United States
             Environmental Protection
             Agency
Office of Solid Waste
and Emergency Response
Washington, DC 20460
EPA/530-SW-86-041
October 1986
&EPA      Waste  Minimization

             Issues and Options

             Volume  I

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Waste Minimization Issues and Options
              Volume  1
            Submitted by:

             Versar, Inc.
         6850 Versar Center
           P. 0. Box 1549
      Springfield, Virginia 22151

                 and

      Jacobs Engineering Group
         251 S.  Lake Avenue
      Pasadena,  California  91101
            Submitted to:

             Elaine Eby
        Office of Solid Waste
       Waste Treatment Branch
U.S. Environmental Protection Agency
          401 M Street, S.W.
       Washington, D.C. 20460
           In Response to:

    EPA Contract No. 68-01-7053
       Work Assignment No. 17
           October 1, 1986


'.' S,  Environmental  Protection
:•'   ;"'."  V, Library
>   -  Soi,.:.  De.,ibcrn Street
"•'v-.^o. ;iii.io,s   60604

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Waste Minimization Issues and Options
              Volume 1
            Submitted by:

             Versar, Inc.
         6850 Versar Center
           P. 0. Box 1549
     Springfield, Virginia 22151

                and

      Jacobs Engineering Group
         25 1 S. Lake  Avenue
     Pasadena, California  91101
            Submitted to:

             Elaine Eby
        Office of Solid Waste
      Waste Treatment Branch
U.S. Environmental Protection Agency
         401 M Street, S.W.
      Washington, D.C.  20460
           In Response to:

    EPA Contract No. 68-01-7053
       Work Assignment No. 17
           October 1, 1986

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                                 DISCLAIMER

     This document has been reviewed and approved for publication by the Office
of Solid Waste, Office of Solid Waste  and  Emergency  Response, U.S. Environmental
Protection Agency.  Approval does not signify  that the contents necessarily reflect
the  views and  policies of  the  Environmental  Protection  Agency,  nor  does the
mention   of  trade   names  or commercial  products   constitute  endorsement  or
recommendation for use.

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                             TABLE OF CONTENTS

                                                                       Page No.

EXECUTIVE SUMMARY 	                     ES-1

PREFACE 	                            1

1.    DEFINITION AND SCOPE OF WASTE MINIMIZATION	       1-1

     1.1   Background and Scope of the "Waste Minimization"
           Definition 	                         1-3
     1.2   Background and Scope of the Issue of Burning for
           Energy as a Recycling Activity 	                   1-4

2.    WASTE GENERATION PROFILE 	               2-1

     2.1   Causes of Waste Generation 	                   2-1
     2.2   Industry—Specific Waste Generation Profile  	               2-6
           2.2.1    Characteristic Waste Stream Generation and
                   Recycling 	                     2-16
           2.2.2    Generation and Management  Profile by Waste
                   Category	                     2-18
     2.3   Process - Specific Waste Generation Profile 	               2-29
     2.4   Summary	                        2-36

3.    SOURCE  REDUCTION PROFILE	               3-1

     3.1   Source Control Methodology 	                   3-2
           3.1.1    Input Material Alteration 	                  3-2
           3.1.2    Technology Modifications 	                 3-5
           3.1.3    Procedural/Institutional Modifications 	              3-11
     3.2   Current and Future Extent of  Waste Minimization
           through Source Control 	                     3-13
     3.3   Product Substitution 	                      3-22
     3.4   Summary of Findings and Observations	               3-28

4.    WASTE RECYCLING  PROFILE 	                4-1

     4.1   Characterization of Recycling Practices and
           Technologies	.„.„,„„„„—	                        4-1
     4.2   Current Extent of Recycling 	                   4-3
           4.2.1    Industry-Specific Profile 	                  4-3
           4.2.2    Waste-Specific Profile 	                  4-7
           4.2.3    Recycling Technology Profile 	               4-22
     4.3   Offsite Recycling	                       4-43
           4.3.1    Commercial Recycling Facilities	               4-43
           4.3.2    Waste Exchanges	                   4-45
     4.4   Future Extent of Recycling 	                    4-58
     4.5   Summary	                        4-61

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                       TABLE OF CONTENTS (continued)

                                                                      Page No.

5.    FACTORS THAT PROMOTE OR INHIBIT WASTE MINIMIZATION 	  5-1

     5.1   Economic Aspects and Technological Innovation 	             5-1
           5.1.1    A Firm's Decision to Invest 	                 5-2
           5.1.2    Investment in Innovative Technology	              5-5
           5.1.3    Investment in Waste Minimization 	              5-7
     5.2   Liability Aspects	                        5-11
           5.2.1    Inability to Obtain Insurance 	                 5-11
           5.2.2  * Cleanup Costs 	                    5-15
           5.2.3    Liability as an Incentive for Onsite and
                   Offsite Recycling	                    5-22
     5.3   Organizational and Attitudinal  Aspects 	                 5-25
           5.3.1    The Organization of Environmental Programs
                   within Firms	                     5-26
           5.3.2    Company Policy-Making and Policy
                   Implementation Processes	                 5-29
           5.3.3    Industry Perception of RCRA 	               5-31
           5.3.4    Origins of Opposition  to Change 	               5-33
     5.4   Consumer Attitudes and Public Relations Issues	              5-36
     5.5   Regulatory  Aspects	                      5-38
           5.5.1    Waste Minimization Certifications 	              5-39
           5.5.2    EPA's Definition of Solid Waste 	               5-41
           5.5.3    Land  Disposal Restrictions	                 5-48
           5.5.4    Technological and Other Requirements for New
                   and Existing TSD Facilities	                 5-56
           5.5.5    Siting 	                        5-58
           5.5.6    Permitting Issues 	                    5-62
           5.5.7    Delisting Issues 	                     5-65
     5.6   Summary 	                         5-66

6.    INDUSTRY EFFORTS TOWARDS WASTE MINIMIZATION 	     6-1

     6.1   Description of  Information Base 	                   6-1
     6.2   Observed Trends in Industrial Waste Minimization
           Efforts 	                           6-2
     6.3   Capital Outlays, Annual Savings,  and Payback Period ...            6-4
     6.4   Summary	                         6-6

7.    GOVERNMENT AND NONINDUSTRY EFFORTS TOWARD WASTE
     MINIMIZATION 	                        7-1

     7.1   Congressional  Initiatives	  •                    7-1
           7.1.1    Congressional Budget  Office 	                7-1
           7.1.2    Office of  Technology  Assessment	              7-2

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                  TABLE OF CONTENTS ^continued)

                                                                  Page No.

7.2   National Research Council 	                   7-3
7.3   Federal Agencies 	                       7-4
     7.3.1     Environmental Protection Agency	             7-4
     7.3.2     Department of Energy 	                 7-8
     7.3.3     Department of Defense	                 7-9
     7.3.4     Bureau of Mines	                   7-16
     7.3.5     Tennessee Valley Authority 	                7-17
7.4   State and Local Efforts	                     7-19
     7.4.1     Regulatory Programs	                 7-19
     7.4.2     Fee and Tax Incentives 	                 7-25
     7.4.3     Loan and Bond Assistance	                 7-33
     7.4.4     Grant Programs	                   7-36
     7.4.5     Information Programs	                 7-37
     7.4.6     Award Programs 	                  7-42
7,5   Nongovernmental, N on industrial £fforts .-„.,.. ,„„..„               7-43
     7.5.1     League of Women Voters	                7-43
     7.5.2     Pollution Probe Foundation 	                 7-44
     7.5.3     INFORM 	                     7-45
     7.5.4     Environmental Defense Fund	               7-46
     7.5.5     German Marshall Fund	                 7-47
7.6   Summary	                        7-47

POTENTIAL STRATEGIES/OPTIONS FOR FURTHERING THE GOAL
OF  WASTE MINIMIZATION	                  8-1

8.1   Identification and  Organization of Options	                8-1
8.2   Potential Criteria for Deciding among Options	              8-7
8.3   Reliance on Authorities and Requirements Defined
     by the Hazardous and Solid Waste Amendments of 1984 ...          8-8
8.4   The Scope of Applicability:  Modification  of
     Definition of Solid Waste  and  Associated Regulations ..            8-10
     8.4.1     Clarification of  Relationship of Treatment
              and Reclamation 	                   8-11
     8.4.2     Clarification of  Relationship of Ingredient
              to  Feedstock 	                     8-12
     8.4.3     Greater Use of Concept of Equivalence in
              Determining Which Recycled Materials Should
              Be Subject to Regulation 	                 8-13
8.5   Performance Standards	                    8-15
     8.5.1     Performance Standards Limiting Volume and/or
              Toxicity of Wastes for Generators 	               8-15
     8.5.2     Waste Generation Marketable Permit  Program ....         8-18
     8.5.3     Prohibit or Restrict Generation of Specific
              Wastes	                       8-22
                                  vn

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                       TABLE OF CONTENTS (continued)

                                                                       Page No.

           8.5.4    Use of Effluent Guidelines to Increase  Source
                   Reduction and Recycling (CWA)	              8-23
           8.5.5    Establishment of Toxicity Levels for
                   Delisting Petitions 	                    8-24
     8.6   Management Practices	                    8-25
           8.6.1    Require Information from Generators on
                   Material Inputs, Uses, and Discharges 	              8-25
           8.6.2    Use of Permits to Limit Amount of Waste That
                   Can Be Land Disposed, Incinerated, or
                   Otherwise Disposed of or Treated per Generator .         8-28
           8.6,3    Require Segregated Waste Streams for
                   Potentially Recyclable Wastes	               8-30
           8.6.4    Require Technical Audits to Identify Waste
                   Reduction Potential 	                  8-33
           8.6.5    Ban the Landfilling, Treatment, or Incineration
                   of Potentially Recyclable  Wastes	               8-34
     8.7   Economic Incentives	                     8-35
           8.7.1    Development of Information and Technology
                   Transfer Network 	                   8-35
           8.7.2    Establish Preferred Procurement  Practices	           8-40
           8.7.3    Develop Improved Waste Marketing Capability
                   for Hazardous Wastes of the Military
                   Services 	                      8-46
           8.7.4    Non-Tax Financial Incentives 	               8-48
           8.7.5    Tax Incentives 	                     8-49
           8.7.6    Waste-End tax  	                    8-52
           8.7.7    Rating Outstanding Recycling Facility
                   Performance 	                    8-55
           8.7.8    Reduced Liability for Generators Using
                   Specially Permitted Recyclers	               8-57
           8.7.9    Recycling Substances Act 	                8-59
           8.7.10   Expedited Consideration of Delisting
                   Petition 	                      8-61
           8.7.11   Enforcement Bounties	                 8-61

9.    ANALYSIS OF FINDINGS 	                    9-1

     9.1   Trends in Waste Minimization 	                   9-1
     9.2   Nontechnical Factors That Promote and  Inhibit
           Waste Minimization 	                     9-4
     9.3   Governmental Efforts to Promote Waste Minimization ....          9-9
     9.4   Options to Further Promote Waste Minimization 	            9-11
                                       vm

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                    TABLE OF CONTENTS (continued)

                                                             Page No.

10.   REFERENCES	                    10-1

VOLUME 2

     APPENDIX A  DATA BASES USED IN THIS STUDY
     APPENDIX B  PROCESS STUDIES

VOLUME 3

     APPENDIX C  RECYCLING TECHNOLOGIES AND PRACTICES

     APPENDIX D  NORTHEAST  INDUSTRIAL  WASTE  EXCHANGE'S  ON-LINE
                 COMPUTER SYSTEM

     APPENDIX E  CONDUCTING A PROJECT PROFITABILITY ANALYSIS

     APPENDIX F  EPA'S DEFINITION OF SOLID WASTE

     APPENDIX G  CORRESPONDENCE  FROM  EPA ON  WASTE MINIMIZATION
                 ACTIVITIES

     APPENDIX H  COMPILATION OF INDUSTRIAL WASTE REDUCTION CASES

     APPENDIX I   ENVIRONMENTAL AUDITING POLICY STATEMENTS

     APPENDIX J  DESCRIPTIONS OF STATE PROGRAMS

     APPENDIX K  TWO  PROPOSED  REGULATIONS  ON  HAZARDOUS   WASTE
                 MANAGEMENT BY TWO COUNTIES IN CALIFORNIA
                                   IX

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                                LIST OF TABLES
Table 2-1   Waste Generation: A Summary of Process Origins,
            Causes, and Controlling Factors	

Table 2-2   Typical Motivational Aspects Related to Waste
            Generation or Minimization 	

Table 2-3   Industry Ranking by Hazardous Waste Generation
            Using 2-Digit SIC Code 	

Table 2-4   Industry Ranking by Hazardous Waste Generation
            Using 4-Digit SIC Code	

Table 2-5   SIC Classification of Small Quantity  Generators by
            Industrial Groups Targeted by the National Small
            Quantity Generator Survey 	

Table 2-6   Profile of RCRA Characteristic Waste Generation by
            the Ten Highest Volume Wastes Generating Industries
            in  1981	

Table 2-7   List of Major Products  Based on Nationwide Total
            Waste Generation Rates	

Table 2-8   List of Major Products  Based on Nationwide
            Hazardous Waste Generation Rates	

Table 2-9   List of Major Products  Based on Specific Total Waste
            Generation  Rates (Ib Total Waste/lb Product)	

Table 2-10  List of Major Products  Based on Specific Hazardous
            Waste Generation Rate (Ib Total Waste/lb Product) ....

Table 3-1   Current and Future Reduction Indices for All Wastes
            Considered  in Process and  Practice Studies	

Table 3-2   Current and Future Reduction Indices for "F" and "K"
            RCRA Wastes Considered  in Process and Practice
            Studies 	

Table 3-3   National Hazardous Waste  Generation and Reduction
            Profile 	

Table 3-4   Summary of Identified Product Substitutions 	

Table 4-1   Ten Highest Volume Waste Generating Industries -
            Generation  and Recycling  Volumes During 1981  	

Table 4-2   Wastes Recycled During 1981 	
Page No.


   2-3


   2-5


   2-8


   2-10



   2-13



   2-17


   2-32


   2-33


   2-34


   2-35


   3-15



   3-18


   3-20

   3-24


   4-5

   4-10

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Table 4-3   F- and K-Code Wastes Unlikely to Be Recycled in
            Significant Volumes	                     4-23

Table 4-4   Ranges of Costs for Technologies Used for  Recovery
            and Recycling of Solvents	                    4-26

Table 4-5   Ranges of Costs for Technologies Used for  Recovery
            and Recycling of Metals	                    4-34

Table 4-6   List of Information and Material Waste Exchanges .....            4-47

Table 5-1   Costs Associated with Hazardous Waste Generation  .....           5-8

Table 5-2   Treatment Processes  Identified 	                  5-17

Table 5-3   Factors That Influence Cleanup Costs of a
            Hazardous Waste Site	                    5-19

Table 5-4   Average Estimated Cleanup Cost by Type of Site 	            5-21

Table 5-5   Waste Materials Defined as Solid  Wastes under the
            Revised Definition 	                      5-44

Table 5-6   Timetable of Land Disposal Restrictions	—...               5-50

Table 5-7   Solvent- and Dioxin-Containing Hazardous  Wastes for
            Which Land Disposal Restrictions Were Proposed
            by EPA	                        5-52

Table 6-1   Characterization of Reported Waste  Minimization
            Techniques 	                        6-3

Table 6-2   Characterization of Reported Efficiency 	               6-5

Table 6-3   Capital Cost Outlays	                     6-5

Table 6-4   Annual Cost Savings	                     6-7

Table 6-5   Payback Periods 	                      6-7

Table 7-1   State Regulatory Programs and Final Authorization
            Status as of December 9,  1985 	                  7-21

Table 7-2   Fee and Tax Incentives to Minimize Waste for
            Hazardous Waste Generators and/or Disposers 	             7-31

Table 7-3   Information Programs That Promote  Hazardous Waste
            Minimization 	                        7-39

Table 8-1   Categories of Waste Management Options and Their
            Relationship to Federal and State Programs 	              8-5

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                               LIST OF FIGURES
Figure 2-1    Distribution of the Total Volume of Hazardous
             Waste Generated by SIC Category 	

Figure 2-2    Management Practices  of the Chemical and Allied
             Products Industries (SIC 28) for Waste Streams
             Containing Nonhalogenated Solvents 	

Figure 2-3    Management Practices  of the Chemical and Allied
             Products Industries (SIC 28) for Waste Streams
             Containing Halogenated Solvents	

Figure 2-4    Management Practices  of the Chemical and Allied
             Products Industries (SIC 28) for Waste Streams
             Containing Halogenated (Nonsolvent) Organic
             Wastes	

Figure 2-5    Management Practices  of the Chemical and Allied
             Products Indistries (SIC 28) for Metal-Bearing
             Waste Streams	

Figure 2-6    Management Practices  of the Chemical and Allied
             Products Industries (SIC 28) for Waste Streams
             Containing Corrosive.Wastes 	

Figure 2-7    Management Practices  of the Chemical and Allied
             Products Industries (SIC 28) for Waste Streams
             Containing Cyanide/Reactive Wastes 	

Figure 3-1    Elements of Waste Minimization 	

Figure 4-1    Comparison of Volume  Generated  and Volume Recycled
             in 1981 by the Ten Highest Hazardous Waste
             Generating Industries 	

Figure 4-2    Distribution of the Total Volume of Hazardous Waste
             Recycled During 1981,  by SIC Category 	

Figure 4-3    Weighted Average Concentrations of Constituents
             in Waste Streams Recovered or Reused  by the
             Chemical and Allied Products Industries (SIC 28) ....
                                                                      Page No.
2-9
2-20
2-21
2-24



2-26



2-28



2-30

3-3



4-6


4-8



4-15

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                          LIST OF FIGURES (continued)
                                                                      Page No.
Figure 4-4   Weighted Average Concentration of Nonhalogenated
             Solvent Wastes Handled by Various Management
             Practices in the Chemical and Allied Products
             Industries (SIC 28)	

Figure 4-5   Weighted Average Concentration of Halogenated
             Solvent Wastes Handled by Various Management
             Practices in the Chemical and Allied Products
             Industries (SIC 28)	

Figure 4-6   Weighted Average Concentration of Metal Wastes
             Handled by Various Management Practices in the
             Chemical and Allied Products Industries (SIC 28) ....

Figure 4-7   Weighted Average Concentration of Halogenated
             (Nonsolvent) Organic Wastes for Various Management
             Practices in the Chemical and Allied Products
             Industries (SIC 28)	

Figure 4-8   Weighted Average Concentration of Corrosive Wastes
             Handled by Various Management Practices in the
             Chemical and Allied Products Industries (SIC 28) ....

Figure 4-9   Weighted Average Concentration of Cyanide/Reactive
             Wastes Handled by Various Management Practices
             in the Chemical and Allied Products Industries
             (SIC  28) 	

Figure 5-1   Organizational Structure  for a Typical
             Corporate Environmental Program  	
4-16
4-17
4-18
4-19
4-20
4-21
5-28
                                      XI 1 1

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                             EXECUTIVE SUMMARY

    The Hazardous and Solid Waste Amendments of  1984  (HSWA)  establish  as a goal
and  national  policy  the   minimization  of  hazardous  waste generation  and  its
subsequent land  disposal.  The achievement of this objective will require a strategy
to reduce, whenever practical, the amount of  hazardous waste generated, treated,
stored, or disposed of.  Both current and  potential efforts for minimizing hazardous
waste are the subject of this study.

    This study originates from  the directive in HSWA that EPA prepare a Report to
Congress  by  October  1986  on waste  minimization.  The  Report to Congress  must
address the feasibility and desirability  of establishing  standards  of  performance,
required  management  practices, or other actions to. ensure  that hazardous  wastes
are managed in  ways that minimize present and future risks to human health and the
environment.

Definition and Scope of Waste Minimization

    Formal definitions of "waste  minimization" and "source  reduction" have not as
yet been issued  by  EPA. Based on information contained in the legislative history of
the Hazardous  and Solid Waste Amendments (HSWA) of  1984, on  discussions  with
EPA personnel,  and  on the  language of HSWA itself concerning waste minimization,
the following working definitions have  been used for  the purposes of developing  this
study and the Report to Congress:
Waste minimization:    The reduction, to the extent feasible, of hazardous  waste
                       that  is  generated  or  subsequently  treated,   stored,  or
                       disposed  of.  It  includes any source  reduction or recycling
                       activity undertaken  by  a generator*  that  results in  either
                       (l)the  reduction  of  total volume or quantity of hazardous
                       waste or (2) the reduction of toxicity of hazardous waste, or
                       both, so long  as  such reduction is consistent with the goal of
                       minimizing present and  future threats to  human  health  and
                       the environment.
Source reduction:       Any  activity  or  treatment  that reduces or eliminates the
                       generation of a hazardous waste within a process.
                                      ES-1

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    "Recycling" is  considered to be a generic term that encompasses both reuse and

reclamation  as  they  are defined  in  EPA's revised definition  of  "solid  waste"
                                               #
published in the January 4, 1985  Federal Register.   These  definitions are as follows:
Recycled:              A material is "recycled"  if it is used, reused, or reclaimed
                       (40 CFR 261.1(c)(7)).

Used or reused:         A material is "used  or reused" if  it is either (1) employed  as
                       an ingredient (including its  use as an  intermediate)  in  an
                       industrial  process  to  make a  product;  however, a  material
                       will not satisfy this condition if  distinct components of the
                       material  are  recovered as separate end products  (as  when
                       metals  are  recovered  from  metal-containing  secondary
                       materials), or  (2) employed   in  a  particular  function   or
                       application as  an  effective  substitute  for  a commercial
                       product (40 CFR 26 1. l(c)(5)).

Reclaimed:             A material is "reclaimed" if  it  is processed  to  recover  a
                       usable  product  or  if  it  is  regenerated.   Examples are
                       recovery  of lead values  for spent batteries  and regeneration
                       of spent solvents (40 CFR  26 1. Kc)(4)).
     In the broadest sense, HSWA regard waste  minimization as  any action  taken  to

reduce the volume or  toxicity of wastes. Thus, waste minimization also includes the

concept of waste  treatment,  which  encompasses such  technologies  as incineration,

chemical  detoxification, biological treatments,  and others.  The Agency has already

embarked  on  a  broad  program for  waste  treatment; thus,  this report  focuses  on

source reduction and recycling, the  two aspects of waste minimization where basic

policy options still remain open.


Overall Study Approach


     During this study, information  was  gathered and analyzed concerning trends  in

hazardous waste  generation  and  the methods used  for  waste  minimization.  The

information was used to characterize recycling and waste generation trends with
*  This study also  addresses the practice  of burning for energy recovery as a form of
   recycling. For consistency  with EPA regulations, it is assumed that  such burning
   recovers  a minimum of  60 percent thermal energy, of which  75 percent is used, in
   order to qualify as recycling.

                                      ES-2

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respect to specific industries, waste volumes,  and  waste types and to select certain
industries  and  processes  in  order  to  study  their  existing  and potential  source
reduction practices.

    Recycling issues  were examined  with respect  to  the following five generic
hazardous waste stream categories:  (1) solvents, (2) halogenated organics other than
solvents,  (3) metals,  (4) corrosives,  and  (5)  cyanides  and  other  reactives.   The
approach used for recycling is not industry-specific.  It is believed that, in general,
the recycling  technologies  available  are independent  of  the  specific  industrial
processes that produce the waste.

    Source    reduction   issues,   unlike   recycling,   were   examined   on   an
industry-specific basis.  Technology  modifications,  process  changes, and  product
substitution, all aspects of  source reduction, are associated with a particular process
or industry, as opposed to a particular type of waste stream.

    For both recycling  and source reduction, trends or general  patterns of  such
practices among U.S.  industries were identified.  Also examined were the following
issues  as they affect a company's  decision to adopt  waste minimization practices:
(1) economic,  (2) regulatory,  (3)  technological,   (4) liability,  and  (5) attitudinal/
organizational.

Key Findings

    Causes of Waste Generation

    In general,  industrial waste is generated  because less than  100  percent  of  the
combined mass  of  all material input  streams  into a production process leaves  such
process as  a final product.  There  are two types  of  raw input materials:   principal
and auxiliary.  The principal  raw materials  are  directly  converted  into the final
product. For example, propylene  and chlorine are the principal raw materials for
the synthesis  of allyl chloride.  The auxiliary  raw  materials are not converted into a
final product, but are necessary to  enhance product quality  or to operate a process.
                                      ES-3

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Examples of auxiliary raw materials  include solvents used for parts cleaning,  water
for washing operations, lime for water treatment, catalysts for reactions, and other
similar operations.

    In the case of  principal raw materials,  waste generation is  directly dependent
on the product yield. The higher the yield,  the less waste is produced as a result of
incomplete conversion,  undesirable byproduct  formation,  or  inefficient operation or
design  of  separation  equipment  used  to  purify  the  product.   Hence,  waste
minimization  efforts are, in  this case, indistinguishable from  efforts to  improve
product  yield.  Such efforts are generally focused on  improvement of  catalysts,
input  material purity, process design, and operational controls.

    In the case of auxiliary raw  materials, waste generation is often  related to the
type and  amount of impurities to be removed, level of energy and water use, type of
material  used, process  and  equipment design, and  operational  controls.  Material
conservation  and loss control efforts through  source reduction and recycling are of
prime importance.   The often-used example of reclamation and reuse of  cleaning
solvents provides an illustration of auxiliary  material conservation.

    Trends in Waste Minimization

    The  level of  waste  generation in terms  of  units  of waste  per unit of product
appears  to have declined significantly in the  last  10 to 15 years.  This  decline  is
attributed to  implementation of a specific  list of source  control  techniques and  four
industry-wide practices identified  by EPA's study  of  18 processes.  EPA  believes,
based on the  literature descriptions of the practices that the 10-15 year timeframe
is when  most of  the  source  reduction  techniques  actually  have  been  applied.
Therefore,  it is estimated  that if  none  of these techniques  were in place  today,
industry could be generating up to twice the waste per unit production than it  does
at present.  (It must be  noted that this  estimate  is  an approximate rather than  a
definitive representation of the  current  extent of  source  reduction practices to
date.)

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    The  likelihood  of  future  reductions  of  waste  generation  appears  to   be
significant.   When  expressed  in terms of unit waste  per unit  product,  estimates
suggest future reductions of  15 to 30 percent compared to the current rate of  waste
generation.   These reductions  would  result from  the extension of existing  source
control techniques and  the application  of new technologies to  their   full  rated
potential.  Again, these  estimates are  approximate and involve  extensive  use of
qualitative data by the Agency.

    Of the total of hazardous waste generated in 1981, approximately  4 percent  was
recycled, according to  information  derived largely  from an  EPA survey. Of  the
4 percent of  industrial  waste  recycled  in  1981,  the  largest  volumes   of  wastes
recycled  were  chromium-bearing  plating solutions  and electroplating wastewater,
whose constituents were reused within the generating process.  Such use  represents
a  cost savings to  the generator both  in  raw  materials  and  in  disposal  costs.
Generators  recycling   plating  solutions  and   wastes  include  the  Transportation
Equipment industry (SIC 37) and the  Primary Metals industry (SIC 33). Other wastes
commonly rec..rled include spent haiogenated and nonhalogenated  solvents 'various
industries), slop oil emulsions and other wastes from petroleum refining (SIC 29), and
emission  control  dusts  and sludges  from production of  steel  and  lead smelting
(SIC 33).

    Future  recycling  will  include  an  expanded  role  for  commercial  recyclers,
transfers of bulU waste among  large  industries,  and  central recovery  facilities.
State-of-the-art  treatment and recycling  technologies  include  mobile  treatment
units  that can be  set up temporarily or  permanently at  generators' facilities by a
commercial  waste   management  company.   Other  case  studies  document  the
cooperative efforts of generators in pooling or trading their wastes in order to share
costs and minimize liabilities.

    Market  demand  is a critical  factor  for a company deciding whether or  not to
reclaim materials that cannot be  used  in their manufacturing  process.   Economics
will seldom support recovering materials with limited  demand.
                                      ES-5

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    Factors Affecting the Decision to Minimize Waste


    Economics.  The principal guiding mechanism  in  most decisions  to implement

waste  minimization  practices  is one  of  economics.   Evaluations  of  technological

feasibility  are  directly  related  to  economic  viability of the source  reduction  or

recycling  technology.  In  the  majority  of  cases  documenting   either  of   these

practices, the cost savings appear to  justify the investment in equipment, services,

methods, or techniques.  The  possibility of increased costs  of land disposal resulting

from increased technological requirements  for land disposal units may also act as  an

economic incentive to reduce wastes.


    Where waste minimization practices are not  adopted, economic factors are

frequently   cited  as  the  principal  reasons.   Economic  impediments  to  waste
minimization include:


    •   Real (as opposed  to  perceived)  absence  of  economic  feasibility  for the
        options considered to minimize waste or maximize yield;

    •   Absence of funds to evaluate waste  minimization options; and

    •   Lack of  capital to  implement  waste minimization measures with proven
        feasibility (e.g., because  economic benefits  of  waste  minimization  may
        appear   minor  in  comparison to  other  projects competing for  limited
        investment capital).


    Regulatory Factors. Regulations may promote waste minimization by limiting

the choices of  waste management and by changing  the relative economics of waste
disposal practices.  In particular, regulations  resulting from  HSWA  may  present a

powerful incentive for voluntary waste minimization. Reasons include:
     •   Technological  and other requirements  imposed  by  HSWA on  all new and
        existing TSD facilities  may lead to an  increase  in the cost  of  land disposal
        and an increase  in closures  of land disposal  facilities; thus,  generators  are
        more likely to  consider waste minimization practices.

     •   Generators must now certify on their hazardous waste manifests that they
        have a waste  minimization program in  place, to the  extent  economically
        practical.   Generators   must  also  include  descriptions  of  their  waste
                                      ES-6

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       minimization  efforts in the biennial  report.  Further,  TSD  permits  issued
       now contain a condition that  the permittee  certify annually  that a waste
       minimization program is in place.

    •  Some companies who now  may  consider waste  minimization  might never
       have  done  so were  it  not  for  these  recent  legislative  and   regulatory
       developments. Other companies, for whom waste  minimization was a result
       of  increasing product  yield, may now give primary consideration to such
       practices  in  light  of  the  land disposal  restrictions   and  limited  waste
       management alternatives.


