01 1 D018
D001 D004 D005 D006 D007 D008 D009 D010 D01 1 D018
D001 D004 D005 D006 D007 D008 D009 D010 D011 D018
D001 D005 D006 D007 D008
D001 D004 D005 D006 D007 D008 D009 D010 D016 F001
D001 D002 D003 D008 D018 D023 D024 D025 D026
D001 D002 D003 D004 D005 D006 D007 D008 D009 D010
D001 D004 D005 D006 D007 D008 D010 D011 D018 D035
D001 D005 D006 D007 D008
D001 D005 D006 D007 D008
D001 D005 D006 D007 D008 D009 D019 F001 F002 F003
D018 F037 F038 K048 K049 K050 K051
D001 D004 D005 D006 D007
D001 D004 D005 D006 D007
D005 D006 D008 F001
D001 D007D008D018
<
'
D001 D005 D006 D007
SIC
Code
Unk.
Unk.
Unk.
7389
7389
2869
4953
2899
Unk.
Unk.
Unk.
3221
2911
Unk.
Unk.
4953
2911
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Source
Code
Unk
Unk
Unk
A89
A71
A33
A99
A89
Unk
Unk
Unk
A54
A75
Unk
Unk
Unk
A89
Unk
Unk
Unk
Unk
Unk
Unk
Unk
Unk
Unk
Unk
Unk
Unk
Unk
Unk
Form
Code
B202
B202
B202
B204
B219
B219
B114
B204
B407
B407
B407
B206
B603
B407
B407
B204
B204
B206
B206
B206
B206
B206
B206
B206
B20
B20
B20
B20
B20
B20
B20
Hazard
Score
2.2E+11
2.2E+11
2.2E+11
2.2E+11
1.9E+11
1.9E+11
1.8E+11
1.8E+11
1.6E+11
1.6E+11
1.2E+11
1.2E+11
1.1E+11
9.0E+10
9.0E+10
8.7E+10
8.5E+10
7.6E+10
7.6E+10
7.6E+10
7.6E+10
7.6E+10
7.6E+10
7.6E+10
7.6E+10
7.6E+10
7.6E+10
7.6E+10
7.6E+10
7.6E+10
7.5E+10
Volume
(Tons)
1524
1507
938
10883.06
4743.09
9581.65
4564.7
4531.4
502.89
7323.96
2999.42
6220.58
10580
2504.52
257.48
4348.14
8564.82
1.51
898.69
10.06
6.11
166.51
38.7
370.38
95.55
129.65
12.95
1.33
2.96
1777.03
3775.38
State
AL
TN
CA
TX
TX
TX
TX
AL
Ml
AR
AR
NJ
LA
GA
TX
OH
OH
CT
Rl
NJ
DE
MD
PA
VA
IL
TX
IA
KS
MO
CA
OH
EPA
Region
4
. 9
6
6
6
6
4
5
6
6
2
6
4
6
c
£
1
1
o
d.
ft
».
f
. t
/
«!
/
*.
5
6
i
I
i
16
-------
EXHIBIT 5
TOP 80 RANKED WASTESTREAM COMBINATIONS WITH GENERATING
STATES AND REGIONS
Rank
31
32
33
34
35
36
37
38
39
40
RCRA Code
D001 F001 F003 F005
D001 F001 F003 F005
D001 F001 F003 F005
D001 F001 F003 F005
D001 F001 F003 F005
D001 F001 F003 F005
D001 D007 D008 D018 D022 D026 D027 D028 D033 D036
D001 D005 D006 D007 D008 F003 F005
D001 D002 D005 D006
D001 D006 D008 F002
D001 D006 D008 F002
F001 F002 F003 F005
F001 F002 F003 F005
F001 F002 F003 F005
F001 F002 F003 F005 .
D001 D005 D006 D007 D008 D01 1 D022 D035 D039 F001
D001 D028 F037 F038
D001 D002 D007 D008 D018 D035 F001 F003 F005 U009
D008
D008
D008
r»orvo
L/V/UU -- - ------
D008
D008
D008
D008
D008
D008
D008
D008
D008
SIC
Code
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
9999
2821
4953
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
2911
2869
Unk.
Unk.
Unk.
1 \*-*\s
wi ir\. ~~
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Source
Code
Unk
Unk
Unk
Unk
Unk
Unk
A99
A73
Unk
Unk
Unk
Unk
Unk
Unk
Unk
Unk
A89
A37
Unk
Unk
Unk
1 Inlx
wurv
Unk
Unk
Unk
Unk
Unk
Unk
Unk
Unk
Unk
Form
Code
B204
B204
B204
B204
B204
B204
B219
B602
B204
B403
B403
B204
B204
B204
B204
Unk.