    Although   HSWA  regulations  may  provide   direct  incentives   for  waste

minimization, there are aspects to other regulatory programs that may  inhibit it.

These include:


    •  Members of the  regulated community frequently cite  the  RCRA  permitting
       process  as  slow, unpredictable, and  costly.   Some  companies fear that  the
       installation of new equipment  associated with source reduction may require
       permitting  as  a  treatment  facility under  the  RCRA  regulations,  and,
       therefore, these companies consider  other waste  management alternatives
       more economical.

    •  The  definition  of  "solid  waste" was revised recently to ensure adequate
       protection  of  human health and the  environment.  EPA's recently  revised
       definition results in  some previously  exempt  wastes having to be  manifested
        when  shipped  offsite for recycling.  Some companies  who  do so fear  that
        they could  be held  liable for damages caused by subsequent handling of  the
        waste.  Other  companies  within the  regulated  community  perceive  the
        regulation  to  require  permitting   if  reclamation   is  practiced   onsite.
        Although  some  onsite  treatment   technologies  will   require  permitting,
        reclamation activities are exempt from  such requirement; misinterpretation
        of the  regulation may result in  waste management decisions that are based
        on  mistaken  economics  and  that   are  actually counter to  regulatory
        intentions.

    «   The problems associated with the siting of  a waste treatment  facility  are
        significant obstacles to expanding treatment and resource  recovery capacity.

     •   The  corrective  action  requirements  imposed by HSWA may also present an
        obstacle in the  permitting of  TSD   facilities.  Specifically, HSWA  require
        that owners  of  all  new TSDs  must  take  corrective actions for  releases of
        hazardous waste (or constituents) from any solid waste management  unit on
        the property.  This  requirement applies regardless of  when the  waste  was
        placed in the unit, or whether  the unit is closed.
                                       ES-7

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    •   The liability provisions of CERCLA and the liability insurance shortage may
        inhibit offsite recycling.  Under CERCLA Sections 106 and  107, a generator
        can be  held  financially responsible for  the  entire cleanup or restoration of a
        facility to which  it has sent wastes.  Although  an incentive for both source
        reduction  and  onsite recycling (discussed below), it also presents a  problem
        for companies  lacking in-house expertise and resources.  Such  companies are
        more likely  to use  offsite  recyclers.   These  generators desire to obtain
        liability insurance to protect  themselves from  third  party  and government
        claims  for  damages  resulting  from environmental  releases  of  hazardous
        substances.  The   cost  of   all  forms  of   commercial   liability  insurance,
        however, has risen sharply  over the past several  years, while  its availability
        has been sharply reduced.
    Liability Issues.  The  issue of  liability may inhibit offsite recycling,  but  may
                          minimization practices.   Generators of hazardous waste
can  be  held liable  and made  to  pay  for damages  resulting from  the subsequent
mishandling of  their wastes under  the  CERCLA statute.  A generator's liability  in
shipping  hazardous  wastes  offsite  for recycling is  therefore  dependent  on the
reliability of the  recycler. Some small  generators, in particular those who  lack the
in-house expertise  to  recycle  onsite,  may  decide  that  they  have  no acceptable
recycling alternative than to  ship  offsite.  This situation, combined with increased
restrictions on land disposal  and  increasing  costs, may  lead to incidents of illegal
disposal.  For companies in  a position  to  practice onsite  recycling,  however, the
combination  of new regulatory  requirements with potential liability may serve as  an
effective incentive to recycle, as well as to enlist source reduction practices.

     Increased transportation  costs of hazardous wastes caused  by liability concerns
may inhibit  use  of  recycled  materials.  Because  transporters  of  hazardous  wastes
face  greater  potential   liability  than  transporters  of  virgin   materials,  the
transporters  may charge  more  for the shipping of  wastes than  for virgin materials.
Costs of waste materials  for  reclamation and reuse may  be higher than  using virgin
materials  because  of  these  higher  transportation  costs.   Faced  with  a  choice
between reclaiming a  material  for reuse  in  a process and using virgin materials,
companies may  choose  the latter under some  circumstances, if  the virgin material is
more economical than reclaiming and reusing the waste material shipped  offsite.
                                      ES-8

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    Attitude/Organizational Issues.  The organization of a company and its attitude
toward waste minimization are also significant factors that both promote and  inhibit
its practice.  Problems may  arise in  larger companies when environmental managers
do  not  effectively  communicate   or  interact  with  their  production-oriented
counterparts  or  those  responsible  for  research  and   development.   Engineers
responsible for production operations may not be fully cognizant of hazardous waste
handling  and  disposal  problems.  Effective  communication of a  corporate  waste
reduction policy to  all operations levels  contributes to  the implementation of a
successful waste reduction program. It is often helpful for a new process or method
to be promoted by  a  high-ranking  individual who is actively committed to  waste
reduction.

    The  effect of habit on industrial design  and management practices may  inhibit
the  creation   of  waste  minimization  programs.   Familiarity   with   production
techniques  gives  rise   to  operational efficiencies.  Thus,  management  may  be
satisfied with production operations  as  they stand, even if  large quantities of waste
are generated,  and  may  be  reluctant  to  try  innovative techniques (the "if it isn't
broke, don't fix it" outlook).  This outlook may inhibit the  development of initiative
among managers to take waste reduction measures.

    Government Efforts to Promote Waste Minimization

    Many State and Federal agencies are undertaking  programs that either directly
or indirectly promote waste minimization and that  may mitigate conflicts caused b ,
regulations  that both  promote  and  inhibit waste  minimization. Examples  of State
programs include the following:

    •   General information  programs  in  which waste minimization  information is
        disseminated through publications and conferences;
    •   Technical  assistance  programs  that provide  generators  with  specific
        technical advice on how their  processes could be  altered  to  reduce  waste
        generation;
                                      ES-9

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    •  Waste exchange programs,  which facilitate recycling by helping companies
       to "match" the wastes they have available  with those that other companies
       can use; and
    •  Grants, awards, loans,  and  bonds provided to companies  instituting source
       reduction or recycling technologies

    The  fee and tax systems of some States are structured to provide incentives to
minimize waste.  In some States, generators are assessed on the  basis of  amounts of
wastes disposed  of.   This  tax,  called a "waste-end" tax, is levied  primarily as a
means to  generate   revenue   and   to  make  land  disposal  the  least  preferred
alternative.  Other systems  grant tax credits for investment in source reduction  =nd
recycling equipment.

    Federal  agencies  also  have  initiated  programs  concerned  with  waste
minimization. Research and development on waste minimization is being conducted
by EPA, the  Department  of  Energy, and  the Bureau  of Mines, as  well  as   by
Congressional agencies such as the  Office of Technology  Assessment (OTA) and  the
Congressional Budget  Office (CBO).  OTA is conducting a study  on source reduction
that   will  examine State and  Federal  activities  and provide  policy  options on  the
types of programs the Federal Government  can  implement  to enhance source
reduction.   CBO  has  completed   a  study   that  examined  different  types   of
"waste-end"  tax systems as a method for encouraging  waste reduction.  In  still
another  example,  the Tennessee  Valley  Authority (TVA) receives  $1.5  million in
Federal appropriations per  year for  implementation of a program  to reduce waste
generation,  improve  waste  collection and  transportation techniques, and enhance
waste utilization in the public and private sectors.

    The  Department of Defense (POD), as a generator  of hazardous  waste, is
involved  in waste  minimization  at both the  research and  implementation  levels  and
its practices may serve as  a model  for generators  in the private  sector.  DOD  has
made it  a  policy since  1980 to limit  the  generation of  hazardous waste  through
alternative  procurement  policies and  operational procedures.  DOD  implements
waste minimization  activities  through  the  Defense  Environmental   Leadership
Pro]ect,  the  Defense  Logistics  Agency,  and the efforts of the individual bases or
                                     ES-10

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installations themselves.  Recently, the Joint Logistics Chiefs  (JLC) of the services
developed  a  waste  minimization  strategy  and   has proposed  it  for   adoption
throughout DOD.  The program would include a review of procedures and equipment,
increased  research   and   development,   and    an   inter-service   information
exchange/technology   transfer.  Because  DOD's  activities  parallel  man/  m  the
private  sector (e.g., painting, plating, metal fabrication), its efforts may  influence
practices in industry, particularly where cost savings are demonstrated.

     Options to Promote Waste Minimization

     As   part  of the  study,  23 options  for -encouraging waste  minimization  are
identified. The options  are based, in  some cases,  on programs that are actually in
place, and  in  others, on new concepts or approaches that  were developed in  the
course  of the  study.   Among  the  options  described  are  regulatory   programs,
nonregulatory programs, and legislative changes.   The options include performance
standards, management practices, and a broad array of economic incentives.

Summary of Findings

     Until recently, waste minimization was undertaken primarily for purposes other
than for  reducing wastes. Waste minimization was an incidental result of efforts to
decrease  manufacturing  costs  through   improvement   of  yields  and  operating
efficiency.  With the  requirements of RCRA  and the  recent  passage  of  HSWA,
however, companies have begun  to  consider such practices as  a  means  to  reduce
wastes,  liabilities, and the costs associated with regulation.

     Despite the factors that may  promote waste  minimization,  some barriers to its
practice  exist.  These are mainly due  to economic difficulties in investing in waste
 minimization  technologies,  economic/financial  difficulties  caused  by   regulatory
 requirements,  real or perceived problems  in  complying  with  regulations  associated
 with implementing  waste  minimization  practices, technological  barriers,  fear of
 changing the product and/or its quality, and lack of in-house  expertise to  implement
 available technologies.
                                      E5-11

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    The  development  of  certain  State  and  Federal  programs  may  alleviate
impediments to waste  minimization.  Because  of  the  increased  interest  in  waste
minimi2ation  brought  about by  HSWA, information programs may  be particularly
helpful  in  clearing  up  misinterpretations of  regulations.   Some  companies  will
benefit  from assistance and education to personnel.  Innovative financial incentives
also may encourage growth in waste  minimization practices.

    The options described in this study for promoting waste  minimization may  also
offer  some  resolution  of conflicts between factors that promote and  inhibit waste
minimization.  The degree  to  which HSWA by itself effects an  increase in waste
minimization  probably  will not be evident  for several years.  Such information  will
be  significant  in  determining   whether  additional  performance  standards  or
management practices are desirable.
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                                   PREFACE

    The  Solid Waste Disposal Act, as amended by  the  Hazardous and Solid Waste
Amendments of  1984 (HSWA), establishes  as an objective the minimization of both
the generation and land disposal of hazardous waste.  It also establishes as a national
policy  that  hazardous  waste  generation  is  (where  practical) to  be reduced  or
eliminated  as  expeditiously  as  possible  (Sections 1003(a)(6)  and  1003(b)).  These
amendments require  generators  (except  small quantity  generators) to  certify  on
their  manifests  that  (1) they have a program  in place to minimize the amount and
toxicity  of  wastes  generated  to  the  extent economically  feasible, and (2) the
proposed  treatment,  storage, or disposal  method  minimizes the present and future
threats to human health and  the environment.  This certification must also  be made
annually  by  holders of Treatment,  Storage, and Disposal  (TSD) permits (issued after
September 1, 1985).  In addition, generators must  include  in  their biennial reports
(Da description  of  the  efforts undertaken to reduce volume and  toxicity of waste
generated, and  (2) a description of the changes achieved  in volume  and  toxicity of
waste.

    HSWA  also  requires  that the U.S.  Environmental  Protection  Agency  (EPA)
prepare a Report  to Congress by  October 1986 that  addresses the  "feasibility  and
desirability" of  (1) establishing standards of performance or of actions  under the
Solid   Waste Disposal  Act   that  require  generators   to   minimize  waste,  and
(2) establishing  management  practices or other requirements so  that  wastes are
managed in  ways that minimize present and future risks to human health  and the
environment.  The  report  must also include  recommendations that EPA  determines
are "feasible and desirable" to  implement  the national  policy  mentioned  above
(Section  8002(r)  of the Solid Waste Disposal  Act, as amended by HSWA). This study
originates from the directive in HSWA  that EPA prepare a Report to Congress.

Report Objectives

    The  primary  objectives of this report are threefold:
    •   To identify waste minimization practices in the  United  States by  major
        industry processes and by major waste stream;

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    •   To  identify  factors  that  promote  and  inhibit  the  adoption  of  waste
        minimization practices by industry; and
    •   To identify strategies by  which waste  minimization can be increased.
     The report  will also serve as a resource document  on  waste minimization  for
Federal and  State  programs, industries,  and the general public.  It  must be noted
that this  study  approaches the objectives  stated  above in  an exploratory  manner
because  of  the size,  diversity,  and complexity of  the  subject area.  The  results,
therefore, must necessarily  be  viewed  as  exploratory  rather  than  definitive
representations of the  waste minimization issue.

Report Organization

     The report has been  organized in accordance with  the three objectives stated
above.  "Waste Minimization," as it is used in this study,  is defined  and explained in
Section 1.  Strategies  (via performance standards, management practices, or other
actions) are discussed in Section 8 and are based to  a  large degree on efforts  already
in practice  by industry and  by government agencies; those  efforts are described in
Sections 6 and 7, respectively.  Information on  hazardous waste generation and  the
methods used to minimize it are  then presented  in the next three sections of  the
report (Sections 2 through 4).  Factors  that promote  or  inhibit waste minimization
are  examined  in Section  5.  More detailed information on  various  technical and
regulatory aspects  of  this  study is presented  separately  in  the appropriate
appendices in Volumes 2 and  3.

Data Sources

     The information contained in this report was compiled from a variety of  sources
including  the 1981  Regulatory Impact  Analysis (RIA) Mail  Survey,   1983 Biennial
Report  Data Base,  1983 Industrial  Studies Data  Base,  1984 National Small Quantity
Generator  Hazardous   Waste   Survey,  State  information,  effluent  guidelines
background  documents, and other literature.  Appendix A contains descriptions  of
the various  data sources, how they  were  used,  the deficiencies or gaps  associated
with them, and the  extent  to which these deficiencies can be rectified.
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             1. DEFINITION AND SCOPE OF WASTE MINIMIZATION


    Formal definitions of "waste minimization" and "source reduction" have  not  as

yet been issued by EPA.  Based on information contained in  the  legislative history  of

HSWA,  on discussions  with EPA personnel, and  on the language  of HSWA  itself

concerning waste  minimization, we  have drafted the following working  definitions

for purposes of this study:
    •   Waste minimization:
    •   Reduction of total
        volume or quantity:
        Reduction in toxicity:
        Source reduction:
        Source control:
    •   Product substitution:
The  reduction,  to  the  extent feasible,  of
hazardous   waste   that   is   generated   or
subsequently treated,  stored, or disposed of.
It  includes any source reduction or recycling
activity  undertaken  by   a  generator  that
results  in  either  (l)the  reduction  of total
volume  or  quantity  of  hazardous waste,  or
(2) the  reduction  of  toxicity  of  hazardous
waste, or both, so long as such reduction is
consistent   with  the  goal  of   minimizing
present  and  future  threats to  human health
and the  environment.

The reduction in the total amount of hazardous
waste generated, treated, stored, or disposed
of as defined  by volume,  weight, mass,  or
some other appropriate measure.

The reduction  or elimination of the  toxicity
of a hazardous  waste by (1) altering the toxic
constituent(s) of the  waste to less  toxic  or
nontoxic   form(s)   or    (2) lowering    the
concentration of toxic constituent(s)  in  the
waste by means other than dilution.

Any  activity  or  treatment  that  reduces  or
eliminates   the  generation  of  a  hazardous
waste within a process.

Any activity or treatment  classifiable under
source reduction with the  notable exception
of product substitution.

The replacement of  any product intended  for
an intermediate  or  final  use  with   another
product  intended and  suitable  for the  same
intermediate or final use.

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    As  the definition of source reduction indicates, this study examines treatment
of  hazardous  wastes  if  it  is  a  part  of the production  process,  as  opposed  to
treatment that occurs  offsite.  This is  explored  in further detail  in  Section  1.2.
Although the  definition  refers to  reduction or elimination of the generation of a
hazardous waste, this study also  examines the  generation  and reduction of wastes
that may not  be regulated under RCRA.  Wastes that are not regulated under RCRA
are included in the study to the extent that the  reduction of such wastes may result
in a reduction of  hazardous wastes  that are  regulated.  For example, in  certain
instances, the  reduction of a wastewater that is exempt from RCRA regulation may
involve  a process change that results in  an  accompanying reduction in hazardous
waste.  Furthermore, reduction of wastewater may result in reduction of  waste  from
the subsequent  treatment of  the wastewater; these sludges are regulated under
RCRA.  This  approach  recognizes that  waste minimization is a function of  more
than one environmental medium.  A reduction  in air pollutants or  wastewater may
also affect the generation of  solid and hazardous wastes.  Thus, it  is necessary  to
examine all components of a process.

    For purposes of this  study, "recycling" is considered to be a generic term that
encompasses  both  reuse  and reclamation  as  they  are defined  in  EPA's revised
definition of "solid  waste" published in the January 4, 1985, Federal Register.  These
definitions are as follows:
        Recycled:           A  material is "recycled"  if  it  is  used,  reused,  or
                           reclaimed (40 CFR 261. l('c)(7)).
        Used or reused:     A   material   is  "used  or  reused"  if   it  is   either
                           (1) employed  as  an  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).   However,  a
                           material  will   not  satisfy  this  condition  if  distinct
                           components of the material are recovered  as separate
                           end  products  (as when   metals  are   recovered   from
                           metal-containing secondary  materials), or (2) employed
                           in  a  particular function  or  application as an effective
                           substitute for  a commercial product (for example, spent
                           pickle liquor used as phosphorus precipitant and  sludge
                           conditioner       in       wastewater       treatment)
                           (40 CFR 261.1(c)(5)).
                                      1-2

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    •   Reclaimed:         A material is  "reclaimed" if it is processed to recover a
                           usable  product or if  it  is regenerated.  Examples are
                           recovery  of  lead  values  from  spent  batteries  and
                           regeneration of spent solvents (40 CFR 26 1. l(c)(4)).
    This  study  addresses burning  for  energy  recovery as  a  form  of  recycling,
assuming that such burning recovers a minimum  of  60 percent of the recoverable
thermal energy, and that 75  percent of  that recovered energy is actually used. This
is discussed in further detail in Section 1.2.

1.1        Background and Scope of the "Waste Minimization" Definition

    Although no formal definition of waste minimization is provided, HSWA and its
legislative  history  make clear that the term includes  both  source reduction and
recycling.  In  particular, Section  1003(a)(6) of  the  Solid  Waste  Disposal  Act  (as
amended  by  HSWA)  states that  one  of  the  objectives of the Act is  to  minimize
"...the generation of hazardous waste  and the  land  disposal of hazardous  waste by
encouraging process substitution, materials recovery,  properly conducted  recycling
and  reuse,  and treatment."   Other  indications of  what  may  qualify  as  waste
minimization  appear  in.  the  HSWA  requirements  for  generators  regarding the
certification, which must appear on the manifest. The  certification must state that
"...the generator of  the hazardous waste  has  a  program  in place  to reduce the
volume or quantity and  toxicity  of such waste  to  the degree  determined  by the
generator to be  economically practicable."  (EPA  states in the  preamble  to  its
codification  of  these requirements  that  the  generator, not  EPA,   is   to   make
determinations of  economically practicable and best method currently  available (50
FR  28734). This is discussed further in Section 5.5.1.)

    An  examination   of  Senate  Report  98-284 (p. 65)  indicates  that  waste
minimization involves a balancing  between two concepts:

     1.   Hazardous waste  is  first to be reduced  or eliminated  as quickly as possible;
         and
    2.   The hazardous  waste  that  is  generated  should be  treated, stored,  or
         disposed  of  in  a manner  to minimize  the "present  and future threat to
         human health and the environment."

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    Section 1003 of HSWA establishes the  general national policy in favor of waste
minimization and refers to the need to reduce the "volume  or quantity and toxicity"
of  hazardous  wastes.   The  Senate  Report   recognizes,  however,  that  waste
minimization does not always mean  a reduction  in volume  of waste  generated.  For
example,  in  some  cases, a  reduction  in  waste volume  may  result in increased
toxicity, and in  such  instance, treatment, storage, or disposal  methods may better
address the present  and future  threat  to  human health  and the environment (SR
98-284  pp. 66-67).  On the other hand, waste concentration may be a useful waste
minimization  technique  (e.g.,  in  preparing  materials  for  recycling).   The  key
concept, however, is  that  waste minimization  must be  protective of human health
and the environment.

    In  the broadest  sense, the language of HSWA implies that waste minimization
includes any action taken  to reduce  the volume  or toxicity of  wastes.  Thus, waste
minimization  includes  the concept  of  waste  treatment,  which encompasses such
technologies  as incineration, chemical  detoxification,  biological treatments,  and
others (Section  10Q3(a)(6)). EPA has already embarked on a broad program for waste
treatment; thus, this report focuses  on  source   reduction  and recycling,  the  two
aspects of waste minimization where basic options still remain open.

1.2       Background and Scope of  the Issue of Burning for Energy as a Recycling
          Activity
     This  report includes burning  for  energy  recovery as  a recycling activity.
Although  EPA's definition of recycling does not specifically  address  burning, other
portions of EPA's regulations indicate that in certain  instances, burning  for energy
recovery  is a recycling activity, even • if  it  will be  regulated in  the  future.   In
particular, 40 CFR 260.10 defines "Boiler," "Incinerator," and "Industrial  Furnace."
Also, 40  CFR  261.6  and 40 CFR 266 (Subparts D and  E) address  the  burning  of
hazardous wastes for energy recovery in boilers and industrial furnaces.  To fulfill
the CFR definition of "boiler," devices must maintain a minimum amount  of thermal
energy  recovery (60  percent), and must "export" at  least 75  percent of this energy
for actual use.  The  definition of "industrial  furnace" also requires the recovery  of
materials  or energy.  If  a  combustion device  meets neither of these criteria, it is
                                       1-4

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defined as an "incinerator" by  EPA  and requires  a permit under Subpart 0 of the
RCRA regulations.  For that reason, incineration activities are not considered to be
recycling in this study.

    References to  such  burning activities may, in  some instances, include situations
in  which less than  60 percent energy recovery  is achieved or  in  which less  than
75 percent of recovered  energy is actually used.  This is because some  of the case
examples  used  may  reflect  a  time  when the  above  referenced  definitions  and
regulations  were not in effect.  It  is  not always  possible  to ascertain from the
literature the degree  of heat recovery maintained.  We have assumed, however, that
future instances of burning for energy recovery will meet the requirements stated in
the EPA  regulations.  In  this  study,  a statement  such  as  "solvent  wastes  are
sometimes recycled by burning for energy recovery" thus is interpreted  to mean we
assume two things:  (1) in the past, some solvent wastes may have been burned with
some  unspecified amount of energy recovered,  and (2) in the future, solvent wastes
burned for energy recovery will result in a minimum of 60 percent of  thermal energy
recovered, with 75 percent of  this  energy "exported" for actual use.

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                        2.  WASTE GENERATION PROFILE

     This  chapter  presents a brief  discussion  of the  causes  of hazardous  waste
generation, including a listing of all industries and their share of waste  production.
A waste generation profile of the Chemicals and Allied Products Industry (SIC 28) is
provided  as  an example to show major chemical  processes and  their  respective
shares  in waste  generation.   Finally,  a summary  of  other   waste  management
practices is included.

2.1       Causes of Waste  Generation

     Industrial wastes  are  generated  in  chemical manufacturing and  formulation
processes, in refining  of  crude  oil and  processing of  metals,  and  in the  use  and
reclamation  of processing  solutions  such as  degreasing solvents and electroplating
baths.  Waste is  generated in chemical  manufacturing  and  formulation processes,
because less  than  100  percent  of  the raw  materials  mass  entering  a  process  is
converted to  final  product. The  attainment of complete conversion, or  100 percent
yield, appears impossible, and should be viewed only as  an asymptotic  limit  of  all
efforts to minimize waste or increase yields.

     Historically, the problem  of waste generation has  been  viewed as a question of
yield maximization.  While a significant effort has undoubtedly  been undertaken to
increase  yield, with a corresponding  decrease  in  waste generation  (e.g., in  the
chemical  process industry), the question of  what  constitutes an acceptable yield
usually has   been   determined  by  comparison  with   the  industry  norm  and  the
competition's economic performance.  In certain cases, corporate management  has
assigned  a low priority to  the maximization  of yield, especially  if the costs of raw
materials and waste disposal were low compared  to  the value added.  This situation
is typical for labor-intensive  processes.  In  such cases,  the prospect of realizing a
marginal  increase in profits by increasing  yield (and lowering waste generation)  is
.offset by the risk of detrimental impact on product quality,  research expenditures,
and  other considerations.
                                       2-1

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    Generation  of  other  industrial  wastes  from  processing  solutions  such  as
degreasing solvents and  plating baths  is not tied directly  to  the problem  of  yield
maximization,  because  these  materials are not converted into  the final  product.
Organic  solvents and  inorganic solutions used  in this  way  become wastes as the
solutions become "spent."  Waste  is also generated from the residues of solvents and
other solutions that are reclaimed by separation technologies such as distillation.
Cost considerations  for  controlling generation of processing solution wastes may be
similar to those for wastes from materials converted into final products.

    How  is waste generated?  Typical industrial process  waste origins, causes, and
controlling factors are summarized in  Table  2-1.  Based on the 22 industrial process
studies presented in Appendix B of this report, this information indicates that-in a
majority of cases, product and process design factors play  a dominant role  in waste
generation.  Thus, it  can be  concluded  that  design decisions  affecting  process,
equipment, or  product  greatly   influence  subsequent  waste  generation.  While
operational aspects also  are significant, they  appear to  be subordinate  to the design
aspects in  their importance to waste generation.

    Why  is  waste generated?  Three  categories  of causes can be distinguished:
economic, motivational, and regulatory.

    Economic  causes include:
     •  Real  (as opposed to perceived) absence  of economic  feasibility  for  the
        options considered to minimize waste or maximize yield;
     •  Absence of funds to evaluate waste minimization options; and
     «  Lack  of  capital  to  implement waste  minimization  measures  with proven
        feasibility  (e.g.,  because  economic  benefits  of waste  minimization  may
        appear minor in comparison with  those  of other projects competing for
        limited investment capital).
     Motivational  aspects  related  to waste  generation (as opposed to minimization)
are  more  difficult  to characterize, since  they  stem   from both  individual  and
organizational attitudes,  perceptions,  biases, experiences,  and  political settings.
Table  2-2  provides a summary  and a brief  description of the typical motivational
aspects identified.
                                       2-2

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     1297s
                    Table  2-1  Waste Generation:  A Summary of Typical Process Waste Origins, Causes, and Controlling Factors
          Waste origin
       Typical  causes
      Operational factors
       Design  factors
     Chemical reaction
•  Incomplete reactant  conversion

•  Byproduct formation

•  Spent catalyst - deactivation
   due to poisoning,  sintering, etc.

•  Catalyst fines due to attrition
•  Inadequate temperature control   •  Inadequate reactor design
                                                                      •  Inadequate mixing

                                                                      •  Poor feed flow control
                                                                      •  Poor feed purity control
                                    •  Catalyst design or selection

                                    •  Choice of process path
                                    •  Choice of reaction conditions

                                    •  Fast quench

                                    •  Inadequate  instrumentation or
                                       controls design

                                    •  Poor heat transfer
     Contact between
 i    aqueous and organic
00   phases
•  Vacuum production via steam jets

•  Presence of water as a reaction
   byproduct

•  Use of water for product rinse

•  Equipment cleaning

•  Cleaning of spills
•  Indiscriminate use of
   water for cleaning or
   washing

•  Excessive clingage
•  Choice of process route

•  Choice of auxiliary operations
     Disposal of unusable
     material s
•  Off-spec product generation
   caused by contamination,
   temperature/pressure excursions,
   reactants proportioning,
   inadequate precleaning of
   equipment, etc.

•  Obsolete material  inventories
•  Poor operator training*
   and supervision

•  Inadequate quality control

•  Inadequate production
   planning and inventory
   control
   Inadequate automation

   Inadequate degree of equipment
   dedication to a single process
   functi on

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1297s
                                                        Table  2-1   (continued)
     Waste origin
       Typical causes
      Operational factors
       Design  factors
Process equipment
cleaning
Metal  parts
cleaning
•  Presence of clingage

•  Deposit formation



•  Use of chemical cleaning agents
•   Insufficient drainage
    prior to cleaning

•   Inadequate cooling water
    treatment

•   Excessive cooling water
    temperatures
   Disposal of spent solvent,  cleaning   •  Indiscriminate use of
   sludge, or spent cleaning solution       solvents and water

                                         •  Excessive dragout
•  Oversized heat exchangers
   resulting in excessive  film
   temperature and  low  fluid
   veloci ties

•  Consideration of on-stream
   cleaning with mechanical
   devices

•  Insufficient controls to
   prevent cooling water from
   overheati ng

•  Choice between cold  dip tank
   or vapor degreasing

•  Choice between solvent and
   aqueous cleaning solution
Metal  surface
treatment
Spills and leaks
cleaning
•  Dragout

•  Disposal of spent treatmertt
   solutions
•  Spillage during manual  material
   transfer operations

•  Leaking pump seals

•  Leaking flange gaskets
•  Poor rack maintenance

•  Indiscriminate rinsing
   wi th water

•  Too fast withdrawal of
   work piece

•  Inadequate maintenance

•  Poor operator training

•  Lack of operator attention

•  Indiscriminate use of
   water in cleaning
•  Counter-current rinsing

•  Fog rinsing

•  Dragout collection tanks



•  Choice of gasket material

•  Choice of seals

•  Use of welded or seal-welded
   construction

•  Plant layout

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                    1298s
                                   Table 2-2  Typical Motivational  Aspects Related to Waste Generation or Minimization
                                    Aspect/Cause
           Origins/Underlying factors
                    Lack of awareness of benefits  of  waste  minimization
•  Poor availability of informaton

•  Lack of trained environmental  staff

•  Low level of management involvement in
   operations/R&D/design
                    Lack of initiative to minimize waste
ro
CJl
                    Negative attitude toward  innovation
•  Lack of competition (i.e., stable market share)

•  "If it isn't broke - don't fix it" attitude

•  Lack of mandate, policy, or leadership

•  Fear of upsetting product quality

•  Low priority ranking of waste minimization projects

•  Absence of company policy or mandate

•  Perception of poor economic/technical feasibility

•  Presence of adequate treatment/disposal  systems
•  "Can't be done" attitude, i.e., rejection of
   innovation because it is outside of habitual range of
   experience

•  Lack of adequate technical skills

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    Current perceived  regulatory  obstacles to  waste  minimization  include  the
requirement to obtain a RCRA permit to install equipment that is viewed by EPA as
part of  the "treatment"  technology.  This requirement  decreases  the  economic
feasibility of recycling  and may result  in  the  landfilling of  recyclable wastes.  In
other cases, there  is a  tradeoff between reducing waste by complying with one set
of regulations that may, in turn,  generate other regulated process waste  streams.
For example, compliance  with stringent solvent air emission regulations  for some
processes results in installation of steam-regenerated carbon bed  scrubbers, which
produce a waste solvent that is often land disposed.

    The  above listing of the economic, motivational, and regulatory causes of waste
generation  is not  complete; however, it  does represent  a  brief  summary of  the
typical factors.  A more detailed discussion can be found in Section 5 of this report.

    Finally, a  different and  broader perspective  deserves  to be mentioned. While
the generation of  hazardous waste,  as discussed above, is  taken from  the  point of
view of a generator (i.e., "internal"),  there is also an "external," or indirect, aspect,
which is demonstrated  by the following example.   A company decides to  replace
certain  existing electric  motors with a  newer, more efficient design, resulting in
savings  in  electricity consumption.  While this  does not  reduce  the  onsite waste
generation,  it  does contribute to  the reduction of water  treatment waste at  the
power plant where the electricity used onsite  is generated.

    Numerous other examples can  be cited to show that a decrease in  product
consumption stemming  from conservation or  some alteration of  its  use  results in the
overall reduction'  of waste  generated in  the  chain of processes leading  to  that
product's manufacture.  From  this broader perspective, product  conservation efforts
by consumers and  efforts to produce more durable  goods appear to be  the  principal
controlling  factors  in waste minimization, or conversely, its generation.

2.2       Industry-Specific Waste Generation Profile

    It was  estimated that in  1983 U.S. industry generated 266 million metric tons of
hazardous waste (CBO  1985).  It  is useful to determine which industries  generate
                                       2-6

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which portion of the  total hazardous  waste stream.  To  obtain  such information,
data from the 1981  RIA Mail Survey (Westat  1984) were analyzed and are presented
in  Table  2-3, along  with data obtained  by  the Congressional Budget Office (CBO
1985).

    As seen  in Table  2-3, the Chemicals and  Allied Products industry (SIC 28) ranks
first in  both compilations as the  nation's  leading  generator of hazardous wastes.
According to the more recent study  (CBO 1985), which included some nonhazardous
waste  streams,  the  Primary  Metals  industry (SIC 33)  ranks  second   and  the
Petroleum/Coal  Products industry (SIC 29)  third.  The RIA Generator Survey data
from 1981 indicate a higher  ranking, by hazardous  waste  volume generated, for the
Machinery,  Except  Electrical   industry (SIC 35),   the  Transportation  Equipment
industry  (SIC 37),  and the Motor Freight Transportation  and Warehousing industry
(SIC 42).  Figure 2-1 illustrates the distribution of hazardous waste generated during
1981 by specific SIC industries.  The quantities (M gals) generated are given for each
SIC code. To obtain a better level of  resolution, another compilation of  1981  waste
generation  data   was  prepared  using  4-digit  SIC  codes  for  waste-generating
industries. It is presented in Table 2-4.  Descriptions of  each of  the  ten industries,
in  the  2-digit SIC categories, generating the  largest volumes  of hazardous  waste
during  1981  follow:

    •   Chemicals  and  Allied Products  (SIC  28) -  Facilities  that  either produce
        chemicals   or   use  chemical  processes to   manufacture  products   from
        manufactured  feedstocks.  A wide range of  industrial and consumer products
        is handled  by this group including:
           Acids,  alkalies, salts,  and  organic chemicals;
           Chemical intermediates to be formulated into synthetic  fibers, plastics,
           materials, dry colors, and  pigments;
           Finished  chemical  products for  use  as materials  or supplies in  other
           industries such as paints, fertilizers, and  explosives; and
           Finished  chemical products for ultimate  consumption (e.g.,  cosmetics,
           drugs, and soaps).
        According  to   the  most  recent  census data,  there  were  9,145  facilities
        categorized  as  SIC   28  in  the  United  States  in 1977  (U.S.   Census  of
        Manufacturers  1977).
                                       2-7

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1299s
              Table 2-3   Industry  Ranking  by  Hazardous  Waste  Generation
                               Using 2-Digit SIC Code
Rank
1
2
3
4
5
6
7
8
9
10
11
12

Percent of total
Major industry SIC code Source A
(1983)
Chemical & Allied Products
Primary Metals
Petroleum & Coal Products
fabricated -Metal -Protlurts
Rubber & Plastic Products
Miscellaneous Manufacturing
Nonelectrical Machinery
Transportation Equipment
Motor Freight Transportation
Electric & Electronic Machinery
Wood Preserving
Drum Reconditioning
Total
28
33
29
34
30
39
35
37
42
36
24
50

47,9
18.0
11.8
9.6
5.5
2.1
1.8
1 .1
0.8
0.7
0.7
< o.i
100.0
waste generated
Source B
(1981)
67.5
2.4
3.1
1.9
< 0.1
< 0.1
10.0
5.6
4.0
1.6
< 0.1
< 0.1
98.0
Source:   A  Congressional  Budget  Office  (CBO  1985).
         B  RIA Generator  Survey  Data  Base.
                                         2-8

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13%
                             SIC  37 Transportation
                             Equipment
SIC 42 Motor  Freight
Transportation
   SIC  35
   Except
Machinery,
Electrical
                                                                         Small  Quantity
                                                                         Generators (all
                                                                         industry  groups)
           Other SICs (not
           small quantity
           generators)
                                              SIC 28 - Chemicals
                                              and Allied  Products
                                                                   68%
        Figure   2-1  Distribution  of the Total  Volume* of Hazardous  Waste
                             Generated by SIC  Category
              Sources: RIA Generator Survey (1981 .Data), Ruder et al. 1985. (1984 Data)
               *Total Volume of Hazardous Waste Generated During 1981 = 42,000 M Gal

                                                2-9

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1299s
             Table 2-4  Industry Ranking by Hazardous Waste Generation
                               Using  4-Digit  SIC Code
Rank Industry
1 Cyclic Crudes & Intermediates
2 Unidentified Chemical Products
3 Industrial Organic Chemicals
4 Construction Machinery
5 Electronic Computing Equipment
6 Trucking & Warehousing
7 Transportation Equipment
8 Petroleum & Coal Products
9 Construction, Special Trade
Contractors
10 Alkalies & Chlorine

Remaining Industries

SIC Code
2865
2800
2869
3531
3573
4200
3700
2900
1700
2812
Subtotal

Total
Percent of total 1981
waste generated
37.0
17.9
8.4
5.0
4.8
4.0
3.0
2.8
2.1
1 .8
86.8
13.2
100.0
Source:   RIA Generator  Survey Data Base.
                                         2-10

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•  Machinery, Except Electrical  (SIC 33) -  Manufacture of  machinery  and
   equipment other than electrical and transportation equipment.  Included are
   machines  powered by  built-in  or detachable  motors,  and  electric  and
   pneumatic-powered  portable  tools.   Excluded   are   electrical  household
   appliances and hand  tools (OMB  1972). There were  48,191  facilities  in the
   SIC 35 category in 1977 (U.S. Census of Manufacturers  1977).

•  Transportation Equipment (SIC 37) - Facilities manufacturing equipment  for
   the  transportation of  passengers  and  cargo  by  land,  air,  and   water.
   Important products of this industry include  motor vehicles, aircraft,  guided
   missiles and space vehicles,  ships, boats,  railroad equipment, motorcycles,
   bicycles, and snowmobiles (OMB  1972).  There were 2,623 facilities  in this
   industry in 1977 (U.S. Census of Manufacturers 1977).

•  Motor Freight Transportation  and  Warehousing  (SIC  42) -  Local  or long
   distance  trucking, transfer  services,  or  terminal  facilities for handling
   freight,  with  or without maintenance  facilities; also includes facilities  for
   storage  of  farm products, furniture,  other  household  goods,  or commercial
   goods of any nature.   Excludes  facilities  for the  storage  of natural gas
   (SIC 4922) and field  warehousing  (SIC  7399)  (OMB  1972).  There were  34,033
   facilities in this  industry category in  1977 (U.S.  Census  of  Manufacturers
   1977).

•  Petroleum  Refining  and  Related Industries (SIC  29) - Facilities primarily
   engaged  in   petroleum  refining,  manufacturing  of   paving  and   roofing
   materials, and compounding  of lubricating  oils and  greases  from purchased
   materials.  Not   included are facilities   manufacturing  and  distributing
   gasoline, or facilities primarily engaged in producing coke and its byproducts
   (OMB 1972).  No   reliable  data on  the  number of  SIC 29  facilities  were
   available during this  study.

•  Primary  Metals  (SIC  33) -  Facilities  engaged in smelting  and  refining  of
   ferrous and nonferrous  metals  from ore, pig, or scrap;  rolling, drawing, and
   alloying of ferrous and  nonferrous metals*, manufacture  of castings and other
   basic products of  ferrous and nonferrous metals;  and manufacture of nails,
   spikes, and insulated wire and cable.  Coke  production is also included  in this
   category (OMB 1972). There  were 2,183  facilities in  this industrial category
   in 1977 (U.S.  Census  of  Manufacturers  1977).

•  Construction  -  Special Trade Contractors (SIC  17)  -  Hazardous  waste
   treatment, storage,  and disposal (TSD)  management  facilities  are  the
   primary  generators   of hazardous waste   under SIC  category  17.  Also
   included  are  general and specialized  contractors  who  perform construction
   activities  including:   industrial   machinery  and  equipment  installation;
   plumbing, painting,  plastering,  and  carpentering;  grave excavation;  gas
   leakage detection; and water  well drilling  (OMB  1972).  There  were 2,096
   special trade  contractors in the U.S. in  1983 (U.S. Census of  Manufacturers
    1977).
                                  2-1

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    •  Fabricated Metal Products (SIC  34)  -  Facilities  that  fabricate ferrous and
       nonferrous metal products such as metal cans, tinware,  handtools, cutlery,
       general  hardware, nonelectrical  heating apparatus,  fabricated  structural
       metal products,  metal  forgings,  metal stampings, ordnance (except vehicles
       and guided missiles), and a variety of metal and wire products not elsewhere
       classified.  Not  included  are the  primary  metals industries (SIC 33) and
       facilities fabricating  machinery, transportation  equipment,  scientific and
       controlling instruments, watches and  clocks, jewelry, and  silverware (OMB
       1972). There were 33,478 Fabricated Metal  Products  facilities in  1983 (U.S.
       Census of Manufacturers 1977).

    •  Electrical and Electronic  Machinery, Equipment, and Supplies  (SIC 36)  -
       Facilities  that  manufacture  machinery,  apparatus,  and  supplies  for the
       generation, storage,  transmission,  transformation,  and  use  of electrical
       energy.  Included is the manufacture of household  appliances.  Not included
       are  the  SIC 35  industries  or facilities  that manufacture  instruments  for
       indicating, measuring, or  recording  electrical  quantities  (OMB 1972).   In
       1983,  there were 14,975 facilities in this industrial category (U.S. Census of
       Manufacturers 1977).

    •  Electric, Gas, and Sanitary Services (SIC 49) -  Facilities engaged in the
       generation, transmission,  and/or  distribution of  electricity or gas or steam
       or  combinations of  any  of these  services;  may   also  include  related
       transportation,  communication,  and refrigeration.  POTWs and   water and
       irrigation systems are included (OMB 1972).   No reliable data on  the  number
       of SIC 49 facilities were available during this study.
Small Quantity Generators


    Small   quantity   generators   (SQGs)  are  facilities  generating   less   than

1,000 kg/month of hazardous wastes (40 CFR 260.10;  51 FR 10174,  March 24, 1986).
The  1984 National Small Quantity Generator Survey (Ruder et  al.  1985) grouped

primary target industries (those likely to generate hazardous wastes) into categories
as listed in Table 2-5.  This table illustrates the broad  range of industries included in
the SQG survey.  For purposes of comparison, corresponding SIC  codes are  listed.

Some SIC codes appear in more  than  one survey category.  Of all the SIC  groups

listed  in Table 2-5,  eight SIC  groups  parallel  those  identified  as   high  volume

generators in the 1981  RIA Mail Survey, namely:  SICs 17, 28, 33, 34, 35, 36, 37, and

42.


     A profile of SQG  industries  and practices may be drawn by examination of data

compiled by Ruder et al. (1985). For example, the 940,000  metric tons  of hazardous

waste generated  by  SQGs during 1981 was less than one-half of one percent of the


                                      2-12

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                1306s
                                Table 2-5  SIC Classification of Small  Quantity Generators by Industrial  Groups
                                            Targeted  by  the National  Small Quantity Generator Survey
                Small quantity generator
                (SQG) industry group
                                   SIC
                                   code
                                                          Corresponding  SIC  classifications
                                 SIC description
                Vehicle maintenance
ro
 i
Chemical  manufacturing

Textile manufacturing

Metal  manufacturing
                Other manufacturing
                Furniture/Wood manufacturing &
                refini shing
07     Agricultural services
16     Construction other than building construction - general contractors
17*    Construction - special trade contractors
42*    Motor freight transportation & warehousing
44     Water transportation
52     Building materials, hardware, garden supply, and mobile home dealers
55     Automotive dealers & gasoline service stations
75     Automotive repair, services, & garages

2&*    Chemicals & allied products

22     Textile mill products

25     Furniture & fixtures
33*    Primary metal industries
34*    Fabricated metal products
35*    Machinery, except electrical
36*    Electrical & electronic machinery, equipment, & supplies
37*    Transportation equipment
39     Miscellaneous manufacturing industries

7      Agricultural services
30     Rubber & miscellaneous plastic products
31     Leather & leather products
32     Stone, clay, glass, & concrete products

24     Lumber & wood products, except furniture
25     Furniture & fixtures
76     Miscellaneous repair services

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                 1306s
                                                             Table  2-5  (continued)
                 Small quantity  generator
                 (SQG) industry  group
                                    SIC
                                    code
                                                          Corresponding SIC classifications
                                 SIC description
PO
 i
Cleaning agents & cosmetic
manufacturers

Formulators

Wood preserving

Pesticide end-users


Pesticide application services



Construction



Shipment/repai r
                 Motor  freight  terminals

                 Laundries
28*    Chemicals & allied products


28*    Chemicals & allied products

24     Lumber & wood products, except furniture

79     Amusement: recreational services, except motion pictures
84     Museums, art galleries, botanical & zoological gardens

07     Agricultural services
49     Electric, gas, & sanitary services
73     Business services

17*    Construction-special trade contractors
24     Lumber & wood products, except furniture
40     Railroad transportation

46     Pipelines, except natural gas
48     Communication
59     Miscellaneous retail
72     Personal services
76     Miscellaneous repair services
79     Amusement & recreation services,  except motion pictures

42*    Motor freight transportation & warehousing

72     Personal services

-------
                 1306s
                                                              Table  2-5  (continued)
                 Small  quantity  generator
                 (SQG)  industry  group
                                                          Corresponding SIC classifications
                                    SIC
                                    code
                                  SIC description
ro
i—*
r_n
                 Photography


                 Printing/ceramics
Paper industry

Analytic & clinical laboratories



Educational & vocational  shops



Wholesale & retail  sales


Other services
73
84

26
27
32
73

26

73
80
82

89
82
83

51
52

72
73
Business services
Museums, art galleries, botanical & zoological gardens

Paper & allied products
Printing, publishing, & allied industries
Stone, clay, glass, & concrete products
Business services

Paper & allied products

Business services
Health services
Educational services

Miscellaneous services
Educational services
Social services
                                                           Wholesale trade-nondurable goods
                                                           Building materials, hardware, garden supply,

                                                           Personal services
                                                           Business services
                                             & mobile home dealers
                 Source:   Ruder  et  al.  1985.

                 "Comparable  SIC Included  in Ten Highest Volume Generator Industries,  1981 RIA Generator  Survey.

-------
total volume of hazardous waste reported generated during that year (Westat  1984
and Ruder et al.  1985).  In  1984, however, this small  fraction of the total  waste
generated accounted  for waste generation practices  at 98 percent of the  generator
facilities  (Ruder et  al. 1985).  The  SQG profile is  dominated by nonmanufactunng
industries  and  closely associated  with  major  population  centers.   The  Vehicle
Maintenance survey  category alone  accounted  for  50 percent  of all SQG  facilities
and  71  percent of  the  total  quantity  of  hazardous   waste   generated  by  SQGs
nationwide.  Other nonmanufacturing industries made up an additional 23 percent of
the SQGs and 15 percent  of the total waste generated.  Metal  manufacturing  SQGs
generated 9 percent of the total waste generated by SQGs.

    The distribution  of SQGs among  industry groups is consistent  with  the  types of
waste streams generated  by  SQGs during  1984.  For example,  62 percent (370,000
million  tons)  of all  waste generated by  SQGs  in that year consisted of lead acid
batteries.  The lead  acid batteries  wastes were  generated by  the  SQG vehicle
maintenance  industries.  Another 18  percent (108,000  metric tons)  were solvent
wastes  generated  by  SQG metal manufacturing, vehicle maintenance, equipment
repair,  printing,  and construction  industries  (Ruder  et al.   1985).  Five  percent
(30,000  metric tons)  were acid or alkaline (corrosive) wastes (Ruder et al. 1985). No
specific waste classification  was given  for the remaining 15 percent  (90,000 metric
tons) of waste generated by SQGs.

2.2.1    Characteristic Waste Stream Generation and Recycling

    The  profile of  hazardous waste  generation by  U.S. industries  also  can  be
characterized  by  the  types of  waste  streams generated in high volumes.  Table 2-6
lists  the  volume  of RCRA  characteristic  waste   generation   by   ignitability
characteristic  (DOOl), corrositivity characteristic (D002), EP-toxicity characteristic
(DOOO, D004-D007), and reactive  characteristic  (D003), reported to be generated by
the ten  highest-volume generator industries in 1981.

    The ignitable wastes consist mainly of solvent  wastes and  also some metal and
cyanide/reactive  wastes;  the  corrosive  wastes are acids and alkalies;  EP-toxic
wastes  include heavy metal wastes and pesticides; and reactive  wastes include
                                      2-16

-------
1371s
                           Table 2-6  Profile of RCRA Characteristic  Waste  Generation  by  the  Ten  Highest  Volume  Waste  Generating  Industries  in 1981
   SIC   Industry description
Ignitabi 1 i ty
characteristic
    (0001)
                                                                   Volume  of  waste  generated  (M  gal)
(Percent)3
 Corrosivity
characteristic
    (D002)
                                                                                                    (Percent)3
  EP-toxicHy
 characteristic
(DODO,  D004-D007)
(Percent)*
                                                                                                                                                            Reactive
                                                                                                                                                         characteristic
                                                                                                                                                            (0003)          (Percent)"1
    28   Chemical and Allied Products                 140            (0.5)

    35   Machinery. Except Electrical                  67            (1.6)a

    37   Transportation Equipment                      40            (2.1)d

    't.'_   Motor Freight Transportation
         and Warehousing                              < 0.1

    ^9   Petroleum and Coal Products                    8.3         (10)d

    :u   Primary Metals                                 2.9          (0.4)a

    17   Construction, Special Trade
         Contractors'1                                 < 0.1

    <4   fabricated Metal Products'1                     5.4          (0.6)

    Ab   Electrical Equipment Manufacture              15            (2.4)d

    49   Electric, Gas, and Sanitary Services
         (includes POTWs)                             < 0.1
                                     8,200

                                     2,300

                                       950


                                       <  0.1

                                        51

                                       220


                                       870

                                       310

                                       170


                                        32
                                     (29)

                                     (54)a

                                     (49)a




                                     (61)d

                                     (26)a


                                    (100)

                                     (38)

                                     (28)a


                                      (6.8)
                                           71

                                          530


                                            0.7

                                            1.8

                                          560


                                          430

                                          320

                                           40


                                           38
                          (4.2)

                         (17)a

                         (28)a




                          (2.2)d

                         (68)a


                         (49)

                         (39)

                          (6.6)d


                          (8)
                   15,000

                      < 0.1

                      < 0.1

                      Nkc
                                                                                                                                                                              (54)
                      < 0.1

                      240

                       40

                       38
                                    « 0.1)
U  b

(8)
Sourt.tj.  RIA Mail Survey  for generators.

a Peitent ol total waste  generated by this industry.
  Bei duse uf inconsistencies in  the data base, the sum of the characteristic waste volumes reported under each category is greater than 100 percent
  of the total waste volume reported for this SIC.
L NOIH  reported.

-------
explosives and propellants.  Of the  characteristic waste  streams listed, corrosivity
characteristic  wastes are  generated in the highest volumes.  This is consistent  with
the large-scale use  of acids and alkalies in  the chemical,  petroleum, and  metal
finishing industries.  Many of the corrosive  waste streams also contain heavy metals
as indicated  by the high volumes of EP-toxic wastes reported  by  most industries.
Ignitable (solvent)  waste generation was reported in the lowest volume for all RCRA
characteristic  wastes.  Reactive  characteristic  wastes are  attributable  mainly  to
the Chemicals  and  Allied Products industry (SIC 28).

2.2.2    Generation and Management Profile  by Waste Category

    The following discussion  presents  an  overview of  management  practices  for
each  of the following categories  of  wastes:  solvents,  halogenated  (nonsolvent)
organics, metals, corrosives, and cyanide/reactive wastes.

    Solvent Wastes

    Solvent  waste generators  include  primarily the industrial users  of  prepared
solvents.  For example, spent, contaminated solvents are generated:

    •   By paint and coatings plants that use solvents  to clean  equipment  tanks
        (Campbell & Glenn 1982);
    •   By manufacturers  of Pharmaceuticals, cosmetics, toiletries, food products,
        and lubricants;
    •   In  metal working  and  machine  maintenance shops  during degreasing of
        equipment;
    •   Through  cleaning   of   surfaces   in   the  plastics  fabrication,  electrical,
        electronics, and printing industries;
    •   By dry  cleaning operations;
    •   In paint stripping operations;
    •   During   drying  and  equipment  cleaning  processes in  the  adhesives  and
        sealants industry; and
    •   During  extraction of  lube oils and waxes in the petroleum  refining industry.
                                      2-18

-------
    A study of (virgin) solvent end-uses  indicated  that  of  the total volume of
solvents  used  in  1981,  the  following industrial applications consumed  the amounts
shown below (Pace 1983):

                                                Percent  of total solvents
    Industrial application                        	used  in 1931
    Paints/coatings/inks                                     44
    Process solvent                                          23
    Metal cleaning (degreasing)                              17
    Dry  cleaning                                             5
    Adhesives                                               4
    Other                                                  _Z
                                                            100

The Chemicals and Allied Products industry (SIC 28) uses solvents  for formulation of
paints,  coatings,  and  inks  and in  various  processes.  These  two  categories of
industrial applications made up 67 percent of  the total solvents used in 1981 (Pace
1983).

    Management practices of  the  Chemicals and Allied Products industries (SIC 28)
for nonhalogenated  and  halogenated  solvent  waste streams  are  illustrated in
Figures 2-2 and 2-3, respectively.  More  than one management practice may  be used
for a particular waste  (e.g., onsite wastewater  treatment followed by  wastewater
discharge).  Therefore,  the  total of all practices represented in Figures 2-2  and 2-3
exceeds   100 percent   for   both   halogenated    and   nonhalogenated  solvents,
respectively.   The   figures  suggest   that  wastewater  discharge  is  a common
management  strategy  for  waste  streams  containing  solvents,   and  less  than
10 percent of  SIC  28 solvent wastes generated are recovered or reused.

     Halogenated Organic (Nonsolvent) Wastes

     Halogenated  organic  wastes  that  are not characterized as  solvents  include
wastes  from  a  broad class of synthetic organic  chemicals  characterized  by the
presence of the halogens (chlorine, bromine, or fluorine) in hydrocarbon compounds.
Approximately  24.2 million  gallons  of  halogenated  organic  wastes  (excluding
solvents) were generated during 1981  (CCA Corporation 1984).
                                      2-19

-------
                    0     10%   20%  30%   40%    50%   60%    70%   80%   90%   100%


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                          10%    20%   30%   40%   50%    60%   70%    80%   90%   100%
                               Percent of Total Nonhalogenated Solvent Waste Generated
                          Figure 2-2 Management Practices of the Chemical and
                                   Allied Products Industries (SIC 28) for
                          Waste Streams Containing Nonhalogenated Solvents2
1 Total of all practices exceeds 100% because
 of overlapping management practices
2Total nonhalogenated solvent waste
 quantity managed = 31,533,503 tons/year
Source: Industrial Studies Data Base
                                                    2-20

-------
                    0     10%   20%   30%   40%   50%    60%   70%   80%   90%   100%

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                     0    10%    20%   30%    40%    50%   60%   70%   80%   90%   100%

                                 Percent of Total Halogenated Solvent Waste Generated1

                         Figure 2-3 Management Practices of the Chemical and
                     Allied Products Industries (SIC 28) for Waste Streams Containing
                                         Halogenated Solvents2
 Total of all practices exceeds 100% because
 of overlapping management practices

•Total halogenated solvent waste quantity
 managed = 7,801,684 tons/year
Source: Industrial Studies Data Base
                                                    2-21

-------
    Generators  of such  halogenated organic wastes  identified by  the RIA Mail

Survey include the following SICs:
    •   SIC  287,  the  Pesticide  and  Fertilizer  industry,  generates  chlorinated
        pesticide dusts  and  rinse  waters.   (Wastes  are  recycled  back  to   the
        manufacturing process).

    •   SIC  24,  the  Lumber  and Wood Products  industry, generates  chlorinated
        organic   wastes  from   the   manufacture   of   the   wood  preservative,
        pentachlorophenol (PCP), and from application of PCP to lumber products.

    •   SIC 76,  Miscellaneous Repair Services, generates PCB-contaminated fluids
        during   the  maintenance  and   repair  of   electrical   transformers   and
        contaminated specialty organic cleaning fluids (nonsolvent).

    •   SIC  97,  National  Security  and  International  Affairs,  generates specialty
        organic wastes.
    Halogenated organic wastes include both liquid and solid waste streams:
    •   Wastewaters  contaminated with  halogenated  organics are generated during
        chemical manufacture from aqueous process steps, solvent extraction, water
        scrubbing of vapors, water washing of organic products, and water quenching
        of reactions.

    •   Sources  of  liquid  pesticide wastes containing halogenated  organics include
        production  process  waters,  rinse  waters  from  container  and  equipment
        rinsing and  cleaning, off-spec  products,  outdated  pesticides, and banned
        pesticides.

    •   Spent solutions containing wood preservatives may be generated at facilities
        where the wood is treated and dried.

    •   Drained  transformer  fluids are  the  major  source  of  liquid  PCB wastes
        containing  greater  than 50  ppm  PCBs.  Approximately  60 percent of  the
        PCB transformers in service (as of 1979) were  owned and  operated  by utility
        companies (Radimsky and Marx 1983).

    •   Solid and semisolid  still bottom-type wastes are generated by the pesticide
        chemical industry during processes such  as the  manufacture  of chlorinated
        pesticides.

    •   Solids and  sludges containing halogenated organics of distillation  residues,
        include  residues  from reclamation  of  solvent  wastes (still   bottoms)  and
        sludges  from  equipment  cleaning  operations  (degreasing sludges).   Still
        bottoms  may  contain  metal   catalyst  particles,  other   metal   fines,
        high-boiling halogenated organic  byproducts, and impurities  (e.g., greases,
                                      2-22

-------
tars,  and polymers).  Degreasing  sludges are  generated  from  the  clean-out  of
degreasing equipment.  The cleaning results in sludges that comprise metal fines,
grit, oil, and  grease-containing halogenated organics.


    The management of  halogenated nonsolvent organic waste by the Chemicals and

Allied Products industries (SIC  28) is illustrated in Figure 2-4.   Over  90 percent  of

the volume  of wastes  containing  halogenated organics is  managed by wastewater

discharge.  The fraction of such wastes  that  are  recovered is  less  than  1  percent,

reflecting  the  technical  difficulty of separating constituents from organic sludges,

and the lack  of uses for the untreated sludges.


    Metal Wastes


    The estimated total volume of all metal-bearing wastes generated  in the United

States for 1981 was  7.9 billion gallons (30 million metric tons).  Of that total volume

generated, approximately 5.6 billion gallons (21 million  metric tons) were  treated  or

stored (Versar 1984), 1.7 billion gallons (6.4 million metric  tons) were land  disposed

(Versar 1984), and less than 0.7 million gallons (2.6 metric tons) were recycled (RIA

Mail  Survey).  Of the waste recycled, the RIA Mail Survey indicates that 7 percent

was handled  offsite and 93 percent was managed onsite.


    Examples  of processes resulting in  generation  of inorganic or organometallic

metal-bearing  waste streams include the following:


    •  Electroplating, photofinishing,  and  printing  industries commonly  produce
        process and rinse waters contaminated with silver, nickel, zinc, tin, copper,
        chromium, lead, or cadmium.

    •  Equipment  cleaning  in  the   steel  and metallurgical  industries  generates
        acidic  or alkaline solutions  containing  toxic  metals   and dissolved oils,
        greases,  and oxides.

    •  Degreasing operations in metal  parts  fabrication industries  generate organic
        liquids or solvents  laden with metal particulates.  Also, flue  dusts  high  in
        zinc  result from  galvanizing  operations and dusts from  electric arc stainless
        steel production contain nickel and chromium.