B205
B219
Unk.
Unk.
Unk.
1 l»lx
wnrti
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Hazard
Score
7.4E+10
7.4E+10
7.4E+10
7.4E+10
7.4E+10
7.4E+10
7.0E+10
6.8E+10
6.6E+10
6.3E+10
6.3E+10
6.3E+10
6.3E+10
6.3E+10
6.3E+10
6.2E+10
5.8E+10
5.7E+10
5.3E+10
5.3E+10
5.3E+10
c ocjL-in
~ ^.Wl_T IV
5.3E+10
5.3E+10
5.3E+10
5.3E+10
5.3E+10
5.3E+10
5.3E+10
5.3E+10
5.3E+10
Volume
(Tons)
36.07
94.32
1.2
1905.18
130.74
0.98
7001.93
3410.43
3295.85
2300
868
6952.6
2.86
17.41
2.67
3124
6785.02
5679
5.2
4.8
3.5
ijt no
UT.9U
1.6
16.8
33.6
7.3
7.23
8.92
0.69
1.2
0.86
State
Rl
NY
IL
Ml
OH
NM
IN
WI
OH
OH
TX
PR
FL
IN
TX
OH
TX
TX
MA
VT
NY
Cl
_ -, e
KY
NC
SC
TN
IL
IN
Ml
MN
OH
EPA
Region
1
2
5
5
5
6
5
5
5
5
6
2
4
5
6
5
6
6
1
1
2
A
T
4
4
4
4
5
5
5
5
5
17
-------
EXHIBIT 5
TOP 80 RANKED WASTESTREAM COMBINATIONS WITH GENERATING
STATES AND REGIONS
lank
.
41
42
43
~\J
44
45
w
46
~w
47
48
49
50
51
52
53
54
55
56
3CRA Code .
D008
\J W \J\J *
D008
D008
^j \j\j\j
D008
!_/ WWW
D008
U \J\J\J *
D008
1*S \J\J\J
D008
\J\J\J\J *
D008
l*J \J\J\J
D008
D001 D007 D008 F001 F002 F003 F005
D001 D018K048K049
D001 F004
D001 F001 F002 F003
rjooi
Li/ W 1
F001 F002 F003
F001 F002 F003
F001 F002 F003
F001 F002 F003
F001 F002 F003
F001 F002 F003
F001 F002 F003
D001 D011 D018D021 D022
D001 D002 D003 D004 D005 D006 D007 D008 D009 D010
K048
D001 F003 F005
D001D002D007
K049
D001 D005 D006 D007 D008 F001 F002 F003 F004 F005
D001 D002
D001 D002 D007
D001 D002 D003
SIC
Code
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
9999
2911
2821
2899
2512
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
3861
2869
2911
3053
2869
2911
7389
2869
2869
2879
Source
Code
Unk
Unk
Unk
Unk
Unk
Unk
Unk
Unk
Unk
Unk
Unk
A33
A89
A92
Unk
Unk
Unk
Unk
Unk
Unk
Unk
A49
A33
A75
A56
A33
A75
A71
A35
A33
A37
rorm
Code
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
B202
B204
B602
B204
B403
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
B204
B105
B503
B403
B602
B202
B206
B21S
B219
B102
Hazard
Score
5.3E+10
5.3E+10
5.3E+10
5.3E+10
5.3E+10
5.3E+10
5.3E+10
5.3E+10
5.3E+10
4.9E+10
3.7E+10
3.2E+10
2.9E+10
2.6E+10
2.4E+10
2.4E+10
2.4E+10
2.4E+10
2.4E+10
2.4E+10
2.4E+10
9.4E+09
6.6E+09
6.0E+09
4.3E+09
3.7E+09
3.3E+09
3.2E+09
1.9E+09
1.6E+09
8.2E+08
Volume
(Tons)
2.75
.2.92
0.7
256.39
2
4.82
3.7
0.7
3.4
4866
3669.25
3990.1
5279.02
4322.9
103.96
72.5
2822.32
44.68
1647.09
107.08
22.93
9376.37
13182.63
19996
3465
36709
3316
3518.1
92363
4266.5
27247.45
State
LA
OK
TX
KS
MO
NE
AZ
CA
Q
TN
OH
NY
AL
NC
NJ
GA
TN
IN
OH
TX
CO
NY
TX
TX
VA
TX
IL
TX
TX
TX
TX
EPA
Regton
6
6
6
7
7
7
9
9
11
4
5
2
4
4
2
4
4
5
C
w
6
8
f
6
6
f
\.