    •  Metal hydroxide or carbonate  sludges often result from  treatment processes
        that  remove metals  from aqueous  wastes generated by the electroplating
        and metal finishing industries  (Stoddard 1981).
                                      2-23

-------
                    0     10%    20%   30%    40%   50%    60%   70%   80%  90%  100%

Recovery/
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Treatment
Q Treatment of ,
»3 Drganics
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                    0    10%   20%   30%    40%   50%   60%   70%    80%   90%   100%
                           Percent of Total Halogenated Organic Waste Generated1

                       Figure 2-4 Management Practices of the Chemical and
                  Allied Products Industries (SIC 28) for Waste Streams Containing
                             Halogenated (Nonsolvent) Organic Wastes2
 1 Total of all practices exceeds 100% because
 of overlapping management practices
2
 Total halogenated organic waste quantity
  managed = 26,478,501 tons/year
Source: Industrial Studies Data Base
                                                    2-24

-------
    •   The  manufacture  of  leaded  gasoline  and  paint  generates  metal-bearing
        sludges.


    Metal finishing  processes  in  the Primary Metal (SIC 33),  Fabricated  Metal

Products  (SIC 34),  Machinery, Except Electrical (SIC 35), Electrical and  Electronic

(SIC 36), and Transportation Equipment (SIC 37) industries account  for  the largest

volumes of metal-bearing wastes reported in the RIA Mail Survey for the study year

1981.


    Figure 2-5  illustrates the  management of  the  small  volume  of  metal-bearing

waste  streams generated  by  the  Chemicals and Allied Products industries  (SIC 28).

The percent of  such waste  streams  that  is  land  disposed  is  greater  than that

reported for solvent  and  nonsolvent organic wastes (Figures 2-2 through 2-4).  These

wastes  are  apparently  stored  in  surface  impoundments (presumably  for  treatment

and separation) prior to disposal.  The low recovery reuse rate is not typical of U.S.

industries as a whole  (see Section  4.2), but indicative of the  lack of reuses for metal

constituents  from these wastes  in the  chemical  industry.


     Corrosive Wastes


     Corrosive   wastes  are  generated  by industries that use  acidic or  alkaline
solutions in production or finishing processes.  Some examples  of processes  in which

corrosive wastes are  generated  include the following:
     •  The metal  finishing  industries (SIC 33 to 37) produce corrosive wastes from
        processes including  electroplating, conversion coating,  etching,  cleaning,
        barrel  finishing, (tumbling),  and  heat   treating.  Spent  alkaline  cleaning
        solutions (e.g.,  sodium hydroxide, sodium  carbonate)  and  pickling  (acid)
        solutions (e.g., hydrochloric, sulfuric, or chromic acid) are among the most
        frequently generated wastes.

     •  The   Electrical  and   Electronics  industry  (SIC 36)   generates  spent
        metal-bearing  acid  solutions from the cleaning of scale from  metals  in the
        production  of semiconductors and  from etching of metal circuit boards.

     •  The  Textile  Mill   Products   industry  (SIC 22)  generates  spent  sodium
        hydroxide from mercerizing.

     •  A  high  volume of  "spent acid" is generated by the Chemicals and  Allied
        Products industry (SIC 28) in production  processes where  corrosive solutions
        are used  as dehydrating agents or catalysts.

                                       2-25

-------
0)
E
to
CO
                    0     10%   20%    30%   40%   50%   60%   70%   80%   90%   100%
     Recovery/
     Reuse
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•—   Organics
O
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                                                        J_
                                                               I
J_
                     0     10%   20%   30%   40%    50%   60%   70%   80%   90%   100%
                                Percent of Total Metal-Bearing Waste Generated11

                        Figure 2-5 Management Practices of the Chemical and
                         Allied Products Industries (SIC 28) for Metal-Bearing
                                           Waste Streams2
  Total of all practices exceeds 100% because
  of overlapping management practices
 >
 ' Total metal waste quantity managed =
  359,321 tons/year
                                                                    Source: Industrial Studies Data Base
                                                    2-26

-------
    Management  of   corrosive  wastes   in   surface   impoundments,  by  onsite
wastewater treatment, wastewater discharge, or land  disposal are reported  by  the
SIC 23 industries.  The percentages of corrosive constituent  waste streams that are
managed by each of these practices are illustrated in Figure 2-6.

    Cyanide and Reactive Wastes

    The category  of  cyanide and  reactive  wastes  includes  wastes with  cyanide
constituents (including  complexes  and organic  and inorganic cyanides),  sulfides,
explosives,  water  reactives,  and strong  oxidizers and  reductants.   Cyanides  and
metal wastes are often generated by the  same process and are thus contained in the
same  waste streams.  For example, copper cyanide waste  is generated from  copper
plating  operations.

    Unlike  solvents  or corrosives, which are  generated  by  a  broad spectrum of
industries, cyanide  wastes, like  metal  wastes,  are  generated  predominantly within
the Metal Finishing and  Processing (SIC  33  to 37) industries. Cyanide  wastes are
also  generated  by   the  following   industries:   Industrial   Inorganic  Chemicals
(SIC 2819),  Industrial  Organic Chemicals'(SIC 2869),  Plastic  Materials  (SIC 2821),
and National Security  (SIC 971 1)  (Versar 1984).

    The Chemicals  and Allied  Products industry (SIC 28) produces  water reactive
wastes   containing  sodium,  sulfides,  phosphorus,  and   potassium.   The  mining,
quarrying, and excavating industries (SICs 10,  U, and 17) and  the National Security
industry (SIC 9711) generate reactive  wastes such as explosives and propellants that
are off-specification or beyond their shelf  life.

    Generating processes for cyanide/reactive wastes include the following:

    •  Cyanide baths used in the Metal Finishing and Processing industries (SIC 33
        to 37) to keep soluble metals such as copper, nickel, silver, cadmium,  or zinc
        in solution  so that they can be used  in either  electroplating or  stripping
        solutions;
    •  Spent  process  solutions, contaminated  rinse waters,  and accidental spills
        from the Metal Finishing and Processing industry;
                                      2-27

-------
                   0     10%   20%   30%   40%    50%   60%   70%   80%  90%  100%


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                    0     10%   20%   30%   40%    50%   60%  70%   80%   90%   100%

                                 Percent of Total Corrosive Waste Generated1

                          Figure 2-6 Management Practices of the Chemical and
                     Allied Products Industries (SIC 28) for Waste Streams Containing
                                            Corrosive Wastes2
1 Total of all practices exceeds 100% because
 of overlapping management practices
2
 Total corrosive waste quantity managed =
 9,378,783 tons/year
                                                                 Source: industrial Studies Data Base
                                                   2-28

-------
    •  Contaminated  rinse waters generally having cyanide concentrations  below
       100 ppm  (usually  10  to  20 ppm),  and  spent  process  solutions  having
       concentrations above  1,000 ppm (Radimsky,  Piacentini, and Diebler  1983);
       and
    •  Other reactive wastes  generated by industries  involved in explosives  and
       propellant manufacture.

    Figure  2-7 illustrates the  management practices employed by the Chemicals
and Allied Products industries (SIC 28) for cyanide/reactive wastes.  Management  is
predominantly  by  wastewater  discharge,  presumably  following  separation  or
treatment in surface impoundments.  The  very small  fraction  of such waste streams
that are recovered  or reused  suggests  limited  technology  for recovery and  few
identified uses  for recoverable constituents.

2.3    Process - Specific Waste Generation  Profile

    In order to examine the major sources of hazardous waste  generation  in more
detail, a study  was conducted to assess the amount of waste generated  from specific
processes within the Chemicals  and Allied Products industry (SIC 28)."  This industry
was chosen  since it is responsible for generating the largest  portion  of hazardous
waste in the U.S. The study was based on waste generation  data contained in the
Industry  Studies  Data Base (ISDB).   The principal  goal was  to  rank  the various
chemical processes reported in  the ISDB  based  on four different groupings.  These
included:
     •   Nationwide total waste generation rate;
     •   Nationwide hazardous (RCRA) waste generation rate;
     •   Specific total waste generation rate (Ib total waste per Ib product); and
     •   Specific hazardous waste generation rate (Ib hazardous waste per Ib product).
     The methodology  used  to differentiate the different waste sources was based on
the  grouping of waste generation  data  from  all processes  used  to  manufacture  a
particular  product.  The ISDB  contains  only data  from surveys of  a  number of
representative  chemical  manufacturing  facilities.  Scale-up  of  ISDB  data  to
nationwide  estimates  for  1984  was  made based on total number of  facilities and
total production  quantities in  1984 for each product/process  category.  Since  a
                                      2-29

-------
                    0     10%    20%   30%    40%   50%   60%   70%    80%   90%   100%


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                    0     10%   20%   30%   40%    50%   60%   70%   80%   90%  100%
                              Percent of Total Cyanide/Reactive Waste Generated1
                     Figure 2-7 Management Practices of the Chemical and
                Allied Products Industries (SIC 28) for Waste Streams Containing
                                    Cyanide/Reactive Wastes2
 Total of all practices exceeds 100% because
 oi overlapping management practices
2
 Total cyanide/reactive quantity managed =
 14,618,951 tons/year
                                                                   Source: Industrial Studies Data Base
                                                  2-30

-------
single  process can  often  be  used  to  generate  more  than  one  product,  this
methodology  may result in double counting, as well as overestimating the waste

generation rates  from the  manufacture  of a  single product.  Because of  these

limitations, the results of this study should  be used with caution - only a qualitative

assessment of the relative magnitude of  waste  generation from the manufacture of

different products can be made.


    Tables  2-7  to  2-10 contain  the  listings  of  the  top  20 products that  are

responsible for producing the  major portion of the waste  generated  from the SIC 28

industry,  according to  the  four  criteria  mentioned  above.  Because of  RCRA

Confidential Business  Information (CBI) constraints,  only  generic  descriptors  are

given  for  products manufactured  at  less  than three facilities.   In addition,  the

products were ranked  in  the order of decreasing waste generation.  These rankings,

however,   take   into  account  waste  generation  not  only   associated  with  the

manufacturing of the cited products, but  also waste generation from any coproducts

using the  same chemical processes.  Again,  therefore, the rankings should be viewed

with caution.


     The following observations  were made on the process-specific  pattern of waste

generation from the Chemicals and Allied Products industry (SIC 28):


     •  Products  characterized  by high value  of  specific total waste generation
        (Ib waste/Ib product) -are  generally not  the  same as  those which  produce
        large  amounts of total waste and/or  total hazardous waste.

     •  Products  characterized   by   high   value   of  specific  hazardous waste
        (Ib hazardous  waste/lb  product)  are  generally   not   the   same  as  those
        generating large amounts of total waste.  Similarly, only 30 percent of the
        major products with high value of specific hazardous waste  are  the  same as
        those responsible for generating large amounts of total  hazardous waste.

     •  All  major  products  with  high   specific   waste  generation  rates  are
        manufactured  at fewer  than  three  facilities.  In  addition,  the  majority of
        these  products  are manufactured  in  only  small  quantities  (less  than
        10,000 metric  tons/yr).

     •  Products  that  generate large amounts of  total waste  generally  do  not
        generate large amounts of hazardous waste.  Similarly, the  percentage of
        the total  waste  that is hazardous  is often  very high  for  those products
        generating large amounts of hazardous waste.
                                      2-31

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2569s
             Table  2-7  List of Major Products Based on Nationwide
                          Total  Waste Generation  Rates
 1.  Toluene
 2.  Propylene
 3.  Secondary Amine,  Amino*
 4.  Ethylene
 5.  Sec. Dialkyl  Amine,  Amino*
 6.  Polyvinyl Chloride*
 7.  Phenol
 8.  Noncyclic Aliph.  Alcohol,  Amino*   18.   Organic*
 9.  Biphenyl, Amino,  Chloro*           19.   Polystyrene/ABS*
10.  Benzene                           20.   Copolymer,  Chloro
11.   Acetone
12.   Epoxide,  Chloro*
13.   Naphthalene
14.   Epoxide*
IS.   Methylene Diphenyldiisocyanate (MDJ)
16.   Butanol
17.   Cumene
Source:   Industrial  Studies  Data  Base.
*Non CBI Descriptor.
                                           2-32

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2569s
             Table  2-8  List of Major Products Based on Nationwide
                        Hazardous  Waste  Generation Rates
 1.   Propylene
 2.   Biphenyl, Ammo, Chloro*
 3.   Phenol
 4.   Ethylene
 5.   Polystyrene/ABS*
 6.   Benzene, Amino, Chloro*
 7.   Alkane, Iso/Isothiocyan*
 8.   Alkane, Carboxylic*
11.   Cyclic Alkane,  Alky!  (Unsat)*
12.   Benzene,  Amino*
13.   Alkane,  Cyano/Thiocyano*
14.   Maleic Anhydride
IS.   Organic*
16.   Methyl Methacrylate
17.   Cyclic Alkane,  Keto*
18.   A-Methyl  Styrene
 9.  Aklyl Metal Coord., Alky! (Sat)-PB*   19.   Xylene
10.  Acetone
20.   Alkane,  Nitro*
Source:  Industrial Studies Data Base.
*Non CBI Descriptor.
                                           2-33

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 2569s
               Table 2-9  List of Major Products Based on Specific
                          Total Waste  Generation Rates
                           (~lb Total  Waste/lb Product)
 1.  Cyclic Ester, Substituent*
 2.  Biphenyl, Amino, Chloro*
 3.  Sec. Amine, Amino'
 4.  Phosphorodithioate, Sub.-SR*
 5.  Benzene, ftnrino*
 6.  Thiourea, Amino*
 7.  Benzene, Amino, Chloro*
 8.  Copolymer*
 9.  Benzene, Amino, Alky! (Sat)-PhenyV
10.  Alky! (Sat)*
11.  Aklyl Phenyl Amine, Amino*
12.  Sec. Dialkyl Amine, Amino*
13.  Polyester/Alky! Resin*
14.  Noncyclic Aliph. Alcohol, Amino*
T5.  'BETrzottnaTole, Thio*
16.  Sulfate-CR*
17.  N,N Alkyl Phenyl Amide, Chloro*
18.  Pyridine, Amino*
19.  Dialkyl  Ether, Substituent*
20.  Diphenyl Thioether, Hydroxy,
       Alkyl  (Sat)*
Source:  Industrial Studies Data Base.
*Non CBI Descriptor.
                                           2-34

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2569s
                 Table 2-10  List of Major Products  Based  on  Specific
                           Hazardous Waste Generation  Rates
                             (Ib Total Waste/1b Product)
 1.  Biphenyl, Ammo,  Chloro*
 2.  Benzene, Amino,  Chloro*
 3.  Cyclic Ester, Substituent*
11.
12.
13.
 4.  Benzene, Amino*                    14.
 5.  Benzene, Amino, Chloro,  Nitro*     15.
 6.  Benzene, Chloro, Nitro,  Sulfonyl*  16.
 7.  Cyclic Alkadiene, Hydroxy*         17.
 8.  Dye/Pigment*                       18.
 9.  Phthalocyamde Dye/Pigment*        19.
10.  Sulfate-CR*                        20.
Alky! Hydrazine*
Alkane,  Iso/Isothiocyan*
M, N Alky!  Phenyl  Amide, Chloro*
Oiphenyl  Thioether,  Hydroxy,  Alky!  (Sat)'
Alky! Metal  Coord.,  Alky!  (Sat)-PB*
Alky! Phenyl Amine,  Chloro,  Chloro*
Cyclic Alkane,  Alky!  (Unsat)*
Furan, Alky! (Unsat),  Benzyl, CycloalkyT
Diether,  Chloro*
Benzene,  Amino,  Chloro,  Alkoxy*
Source:  Industrial Studies Data Base.
*Non CBI Descriptor.
                                           2-35

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    The first three observations together seem to  indicate that the  majority  of  the
waste  is  generated  from  the manufacture  of  products  in  great demand.  The
processes used  to  manufacture  these  products, however, are often  continuous and
well established and  thus may  not  leave  much  immediate  potential  for  waste
reduction.   Other chemical processes, such as those used to  manufacture propylene
and benzene/toluene/xylene (BTX), also  appear to  be  responsible for the generation
of large amounts of hazardous wastes.

2.4     Summary

    Hazardous waste generation from industrial processes is a  function of process
and equipment  design.  The more  efficient the use of raw materials in a process,  the
higher  the  product  yield from a process and  the  lower the waste generation rate.
Hazardous  waste generation from processing  solutions such as degreasing  solvents
and plating  baths is a  function of "good housekeeping" such as  materials and  waste
segregation, and material conservation.

    Decisions   to   employ  waste  minimizing   (yield  maximizing)  process  and
equipment  designs  depend on  complex economic, motivational,   and  regulatory
factors.  Examples include:
    •   Costs of  waste minimization include the  analysis of  the process design and
        operation options, as well as the capital investment in the equipment itself.
    •   Evaluations of  costs  vs. competitiveness and quality of the  product are
        influenced by the attitudes of individuals and corporate management.
    •   Compliance  with  existing   regulations  is an  important  factor in process
        design. Some tradeoffs among waste streams are  inevitable, especially from
        emissions  that  are  concentrated as a solid  waste  to  meet air emission
        standards.
    •   Product conservation by consumers and  efforts  to  produce  more durable
        goods result  in  an overall  reduction  of  waste  generated in the chain of
        processes leading to product manufacture.
    The profile of hazardous  waste generation  by U.S. industries is dominated by
the Chemicals and Allied Products industry (SIC  28), which generated 68 percent of
the total volume of  hazardous waste reported in  1981 (RIA  Generator Mail Survey).

                                      2-36

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Metal  finishing  industries  such  as  Machinery,  Except   Electrical  (SIC 35)  and
Transportation Equipment  (SIC 37) account  for  another 15 percent  of  hazardous
waste generated  in 1981.  Less  than one-half of one percent of the total hazardous
waste generated is attributed to small  quantity generators.

     A study  of  process-specific  wastes  of the  Chemicals  and  Allied  Products
industry  (SIC  28), based on  information in the Industrial Studies Data Base (ISDB),
indicates  that there is no  correlation  between chemical  products with high specific
total waste generation  or  high specific  hazardous waste generation  and  chemical
products  with large  amounts  of  either  total  waste  or   total  hazardous  waste
generation.  For  some  processes  in   which  large  amounts  of hazardous  waste are
generated, however,  the  hazardous waste accounts  for  a large percentage of  the
total waste generated.

     Waste streams generated in highest volume by U.S.  industries  (including  SQGs)
are  corrosive  wastes,  spent acids,   and  alkalines  used in  the  chemical,  metal
finishing,  and petroleum refining  industries.  Many  of  these waste  streams also
contain  high concentrations of heavy metals,  making them EP-toxic  wastes.  Solvent
(including  ignitable)   wastes   are generated   in  large   volumes  both  by  the
manufacturing industries and by a  wide range of equipment  maintenance  industries
that generate spent  cleaning  and degreasing solutions.  Cyanide/reactive  waste
generation is  confined  primarily   to   chemical  industry  manufacture  of specialty
chemicals  and spent  cyanide  plating solutions  and sludges generated  by  metal
finishing industries.  Management  practices  of  the Chemicals and  Allied  Products
industry  (SIC  28), reported  in  EPA's Industrial  Studies Data Base,  suggest that
wastewater  discharge of  treated waste streams and  disposal  of some wastes  are
common  industry  practices,  with  recovery  and reuse limited to halogenated and
nonhalogenated solvents.

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                        3.  SOURCE REDUCTION PROFILE

    Source  reduction was previously  defined in Section  1  as "any  activity that
reduces or eliminates the generation of waste  within  a process."  This is a broad
definition, and it  requires further clarification. Conceptually, reduction in waste
generation  from  an  existing  manufacturing  process  can  be  accomplished  by
(1) in-plant changes and  (2) a decrease in product  output.

    The  activities  most  readily  identifiable with  source  reduction are  in-plant
changes.  Essentially, these include alterations of the variables  that  are  under the
direct  control  or influence of the producer or waste generator. Implementation of
in-plant modifications  results in  "source  control" and consists of  input  material
alterations, technology alterations, and procedural/institutional alterations.

    Source  control  techniques  are characterized and discussed in  Section 3.1. The
techniques are based  on  the  22 studies  of  individual  processes  and   practices
presented in  Appendix B and on other information. Section 3.2  provides a  summary
of the  individual qualitative estimates of current  and future extents  of  waste
minimization for each of the 22 processes  and practices.  In addition, the individual
estimates have been  synthesized  into  general  approximate  estimates  of  waste
reduction for the entire U.S. industry.

    A  decrease in product output  can  also lead to source reduction.  Product output
is  governed  by the  demand  for  that  product,  a  factor that  is  external  to  the
production unit.   Product  demand,  in turn, is governed by a host  of  other factors,
most of which  are not under the control or even  the  influence of the producer  or
waste generator.  This study has addressed reductions in product output only  to the
extent  of partial  identification  of  possible  product  substitution   alternatives.
Product substitution, by  itself, was considered part  of  source reduction because it
contributes (albeit indirectly)  to reduction  or elimination of waste  produced "within
a process" by decreasing demand  for the product. Product substitution is discussed
in greater detail in Section 3.3.  An overall summary  of  findings and observations is
provided in Section 3.4.
                                       3-1

-------
    Source  reduction, therefore, is  composed  of both in-plant changes (or source
control)  and product  substitution.   The  interrelationship  of  waste  minimization
components is graphically depicted in Figure 3-1.

3.1        Source Control Methodology

    The  intent of this section is  to characterize the dominant techniques in each of
the  categories  of  source  control,  i.e.,  input  material  alteration,  technology
alteration,  and  alteration of procedural or institutional  settings.  The  material 'is
largely based on  the 22  studies of individual  processes and  practices, in  which over
400 source control techniques were discussed and evaluated. This section also draws
from other sources of information, such  as  Section 6 of this report (Industry Efforts
Toward Waste  Minimization) and Section 5, Factors That  Promote  or  Inhibit  Waste
Minimization.

3.1.1      Input Material Alteration

    To characterize input material alteration correctly, a  distinction must be made
between   those  manufacturing processes  that chemically  convert  or  synthesize
essentially pure raw  materials into  a desired product and those  that  principally
remove  impurities from  the  feed  to  convert  it into  a  useful   product  or
intermediate.  An  example of the former is ethylene dichloride synthesis through
oxychlorination  using  ethylene, hydrogen chloride, and oxygen; an  example  of the
latter  is titanium  dioxide produced  from  ilmenite ore through a chloride process
where  iron  and  other  impurities are removed  to  obtain  purified titanium dioxide
pigment.  This distinction  is important because input material  alteration takes on a
different meaning for each type of process.

    In the  synthesis  process, waste can be  minimized only to  a limited extent by
feed material purification (most processes of this type  already utilize relatively high
purity  feed).  For example,  the use of  purer propylene  feed  in  the synthesis of
acrylonitrile through ammoxidation  of  propylene did  not  result  in  an  observable
decrease  in byproduct  formation (see process study Bl).  Additionally,  achieving a
high degree of purification  is  usually  very   costly,   results  in increased  energ/
requirements, and produces wastes in itself.
                                       3-2

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       1400s
                                                            WASTE MINIMIZATION
       RECYCLING
CO
 i
CO
INPUT MATERIAL
  ALTERATION

•  Material purification
•  Material substitution
                                                              SOURCE REDUCTION
                                                                                                  TREATMENT
                                     SOURCE CONTROL
TECHNOLOGY
ALTERATION

•  Process changes
•  Equipment, piping,
     or layout changes
•  Process automation
•  Changes to operational
     settings
•  Energy conservation
•  Water conservation
                                                                                           PRODUCT SUBSTITUTION

                                                                                               •  Alteration of composition
                                                                                               •  Alteration of use
PROCEDURAL/INSTITUTIONAL
      ALTERATION*	

•  Waste stream segregation
•  Procedural measures
•  Loss prevention
•  Personnel practices
        •Also  referred  to  as  "good operating practices," "good housekeeping," or "better operating practices"  in other parts of
         report.
                                                Figure 3-1  Elements of Waste Minimization

-------
    In the  second type  of  process,  where  input  materials contain  a  significant
amount of impurities, feedstock pretreatment  and  substitution (i.e.,  with  a higher
grade  of  material)  are  very  effective  waste reduction techniques.  An  example
involves the use of higher grade ilmenite with low iron content  for titanium dioxide
production.   There,  an  ore  pretreatment  process can  be  used,  which  produces
marketable  iron  oxide and higher grade ilmenite.  This  higher  grade ilmenite, in
turn,   reduces  chlorine  losses associated  with  processing  lower  grade  ilmenite
directly.  Another example involves using lighter feed crude for petroleum  refining
so as  to reduce  the  amount  of impurities requiring  removal before processing.  In
general, the  estimated future  potential for  feedstock pretreatment  or substitution
remains  low,  since  producers  already  invest  considerable effort  to  keep  the
manufacturing  cost down by providing  the highest  possible grade of raw materials to
their process.

    The above discussion has been limited to the principal raw materials, i.e., those
that are converted into the  final product.  The issue  of input  material  alteration,
however,  also  encompasses  auxiliary  raw materials.  Auxiliary raw  materials  are
those  materials that  take  part in the  process but do  not become part of  the final
product.  Examples  include boiler feedwater treatment  chemicals or cooling water
treatment chemicals that are  encountered   in utilities  use associated  with  many
processes.  Other examples of auxiliary  raw materials  are process water used to
wash  the  product or  intermediate, or  a solvent used to  wash metal  parts  in metal
surface finishing.

    Source  control in the  area of altering auxiliary raw materials should be oriented
primarily   toward  substituting  less  toxic   or  more  environmentally  acceptable
substances for  those  materials.  Thus, aqueous solutions  of biodegradable detergents
can sometimes be substituted for chlorinated  solvents.  Similarly, chemical  solutions
used for equipment cleaning can sometimes  be  replaced by hydroblasting, which uses
only  water.  Other  examples of substitution  include use  of less  toxic  trivalent
chromium    instead  of   hexavalent   chromium  in   chrome   plating,   use   of
aqueous-processable  instead  of  solvent-processable  resist  in the  manufacture  of
printed circuit  boards,  or  use  of  nondichromate  corrosion  inhibitors  in cooling
                                       3-4

-------
'water.  We have observed that auxiliary materials alteration has a higher  potential
for future application  than  the previously  described  purification  of  principal  raw
materials.

3.1.2      Technology Modifications

    Generally,  technological  modifications  were  found  to be  the  most  effective
means of reducing waste generation.  It was deemed  convenient to  distinguish  the
following categories of modifications:
     •  Process modifications;
     •  Equipment modifications;
     •  Process automation;
     "•  Changes in operational settings;
     •  Water conservation; and
     •  Energy conservation.
     Process modifications or changes, in the  context  of this study, mean the use of
alternative low-waste process pathways to obtain the same  product, modification of
reaction  parameters,  or  modification   of  separation  parameters.  Many  times,
process modifications will entail subsequent equipment modifications.  An example
of an alternative  process pathway is a chloride route to titanium dioxide, as opposed
to a  more  waste-intensive sulfate route. Another example is  the use  of  screen
printing,  instead  of  photolithography,  for image transfer  in printed circuit board
manufacture; this approach eliminates the use of developers.  The search  for  an
alternative process pathway usually involves considerable research and development
effort and thus may require a long  implementation period.

     Modification  of  reaction  parameters  consists of  improvements to catalyst
activity,  selectivity,  and stability; improvements to reactor design; and alteration of
reaction  pressure and   temperature.    Modification  of  reaction   parameters  is
considered  to be one of the more  exploitable  areas  in the efforts to reduce process
waste generation.  Hazardous wastes generated in a chemical conversion  process are
the result of  undesirable side reactions and left over unconverted reactants.  These
undesirable compounds or wastes are separated from the  product  downstream  of the
                                       3-5

-------
reactor as part of the product purification step.  Typically, the byproducts leave the
process as  distillation  column lights or heavies. Hence, an increase in conversion or
yield  will decrease both the byproduct  formation  and/or the amount of  unreacted
feed.   This,  in  turn,  usually results  in  a lower amount of waste  generated.  The
increase in yield is principally governed by catalyst activity and selectivity, reactor
design, and reaction conditions.

    Use of a more active and stable catalyst allows for an  increase in conversion
without the need to provide larger reactor volume;  a  more selective catalyst allows
for inhibition of side-reactions  that  lead to  undesirable byproduct formation. An
example of drastic  improvement in  yield and  subsequent  reduction in  byproduct
formation  is  acrylonitrile  synthesis via catalytic  ammoxidation  of propylene (see
process study B1).  There, a switch  from antimony-uranium catalyst to  ferrobismuth
phosphomolybdate catalyst in 1972 boosted the conversion (and thus the capacity) by
35 percent. A more recent example is provided by a  catalyst  for oxychlorination of
ethylene to  ethylene  dichloride  in  vinyl  chloride  monomer manufacture.  The new
catalysts,  introduced  by the Japanese  in 1983, can reportedly  produce  ethylene
dichloride   yields   comparable   to  those  obtained   from   direct  chlorination.
Additionally, since the catalyst is more stable, it maintains its activity over a longer
time  period.  This  reduces  the waste   associated  with catalyst  changeover  and
subsequent disposal.

    The second important aspect related  to reaction parameter modification is the
reactor design.  Generally, the reactor design is based  on kinetic  data related to an
accepted reaction  model.  Such data  are derived  experimentally, usually  using
bench-scale   test  apparatus.   The   reactor  design  is  first performed  for  the
commercial scale  reactor,  from  which the pilot-scale  design  is derived.  The  data
obtained from the pilot reactor  are then  used to scale-up the design to commercial
size.  From the waste  generation (or yield) point  of view, good reactor design should
encompass such factors as:

    •  Selection  of the proper reactor type,  i.e., plug flow versus perfectly mixed
        type;
                                       3-6

-------
    •  Good contact between reactants and catalyst;
    •  Minimization of local temperature or concentration gradients; and
    •  Selection  of  an optimum  strategy for reactant addition  or  temperature
       trajectory for batch reactors.

    An  example  of how alteration   of   the  reactor  design  can reduce  waste
generation  is   the  modification  of  an  allyl  chloride   synthesis  reactor  in
epichlorohydrin  manufacture.  By providing better mixing,  alteration of  reactor
design has resulted in a drastic decrease of tar formation.  Another example  is the
development of the  fluidized  bed catalytic  oxychlorination  reactor  used  in  vinyl
chloride  monomer  (VCM)  manufacture.  This  reactor  design  provided  better  yields
than its  predecessor, a fixed  bed  reactor.  In  phenolic resin synthesis,  reactant
addition  and temperature trajectory  can  minimize the content of the  unreacted
phenol present in the post-reactive mixture. The reactant addition and temperature
trajectory strategy is generally very important  to yield  considerations in the design
and operation of batch (or  plug-flow) reactors.

    A related reactor design aspect is rapid quench of  the  post-reactive  mixture.
As  long   as  the reactive gas  mixture has  good contact  with the catalyst, side
reactions leading to byproduct formation are inhibited.  However, when the hot gas
leaves the catalytic  zone, side reactions may occur and lead  to excessive formation
of byproducts.  Quick cooling,  preferably  through  direct quench,  is  important in
processes  such  as acrylonitrile synthesis  and  perchloroethylene-trichloroethylene
coproduction.  In  summary, the  reaction  parameter  alteration  is viewed as the
principal area for exploration in search for  low-waste process  routes.

    A third area related  to  process  changes is modification of separation process
parameters.  This approach is illustrated by additional  concentration of the  bottoms
stream leaving a distillation column.   This results in less product leaving the process
and subsequently in lower waste generation rates.  The limitations  of this  approach
may  lie  in vastly increased energy consumption or physical property limitations,
such  as   viscosity  or  azeotrope formation.   In  this  context,  the use  of  novel
purification/separation techniques  (such as  supercritical  extraction) is  considered
promising.
                                       3-7

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     Process modification  involving concentration of nonrecyclable waste  has been
identified  as a subject of considerable controversy throughout  the  course of the
study. The controversy stemmed from  the  original  definition  of waste minimization
as an activity resulting in a "reduction of  total volume  of hazardous waste."  Under
this  definition, reduction  of the water content of hazardous waste would be viewed
as minimization, in  spite of  a possible increase in the concentration of hazardous or
toxic substances.  The conflicting  viewpoint  is that the waste minimization  effort
should be  concerned with reduction of the  toxic components in  the  waste stream,
and  that a  decrease of  the  water  content should  not  be  viewed  as  a valid  waste
minimization activity, because it  is  the equivalent   of  dilution as a  means of
decreasing toxicity.  This viewpoint corresponds with this study's definition  of  waste
minimization (see Section 1),  even though some of the process studies have listed
dewatering as a source control technique.

     Equipment  modifications, as  defined  in  this study,  differ   from   process
modifications in that  the  process  function remains unchanged.  Waste reduction is
accomplished by  reducing  or eliminating  equipment-related   inefficiency.  An
example from the paint  manufacturing process is the use of mechanical wall wipers
to reduce the amount  of paint clinging  to  the wall  of  the  tank after the batch  has
been  emptied.  In  this application,  the cleaner  equipment surface means  reduced
generation  of waste resulting from cleaning  of the  equipment.  Other  examples
include  the  use of  double mechanical seals  on pumps  to  lower the  probability of
spillage with the associated cleanup waste and inhibition of heat exchanger fouling
deposits  by  provision  of  higher turbulence  using  tube  inserts or by provision of
smooth  heat exchanger surfaces,  e.g., electropolished tubes.  A  related aspect to
equipment  modification is proper piping and plant layout.  Minimizing the length of
piping runs, allowance for self-drainage,  or designs  allowing for "pigging" (i.e.,
cleaning of  pipes using fluid-propelled  inserts)  all affect  the  quantity  of  waste
generated.

     The relationship of process automation to  waste minimization is  demonstrated
through the following considerations:
                                       3-E

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    •   Increased  automation means lessening  the probability  for  operator error,
        which reduces the probability of spills and off-spec product generation; and
    •   Increased  automation can result in higher  product yields because of smaller
        deviations from the set points, or because  of on-stream  automatic set point
        optimization.
    Examples include  automated batching systems, where the  manual handling and
measuring  of  substances is  replaced  by  automated  closed transfer systems.  Such
systems can be employed with almost any type of batch operation involving material
handling  or  liquid  transfer.  In  a  continuous  process,  an example of  improved
automation  is a supervisory  system  that uses a computer  to monitor and reset the
controller  set  points  automatically  to achieve an  optimum  process  performance.
The  use  of  a  real-time  column  simulation  coupled with   automatic set-point
adjustment has been applied to a gas/oil desulfurizer fractionator operation in order
to maximize product recovery.

    Changes in operational  settings of equipment involve adjustment to,  but not
modification  of,  equipment.   An   example  includes  reducing  the  atomizing air
pressure  to paint spraying  application equipment,  which  reduces overspray  and
associated  waste.  Another example is adjusting the  speed of workpiece  withdrawal
from  a cleaning  or  plating  bath.   This, in  turn,  affects the amount  of  solution
remaining  on  the  workpiece (called "drag-out").  Slower  withdrawal  produces  less
drag-out, which results in less solution  carryover into rinsing and hence reduces the
generation  of waste treatment sludge. Changes to  operational  settings in general
are easy  and inexpensive to  implement and often result in substantial  reductions in
generated wastes.

    Energy conservation contributes  to minimizing  the  waste associated with the
treatment of raw  water, cooling water blowdown,  and  boiler blowdown,  along  with
the wastes associated  with fuel  combustion (such  as  ash   or soot).   As steam
consumption is decreased, raw water requirements are decreased, along  with boiler
blowdown and  cooling water  used  to condense low-pressure  steam.  However, it
must  be  noted  that an increase in energy conservation is  often associated with an
increase  in  the number of heat exchangers used in the process. This may have the
                                      3-9

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undesired  effect  of  increasing  the  wasteload  associated  with  heat  exchanger
cleaning.   Generally,  however,  the  effect  of   energy  conservation  on  waste
generation is small.

    Water conservation  can  contribute to a reduction of the quantity of the toxic or
hazardous  components of  aqueous  waste.  For example, if water  is used  to  wash
away  the soluble impurities from an  organic product or semi-product (e.g.,  ethylene
dichloride), the water  stream  emerging  from  the wash  operation  will  also  be
saturated  with  the product  (or  semi-product).   Although  the  product would  be
expected to be insoluble  in water, certain losses are inevitable because  of small but
measurable solubility or physical entrainment. Therefore, reduction in the amount
of water used in the wash will also mean reduction  of product  loss and its carryover
into the  treatment section.  This will subsequently reduce  the volume of  treatment
sludge produced.  The  individual  reductions  may  be  small or  may  even appear
inconsequential; nevertheless,  on a total  basis, water conservation is  expected to
have  a measurable effect on waste  generation. As approaches  to source  control,
water conservation and energy conservation appear  to  be  less  important  than
process  changes,   equipment  changes,  increased  automation,   and  changes  to
operational settings.

    In summary, technology  modification appears to be a central area  of focus for
waste minimization.  Out of  153 examples of  reported source reduction techniques
identified   in  this  study,   113 techniques  (42 percent)  were  classified  as
process/technology  modifications    (see   Section  6).   In  general,   technology
modifications are  most  efficiently addressed  during the planning  or design period
when  decisions can be implemented more easily and less expensively, compared to
an  operational phase which alters existing equipment  or processes.  It should also be
noted that the range of options available to the designer of a new facility is usually
considerably wider than  the range  of  available revamp options for an existing plant.
In this context, the awareness of the benefits of source  control among the process
designers (usually  licensors and engineering firms) can have  a profound  impact on
the prevention of future  hazardous waste  generation.
                                      3-10

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3.1.3      Procedural/Institutional Modifications

    This category of source control  techniques relates to alteration of  procedures
or organizational and  institutional  aspects  of  a  manufacturing  operation.  For
example, proper scheduling of batch operations can have a dramatic  effect on waste
generated from  equipment cleanup.  Another example would be the introduction of a
new requirement by corporate management that  each  plant manager be  responsible
for the periodic reporting of  quantity, composition,  and  disposal  costs of every
manifested  waste leaving  his  facility, along  with the  reporting  of  progress  in
achieving  quantity  reduction  of such wastes.  By itself, this is not a  direct waste
reduction  measure;  however, it does raise awareness  of the  problem  within  the
manufacturing unit and, ultimately, results in activities leading to a  reduction of the
quantity of waste generated.

    Procedural   or  institutional  modifications   were   termed  "good   operation
practices" (GOP), but also are referred  to  as "better operating  practices" or simply
as "good housekeeping." The  goal  of GOP  is to ensure that  no additional waste is
generated because  of  human  intervention (or  lack of it). Based on  the information
presented in the process and  practice  studies, GOP is composed of the following
elements:
        Employee training;
        Management initiatives*
        Inventory control;
        Waste stream segregation;
        Material handling improvements;
        Scheduling improvements;
        Spill and leak prevention;
        Preventive maintenance; and
        Process documentation.
     All of the above elements are essential to  an  effective GOP program.  Without
proper  employee  training and management initiatives, easily solved problems can
expand  and eventually get out of hand.  The simple act of a  paint  booth  operator
indiscriminately overspraying the paint will adversely  affect waste generation rates
and may require both training and intervention of  management.  The importance  of
                                      3-1

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inventory  control  is demonstrated by  cases in some industries  where  the plant
management  was not truly aware of  the actual  mass balance and amount of waste
generated, because the balances were  either not performed or their importance  was
overlooked.   Typically,  when  management  learned  of  the  quantities  and  the
associated  disposal  costs  of  wastes  produced,  corrective action  was   quickly
undertaken.

     The  practice  of  segregating  wastes  has  proved  beneficial  in   promoting
recyclability  of  solvents.  For example, providing dedicated collection tanks  or
drums for  each type of spent  solvent makes  the solvents recyclable in that expensive
fractional  or  azeotropic distillation is not required for reclamation; rather, a more
commonly  used single stage batch still is sufficient. Segregation of hazardous waste
streams  from  nonhazardous  waste streams will  result  in   volume reductions  of
hazardous waste in cases where a mixture of such wastes is classified as hazardous.

     Material   handling  improvements  involve,   for  example,   specifying  larger
containers for storing or  containing toxic or hazardous substances. The  underlying
principle in this option is that the same  volume of the substance contacts a smaller
surface area  in  the fewer large  containers  than  in  the more numerous  smaller
containers.   This,   in  turn,   results  in   a  smaller leftover  amount  and  a  lower
probability of spills because of reduced handling.  In fact, some companies  converted
from drums to tote bins, megadrums, or even to bulk handling of certain  materials.

     Proper scheduling of  batch   operations  is  of paramount importance  to  the
resulting equipment cleaning  frequency and the  associated  wasteload.   Equipment
cleaning waste is often a major waste stream associated with  batch  operations.

     All  of   the   above   GOP  elements   and   the   remaining   ones   (preventive
maintenance,  process documentation, and spill prevention)  are  discussed in detail in
Practice Study B19 in Appendix B.

     Based  on  the  process and practice studies prepared for this report, the following
observations are made regarding GOP and its application in  various industries:
                                      3-12

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    •   GOP tends to be  more effective for processes characterized by  high labor
        participation  (e.g., metal parts cleaning or electroplating);
    •   GOP  tends  to  be  more   effective   for  batch  processes  (e.g.,  paint
        manufacturing  or  organic dyes and  pigments)  than  for continuous processes
        (e.g., vinyl chloride monomer production or petroleum refining);
    •   GOP is generally well accepted, well understood, and the  most  frequently
        applied source control technique.
    The  first  two  observations  are  not  totally  unexpected,  considering  that
labor-intensive processes  are  subject  to  higher probability  of  human error,  which
results  in waste through off-spec product  generation, inadvertent spills and  leaks,
and mixing of hazardous wastes with sanitary wastes.

    The  third  observation  is  consistent  with the  common  business  practice  of
selecting  source   control  techniques  that  are  obvious,  easy,  and   relatively
inexpensive  to implement  prior  to  selecting  more sophisticated  measures.  Since
GOP is  easily implementable, cost effective, and often related  to health and safety,
current use is  high.  However, a significant potential for improvement still exists,
especially  in  the  area of  management   initiatives designed  to  promote   waste
minimization activities in the  firm.

3.2       Current and Future Extent of Waste Minimization through Source Control

    In  order  to  fully  assess the  desirability   and proper   form   of  additional
government actions designed  to promote  waste minimization,  consideration should
be given to  the extent  to  which waste generation  has alread/  been minimized and
the future  extent  of additional  reductions.  The derivation of this  estimate was
based  entirely  on  the  exploratory  study  of  the 22 different  waste  producing
industrial processes and practices contained in Appendix B.

    In  this  study,  the current level  of  waste minimization  is estimated  using  3
current reduction index (CRI),  a variable directly related  to  the percent that waste
has been reduced compared to  the amount that  would have  been  generated if none of
the noted source control techniques were in place at their current application  level.
                                      3-13

-------
The  CRI  was  derived  for  each technique, every  waste stream,  and the  entire
process,   based   on   EPA's  analysis  of  each   technique   in   three   categories:
effectiveness, extent of current use, and future application potential. The  details of
how  the  analyses were developed  and transformed  into  CRI  are given  in  the
introduction to Appendix B.

    The  future potential  for  waste reduction  is  characterized  in  this study by a
variable   called  future  reduction  index  (FRI),  which is a  measure  of  possible
fractional reduction  of the waste  currently  generated.   This  reduction  would  be
achieved by implementation  of all source control techniques to  their full estimated
application potential instead of  their estimated  current  application levels.  Again,
FRI was based on the ratings and the methodology presented in the introduction to
Appendix  B.

    Both  CRI and FRI are qualitative estimates of currently achieved and potential
future waste  reduction.  In the  index format  a scale of 0 to  4  is used; the  index  can
be converted to a percentage by division of  CRI or FRI by 4. It should be noted that
the indices were devised to be  independent of production  rates,  i.e., they pertain to
specific waste generation expressed  in pounds of waste per pound of product.

    The summary of results obtained  for each of the studied processes and practices
(with  the notable  exception  of the study of  good operating  practices where ratings
were  not  developed) is given  in Table 3-1.

    For  all   waste  streams  considered  (including   both  RCRA  and non-RCRA
streams), the CRIs range from  1.0 to 3.1 (25 to  78 percent).  The CRIs  indicate that
some  reductions  have already been  achieved.  It must be  noted, however, that such
reductions did not occur as a result of actions designed specifically to reduce waste;
rather, the minimization of waste  was incidental and resulted from the  efforts to
maximize yields and improve the ooerating efficiency (see also Sections 2  and 6). It
is only recently  that waste minimization  (and  source control in particular) became
an area of focused activity, primarily  as  a  result of  RCRA  regulations leading to
significant increases  in waste management cost and generator's liability.
                                      3-14

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1402s
                       Table 3-1  Current and Future Reduction Indices for AH
                          Wastes Considered in Process and Practice Studies
Number No. of Current Future reduction index
of source reduction (FRI)
SIC
Code
2491
27
2869
2879

2869
2816

2365

2851
28128
2824
2822
28692
2869

2869
Process/ Study waste control index
practice number streams methods (CRI) Probable
Wood Preserving 818 5 20 3.0 0.5
Printing Operations 812 3 20 2.5 0.7
Acrylomtrile 81 4 18 2.0 0.7
Agricultural Chemicals 82 5 8 2.0 1.0
Formulation
Epichlorohydrin 84 5 17 3.1 0.7
Inorganic Pigments B5 3 7 2.1 0.3
(Titanium Dioxide)
Organic Dyes and 87 5 15 2.4 0.6
Pigments
Paint Mfg. 88 5 20 2.2 0.7
Phenolic Resins 810 5 21 1.8 0.7
Synthetic Fiber Mfg. 813 3 10 2.3 0.5
Synthetic Rubber Mfg. 814 5 17 2.1 0.4
1 ,1 ,1-Trichloroethane BIS 4 13 3.0 0.7
Trichloroethylene/ B16 6 19 2.3 0.4
Perchloroethylene
Vinyl chloride 817 8 31 1.5 0.1
Maximum
1.6
1 .4
1.5
1 .2

0.9
0.5

1.2

1 .7
1 .2
0.8
0.8
0.8
0.9

0.3
        Total  for  SIC  28
                                        58
199
2.2(a)     0.6(a)
                                                                                         l.O(a)
                                                   3-15

-------
1402s
                                        Table  3-1  (continued)


SIC
Code
2917
3471
3471



Process/
practice
Petroleum Refining
Electroplating
Metal Surface
Treatment
3679052 - Printed Circuit

M/A
NA
N/A
Boards
Metal Parts Cleaning
Equipment Cleaning
Paint Appl icat ion


Study
number
89
B3
•B6

Bll

620
822
821
Number
of
waste
streams
17
4
5

5

5
2
5
No. Of
source
control
methods
43
22
25

18

20
21
11
Current
reduction
index
(CRI)
2.2
1 .8
1.0

2.0

2.0
2.6
1 .9
Future reduction index
(FRI)

Probable Maximum
0.5 1.2
0.8 1.9
0.7 1.3

0.7 1.9

1.2 1.9
0.7 1.4
.1.1 1.7
NOTES: (a)  Arithmetic  averages.
                                                   3-16

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    Although  no specific steps were  undertaken  in  this  work to  determine  the

precise  chronology associated  with  each  source  control  technique  currently  in

application, EPA's  analysis suggests most  of  the noted techniques responsible  for

achieved reduction  were probably introduced within  the last  15 years.


    Table 3-2 lists FRI  and  CRI  derived  only  for  streams containing  "F" and  "K"

RCRA wastes. The individual CRIs and FRIs are  similar to  those given  in Table 3-1,

where the compilation was based on both RCRA and non-RCRA streams.  This may

be  indicative  of  the  fact  that the  reduction  of  hazardous  RCRA  wastes is
accomplished  through  application  of  the  same  methodology and  underlying  process

principles that are applicable  to non-RCRA wastes.


    The 22 studied processes/practices provided the basis for nationwide projections

of  currently  achieved and possible  waste  reductions.  The  nationwide  estimates
given in Table 3-3 were computed using the following approach:


    •   First, the top  12 general  industry groups given by  two-digit  SIC codes were
        assembled  in  the order  of  their  fractional  contribution  to  the  overall
        national  hazardous waste  generation in 1983.  The ranking order was  adapted
        from Table 2-3, based on the 1983 CBO data.

    •   Second, for each two-digit  SIC grouping a representative set  of  processes
        was selected out of  the 22  that were studied.  For example, the fabricated
        metal products  group  (SIC 34) was  represented by  electroplating,  metal
        surface treatment, metal parts cleaning, and paint application.

    •   Third, average CRI  and FRI values were computed for each representative
        set of processes in  every group,  based  on  the individual values listed in
        Table 3-7.   For  example,  the  CRI   for  SIC 34   group was   obtained  as
        (1.8 + 1.3 -i- 1.6 +  l.9)/4  = 1.6;   i.e.,   arithmetic  average   of   CRIs  for
        electroplating, metal surface  treatment,  metal parts cleaning,  and paint
        applications.  (The Agency did not have adequate data to produce an  average
        that is weighted  for  the relative contribution  of waste represented  by each
        of the CRTs used to calculate the CRI for a specific SIC group.)

     •   Fourth, the nationwide CRI and FRI values were obtained by weighting the
        average  group   values,  by  the   fraction  associated  with  each  group's
        contribution  to the   overall waste generation  rate.   For   example,  from
        Table 3-3:

              CRI  = 0.478 x  2.7 + 0.13 x 2.7 + 0.1  18 x2.0 +...etc. = 2.4.
                                       3-17

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1402s
                    Table 3-2  Current and Future Reduction Indices for "F" and "K"
                        RCRA Wastes Considered in  Process  and  Practice Studies
SIC
Code
  Process/
  practice
Study
number
Number      No. of      Current   Future reduction index
  of        source     reduction  	(FRI)	
 waste      control      index
streams     methods       (CRI)    Probable       Maximum
2491   Wood Preserving (b)     818
27     Printing Operations     B12

2869   Acrylonitril*            Bl

2879   Agricultural Chemicals   82
            Formulation

2869   Epichlorohydrin          84

2816   Inorganic Pigments       85
       (Titanium Dioxide)

2865   Organic Dyes and         87
         Pigments

2851   Paint Mfg.               88

28128  Phenolic Resins         810

2824   Synthetic Fiber Mfg.    BU

2822   Synthetic Rubber Mfg.   814

28692  1,1,1-Tnchloroethane   815

2869   Tricnloroethylene/      B16
       Perchloroethylene

2869
Vinyl Chloride

Total for SIC 28
  817
  1

  0

  1

  0

  3

  2


  3

  19
                                              14
                                              6

                                              8

                                              2


                                              13

                                              N/A
 9

N/A

 1

N/A

 9

11


18

75
                                   3.0
                                   2.0
2.3


3.9

N/A


2.3


2.0

N/A

3.0

N/A

3.0

2.0


2.9
0.5
0.6

0.7

0.3


0.7

N/A


0.6


0.6

N/A

0.3

N/A

0.7

0.5


0.2
                                                  1 .6
                                                  1.5
                                                            0.9

                                                            N/A
1 .7

N/A

0.3

N/A

0.8

1.0


0.6
                                                                2.5(a)    0.6(a)
                                                                                  l.O(a)
                                                   3-18

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1402s
                                        Table 3-2 (continued)


SIC
Code
2917
3471
3*71


Process/
practice
Petroleum Refining
Electroplating
Metal Surface


Study
number
89
83
B6
Number
of
waste
streams
2
3
2
No. of
source
control
methods
17
28
IT)
Current Future reduction index
reduction (FRI)
index
(CRI) Probable
1.5 0.6
1.8 0.8
1.3 B.3

Maximum
1 .7
1.9
0.8
       Treatment

36790S2 - Printed Circuit
          Boards
Bll
N/A    Metal Parts Cleaning   B20

N/A    Equipment Cleaning     822

N/A    Paint Application      821
                        7

                       21

                        6
2.2


1.6

2.6

1.9
                                           0.7
                         1 .8
NOTES:  (a)  Arithmetic averages.
        (b)  Wood preserving wastestreams are sent to wastewater treatment which generates a
            RCRA-listed waste.
                                                   3-19

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                1401s
                                         Table 3-3  National Hazardous Waste Generation and Reduction  Profile
co
i
rs>
O
SIC
Code
28

33
29

34

30

39

35

37

42

Industry
Chemical and
Allied Products
Primary Hetals
Petroleum and Coal
Products
fabricated Metal
Products
Rubber and Plastic
Products
Hiscel laneous
Manufacturing
Machinery Except
t leclrical
Transportation
Equipment
Motor freight
Transportation
Percent of
total waste
generation (a)
47. 9

18.0
11.6

9.6

5.5

2.1

i.e

I.I

0.6

Waste reduction indey (b) Representative process studies
future future Total Analog process study
Current (probable) (maximum) number numbers (c)
2.5 0.6

2.5 0.6
1.5 0.6

1.6 0.9

2.6 0.7

1.9 0.9

1.9 0.9

1.9 0.9

1.6 1 . \

1.0 9 Bl. B2, B4. B7, B8. B13. BIS
thru B17
1.0 9 Assumed same as SIC 28
1.7 1 B9

1.5 4 B3. B6. B20. B21

1.4 1 B22

1.4 4 B6. B20. B21. B22

1.4 4 B6, B20. B21. B22

1.4 4 B6, B20. B21. B22

1.7 1 B20


-------
             1401s
                                                              Table 3-3  (continued)
                                          Percent of          Waste reduction index (b)           Representative process studies
             SIC                          total waste                 Future     Future     Total          Analog process study
             Code    Industry             generation (a)   Current  (probable)  (maximum)   number              numbers (c)
36     Electric and Elec-          0.7
       tronic Machinery

24     Wood Preserving             0.7

50     Drum Reconditioning        <0.1

       Overall                    100.0
                                                              1.7
0.6
                                                              3.0        0.5

                                                              2.6        0.7

                                                              2.3(d)      0.6(d)
1.3


1.6

1.4
86. Bll


B18

B22
CO
 I
            NOTES:    (a) Obtained from CBO 1985,  see  Table  2-3.
                     (b) Average values for all  analog studies  listed  (based on RCRA stream only,  see Table 3-2).
                     (c) See Appendix B.
                     (d) Weighted average.

-------
    The resulting CRI value is  2.4, which, on the scale of  0  to 4, is equivalent to
60 percent reduction achieved  with respect to  the  waste  that  would  have been
currently  generated if none  of  the  source  control  techniques  identified  were
practiced  at all.  Conversely,  this  means  that  if  none of  these  techniques were
currently  in place, the  industry might be generating l/(l - 0.6) = 2.5 times as much
waste on a "per unit" basis as it does at the present.

    The future reduction index (FRI) ranges from  0.7 to 1.3, on the scale of  0 to 4.
This suggests a  20 percent  reduction  might be  possible compared  to  the current
waste generation  rates  if all  noted techniques  are  used to  their  full estimated
potential.

    In qualitative  terms (which  seem  to  be more appropriate considering that  the
CRI and FRI both  reflect qualitative analyses by  EPA), it appears that industry  has
reduced its  "per unit"  production waste generation noticably. Furthermore, most of
the noted  source control methods that are  responsible for such  reductions appear to
have  originated through  the efforts to decrease  the  manufacturing costs through
increasing yield of  chemical conversion, conservation  of  expensive auxiliary raw
material,  energy  conservation,  cost  of labor,  and increase  of  overall  operation
efficiency.  Rarely,  wastes appear  to have  been minimized as a result of activities
specifically  focused on waste minimization. This  trend  has been observed to  occur
with increasing intensity since the early  1980s (see Section 6.0).

    Although some reduction  has  occurred, it also  is  quite  clear that further
reductions appear feasible.  This possibility is supported by EPA's  analyses and  the
simple fact that over 200 million tons of hazardous waste continue to be generated
despite all current source reduction.

3.3       Product Substitution

    As  mentioned  previously,  product  substitution was  considered  to be a part  of
source reduction because  it  has a potential  for  reducing  waste generation at the
source.  Product  substitution  is defined as the replacement of an original product
with another product intended  for the same end use.  An example is  substitution  of
                                      3-22

-------
wooden pilings with  concrete pilings  for  marine  construction, which affects the
amount of creosote-treated  wood produced and thus the waste associated with its
production.

    A related area is  product conservation or alteration  of  its end  use,  where a
change occurs in the manner in  which the  product is used.  For example, better tire
maintenance  by  consumers  will  lower tire  replacement  frequency,  which  will
subsequently affect production of synthetic rubber and related waste generation.

    The  area of  product  substitution  or  conservation  is  extremely  important,
because  it affects not only  the  wastes associated directly with manufacture, but
also the wastes  associated  with  the  disposal  of the  used  product, which also  may
pose an environmental problem. This area is also extremely complex because  of the
need  to  consider  all  elements  that  the feasibility  analysis  of   the  proposed
substitution  entails.  The  issue involves evaluation of feasibility  in  four separate
areas:

     1.  Technical  feasibility:  it must  be determined that a substitute will  function
        well in place of the original product and that the replacement frequency is
        satisfactory;
     2.  Environmental  feasibility: the manufacture and disposal of  the substitute
        product must confer greater environmental benefit (lower overall emissions
        and/or lower toxicity) than the original  product;
     3.  Socioeconomic    feasibility:    the    incremental   costs  associated   with
        substitution must  be compatible with the  net  environmental benefits  of the
        substitution.  In other words,  minor environmental benefits  would likely not
        justify substantially  higher costs.
     k.  Sociopolitical feasibility:  where government  action  is  being  considered,
        approaches to  promoting the use  of  a  substitute  must be  found; these
        approaches must be  compatible with the precepts of a free-market economy.

     The evaluation of  feasibility in all four areas  is complex  and was deemed to be
outside  of   the  scope  of  this  study.  However,  possible  product  substitution
alternatives  were identified  for future analytical  work.   These alternatives are
described in detail in Section 10  of each process study provided in  Appendix B and
also are  summarized  in Table 3-4.
                                       3-23

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 1399s
                                                     Table 3-4  Summary of Identified Product Substitutions
       Process study
        Use of product
                                                                     Identified substitutes
                                                                                                                            Remarks
   Acrylonitrile
      (vinyl  cyanide)

   Agricultural chemicals
      1ormulation
    Elpctroplating
oo
 i
ro
    Epi Llilorohydrin
Manufacture of acrylic and
  modacrylic fibers

Pest control (insects, diseases,
  parasites, weeds, etc.)
Fabric yardage extension
Integrated pest management
Protection and cosmetic enhancement
  of metal surfaces
Refined:  epoxy resins, elastomers

Crude:  synthetic glycerol for
        cosmetics and drugs
Zinc plating
Titanium dioxide vapor deposition
Aluminum ion vapor deposition

Nickel plating
None

Natural moisturizers, e.g.,
  lanolin; natural glycerol;
  sorbi tol
                                                                                                       Precedented in 1973.
Biological, genetic, "cultural," and chemical control
  of pests.  Not widely implemented because of lack of
  knowledge of methods, lack of trained IPM personnel,
  and questionable economic feasibility, and inferior
  fruit/vegetable appearance.

Substitute for cadmium plating.
Substitute for cadmium plating in some applications.
Considerably more expensive than electroplating, but
  free of hazardous waste.
Could replace cosmetic chromium in the absence of
  consumer opposition.

Epoxy resins from refined epichlorohydrin are valued
  for their strength and  resistance to chemical attack.
Natural glycerol is a byproduct of soap manufacture
  from animal and vegetable fats and oils.
    Inorganic pigments
      (titaniurn dioxide)
Paint pigment

Opacifier for paper products
    Metal  surface finishing   Protection and cosmetic  enhancement
                                of metal surfaces
None

Alumina or silica clays

Zinc vs. nickel plating
Electroless copper vs. nickel
Higher-quality, longer lasting paints could be
  produced.
These clays are not as bright as titanium dioxide.
                                                                          Practiced in the printed circuit board industry.