6
C
«.
6
6
6
6
18
-------
EXHIBITS
TOP 80 RANKED WASTESTREAM COMBINATIONS WITH GENERATING
STATES AND REGIONS
Rank
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
RCRA Code
D002
D001
D001
D001
D001
D001
D001
D001 D002 D007 D018 D021 F002 F003 F005
K022
D001 D002 D007 D018 D021 F002 F003 F005
D001 D002
D001 D002 D003 D007 D018 D019 D021 D022 D028
K022
K022
D001 D002 D019 D032 D033 D034 D039 F002
D001 D002
D001 D002
D001 D002
D001 D002
D001 D002
D001 D002
r\r\r\-t r\r\f\f\
UTUVI U\J\J£.
D001 D002
D001 D002
D001 D002
D001 D022
D001 D002
D001 D002
D001- D002
D001 D002
K022
SIC
Code
2869
2869
2869
2869
2869
2822
2869
2865
2865
2865
2819
2869
2869
2865
2869
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
i i~i-
\JI IK.
Unk.
Unk.
Unk.
2869
9999
2869
2869
2821
2869
Source
Code
A09
A35
A35
A35
A35
Unk
A35
A31
A33
A34
A37
A33
A33
A35
A33
Unk
Unk
Unk
Unk
Unk
Unk
uHK
Unk
Unk
Unk
A37
Unk
A33
A33
A49
A33
Form
Code
B207
B219
B219
B219
B219
Unk.
B207
B204
B602
B204
B219
B212
B606
B602
B219
Unk.
Unk.
Unk.
Unk.
Unk.
Unk.
\jfit\.
Unk.
Unk.
Unk.
B202
Unk.
B219
B219
B102
B219
Hazard
Score
8.0E+08
6.4E+08
6.4E+08
6.4E+08
6.4E+08
6.1E+08
5.4E+08
4.8E+08
4.7E+08
4.3E+08
3.2E+08
2.9E+08
2.3E+08
2.3E+08
1.9E+08
1.7E+08
1.JE+08
1 .7E+08
1.7E+08
1.7E+08
1.7E+08
< -»er i no
1 .1 CTVO
1.7E+08
1.7E+08
1.7E+08
1.7E+08
1.5E+08
1.5E+08
1.5E+08
1.4E+08
1.1E+08
Volume
(Tons)
8001.82
27
290.3
50.3
11387
3068
10250.52
2348.7
9432
4316.71
15997
2900
23281.64
4609.19
42.5
56.42
136.64
2.29
1.06
167.6
6.35
-7 tn
I . u
14.98
3060.5
2.45
3414.5
621.41
112.28
7300.38
1828.55
10846
State
TX
WV
AL
LA
TX
TX
AR
TX
AR
TX
IA
PA
TX
TX
MD
KY
TN
IL
OH
Wl
LA
r\if
\Jl\
TX
CA
LA
TN
VA
TX
CA
TX
TN
EPA
Region
6
3
4
6
6
5
6
6
6
6
6
7
3
6
6
3
4
4
5
5
5
e
u
6
6
9
6
4
3
6
9
6
19
-------
EXHIBIT 5
TOP 80 RANKED WASTESTREAM COMBINATIONS WITH GENERATING
STATES AND REGIONS
Rank
75
76
77
1 1
78
1 \J
79
80
RCRA Code
D001 D002 F003
D001 D002U008U113
K027
1 \\JC-I
K027
D001K013U003
D018D038K022K083
SIC
Code
2819
2869
2865
2865
2869
2865
Source
Code
Unk
A33
A33
A33
A33
Unk
Form
Code
Unk.
B101
B409
B403
B219
Unk.
Hazard
Score
1.1E+08
18908809
443896.6
177869.9
166236.7
34526.41
Volume
(Tons)
596.35
189524.4
11123.19
4457.09
5554
17303
State
TX
LA
WV
TX
OH
EPA
Region
4
6
6
3
6
5
20
-------
Exhibit 6.
Hazard Ranking of Metals in Toxics Release
Inventory Releases from Combustion Facilities
Metal
lead
copper
mercury
silver
cadmium
chromium
manganese
zinc
nickel
antimony
arsenic
barium
cobalt
Percent of
Overall Metal
Hazard Score
76
20
3
<1
<1
<1
<1
<1
<1
<1
<1
<1 i
<1
21
-------
-------
-------
------- |