-------
  1309s
                                                                      Table  3-4  (continued)
        Process study
        Use of product
  Identified substitutes
                                                                                                                            Remarks
    Organic dyes and
      piyments
    Synthetic fibers


    Synthetic rubber
Coloration of textiles,  paints,
  paper, plastics,  printing  inks
Acrylic, nylon,  olefin,  and
  polyester fibers

Vehicle tires and other  uses
CO

en
    1,1,1-Trichloroethane
    Tnchloroethylene/
      perchloroethylene
Solvent for vapor degreasing and
  cold cleaning operations
Principal solvents for cleaning
  operations
    Vinyl  chloride
Manufacture of polyvinyl  chloride
  (PVC) and its copolymers
Disperse dyes
Reactive dyes
Natural  fibers


Natural  rubber

Ethylene-propylene rubber (EPR)
                                                                   Recycled  1,1,1-TCE
                                                                   Water-soluble synthetic cleaners
1,1,1-trichloroethane (1,1,1-TCE)
Petroleum solvents

1,1,2-trichloro-l,2,2-trifluoro-
  ethane
Alkaline cleaning fluid
Clay, cast iron, ductile steel

Alumi num
Growing use due to growth of synthetic fabrics.
Wider use depends on development of techniques such as
  use of fixation accelerators,  short-liquor dyeing,
  or low-temperature dyeing.

New finishing techniques are required to give natural
  fibers the desirable properties of synthetic fibers.

Synthetic rubber use could decline by using radial
  tires, which require more natural rubber.
Though a synthetic rubber, wider use of EPR can reduce
  waste because of its relatively low fractional  waste
  loads.
Synthetic rubber use can be reduced through practices
  which reduce tire replacement frequency.

The prospects for product substitution are best for
  recycled 1,1,1-TCE.  Water-soluble cleaners require
  changes in cleaning practice.

1,1,1-TCE is less toxic.
Petroleum solvents are used in dry cleaning operations,
  but are highly flammable.
This solvent is little used because of high cost and a
  need for work environment control.
Combined with ultrasonic equipment, alkaline cleaning   '
  fluid can remove oil residues.

These materials have large-diameter piping applications
  and can replace PVC there.
Aluminum can be used in irrigation piping applications
  to replace PVC.

-------
   399s
                                                                      Table 3-4 (continued)
        Process study
        Use of product
                                                                      Identified substitutes
                                                                                                                             Remarks
    WooiJ preserving
    Paint manufacture
    Petroleum refining
CO
 i
no
cr>
    Phenolic resins
    Printed circuit boards
Preservation of railroad ties,
  utility poles, and pilings

Coatings for architectural  struc-
  tures
                              Coatings for functional and cos-
                                metic enhancement of products
Gasoline, kerosene, distillate,  and
  residual fuel oils for use as
  fuels, plus other crude petroleum
  products

Binding resins, tackifiers, and
  insulation  (phenolic foam) for
  plywood, granulated wood, mold-
  ings compounds, laminates, spun
  insulation, foundry binders,
  abrasives,  protective coatings
Business machines, computers, home
  entertainment and communications
  equi pment
                                                                    Steel-concrete substitutes
                                    Steel-concrete substitutes cost considerably more than
                                      wood.
Brick, marble, glass, colored       Exterior architectural applications.
  concrete, anodized metal siding",
  vinyl-coated siding
Wood paneling, fabric coverings,
  wal1 paper
                                    Product coating applications.
                                    Chrome yellow is still required in  traffic paint.
                                                                                                        Interior architectural applications.
                                      Powder coatings,  plastic coatings
                                      Yellow iron oxide,  organic
                                        pigments
Solar, nuclear, coal energy;
  gasohol and methanol
Injection-molded thermoplastics

Thinner laminates, low-pressure
  polyester or melamine laminates
Epoxy or silicon resins
Pine from the Pacific Northwest
Surface mounting, reduction of
  board size
Use of injection-molded thermo-
  plasti cs
Alternative energy sources have limited economic
  practicability relative to petroleum sources.
These can serve as substitutes for phenolic resin
  binders in the manufacture of waferboards.
Pine from the Pacific Northwest is less absorbent than
  Southern pine.

Product reconfiguration eliminates some plating steps
  and reduces waste generation from other cleaning,
  plating, and photoresist stripping steps.

-------
                                                                    Table  3-4  (continued)
      Process  study
        Use of product
  Identified substitutes
                     Remarks
  Printing  operations
Printed matter using heat-set
  solvent-base inks,  and  plates
  and films containing  silver
CO
 i
Water-borne inks (used currently
  in gravure and flexographic
  printing)
Utraviolet (UV) inks
                                                                 Electron-beam-dried (EB)  inks

                                                                 Heat-reactive inks
                                                                 Electrostatic screen printing
Water-borne inks require more energy to dry, require
  brief process stoppages, possess a low gloss, and
  cause paper curl.
UV inks are 75 to 100 percent more expensive than
  heat-set inks, and papers that contain them cannot
  be deinked by conventional methods.  UV lighting is
  hazardous to personnel, and UV light acting on
  oxygen creates ozone.
E6 inks can be created from UV inks.  Electron beams
  cause x-rays and paper degradation.
Heat-reactive inks have less than 20 percent of
  volatile content of heat-set inks, but cannot be
  used in sheet-fed  processes and can permit buildup
  of static electricity.

-------
    Finally, it  must be noted that of  all the source  reduction techniques discussed,
product  substitution  is  the  most  controversial.  Industry  generally  viewed  the
inclusion of product  substitution as part of waste  minimization as inappropriate,
because  they   perceive   it  as   leading  to   government  intrusion  into  the  free
marketplace.

3.4      Summary of Findings and Observations

    Observation #1

    Until recently, (prior  to  the 1980s) waste  minimization was rarely directly
addressed by industry, Le.,  it was rarely pursued as  a separate and specific project
objective.  Rather, waste minimization  occurred  mainly as a result  of efforts to
decrease  manufacturing  costs  through  improvement  of   yields  and   operating
efficiency.

    Observation #2

    Because of implementation of the various source control techniques discussed in
Appendix B, the level of  waste generation in terms of units of  waste  per unit of
product may have declined  significantly in the  last 15  years (the  time frame during
which most of the noted  techniques have been applied).  If none of  these techniques
were in place  today,  industry might be generating as much  as 2.5 times  more waste
per unit  of product than it  does  at present.   This figure  is based  on qualitative and
preliminary  information and should not be considered  definitive.

    Observation #3

    The   potential  for  future   reduction  of  waste   generation  appears  to  be
significant.  The  estimates  range  from 18 to 33 percent reduction of unit  of  waste
per unit of product  compared  to  the  current level  of waste  generation.  These
reductions would result  from the  extension of existing source control techniques and
the  application  of  new  technologies  identified  in  Appendix B  to  their  fullest
potential.  The time  scale  over  which  these reductions  may  take place was not
estimated; however, it appears unlikely that a period  would exceed 25 years.
                                      3-28

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    Observation #4

    Waste minimization  through  further  extension  of  good  operating  practices
appears most promising in the industries characterized by high labor  utilization, or
where  batch  processing  is  used.   Additional  implementation of  good  operating
practices  will probably have only limited  effect on waste generation  in large-scale
continuous processes with a relatively high degree of automation.

    Observation #5
    For  continuous  processes  generating  large  amounts of  waste,  the  most
promising  area  for  source  control  is  technology  modification.  Input  material
alteration  is  most  effective in  those  processes where  impurities  constitute  a
considerable fraction  of  input materials or where  the potential  exists for lowering
the toxicity of the auxiliary raw material.

    Observation #6

    Energy conservation  contributes  to  a  lowering of   waste generation  from
utilities  serving  the   production  process.  However,  it   may  produce  additional
wasteloads associated  with periodic cleaning of added  heat transfer equipment.

    Observation #7

    The  approach  of  reducing  the  water  content of hazardous  waste  to  obtain
"volume  reduction" does not appear worthy  of  classification  as  a  valid waste
minimization technique. It is viewed as a  reverse equivalent of dilution as a means
of reducing toxicity.   However,  conservation  of  water can contribute to a limited
extent to reduction of waste generation in cases where water is in contact with  the
organic phase.  This is because the carryover of  organics into the treatment section
is lessened, together  with  the related  sludge  output.  Waste resulting  from  raw
water treatment can  be  reduced through  water  conservation efforts.  In certain
cases,  the  wastewater treatment sludge can  also  be  reduced, e.g., the  sludge
resulting  from coprecipitation of toxic metal hydroxides  together with  the calcium
and magnesium  hydroxides.
                                      3-29

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     Observation #8

     In  a chemical  process,  catalyst  use and  reactor design  appear to have  the
strongest potential  impact  on  waste  generation.  Improved  catalyst  selectivity,
along  with optimum  reactor  design  (or reaction strategy, such  as temperature
trajectory for batch reactors),  directly affects  the amount of byproduct  formation.
The  byproducts  form  a  waste  stream  which  typically  exits  the process  in  the
separation section,  e.g.,  as  distillation  column  bottoms.   Advances in catalysis
science  and application  together  with advances in  kinetics  and  applied  reactor
design methodology have been particularly intensive in the last 15 years.

     Because catalyst and reactor characteristics are often critical  to  product  yield,
(and  thus  to  the  profitability of  the  operation),  they  are  usually  considered
proprietary.

     Observation #9

     Product substitution  is  an  extremely  complex  and   sensitive  issue.   Full
assessment  of  any product substitution alternative  must address,'at the  very  least,
the following issues:
     •   Technical feasibility — i.e.,  a substitute  must provide the same function as
        or better function than an original product.
     •   Environmental  feasibility  —   i.e.,  comparison  of  wastes  and  emissions
        associated  with  the substitute's manufacture and  disposal  to  that of  the
        original product must clearly favor the substitute.
    Both quantity and type of wastes and emissions should  be  considered, along with
the comparative lifetimes  of  the  original product and  its proposed  substitute.  In
addition, these  substitutions should  be feasible  from  a  socioeconomic standpoint
(increased  costs compatible with net environmental benefit).  Finally, where direct
government intervention  is involved, implementation approaches  should  not violate
the principles governing the functioning of a free market economy.
                                      3-30

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                        4.  WASTE RECYCLING PROFILE

    This chapter  discusses both  the  concept and  practice of  recycling  hazardous
wastes  in the United  States.  The focus of this chapter is  on  a characterization of
recycling  practices  including  identification  of   participating  industries,   waste
streams  recycled,  and  frequently   employed   recycling  technologies.  Offsite
recycling options and the future extent of recycling are also discussed.

    Section 4.1  presents a brief characterization  and examples of  waste recycling
practices.  Section 4.2 addresses  patterns  of recycling  in  the  United  States.  This
information is presented in  three ways:  industry-specific, waste stream-specific,
and technology-specific.  The  industry-specific  section summarizes the recycling
activities of  the  ten  highest  volume  hazardous   waste generators  and discusses
recycling  by  small quantity  generators  as a class.   The waste-specific  section
discusses the  types and  volumes of waste streams  that  are recycled  and those for
which there is limited or no potential  for recycling. The technology-specific section
includes a discussion of  the more commonly  used recycling technologies for various
categories  of wastes,  the costs associated with each category,  and the uses of the
recycled products.

    Section 4.3  describes the factors  involved with  offsite recycling.   The  options
discussed  in  this section include  commercial recycling  facilities, waste exchanges,
information exchanges,  material exchanges,  and other cooperative offsite recycling
arrangements.

    Section 4.4  discusses the future extent of recycling from  an economic point of
view.  This  includes a discussion of the incentives for  recycling produced  by  the
Hazardous  and Solid Waste  Amendments of 1984 (HSWA) and other economic factors
such as projected increases in feedstock and  fuel  costs,  raw material  shortages,
foreign  competition, and new technologies.

4.1        Characterization of Recycling Practices and Technologies

    Recycling of waste materials  can be characterized by three  major practices
(1) direct use  or reuse of the  material  in  a  process, (2) reclamation by recovering
                                       4-1

-------
secondary  materials for a separate end  use  (e.g., recovery  of  metal  from  sludge
material),  and  (3) removing  impurities  from  a  waste to obtain a  relatively pure,
reusable substance (e.g, removal of impurities from a cyanide plating bath solution
results  in a bath that can be reused).  The current extent of recycling  of hazardous
waste  by  U.S.  industries appears  to  be  minor in  comparison  with  other  waste
management  practices.  Less than  five  percent of hazardous  waste  generated  in
1981 was reported to be recycled or reused (RIA Mail Survey, generators 1981).

     This pattern of recycling has both industry-specific  and waste-stream specific
components.  Some  major industries are more  likely  to recycle than  others; that is,
they recycle a substantially larger  fraction of the  waste they generate.  Within an
industry category, some wastes are more likely to be recycled than  others (e.g.,
solvents more than pesticides), and the patterns of  onsite and offsite recycling vary
with the- size- of the- industry and the waste stream generated.

     The pattern of  recycling in the United States  is in fact predominantly an onsite
waste  management  practice, accomplished  either  by  using  the  waste  directly
without  prior  processing  or by reclaiming the  waste to recover constituent materials
that then  can be used directly.  Eighty-one  percent of  the volume of  hazardous
waste  recycled by  U.S.  industry  in  1981 (the  RIA  Mail  Survey  study  year) was
performed  onsite. However, the profile of recycling in the United States is changing
to  include  offsite  commercial recycling operations and direct transfers  of  waste
from generator companies to others who can reuse the waste.

Waste streams that  are recycled directly are  those that  can  be  used as ingredients
or  feedstocks in a  production  process  or as an  effective substitute for  a  raw
material. Examples of recovery of a product  to be returned to a  process include
(1) the  distillation  and  reuse  of  solvents as  equipment cleaning fluids by offsite
commercial operations  and (2) the recycling  of pesticide  dusts  collected  in  bag
filters during  product  formulation  (an  onsite  recycling operation).  Ferric  chloride
waste from the titanium dioxide manufacturing process (chloride route)  is reused as
a feedstock in water treatment,  thus  serving as an effective substitute  for a raw
material in another process.
                                       4-2

-------
    In order to be reusable,  recycled wastes must have the functional  properties of
the virgin  material.  Waste streams  that  are high in impurities  or  that  are not
amenable for direct reuse must  be  processed to recover  the  materials of value.
Some wastes can be recycled only after their hazardous constituents  are removed.
The type of reclamation  processes used are dictated by the type of waste  and the
nature of contamination.  Reclamation  processes fall into the following  categories:
        Chemical separation (e.g., distillation);
        Physical  separation (e.g., ultra filtration and reverse osmosis); and
        Electrochemical separation (e.g., electrolysis).
     Manufacturing  byproducts  or  secondary  recovery  products  also  may  be
reclaimed  from process wastes.  One  example is  the recovery  of hydrochloric acid
by scrubbing of combustion gases during thermal destruction of chlorinated organic
wastes.  The  recycling  value of organic wastes  may  also  include thermal  energy
recovered  during combustion, if 60 percent  of the potential  energy  in  the  waste is
recovered   as   heat   and   75 percent   of   the  recovered   heat  is  actually  used
(40 CFR 261.6).

4.2       Current Extent of Recycling

     This section examines the occurrence of hazardous waste recycling  according to
the  type of industry  that generated the recycled waste, and also according to the
types of waste streams recycled.  A brief sketch of available recycling technologies
and  their relative costs is presented.

4.2.1     Industry-Specific Profile

     The pattern of recycling in the United States varies with  the type and size of
the industries involved.  The industry-specific profile below  characterizes recycling
by U.S. industries according to  the fraction of each industry's waste that is recycled
and  the distribution among industries of the total volume of  waste that is recycled.
Patterns of recycling that are unique  to small quantity generators are identified.
This information was derived largely from  the RIA Mail Survey data base and from
an analysis of those data by Westat (1984). Additional data on recycling  by small
                                       4-3

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generators were obtained from the  1984  National Small  Quantity  Hazardous Waste
Generator Survey (Ruder et al. 1985).

     Of the 42 billion gallons (159  billion  metric tons) of hazardous waste  generated
by U.S. industries in 1981  (RIA Mail Survey, generators 1981), 1,575 million gallons
(6 million metric tons) or approximately  4  percent  were recycled.  Table 4-1  lists
the  volumes  of hazardous waste generated  and recycled  in 1981 by the ten highest
volume hazardous waste generators, subdivided  into the fractions recycled  onsite or
offsite.  The volume recycled  offsite  by  each industry  is  further divided into (1) the
volume of wastes recycled offsite  by the  same  firm that generated the wastes  and
(2) the volume  recycled offsite by  other firms.   Note that Table 4-1 does not reflect
the  volumes of wastes handled by  management practices other  than   recycling.
These  data  suggest that the volume  of  waste recycled  onsite  by a  generator
increases with  the  total volume of waste recycled.  That is, industries that recycle
large volumes of wastes are more likely to do so onsite than offsite.

     Figure 4-1  illustrates the information  provided in Table 4-1.  Among the  high
volume generators,  there  is a notable variance  from  the average  of  4 percent  of
waste  recycled  for  all   SICs.  The  Transportation Equipment  industry (SIC 37)
recycled 900 M  gals, 39 percent of their  total waste, over twice the volume of  the
largest generator  (Chemicals  and  Allied  Products industry  (SIC 28) at 340 M  gals
(1.2  percent)  recycled). This pattern is consistent with the types of waste generated
during  motor  vehicle  manufacture,  namely,  metal  cleaning  (degreasing)  wastes,
electroplafirrg wastes, and other product fabrication wastes.  These  wastes  are often
dilute  and uniform  in constituents, and, therefore, may be easier to  reprocess than
many of the organic sludges and still bottoms generated by the Chemical and Allied
Products  industries (SIC  28).  Of the remaining high  volume  generators,  only  the
Motor  Freight  Transportation  and  Warehousing industry generators did not report
recycling  some  portion of hazardous  waste  generated.  In actuality, although some
spent halogenated and nonhalogenated solvents  generated by SIC 42 industries were
recycled at  TSD facilities during  1981, no  SIC 42 generators reported recycling  of
their hazardous wastes in the RIA Generator Mail Survey.
                                      4-4

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                                                                             Table 4-1   Ten Highest Volume Waste Generating Industries  -
                                                                                          Generation and Recycling Volumes  During 1981
-f=»
 I
O1


SIC
26

35

37
42



Industry
Chemicals and Allied
Products
Machinery - Except
Electrical
Transportation Equipment
Motor Freight
Transportation
Volume of waste
generated
M gals

28,000

4,200
2,300

1.700

Total volume
M gals

340

26
900

NR"

recycled
(Percent3)

(1.2)

(0.6)
(39)


Volume
recycled
onsi te
M gals

300

18
880

NR"
(Percent3)

(1.1)

(0.4)
(38)


Volume recycled
offsite
M gals (Percent3)

32 (0.1)

7.9 0.2
22 (0.9)

NR"
Volume recycled
offsite by same firm
M gals (Percent3)

0.4 (< 0.1)

< 0.1 < 0 1
NR"

NR"
Vol unte
offsite
M gals

31

7.9
22

NR"
recycled
by other t i nn
(Percent3)

(0 1)

(0.2)
(0.9)


     29

     Hi

     17
Petroleum and Coal Products      1,300

Primary Metal Industries         1,000

Construction - Special
   Trade Contractors               870

Fabricated Metal  Products          820

Electric and Electronic
   Equipment                       670

Electric,  Gas,  and
   Sanitary Services               470
   (includes POTHs)
 36

170


  0.2

 24


 47


  3 3
  (2.8)

 (17)


«  0.1)

  (2.9)


  (7.0)


  (0.7)
32

18


 0.1

14


 0.4


 0.1
  (2.5)

  (1.8)


« 0.1)

  (1.7)


  (0.1)


« 0.1)
  4.2       (O.i)

150        (15)
                                                                                                                     46
                                                                                                                      3 2
 0.2      (< 0 1)

NR"
                                                                                                                      0.1      (<  0.1)        NR"

                                                                                                                      9.6        (1.2)         0.9        (0.1)
                                                                                                                                (6.9)       <  0.1
                                                                                                                                                       <  0.1
  4 0

150


  0.1

  8 7


 4b
                                                                                                                                (0.7)       <  0.1       (<  0  I)
  (0  1)

 (15)


«  0.1)

  (1.1)


  ( b . '>)


  (0  7)
    3 Percent of total waste generated (by SIC).
    Source:   RIA Generator Survey data.
    NK' - No recycling of this type reported in RIA Generator Survey.

-------
       SIC
CT.
28


35


37


42


29


33


17


34


36


49
                               500                1,000               1,500              2,000
               I  I  I  I  I  I  I  I  I  I  I  I  i  I  I  I  I  I  I  I  I  I  I I  I  I  I  I  I  I  I  I  I  f  I  I  I  I  I  I
              psssssssssssas^^
             >WgS$$$$SS^$SS^
              ps^$^^^*^^
                                                                        28,000  MGAL

                                                                4,200 MGAL


                                                         2,700 MGAL
             SSSSSSSSSSSSSSS^^
             ^^•——^_  W^f-^r^-T^f^^*
              jWSSSSSgSSSSSg^^
                                                   Volume Generated
                                                                                                Volume Recycled
             fSSSSSSSSS^^
                   {47 MGAL |
                  J3.3MGAU
             I  I  I  I  I  I  I  I I  I  I  I I  I  I   I  I  I t  I I  I  I  I  I  I  I  I  I  I  I  I  I  I  I  I  I  I  I  I  I
                        500
    SIC
           Industries
     1,000

VOLUME (M GALS)
1,500
                                                                                          2,000
     28  Chemicals and Allied Products
     35  Machinery, Except Electrical
     37  Transportation  Equipment
     42  Motor Freight Transportation
     29  Petroleum and Coal Products
     33  Primary  Metal Industries
     17  Construction, Special Trade Contractors
     34  Fabricated Metal Products
     36  Electric  and Electronic Equipment
     49  Electric,  Gas and Sanjtary  Services
     Source: RIA Generator Survey
     * No recycling by generators was reported in RIA Generator Survey.
                                         figure 4 - 1    Comparison of Volyme  Generated and Volume Recycled in  1981
                                               by  the Ten Highest  Volume Hazardous Waste Generating Industries

-------
    Figure 4-2 illustrates the percentage of the  total volume  of  hazardous waste
generated that was recycled during 1981 by  individual  SICs.  Three  manufacturing
industries,  the Transportation Equipment industry (SIC 37), the Chemicals and Allied
Products industry (SIC 28), and the Primary  Metals industry (SIC 33), accounted for
89 percent  of  the total volume of hazardous  waste recycled in the  United States in
1981 (RIA Mail Survey, generators).

Small Quantity Generators (SQGs)

    Offsite recycling accounted  for the disposition of approximately 65 percent of
the hazardous waste  generated  by  SQGs  during  1984.  Another  6 percent  was
estimated  to be recycled onsite (Ruder  et  al.   1985).  (These  numbers reflect  an
overlap with other  management practices including onsite  disposal  in public sewers,
waste treatment, and offsite disposal.)

    Recycling is favored  by SQGs over disposal for wastes shipped offsite (Ruder et
al.  1985).  Those SQGs generating more  than 100 kg/month of hazardous waste were
more likely to recycle their wastes  than  the smaller SQGs.  Furthermore, the  larger
the volume of waste generated by the SQG, the more likely it  was that the  waste
was shipped offsite  (Ruder  et  al.   1985).   These  data   suggest  an  inability  or
unwillingness of SQGs to  manage  large volumes of waste onsite.  This  pattern for
SQGs is unlike that observed  for large quantity generator industries that are more
likely to recycle larger volumes of wastes onsite than offsite (see Table 4-1).

4.2.2     Waste-Specific  Profile

    The distribution of hazardous waste recycling as a function of the waste stream
may be calculated either from the total volumes  of  waste streams recycled or from
the constituent concentrations of those waste  streams.

    The following distribution of the  total volume of waste recycled during  1981 is
based on volume data recorded for five major hazardous waste categories:
                                      4-7

-------
22%
                                        SIC  33  Primary Metals]
                                        (170  MGal}
                                         11%
                                                                      Other SICs
                                                                      (170 MGals)
         SIC 28 Chemicals
         and Allied  Products
         (340  MGal)
                                   SIC  37
                                   Transportation
                                   Equipment  (900 MGal)
                                                      57%
  Figure  4-2  Distribution of the Total Volume* of Hazardous  Waste
                Recycled During 1981, by  SIC  Category


                          Source •. RIA Generator Survey
            'Total Volume of Hazardous Waste Recycled in 1981 was 1580 M Gal
                                         4-8

-------
                                   Waste Categories
      24%           Solvents(halogenated and nonhalogenated)
    <0.1%           Halogenated (nonsolvent) waste
      28%           Metal-bearing wastes
      29%           Corrosive wastes
      20%           Cyanide reactive wastes
     100%
    Some  wastes have  characteristics  of more  than  one  waste  category.   For
example,  the  volume  of metal-bearing  wastes is underestimated  because pickle
liquor is included (for  the purposes of counting)  as a corrosive  waste rather than a
metal-bearing waste.

    More  detailed  volume  data  on  specific  wast-e  streams  are presented in
Table 4-2, which lists  the highest waste volume for  each of the five major waste
categories that were  recycled during  1981 either onsite or offsite.  These waste
streams are identified  by RCRA waste codes (40 CFR 261.31) and, in  some cases, by
mixture codes (e.g., XOOO.  The mixture codes were developed by Westat (1984) to
describe waste  streams consisting of mixtures of two or more RCRA wastes.

    Waste streams recycled  onsite during 1981 in  volumes higher  than  or  equal to
100 M gal included:
    •   D007 - chromium waste;
    •   D002 - corrosivity characteristic waste; and
    •   F006 - wastewater  treatment   sludges  from   electroplating  operations
               (classified as a cyanide/reactive waste).
The only waste recycled offsite in a volume higher than  100 M gal was K062 - pickle
liquor (classified as a corrosive waste).  These  four wastes account for 49 percent of
the total  volume of waste  recycled  in  1981  (excluding  wastes for  which no  RCRA
waste code was given).

    Large  volume metal-bearing waste  streams (excluding  pickle liquor) that were
recycled during  1981  were  handled  offsite.   Such  wastes are typical  of plating
solutions,  rinse waters, and sludges generated and  recycled  by the Transportation
Equipment (SIC 37) and Primary Metals  (SIC 33) industries.  Slop oil emulsion solids

                                       4-9

-------
)421s
                                                                          Table 4-2  Wastes Recycled During  1981
Description of WESTAT
waste stream waste code'
Solvent wastes
Spent nonhalogenated
solvents
Igni table solid waste
Spent halogenated solvents
used in degreasing
Spent nonhalogenated solvents
Spent nonhalogenated solvents X002
Heavy ends form the distil-
lation of ethylene
di chloride in ethylene
dichloride production
Spent halogenated solvents X001
Spent halogenated and non- X018
halogenated solvents
•f" Heavy ends from dis-
i— • ti nation of ethylene
° dichloride (ethylene
dichloride production);
heavy ends from dis-
tillation of vinyl
chloride (vinyl chloride
monomer production) X084
Acetone
Ethyl acetate
Metal -bearing wastes
Chromium
Lead
Slop oil emulsion solids
(petroleum refining)
Dissolved air flotation float
(petroleum refining)
Emission control dust/sludge
from primary production of
steel in electric furnaces
Emission control dust/sludge
from secondary lead smelting
Haste category
RCRA Volume recycled Volume recycled Total volume Halogenated Metals Corrosives Cyanide/
waste code onsite (mgal) (I) offsite (mgal) (t) recycled (mgal) Solvents (nonsolvent) reactives
orqanics

F005 84 (86) 13 (14) 97 X

0001* 37 (58) 26 (42) 63 X
F001 10 (24) 32 (76) 42 X

F003 (O.J) (0.1) 17 (99.9) 17 X
mixture F003, F005 5.$ (40) 8 (60) 14 X



K019 NR 4 4 X
mixture F001. F002 0.] (2) 3.1 (98) 3.2 X
mixture F002,F003,F005 l.Q (32) 2.2 (68) 3.2 X








mixture K019, K020 NR 2.5 2.5 X
U002 1.8 (78) 0.5 (22) 2.3 X
U112 0.2 (77) (0.1) (23) 0.2 X

0007 470 (99) 0.3 (0.1) 470 X
0008 32.Q (66) 17 (34) 49 X

K049 40 (98) 0.8 (2) 40 X

K048 35 (97) 0.9 (3) 36 X


K061 11 (38) 18 (62) 29 X

K069 5.6 (56) 4.5 (44) 10 X

-------
                                                                                            Table 4-2  (continued)
 Description of
  Haste stream
  WESTAT             RCRA       Volume  recycled       Volume recycled           Total volume
waste code1        waste code     onsite  (mgal)   (t)  offsite  (mgal) (1)      recycled  (mgal)
                                                                                      Waste category
                                                                         Halogenated    Hetals   Corrosives  Cyanide/
                                                              Solvents  (nonsolvent)                         reactives
                                                             	oraanics	
 Metal-bearing wastes (continued)

 Mixture of barium,  cadmium,
   chromium, lead,  and
   mercury                      X039
 API separator sludge
   from petroleum refining;
   hexavalent  chromium and
   tead

 Ignitable solid waste

 Washes and sludges from
   ink  formulation

 Halogenated (nonsolvent)  orqanics

 Untreated process wastewater
             mixture of D005,DOOb,      9.5
                 0007,0008,0009
                     K051                7.2

                     D001*              4.3


                     K086              <0.1
Corrosivity-characteristic
  solid waste (not listed
  in Subpart 0)

Spent pickle liquor (steel
  finishing operations)

Ignitable solid waste

Sulfuric acid, thallium
  salt (1)

Cresylic acid
            (96)

            (90)
                                                                                           NR
0.3     (4)

0.5    (10)


2.4    (99)
   U054
                    0002


                    K062

                    D001*


                    PI15

                    U052
                                                                                                                 9.5
                                                4.8
                                                                                     2.4
from production of toxaphene
Lindane (1,2, 3,4,5, 6-hexachlorocy-
clohexane, gamma i saner)
CHlordane, tech.
p-Oichlorobenzene
Heptachlor
Pentachlorophenol P090
DDT
Corrosive wastes
K098

0013
U036
U072
P059
F027
U061

0.22 NR 0.22

NR 0.1 0.1
NR <0. 1 <0. 1
<0.1 NR <0.1
NR . <0.1 <0.1
<0.1 (20) <0.1 (80) <0.1
NR <0.1 <0.1

X

X
X
X
X
X
X

270         (88.5)       35     (11.5)         305


 28          (9.8)      260    '(90.2)         290

 71                       NR                   71


   NR                    1.6                    1.6

   NR                    1.2                    1.2

-------
                                                                                            Table 4-2 (continued)
Pescription of WESTAT
waste stream waste code'
peactive characteristic
waste
Corrosivity characteristic
waste containing lead X052
Chrysene
pis (2-ethylhexyl) phthalate
Cyanide/reactives
Wastewater treatment sludges
from electroplating
operations
Reactive characteristic waste
Spent plating bath solutions
from electroplating operations
Spent stripping and cleaning
bath from electroplating
Ammonia still lime sludge from
cok i ng
Sodium cyanide
Still bottoms from final
purification of acrylonitrile
Plating bath sludges from
electroplating
Cyanides
Jgni table solid waste
Waste category
RCRA Volume recypled Volume recycled Total volume Halogenated Metals Corrosives Cyanide/
waste code onsite (mgal) (t) offsite (mgal) (t) recycled (mgal) Solvents (nonsolvent) reactives
	 	 	 	 	 	 oraanics
0003* 0.7 NR 0.7 0.7


mixture of 0002, 0008 0.4 NR 0.4 0.4
K050 0.3 (99) ( 0.1) 0.3 0.3
U028 NR 0.1 0.1 0.1



F006 430 (96) 19 (4) 449
0003* 18 (98) 0 3 (2) 18

F007 3.3 (72) 1.3 (28) 4.6

F009 0.6 (33) 1.1 (67) 1.7

K060 1.3 NR 1.3
P106 NR 0.5 0.5

K012 0.2 NR 0.2

F008 0.1 (24) 0.2 (76) 0.3
P030 <0.1 (80) <0.1 (20) <0.l
0001* NR 0.1 0.1
X


X
X
X



x
X

x

x

x
X

x

x
X
X
'source:  RIA Hail Survey (TSD and Generator Surveys).




*tisted in more than one waste category.




NR = Not reported.

-------
and other metal-bearing wastes from petroleum refining (SIC 29) were  also recycled
onsite.  Metal wastes recycled offsite were  K061 (emission control dust/sludge from
primary production of steel in electric  furnaces)  and K086 (washes and sludges from
ink formulation).

    Wastewater  treatment sludges from  electroplating operations  (F006)  account
for over 90 percent of the volume  of cyanide/reactive waste recycled during  1981.
Reactive  characteristic  wastes  (D003)  and  spent  plating bath  solutions  from
electroplating  operations  (F007)  account  for  another   9   percent   of  the
cyanide/reactive  wastes recycled.  Ninety-five percent of recycled cyanide/reactive
wastes were managed onsite.

    During 1981  the Chemicals and  Allied  Products industries (SIC 28) recycled
74 percent of the total halogenated and nonhalogenated solvents that were recycled
in that  year  (RIA Mail  Survey); 65  percent were SIC 28 wastes recycled onsite and
another 9 percent were SIC 28 wastes recycled offsite (RIA Mail Survey).  The metal
finishing industries (SICs 33 to 37) recycled another 22 percent of the solvent wastes
that were recycled, with an  even distribution between onsite and offsite recycling.
The relatively low volume  of halogenated  (nonsolvent) organics  recycled  can  be
explained  by  the  low  recovery  value  of  those  wastes.  Of  the  halogenated
(nonsolvent) organic wastes that were recycled, 48 percent were recycled onsite and
52 percent were recycled offsite (RIA Mail Survey).

    Ignitable  solid waste  (D001),  distributed   among  the  solvent,  metals,  and
corrosive waste  categories,  accounted  for almost 5 percent of all  waste  streams
reported  to  be  recycled  during  1981.   Approximately  one-half  of all recycled
ignitable  solid  wastes  reported  were solvents.  Although  the  constituents of these
waste   streams were  not reported  in  the  RIA  Mail Survey,  it  is  known that
reclamation still  bottoms and other unrecyclable solvent  wastes  are  used for heat
recovery in industrial boilers.

    A  waste-specific  profile of recycling may  also be drawn from  examination of
the constituent  concentrations of hazardous waste  streams managed  by   various
practices.  Weighted  average  concentrations  of  constituents in  waste  streams
managed  by recovery/reuse (recycling)  practices were  calculated from data  stored
                                      4-13

-------
in EPA's Industrial Studies Data Base (ISDB).  (Appendix A provides a  description of
this data base.)  These data, which represent management practices of the Chemical
and Allied  Products  (SIC 28) industries  only, are illustrated in  Figures 4-3  through
4-9.  The weighted average concentration is calculated by the following equation:

                               CW=[I(CC-CV)]/ICV
Where
               Cw = weighted  average concentrations;
               Cc = constituent concentration (weight %); and
               Cv = constituent waste stream volume.
    The figures  illustrating  the   management of  waste  streams  that  contain
halogenated  and nonhalogenated  solvents,  halogenated organics,  corrosives,  or
cyanide/reactive wastes (Figures 4-4, 4-5, 4-8,  and  4-9, respectively) indicate  that
the higher  the weighted average  concentration  of  those  constituent  wastes  in a
waste  stream, the more probable  the selection  of recovery/reuse as a management
option.  The difference between the weighted average concentrations of corrosive
(Figure 4-8) or cyanide/reactive (Figure  4-9) wastes managed by recovery/reuse and
other management options was  less than  5 percent.  These suggest  a threshold level
for recycling  between  1  and 5 percent weighted average  concentration  for those
constituent  wastes.   Nonhalogenated  solvents  have  a  similar  profile, with an
apparent threshold level for recycling  between  1 and  9 percent  weighted average
concentration.

    The weighted  average  concentrations  for constituent  halogenated  solvent
wastes  (Figure  4-5)  and   halogenated  organic  wastes  (Figure 4-7)   that  are
recovered/reused are much  higher (37 to 42 percent) than those of nonhalogenated
wastes  and  much  higher than  the  weighted  average concentrations of halogenated
waste  streams  managed  by  other practices.   Metal  constituent waste  streams
(Figure 4-6) apparently are  not handled in any substantial volume by the SIC 28
industries.   The  weighted  metal  constituent  concentrations  of  waste  streams
managed by any practice in SIC 28 are, according to  the ISDB data, several orders of
magnitude lower than those values  for other constituents.
                                     4-14

-------
              c
              o
              0)
              o
              c
              o
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              d>
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45%

40%

35%
30%
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-------
                       1%   2%   3%    4%    5%    6%    7%    8%   9%   10%


Recovery/
Reuse
Onsite
Wastewater
Treatment
O
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'•£ Treatment of
55 Organics
>_
Q.
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                   0    1%   2%   3%    4%   5%    6%    7%    8%    9%   10%
                                  Weighted Average  Concentration
              Figure  4-4 Weighted  Average Concentration of  Nonhalogenated
                 Solvent Wastes  Handled by Various Management  Practices
                   in the Chemical and  Allied  Products Industries  (SIC 28)
Weighted Average Concentrations
2 [(Constituent Concentration, (Weight %)) x
 (Constituent Waste Stream Volume)] +
Z (Constituent Waste Stream Volume)
 Source: Industrial Studies Data Base
                                              4-16

-------
c
Recovery/
Reuse
Onsite
Wastewater
Treatment
O
0
"•^ Treatment of

-------
                         0.0050%   0.0100%   0.0150%   0.0200%   0.0250%   0.0300%


Recovery/
Reuse
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1
                                   Weighted Average Concentration

           Figure  4-6 Weighted Average Concentration of  Metal  Wastes  Handled
           by Various Management  Practices  in the Chemical  and  Allied Products
                                        Industries  (SIC 28)
Weighted Average Concentration
E [(Constituent Concentration, (Weight %)) x
 (Constituent Waste Stream Volume)] +
2 (Constituent Waste Stream Volume)
 Source: Industrial Studies Data Base
                                              4-18

-------
                         5%      10%     15%    20%     25%   30%     35%    40%


Recovery/
Reuse
__
Onsite
Wastewater
Treatment
0
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to Drganics
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                   0      5%      10%    15%    20%    25%   30%    35%   40%
                                  Weighted Average Concentration

                Figure  4-7 Weighted Average  Concentration  of  Halogenated
              (Non-Solvent) Organic  Wastes  for  Various Management Practices
                   in the Chemical and  Allied Products  Industries  (SIC 28)
Weighted Average Concentration=
I [(Constituent Concentration, (Weight %)) x
 (Constituent Waste Stream Volume)] +
2 (Constituent Waste Stream Volume)
 Source: Industrial Studies Data Base
                                              4-19

-------
                            1%
2%
                                                 3%
                    4%
                                                                     5%

Recovery/
Reuse
Onsite
Wastewater

Treatment
—
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Organics
0
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                                      2%
          3%
                                                          4%
                              5%
                                                                              6%
                                   Weighted Average  Concentration
         Figure  4-8 Weighted Average Concentration  of Corrosive  Wastes  Handled
                           by Various  Management  Practices  in the
                       Chemical and  Allied  Products Industries (SIC 28)
Weighted Average Concentrations
S [(Constituent Concentration, (Weight %)) x
 (Constituent Waste Stream Volume)] +
I (Constituent Waste Stream Volume)
                                              4-20
 Source: Industrial Studies Data Base

-------
                         1%
2%
3%
4%
5%
6%
7%
8%

Recovery/
Reuse
Onsite
Wastewater
Treatment
O
O
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(5 Drganics
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                         1%      2%      3%     4%      5%     6%
                                   Weighted Average Concentration
                                      7%
                                     8%
              Figure  4-9 Weighted Average  Concentration  of Cyanide/  Reactive
          Wastes Handled by  Various Management Practices in the Chemical and
                               Allied  Products  Industries (SIC 28)
Weighted Average Concentrations
I [(Constituent Concentration, (Weight %))
 (Constituent Waste Stream Volume)] +
I (Constituent Waste Stream Volume)
             4-21
 Source: Industrial Studies Data Base

-------
Wastes Unlikely to Be  Recycled

     Some production processes result in unwanted byproducts which are rarelv  used
in any  manufacturing  or  processing  operations.  For  example, the residues from
waste  solvent distillation  processes  are  concentrates  of  the  same  nonvolatile
contaminants or  impurities present in the original waste stream.  These impurities
generally are unwanted since  there is no  use  for  them  in any  production  process
except for heat recovery in boilers or incinerators.

     Table 4-3 presents a summary of  RCRA F- and K-code wastes (40 CFR 261.31.)
that have limited or no potential for reuse. Because of their limited potential use.
source reduction  may  be  the appropriate  waste  minimization  strategy  for  these
waste streams.

4.2.3     Recycling Technology Profile

     Recycling technologies are easily categorized  according  to  the  type of waste
treated.  There are, however, some  overlaps in technology applications, such as the
application  of centrifugatiorv to  phase separations  of  both  inorganic  and  organic
wastes.  Categories of waste recycling technologies identified for this report include:
          Solvent waste recycling technologies;
          Halogenated organic (nonsolvent) recycling technologies;
          Metal-bearing waste recycling technologies;
          Corrosive waste recycling technologies; and
          Cyanide and reactive waste recycling technologies.
    The following  discussion describes applications  of the more commonly used
recycling  technologies for  each category  of  waste,  the  costs  associated with
different unit operations falling under each category, and the uses of the recycled
products.  A profile of each category of technologies is presented  in Appendix C-l
through C-5.
                                      4-22

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                                    Table 4-3  F- and K-Code Wastes Unlikely to Be Recycled in Significant Volumes
  EPA waste code
                             Waste
                                                                       Reason for limited or nd recycling
F007, F008, and F009

F010, F011, and F012
F020, F021, F022,
  F023, F026, F027,
  and F028

K002 - K005
-e»  K007
oo

    K011


    K013
Spent cyanide plating solutions

Spent cyanides containing metal
  treating solutions

Polychlorinated aromatic wastes
                         Treatment sludges from chrome
                           pigments production

                         Sludges from iron blue production
                         Bottoms from acrylonitrile
                           production

                         Bottoms from acetonitrile
                                                                      CN content is usually destroyed before recycle is attempted.

                                                                      No metals of value to recover.


                                                                      Likely to contain dioxins.
                                         Contain both trivalent chromium hydroxide and varying amounts of heavy metal
                                         chromate salts which are not easily reducible or separable.

                                         These contain iron blue (iron ferrocyanide)  in addition to other insoluble iron
                                         compounds.   The ferrocyanide is not easily destructible.

                                         Wastes are  higher molecular weight cyanides:   not useful  in  a production process.
                                         Only  option for recycling is burning for fuel value.

                                         Same  as above.
K014
K015
Purification wastes from
  acetonitrile

Still  bottoms from benzyl
  chloride
                                                                  Same as above.
                                                                  Contains polyhalogenated aromatics of little value.

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    1212s
                                                                     Table  4-3  (continued)
      EPA waste code
    Waste
                                                                           Reason for limited or no recycling
    K016 to K020


    K022

    K024

    K027


    K095-96 and K030
i
r>o  K105
    K073
    K031
    K032, K033, K034, &
      K097

    K041, K098, K042,
      K043,and K099

    K044 to K046

    K084, K101, and K102
Still bottoms from chlorinated
  aliphati cs

Tars from phenol production

Tars from phthalic acid production

Residues from toluene diisocyanate
  production

Still bottoms from
  1,1,1-tri chloroethane

Aqueous wastes from chlorobenzene
  production

Chlorinated hydrocarbons from
  chlorine products

Wastes from arseno-pesticides

Wastes from chlorinated pesticides
Contains higher molecular weight polyhalogenated materials of  little value.


Except for its fuel value, of no value as a  feedstock.

Same as above.

Polymeric isocyanates useful only for fuel.


Contains higher molecular weight polyhalogenated materials of  little value.


May contain low levels of dioxins.


Contains polyhalogenated materials of little value.


Contains unwanted organparsenates.

Contains polyhalogenated materials of little value; may also contain dioxins.
Wastes from chlorinated pesticides        Likely  to  be  contaminated  with  dioxins.
Explosives wastes

Pharmaceutical  wastes
Safety considerations limit reuse.

Unwanted arsenic-containing byproducts limit reuse.
    Source:  U.S. Environmental Protection Agency 1980 RCRA Background  Listing Document.

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Solvent Recycling

    Solvent  recycling  is  achieved primarily by  distillation of  pure  solvent  from
spent solvent wastes le.g., those  generated during  degreasing  or other equipment
cleaning operations).  Other types of unit  operations used to recover solvents  from
emulsions, dispersions,  or other complex  solvent wastes  include:  solids  removal,
liquid-liquid  separation  techniques,  emulsion/dispersion   breaking,  dissolved  and
emulsified organics  recovery, and  organic  vapor recovery.   Further  information on
solvent recycling technologies is presented  in Appendix C-l.

    Technical  criteria  for selection of  technologies for  the  recycling of solvent
wastes include  the phase and concentration of the solvent, types and concentrations
of  contaminants in   the  solvent,   and  recycled   product purity  requirements.
Segregation of waste streams is an important first step in  solvent waste recovery.
Whenever  solvent   wastes (or  other  organic  wastes) are recycled  for  process
applications,  purity requirements dictate  that the  individual  constituents  be
segregated to the maximum extent possible, at  every step  of use in  the generator's
facility until recovered at the reclaimer's facility. The importance of waste stream
segregation is illustrated by the following examples:

    •   Mixed  solvents  with   close  boiling  points  (e.g.,  a  solvent   mixture of
        1,1,1-trichloroethane  (TCA)  and  1,1,1-trichloroethylene  (TCE)) cannot be
        reclaimed by pat distillation.  Although recovered  TCA  or  recovered TCE
        may be sold  for over $2.00  per gallon, a recovered mixture of these solvents
        is worthless.
    «   If  solvent wastes are  to  be used for  fuel,  care  must  be  taken  to  avoid
        contamination  with certain constituents such as inorganic chlorides, PCBs,
        or other  highly chlorinated organics that could render the solvent unusable.
        For mixed solvent wastes, parallel separation and  recovery operations  may
        be required  to maximize the value of the recovered constituents.

    The general ranking  of capital and operating/maintenance  costs  for solvent
recovery technologies is shown in Table 4-4 and discussed below.

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             1227s
                                              Table 4-4  Ranges of Costs for Technologies Used
                                                   for Recovery and Recycling of Solvents
             Technology
                                            Capital  costs3
                                       Low       Medium      High
Operating and maintenance costs'5
    Low      Medium     High
ro
01
Solids removal

  Gravity sedimentation
  Fi1tration
  Centri fugation

Liquid-liquid phase separation

  Decant tank
  API  separator
  Tilted-plate separator

Emulsion/dispersion breaking

  Coalescer
  Centri fuge
  Chemical  de-emulsifying
   agents
  Air  flotation equipment
   (dissolved or diffused)
             Dissolved & emulsified organics recovery

               Steam or air stripping
               Carbon adsorption
               Solvent extraction
               Supercritical fluid
                extraction
               Membrane separation
                (ultrafi 1 tration, reverse
                osmosis)

-------
              1227s
                                                           Table 4-4  (continued)
             Technology
                                         Capital costs3
                                     Low      Medium     High
Operating and maintenance costs"
    Low      Medium     High
             Organic vapor  recovery

               Condensation  (cooling
                water,  chilled water,
                refrigeration)
               Carbon adsorption

             Distillation
ro
Pot distillation
Steam distillation
Fractional distillation
Film evaporation
 (wiped, scraped)
Dryer (double-drum or
 other)
                                                     *          •
                                                     *          •
             a Total  installed cost ranges for commercial-sized units are broadly classified as follows:  Low - under
               $25,000; Medium - $25,000 to $250,000; High - over $250,000.

               Operating and maintenance costs - direct costs for chemicals, utilities (steam, cooling water, electricity)
               and/or direct labor are broadly classified as follows:  Low - passive, no specific requirements, direct costs
               under $0.02/ga1; Medium - requires varying operating and maintenance labor and/or moderate chemicals or
               utilities, direct costs approximately $0.02 - $0.40/gal; High - requires skilled operators, lab support,
               frequent maintenance, and/or high chemtcal or utility costs, direct costs approximately $0.40/gal or over.

-------
     Distillation  is  a widely  used technology  for solvent recovery.   Commercial

recycling  operations  often  use  some  type  of  distillation for solvent reclamation.

Applications of some distillation unit  operations are explained below.  Each of the
operations also is discussed in  detail in Appendix C-l.


     •  Pot  distillation is used  to reclaim  halogenated as well as  nonhalogenated
        solvents   from  wastes.   For  example, acetone  used as  a  paint  cleaner
        commonly is  recovered from  nonvolatile  oils,  resins, and  pigments, by pot
        distillation.

        Thre offsite  charge for pot distillation  is typically  $0.50 to $1.00 per gallon,
        and  disposal  costs  for  pot bottoms may  be  additional, particularly if the
        waste stream has a low yield of recyclable organics.  The recovered product
        is  sold by commercial recyclers for  50  to  80 percent of virgin solvent prices
        with   purity   95 percent   or   higher  (personal   communication   with
        Mr. Donald L. Corey, Chemical Waste Management, Inc., Somersville, Mass.,
        August 9, 1985).  Lower  purity solvents and  some solvent  blends  may  be
        usable in limited applications at reduced prices.

     •  Steam distillation is applicable to the reclamation  of solvents that are water
        insoluble.  For such wastes, steam  injection  allows  the  distillation to  be
        performed at lower temperatures  than in pot distillation.

     •  There  is a   very  limited  market  for reclaiming  both  halogenated  and
        nonhalogenated  solvent  mixtures  using  fractional  distillation.  The capital
        cost  and  the  operating  costs  (energy  requirement per  gallon  of  recovered
        product)  are much higher than  with pot  distillation, and tend  to restrict this
        option only  to high-priced specialty solvents and to applications in which
        high  purity is required.  Much  of  this  recovery  by fractional distillation  is
        conducted on a toll basis for large volume generators of such waste.


     Super  critical fluid extraction (see Appendix C.I) is  a developmental  technology

with  no  commercial applications identified during this  study.  However,  substantial
energy savings over  pot  distillation and fractional  distillation  processes are  claimed
for supercritical  fluid extraction, with resulting operating costs as low as $0.10 per

gallon   (personal   communication   with    Donald    Corey,   Chemical   Waste

Management, Inc., Sommerville, Mass., August 9, 1985).


     Membrane  separation of  waste  solvent contaminants  (by  ultrafiltration and

reverse osmosis)  has been available commercially  for over 10 years,  and  its use has

increased steadily with  improvements  to  the process. Ultrafiltration is a membrane

separation  technique used by both onsite  and offsite recovery facilities to separate
                                       4-28

-------
large organic molecules  (contaminants)  from  low  molecular  weight  solvents.  One
onsite  facility is replacing an air flotation unit with an ultrafiltration system.  This
substitution  is  expected  to  lower  both  operating  and  maintenance  costs.   Total
operating costs  for an older ultrafiltration installation at the same facility are under
$0.05 per gallon  (personal  communication  with  Donald Corey,  Chemical  Waste
Management, Inc., Sommerville, Mass., August  9, 1985).

     Condensation  is  the  recovery  of  solvent   vapors  in  a  cooling  system.
Condensation can be used alone  (e.g.,  to recover volatile solvents  from storage
tanks)  or in conjunction with such unit operations as distillation, carbon adsorption,
and air or steam stripping.

     Heat  "Recovery  During  Combustion.    Solvent   wastes   that  are   highly
contaminated, contain  mixtures that are  difficult to fractionate, or are the residues
from reclamation  operations, commonly are blended and reused for their fuel  value.
The  physical properties of waste  solvent blends reused for fuel are  different from
those of conventional fuel oils.  In  particular,  they tend  to be  less viscous  and  to
have lower flash points.

     Combustion  units  that  can  accept  waste solvent  blends include  industrial
boilers,  blast furnaces,  light-weight aggregate kilns, cement kilns,  and  hazardous
waste  incinerators.  The  use  of  halogenated  solvent  wastes  or  waste  blends  in
incinerators  is  limited  to corrosion-resistant  combustion  systems because   of the
acid gas (e.g., HC1) produced during combustion.  When halogenated  solvent  wastes
are incinerated, the vent gases must be scrubbed to minimize acidic emissions.

     •   Industrial  boilers.  Combustion of solvent  wastes at destruction efficiencies
        of 99.99 percent  (required) or  higher can be performed in large  industrial
        boilers  (25 million  Btu/h  and  over), but  is  subject  to  RCRA and   other
        environmental  regulations.   Boilers  that   fire  intermittently   must  be
        modified to provide purge  cycles before and after firing  low-flash fuel  to
        avoid accidental pre- or post-ignition.   Currently, there are some permitted
        large industrial boilers combusting solvent  wastes.  Depending  on the quality
        of the  recycled solvent fuel,  the unit  value of solvent fuels combusted  in
        industrial  boilers  varies from  a  nominal charge  or credit  up to  $0.05 per
        pound for  high-quality recycled fuel.
                                      4-29

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    •   Blast furnaces.  Reuse  of  nonhalogenated solvents as fuel  or feedstock in
        blast furnaces represents a substantial  recycling  market, particularly on a
        regional basis in  the Midwest.   A patented  process, CHEM FUEL® (U.S.
        Patent  No. 4,443.251; Cadence  Chemicals), uses  a wide  range of  pigments,
        resins,  or solvent  discards,  including  still  bottoms, as  feedstock  or  to
        supplement coke in blast furnaces.

    •   Light-weight aggregate kilns. Nonhalogenated solvent wastes also are used
        as  fuel in  kilns for  manufacturing  light-weight aggregate (expanded  shale)
        used  in building  construction.   Depending  on  the  fuel quality, the  kiln
        operator charges suppliers as  low as $0.03 per pound, or gives them credit as
        high as $0.01 per pound, excluding taxes and the cost of transportation.

    *   Cement kilns and hazardous waste incinerators. Cement  kilns and  hazardous
        waste  incinerators  can reuse  solvent  waste  as a  supplementary  fuel.
        Cement kilns  can handle  moderate  levels of halogens  (up  to  10%), while
        hazardous waste  incinerators  can  handle higher  halogen   levels.   Unlike
        industrial  boilers,  kiln  and  incineration  burners  fire  continuously  and
        therefore can handle solvent fuels with only minor modifications.

    *•   Other  waste solvent  fuel  uses. Various  treatment  processes have  been
        developed to blend  and  react solvents with fuel  oil  and other  additives to
        produce a synthetic  fuel with properties comparable to conventional  fuel oil;
        solvents also are briquetted with sawdust  or other organic matter for use as
        a coal or coke substitute.  High treatment processing costs are offset by the
        savings  in  equipment  modifications  that  would  be required if  treatment
        processing were not used.
    Solvent  wastes  that  are  recycled  may  be  reused as  solvents, used  in  the

manufacture of other products, or used as  a  fuel  to  generate heat.  The following

are some cases that illustrate  the potential  for  onsite or offsite reuse of treated

solvents by individual facilities:


    •  Charleston NSY,  Charleston,  S.C., has constructed  a "flushing rig"  out of
       spare parts to remove impurities from refrigerant so it can be recirculated
       through the system (Higgins 1985);

    •  Solvent vapors are recovered by Rexham Corp., Matthews, N.C.,  and sold to
       the coating industry for  reuse (Kohl, Moses, and Triplett 1984);

    •  Southern Coatings,  Sumter, S.C.,  operates a continuous collection system
       for spent solvent that is distilled; the reclaimed solvent is  used primarily for
       cleanup (Kohl, Moses, and Triplett 1984);

    •  Bowling Co., Mt. Olive, N.C., distills spent  acetone for  reuse as a thinner
       (Kohl, Moses, and Triplett 1984); and
                                      4-30

-------
    •  Low-grade paint is manufactured using still bottoms from the recycling of
       spent solvents.  Chemical Recovery Systems, Romulus, Michigan  (Campbell
       and Glenn 1982).
Halogenated Organic (Nonsolvent) Waste Recycling

    Although  nonsolvent  halogenated  organic  wastes  account  for  only  a small
fraction  of recycled  wastes (<0.1  percent  in  1981), some waste streams that  are
recycled  include  process-generated  dusts and  off-specification  products from
pesticide  manufacture and formulation; still bottom  residues and sludges from  the
manufacture  of chlorinated organic compounds, degreasing operations, or  solvent
waste reclamation; a variety  of  liquid  waste  streams from  aqueous washing steps
and extractions during  product  manufacture; PCB-contaminated dielectric fluids;
and spent solutions from  treatment of wood  with halogenated preservatives.

    In chemical  manufacturing  and formulation facilities  (SIC 28),  recycling  of
wastewater  contaminated  with  halogenated  organics  eliminates  the expense  of
transporting large volumes of contaminated  water  to treatment or  disposal sites.
Feedstock recovery  processes incorporated  into organic  chemical  manufacturing
processes maximize efficiency and avoid disposal of valuable materials.

    A variety  of  unit operations  are  employed  to  recycle feedstocks  and spent
dielectric  fluids,  recover  secondary  products,  or  obtain heating  energy from
halogenated organic wastes. Some examples include the following:
    •   Pesticide  dusts  and  rinsewaters  are  typically  recycled  onsite,  where
        recovered materials  are  returned  to  the  manufacturing or  formulation
        process.
    •   Highly  chlorinated  still  bottoms  from  distillation  of  crude  halogenated
        solvents  may  be  chlorinated  to  produce   commercial   grade   carbon
        tetrachloride  (Versar   1975,  V/ersar  1980,  personal  communication  with
        Mr. John  Huguet, Ethyl Corporation, February 1980).
    •   Liquids,  sludges,  and  other  halogenated  organic  residues that cannot  be
        reclaimed can be used  as fuel in cement kilns, provided the waste fuel  does
        not exceed 10 percent  of the total fuel content (Stoddard et al. 1981).
                                     4-3;

-------
     •  PCB-contaminated  dielectric  fluids  are  reclaimed  by  state-of-the-art
        processes   that   remove   the    PCBs   by   solvent   extraction   with
        dimethylformamide or dechlorination with sodium compounds.
     •  Hydrochloric acid is  recovered  as a byproduct of  incineration of chlorinated
        organic  waste.  The acid  is recovered  by  scrubbing the combustion gases
        with water.  One use of the recovered acid is for (onsite) neutralization of
        alkaline  waste streams. Alternatively,  the  acid may  be concentrated  and
        then sold for reuse.
     Fees for offsite dechlorination  of  PCB-contaminated oils  range  from $1.80 to
$2.50 per gallon  of  waste  oil.  The  dechlorination  process  equipment  may  be
mounted on mobile equipment,  which can be moved by a vendor (or generator) from
site  to  site.  Availability of commercial  dechlorination facilities is discussed in
Section 4.3.   Dechlorination  is  effective  on wastes  contaminated with  PCBs at
concentrations  between   50  to  10,000 ppm.   At  concentrations  greater  than
10,000 ppm  (1 percent),  the  cost of  sodium reagent compares unfavorably with the
cost of incineration.  The charge for incineration  of organic  wastes currently  ranges
from approximately  $500  per  metric ton  for  liquid injection  incineration  to
approximately $1,200 per  metric  ton for rotary  kiln incineration (Pope  Reid  1986).
Higher rates are charged for halogenated organic wastes (Pope Reid 1986).

     Recycling and disposal  costs for other nonsolvent  halogenated organic  wastes
are  dependent primarily  on  the heating value and chlorine  content of the  waste.
Premiums may  be charged for high  concentrations of specific  contaminants (e.g.,
ash,  solids, or PCBs).  The  price of fuel with a good heating  value (over  100,000 Btu
per gallon) and 2  to 3 percent chlorine  varies from $20 per ton credit  to $20 per ton
charge delivered (taxes  and  transportation  not  included); the charge is higher for
wastes with a lower heating value, higher chlorine  content, and  other contaminants
(personal  communication  with  Donald Corey,  Chemical Waste Management, Inc.,
Sommerville, Mass., August 9, 1985).   The maximum halogen  loading  for  wastes to
be used  as  fuel is usually 5  to 10 percent.  (Further  information  on  halogenated
organics is presented  in Appendix C-2.)
                                      4-32

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Recycling of Metal-Bearing Wastes

    Toxic  metal-bearing wastes are hazardous wastes  containing significant  levels
of metals, and organic  and inorganic metal compounds.  Examples  of metal wastes
are alkali metals, mercury-bearing  sludges from chloralkali production, chromate-
and iron  cyanide-based pigments,  and  ferrous  chloride-based  pickle  liquor.  Iron
cyanide-based  pigments also  fall under  the  category  of  cyanide/reactive  wastes,
although they are not an EP  Toxic-category waste.  The pickle  liquor is a reactive
waste as well as  a metal waste.  Technologies used  for recovery  and recycling of
metal-bearing waste streams  include:
        Metal concentration processes;
        Metal reduction and recovery,
        Particulate and vapor recovery;
        Cyanide destruction; and
        Agglomeration techniques (not widely used).
    These  technologies  will   be   discussed   in   detail  because   recycling   of
metal-bearing  waste  streams  accounts  for  a  large  volume  of the  total  waste
recycled by U.S. industries.

Metal Concentration Techniques

    Metal concentration techniques have wide application in both onsite and  offsite
recycling operations  (e.g., recovery of metals  from plating and  finishing solutions).
Metal  concentration  techniques include  hydrometallurgical  processing  (leaching),
solvent   extraction,   ion   exchange,  precipitation,  crystallization,   calcination,
evaporation, membrane separation, adsorption,  and  foam flotation.  A great deal of
current  technological  work  is  focused  on methods to  economically  concentrate
metal compounds  into  a solution or sludge from a  bulk  solid  or  liquid  (personal
communication    with    Donald Corey,    Chemical   Waste    Management, Inc.,
Sommerville, Mass.,   August 9,  1985).     The    range   of   capital    costs    and
operating/maintenance   costs  for  metal recycling  techniques  is  presented  in
Table 4-5.  The  variety of  metal-bearing waste   streams  makes  generalization
difficult.  As  with other waste categories, segregation of metals during processing
and reclamation simplifies and improves the economics of metals recovery.
                                      4-33

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             1227s
                                              Table 4-5  Ranges of Costs for Technologies Used
                                                    for Recovery and Recycling of Metals
             Technology
                                       Low
Capital  costs3
    Medium     High
Operating and maintenance costs
    Low      Medium     High
-F=>
 i
oo
Metal  concentration processes

  Hydrometallurgical (leaching)
  Solvent extraction
  Ion exchange
  Precipi tation
  Crystal 1ization
  Calci nation
  Evaporation
  Membrane separation (reverse
   osmosis, electrodialysis)
  Adsorption
  Foam flotation
             Metal reduction and  recovery
               Electrolytic  recovery
               Sodium borohydride
               Reduction  furnaces
               Other reducing processes
             Particulate and vapor recovery

               Particulate recovery
               Selective adsorbents
               Wet scrubbers

-------
              1227s
                                                           Table 4-5  (continued)
              Technology
     Capital  costs3
Low      Medium     High
Operating and maintenance costs
    Low      Medium     High
              Cyanide  destruction
             Agglomeration -  feed to furnaces

                Pelletizing
                Green  balling
CO
en
              a  Total  installed cost ranges for commercial-sized units are broadly classified as follows:
                $25,000; Medium - $25,000 to $250,000; High - over $250,000.
                                                      Low - under
                Direct  costs  for chemicals, utilities (steam, cooling water, electricity), and/or direct labor are broadly
                classified as  follows:  Low - passive, no specific requirements, direct costs under $0.02/gal; Medium -
                requires varying operating and maintenance labor and/or moderate chemicals Or utilities, direct costs
                approximately  $0.02 - $0.40/gal; High - requires skilled operators, lab support, frequent maintenance, and/or
                high  chemical  or utility costs, direct costs approximately $0.40/gal or over.

-------
•   Hydrometallurqical concentration  (leaching).  Most metals  can be leached
    out of solids and sludges by extended contact  with  specific acids.  Leaching
    of  metals with sulfuric  acid, although  inexpensive  (approximately $70 per
    ton), causes minor corrosion problems  and is  not selective.  Ammonia and
    ammonium carbonate  are  leaching  solutions having the best selectivity  for
    solubilizing copper and nickel,  but  are more  expensive than sulfuric acid
    (Mehta 1981).

•   Solvent   extraction.   Selective  solvents  can  be  used   to  extract  and
    concentrate  metal  cations  from   leachates  and   other   metal-bearing
    solutions.  The cost of such operations limits commercial applications.

•   Ion  exchange  resins.  Ion  exchange resins are  used  extensively  in  large
    plating shops to reconstitute rinsing waters. Two liquid ion exchange resins
    that  are  commercially  available are dinonyl-naphthalene  sulfonic  acid and
    didodecylnapthalene sulfonic acid (Peterson et  al.  1982).  A limitation  in the
    commercial application  of ion  exchange  resins as  a  metals concentration
    process is the  uncertain  life of  the resins  compared with their fairly high
    cost.  Loss of  resin  efficiency resulting from  plugging  and  fouling  is
    minimized, howeve-r,  by prefiltering the  waste  feed.  Cyanide  baths and
    cyanide  rinse  waters  can  poison the resin and can  result in loss of metals
    that come out  of solution as complexes instead of simple cations.

•   Precipitation.   A  commonly reported  wastewater  treatment  method for
    toxic  metals  is hydroxide  precipitation using either  lime or  caustic soda
    (Peterson et al. 1982).  It is, however, often difficult  to  recover  metals from
    the hydroxide  sludges.  In some  cases sulfide precipitation is  used  following
    a  reduction step  such  as ferrous  reduction  of  hexavalent  to  trivalent
    chromium (Higgins and TerMaath 1982).  Metal ferrites can  be  precipitated
    from wastewater by the  addition of a ferrous  salt.   The metal  ferrites are
    recoverable  because   of   the  size   of  the  crystals   and  their  magnetic
    properties.

•   Crystallization.  Ferrous sulfate  is  recovered from pickling acid by cooling
    the solution to  lower the solubility of the metal salts.  In  a similar process,
    capper sulfate  is removed  from copper etching  baths by  refrigerating  or
    freezing the bath. The latter process is used  by a number of  printed circuit
    fabricators and  metal  finishing   shops   (personal   communication   with
    Gerd Scharlack, Keramchernie, Don Mills, Ontario, Canada, 1986).

•   Calcination. Lead oxide  is recovered from leaded tank bottoms by  reacting
    the  sludge at  high temperature to  drive  off water  and  other volatiles,
    incinerating residual organics, and oxidizing the lead.

»   Evaporation.   Chromium   is  recovered  from chromium   rinse  tanks  by
    evaporation, often in combination with  ion  exchange.  The major  limitation
    of  evaporation  for  concentrating   metals solutions   is  the  high  energy
    requirement for heating,  although  solar evaporation  may  be  used in the
    West.  In  order  for evaporation to be cost-effective, the waste  solutions
    must be high in metals, a condition  achieved in the  electroplating  industry
                                  4-36

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       by process modifications such as counter-current rinsing.  In addition, the use
       of multiple-effect evaporators instead  of single-effect  evaporators reduces
       energy consumption.

    •  Membrane Separation. Substantial improvements  in  membrane  technology
       have  resulted  in  increased  commercial use of some membrane separation
       technologies (ultrafiltration, reverse osmosis) for metal recovery in recent
       years.  Some examples of  applications of membrane separation technology
       include the following:

       -  Ultrafiltration  membranes  are  used to  pretreat  organic  solutions  by
          removing suspended, colloidal, and large molecular dissolved solids.

       -  Reverse osmosis has been used widely for such commercial applications as
          the recovery of nickel from  nickel-plating  solutions.  In addition, reverse
          osmosis has  been  used  to  recover  metals from mixed plating  wastes,
          copper- and  zinc-plating solutions,  and  silver-bearing  photoprocessing
          solutions (Daignault 1977).  A limitation of the reverse  osmosis process is
          associated   with  the   membrane's   strength   to   withstand  -extreme
          temperature  and pH conditions.  For example, chromic acid  and  high pH
          cyanide baths  have  been   particularly  difficult  to  treat  by  reverse
          osmosis.   However, Rozelle  et  al.  (1973) reported  development  of  a
          polymer membrane for  reverse  osmosis treatment  of  both  acidic  and
          alkaline finishing solutions.

    •  Electrodialysis.   This  process  involves  the  application   of  an  electrical
       potential across a membrane  and appears to be limited  in its commercial
       application for technical and economic reasons.

    •  Adsorption.  Columns of  natural or synthetic adsorbents  can  be  used to
       selectively  remove   metals   from   wastewaters.   The   metals  are  then
       recovered by regenerating the  column with acid.

    -<•  Foam   Flotation.    This  is a  relatively  new  process,   demonstrated  to
       effectively remove  copper,  zinc,  chromium,  or lead  from  solution.   The
       process  involves the flotation  of foams after addition of polyelectrolyte and
       adjusting the pH.   No commercial installations of foam  flotation equipment
       were identified during this report.
    Many of the other unit operations used for metals recovery  are  widely  used  and

continuously improved.  Christensen and  Delwiche (1982) reported effective removal
of chromium,  nickel,  copper,  and  zinc from  electroplating  rinse  waters  by  a
three-step  system  of  hydroxide  precipitation,  flocculation,  and  ultrafiltration.

Various improvements in metals reduction by electrolytic recovery  have  been  made

to enhance  mass  transfer  rates,  extend electrode life,  and remove continuously

deposited metals from flat electrode plates.  Although in most instances it is best to

use the electrolytic  recovery  process on segregated metal waste streams, Battelle


                                      4-37

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(Columbus,  Ohio) and  Rolla  Metallurgy  Center have  developed  an  electrolytic
process  that  removes  copper  from  a  mixed-metals  leachate.   Silver  can  be
electrolytically recovered from spent photographic  developing  solutions (Daignault
1977).

    The principal  use  of metals  recovered  from  hazardous  wastes  is for onsite
recycling as a  feedstock.   Examples  of  recycled  feedstocks  include  mill  scale
recycled to steel  mills,  lead oxide recycled to tetraethyl  lead manufacture,  and
reclamation of process baths and  rinse tanks  in  metal finishing industries.  Onsite
recycling of these feedstocks can be cost-effective in major facilities.

    Offsite metal recycling  activities include both the recovery of scrap metals for
re-refining, and recovery of metal compounds for other applications.  Commercial
recyclers charge  or credit the generator for metal-bearing wastes depending orr the
specific metal that is recovered and its concentration.  The highest credit per pound
for a recovered metal is  approximately  50 percent of the  current  market price for
that metal.  For a dilute solution,  the charge (excluding transportation  and  taxes) is
approximately the  same  as  for disposal.  Some  examples  of metal-bearing wastes
recycled offsite and uses-of the recovered products are:
        Recovery of zinc contained in flue dust  from steel  mills.  The zinc is  used
        for production of zinc and technical grade zinc salts;
        Recovery of vanadium from spent sulfuric acid catalysts;
        Reuse of metal solutions  and sludges (e.g., copper,  nickel, and zinc) as raw
        materials in chemical manufacture;
        Recovery of trace metals (copper, boron, manganese, zinc, and  magnesium)
        for fertilizer manufacture;
        Recovery of metal hydroxides from concentrated sludges  for manufacturing
        metal salts;
        Recovery of precious metals; and
        Recovery of cobalt and molybdenum, along with nickel and vanadium, from
        hydrotreating catalysts used in petroleum refining.
                                      4-38

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    Since  precious metals (gold,  platinum, palladium) can  be  recovered almost

quantitatively from waste solutions, there are numerous onsite recovery  operations

as well  as  offsite re-refineries  for  those  metals.   Re-refiners  also  actively  seek

silver-bearing wastes  from any  of  the following sources:  used  photographic film;

photographic paper; electrolytic silver (flake); ash from  burning of photographic film

or paper; metallic replacement cartridges; and other solutions  and sludges.  (Further

information on metals is presented in Appendix C-3.)


Corrosive Waste Recycling  Technologies


    Techniques  commonly  used   to  recycle  corrosive   wastes   are  thermal

decomposition, evaporation, crystallization,  ion exchange, and  oxidation.  Several of

these technologies overlap  those  described  above for metals because many corrosive

wastes are  metal-bearing solutions or sludges.  Uses for spent  corrosive solutions

typically  are  found  in  large volume applications and  in basic  or heavy  industrial

classifications. See Appendix C-4 for further information on corrosives.


    Thermal  decomposition  is used  in  the recovery  of at  least three  types  of

materials:   (1) spent alkylating  acid from petroleum refineries; (2) acid values from

spent pickle liquor; and (3) hydrochloric acid from chlorinated hydrocarbon wastes.
        Spent alkylating  acids (RCRA waste code D002) from  petroleum  refining
        consist  of  sulfuric acid  contaminated  with  organic materials.  This  spent
        acid  is  frequently  returned  to  nearby sulfuric  acid plants  where  it  is
        thermally  decomposed  to sulfur dioxide,  water, and oxygen.  The  sulfur
        dioxide  is recovered and used to produce fresh acid, which is  then  supplied
        to  the refineries  (Versar  1980).   Recovery of spent alkylating  acid is widely
        practiced among major  petroleum   refineries,  and  spent  acid processing
        plants   are  generally  located  adjacent  to  major refineries  (personal
        communication  with  Gordon  Jolley,   Exxon  Chemical   Americas,  Baton
        Rouge,  La., June 13, 1985).  Allied-Signal, Stauffer, duPont, and American
        Cyanamid all operate such facilities near major petroleum refineries located
        in the Northeast and along the Gulf Coast.

        Recovery of hydrochloric  acid from  pickle liquor (K062) could be practiced
        at  many iron and  steel mills.  Though the costs of  the operation are high and
        account,  in  part,  for  its  infrequent use,  recovered  acid  could  be  of
        significant  value.  Currently, iron chlorides are recovered  from this  waste
        more often than HC1.
                                      4-39

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     •   Halogenated  acids are recovered by  scrubbing of vent gases of incinerators
        burning highly halogenated  wastes  (Inform  1985).  The incinerator off-gases
        are water scrubbed to generate dilute HC1 solutions, which are concentrated
        for sale  or   internal  reuse.   The  Dow  Chemical facility  in  Pittsburg,
        California, uses this technology (Inform 1985).


     Evaporation.   Processes based on  evaporation are  another extensively used
method for recovery  of corrosive wastes.
     •   DuPont  recovers  ferric  chloride  from  titanium  dioxide  process  wastes.
        Partial  evaporation of the  process wastes  generates a  40 percent ferric
        chloride solution  that  can be resold.  Use  of  such  technology has provided
        duPont  with  an  additional  product  line  and has eliminated  the  cost  of
        neutralizing  large  volumes  of  aqueous  ferric  chloride  wastes.   Further
        application  of this technology, however,  is constrained by limited markets
        for ferric chloride,  which  competes  with alum for use  as a  water treatment
        chemical.

     •   Evaporation is also applicable  to corrosive acid and alkali solutions.  Dilute
        solutions of  sodium  hydroxide, phosphoric acid, chromic acid,  and  nitric  acid
        are  corrosives suitable  for  concentration by  evaporation.  Many  alumina
        plants reconcentrate  spent dilute caustic  by  evaporation  to regenerate  50
        percent  caustic  solutions for  internal  reuse (Versar  1980).  These  efforts
        reduce the  need  to purchase  large  volumes  of  this  raw  material  and  to
        neutralize large volumes of spent dilute caustic.

     •   Several  chloralkali producers  send spent  sulfuric  acid,  used  for  chlorine
        drying, to  sulfuric acid plants  for reconcentration (personal communication
        with  Edward Laubusch, Chlorine Institute, New York, N.Y.,  June 18, 1985).
        This effort also saves  the costs involved in neutralization  or disposal  of a
        corrosive waste.

     •   Spent nitrating, acids  from production of either fuming nitric  acid or  organic
        nitro compounds are also  reclaimed  by  distillation or evaporation methods
        (personal  communication  with  John  Cooper,  duPont,  Wilmington,  Del.,
        July 1, 1985).

     •   Phosphoric  acid  is  concentrated to standard  acid strength  by evaporation
        under  vacuum.  This  is  normally  done in the  production  of  wet-process
        phosphoric acid in the fertilizer  industry.   The metal  plating industry  may
        evaporate  chromic  acid solutions from plating-rinse tanks.  This  option has
        been  proposed for use  in  the electroplating industry; the extent  to which  it
        is currently  used is unknown.
     Crystallization is another practice in  use  for the recycling of  corrosive wastes.

In  metal  finishing operations,  iron  salts  (mainly  ferrous  sulfate) are crystallized
                                      4-40

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from  pickle  liquor solutions, and  sulfuric acid is recycled  to  the pickling  baths.

Commercial  processes use cooling, either direct  or indirect  or combinations  of  the

two, to  trigger crystallization.


    •   Ferrous sulfate is recovered by crystallization  in large steel mills where  the
        capital  outlay  for the equipment is offset by  the large volume of  pickle
        liquor (Versar  1980).  The separated ferrous sulfate is adequate for use as a
        flocculating agent in wastewater treatment plants.  The  value of recovered
        ferrous  sulfate, disposal costs,  and  availability  of  a market  for  ferrous
        sulfate are also included  in the process economics.  A similar process exists
        for recovery of ferric chloride from  spent HC1 acid pickling solutions.  This
        process shows little economic  promise  for  the  metal  finishing industry,
        which  consists of  many  generators  of  small quantities  of pickle  liquor.
        Reconcentration of original acid  is energy-intensive and is  practiced only by
        a few  commercial recyclers, who procure  spent  pickle  liquor  from  other
        local   firms   and  convert   it   to   ferric   chloride  for  sale  (personal
        communication,  Howard   Kaiser,   Director   of   Environmental  Affairs,
        Conservation Chemical, July 16,  1985).

    •   Cupric  chloride  and copper  sulfate  also may  be  recovered from copper
        cleaning  solutions  through crystallization. Printed  circuit  manufacturers
        and  metal finishers make use of this because the value of the copper salts
        justifies use of the process.

    •   Aluminum  hydroxide (hydrated  alumina)  is recovered from aluminum etch
        solution  by a recently  developed  cooling process.  The  etch  solution is
        recycled directly,  whereas the alumina can be  sold  in  bulk as a raw  material
        to an aluminum producer.
     Ion exchange resins are capable  of  removing  heavy metals  and cyanides from

acid and  base  solutions.   The process  is  applicable in  the  electroplating, metal

finishing, and  fertilizer manufacturing  industries  and  has been  used at  numerous

installations since the mid 1970s.


     Oxidation   is another technique  for  corrosive  material  recovery.  Byproduct

hydrogen chloride can be oxidized to produce  chlorine.  The chlorine is then used to
produce  chlorinated  hydrocarbons.  DuPont  operates  the process  at their Corpus

Christi,  Texas,  facility  (written  communication  from  J.  Cooper,  E.I.  duPont

de Nemours, October 1985).
                                       4-41

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Recycling Technologies for Cyanides and Reactive Wastes

    This  section  describes  techniques used  for  recycling  cyanide  and  reactive
wastes. Several examples are presented  of  recycling technologies either in current
use or in development.

    Cyanides.  Potential  techniques for recovering  and  recycling cyanide  solutions
from   metal  plating  (e.g.,  zinc,   cadmium,   brass,   and  silver  plating)  are:
(1) refrigeration/crystallization,     (2) evaporation,     (3) ion    exchange,     and
(4) membrane    separation     (reverse     osmosis     or    electrodialysis).     A
refrigeration/crystallization  process for  removal  and  recycling  of  cyanide  from
plating solutions  that  contain excessive  amounts  of  sodium carbonate  has been
patented by the Department  of Defense (DOD).  Although this process is considered
promising  by some  members of the electroplating  industry, its  widespread use is
limited by formalities involved in obtaining  necessary  permission for  use from  the
DOD.

    One type of  cyanide waste that  is commonly  recycled  is cyanide  wastewater
from  precious metal  beneficiation.  After traces of  gold or silver are precipitated
with zinc  or adsorbed onto carbon,  the cyanide  solution can be recycled.  However,
in other industries, such as Transportation Equipment (SIC 37), cyanide wastewaters
are treated  to  recover metals, and the residual cyanide is destroyed  by alkaline
chlorination. The  relatively low cost of fresh cyanide makes this  practice the most
cost-efficient for  management1. (See Appendix C-5 for further information.)

    Reactive Wastes. The major technology currently used to recycle reactives  is a
metal   substitution   process.   Sodium   metal  is   recovered   from   reactive
sodium-calcium   alloy  wastes  using  a  closed  loop   system  which  involves  a
replacement reaction between calcium and  salt. This  technology is  in use at  the
duPont, Niagara  Falls, New York, sodium  production  plant  where  1,000  tons of
usable sodium are  recovered  and 1,200  tons  of  RCRA  hazardous  wastes  are
eliminated per year  (from written  communication  with J. Cooper, E.I. duPont  de
Nemours,  October 1985).

-------
    The  primary barrier to the recycling of other water-reactive wastes (e.g., most
alkali metal wastes) is technical feasibility.  There are, however, efforts underway
at DOD facilities to investigate possibilities of overcoming this problem.

    A  technique  using   evaporation   is  being  studied  to  reclaim  ammonium
perchlorate from propellant  wastes.  A process to recover  cyclotrimethylene  base
trinetramine and  cyclotetrametaylene  tetranitroamine (RDX and  HMX),  which is
based on  solubility  differences, is also  being  studied  by the  explosives  industry.
Elemental phosphorus is recovered from phosphorous wastes by  a retorting process
that is widely  used in  the phosphorus chemicals  segment of the inorganic chemicals
industry (Versar 1980).  (See Appendix C-5 for further information.)

4_3       Offsite "Recycling

    Offsite  recycling of  hazardous  wastes  is a  management option  for  some
generators. A generator's decision to recycle offsite depends  on  such factors as the
size of the company,  the volume of the  waste, and the expertise available within the
plant  or  facility.   Options for  offsite  recycling  that are  discussed in this section
include  commercial recycling  facilities,  waste  exchanges,  and other cooperative
arrangements.

4.3.1      Commercial Recycling Facilities

    Many recycling facilities are privately owned companies  that accept hazardous
wastes from generators, and  then process the  wastes  to make them suitable  for
reuse. Profits  are  derived from the income the companies receive  by  reselling  the
recycled  wastes as  raw materials.

    Depending on  the type  of  waste,  the commercial  recycler  may buy hazardous
wastes from a generator or charge the generator  a fee for accepting  the waste.  The
value  of  a waste to a  commercial recycler depends on the type, market value, purity
(quality), and quantity, of waste generated; how often the waste is produced; and  the
distance between the generating facility and the recycling facility.
                                      4-U3

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     Both  mobile  and  stationary  treatment  equipment   is  available.   Mobile
recycling/treatment units include detachable  trailers  of  recycling (or treatment)
equipment that can  be  moved periodically to the generator's premises,  where it  is
operated by the commercial recycler.  A number of companies with mobile PCB-oil
treatment  facilities have  been  issued  PCB-disposal permits  by  EPA  headquarters
(Pesticide and Toxic Chemical News, 1985). These facilities include:
        Acurex, Mountain View, California (chemical dechlorination):
        Chemical  Decontamination  Corporation, Birdsboro, Pennsylvania (chemical
        dechlorination);
        Quadrex HPS, Gainsville, Florida (physical separation);
        Sunohio, Canton, Ohio (chemical dechlorination); and
        Transformer Consultants, Akron, Ohio (chemical dechlorination).
    American Mobile Oil Purification, (New York) and  Acurex have active research
and development permits for mobile chemical dechlorination and physical separation
systems, respectively.

    Another form  of commercial recycling is an arrangement called batch toiling.
Through this arrangement, a commercial recycler may accept hazardous waste  from
a generator, treat it,  and return the  recovered  product to  the  same generator,
charging the generator a fee for this service. This agreement  would  be  attractive to
a generator if the cost  of the reclaimed material from the batch toller were cheaper
than the equivalent virgin  material  inclusive  of transportation  and handling costs.
Companies generating small  volumes of a waste and/or located substantial distances
from  a batch  toller, however,  could  find the economics  for purchasing virgin
material  to  be preferable  to  that of recycling.   (See  also  Section  5.2.3  for a
discussion of the effect  of liability on costs of transportation of  hazardous wastes.)

    A variation  of  this type of batch-tolling  agreement  is  practiced by  some
companies who sell chemicals for use in processes and agree to buy back or accept
the  spent material  for reclamation.   For example,  CP  Chemicals in Sewaren,  New
Jersey, manufactures plating  chemicals and accepts spent  plating solutions  from
customers for reformulation.  CP Chemical  then supplies the  reformulated  solutions
to the  customers  (personal  communication with  Vincent Krajewski,  Director of
Environmental   Affairs,   CP  Chemical,   Sewaren,    N.J.,   July   16,   1985).
                                     4-44

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Harshaw-Rltrol has similar arrangements  with its long-term customers  (personal
communication  with  Mr. David  Wilson,  Manager of  Environmental  Affairs  and
Safety, Harshaw-Filtrol, Cleveland, Ohio, July 16, 1985).

    Safety Kleen, a commercial recycler headquartered in Elgin, Illinois, provides a
similar  type of batch-tolling service,  but goes a  step  further  by supplying  the
process equipment  and  chemicals as one unit.  The company  operates  mobile units
that provide fully-contained  degreasing  systems to  user (generator) facilities  in a
variety  of locations throughout  the  United  States.  Safety  Kleen  leases  systems
consisting of solvents contained  in an apparatus used for  degreasing machine parts.
On  a periodic basis, Safety Kleen's  mobile units return  to  the  generator's  facility
and replace spent  solvent  with fresh solvent.  Then the spent solvent is transported
to  a central  recycling  facility.  The  generator is  assured  of  having the  waste
recycled and  avoids some of the paperwork and costs of transporting a hazardous
waste.

    Additional information on the locations and services of  commercial recyclers  is
being  compiled by  the  USEPA  Office  of Solid Waste (OSW),  Waste  Management
Division, Waste Treatment Branch.  Several data bases are  used by  OSW to access
such  information  including  the  Hazardous  Waste   Data  Management   System
(HWDMS), the RIA (1981) Mail Survey  data  base, and the  RCRA Biennial data base.
Recently,  the  recycling  facility information  contained  in  these  sources  was
compared with  several commercial  directories,  including  the Hazardous  Waste
Services   Directory  (J.  J.   Keller  1984)  and  Industrial  and  Hazardous  Waste
Management Firms 1985 (Environmental  Information Ltd. 1985).

4.3.2      Waste Exchanges

    One alternative to  onsite recycling or shipping wastes offsite  to commercial
recyclers is direct shipment  of  wastes  to  other companies who can use the waste
material in their operations.  Recipient companies either use the waste untreated or
subject  it  to  a minimal amount  of treatment before reuse.  The  success  of such
waste transfer operations depends on (1)  the supply and demand for a specific waste
and (2) a mechanism by  which interested parties can make contact and  negotiate an

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agreement.  Waste exchanges are private or government-funded organizations that
facilitate recycling transactions by identifying the  supply  and demand for specific
wastes and bringing together waste generators and potential waste users.

     Wastes currently recycled through waste  exchanges include acids, alkalis, other
inorganic chemicals, organics and  solvents, metals, and metal  sludges.

     •  Solvents and metal wastes are frequently listed  by  waste exchanges because
        they have  a high recovery value.
                                                                               in
Corrosives  also  are  frequently  listed,  and  are  exchanged  for  use
neutralization processes.  Although metal-bearing cyanide wastes are listed,
usually only the metals are recovered and the cyanides are destroyed.
Reactives, such as explosive  wastes, are rarely  listed  by waste exchanges
because of their  low recovery potential and the difficulties  involved  with
transporting them.
Some halogenated  organic  wastes, in particular pesticides and PCBs, are
rarely recycled and thus are not  listed by waste exchanges. Approximately
20 to 30 percent  of listed wastes are exchanged (i.e., either acquired  or sold)
(Industrial Material Exchange 1985; Banning and Hoefer  1983, Banning  1984;
Piedmont Waste Exchange 1984).
    There are two types of waste exchanges:  Information Exchanges, which act as
clearinghouses  through  which  interested  parties  can  find out  what  wastes are
available  and  what  wastes  are  wanted;  and  Material  Exchanges,  which  take
temporary physical possession of the waste and may initiate or actively participate
in the actual transfer of  wastes  to users.  (A list  of  information  exchanges and
material exchanges is provided  in Table 4-6.  Further information on the exchanges
is provided in Appendix C-6.)  Supplementing  the  activities  of these  two types of
waste  exchanges  are waste  brokers.   The  brokers,  for a  fee,  locate either  a
generator of  a wanted waste, or a company that can make use of  a particular  waste
type.

Information Exchanges

    At  present,   information  exchanges  are  the  most  prevalent  type of  waste
exchange.  Through such  services,  industries can  find  published  lists  of wastes
                                      4-46

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1727s
        Table  4-6   List  of  Information  and Material  Waste Exchanges
Organization/Address/Telephone                        Contact person
Information Exchanges:

California Waste Exchange                             Robert McCormick
Department of Health Services
Toxic Substances Control Division
714 P Street
Sacramento, California  95814
(916) 324-1818

Canadian Waste Materials £xcharuje                     Robert Laujjhlin, PhD
Ontario Research Foundation
Sheridan Park Research Community
Mississauga, Ontario
CANADA  L5K 1B3
(416) 822-4111

Chemical Recycle Information Program                  Jack Westney
Houston Chamber of Commerce
1100 Milam Building, 25th Floor
Houston, Texas  77002
(713) 658-2462

Georgia Waste Exchange                                Clinton Hammond
Business Council of Georgia
P.O. Box 7178, Station A
Marietta, Georgia  30065
(404) 448-0242

Great Lakes Regional Waste Exchange                   William Stough
3250 Townsend NE
Grand Rapids, Michigan  49505
(616) 451-8992

Industrial Materials Exchange Service                 Margo Siekerka
2200 Churchchill Road, #24
Springfield, Illinois  62706
(217) 523-8700

Industrial Waste Information Exchange                 William E.  Payne
New Jersey Chamber of Commerce
5 Commerce Street
Newark,  New Jersey  07102
(201) 623-7070
                                        4-47

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 1727s
                           Table 4-6   (Continued)
Organization/Address/Telephone                        Contact  person
Inter-Mountain Waste  Exchange                         Joe  Parkinson
HATCHCO-W.S. Hatch Co.
643 South 800 West
Woods Cross, Utah  84087
(801) 295-5511

Midwest Industrial Waste Exchange                     Clyde H. Wiseman
Ten Broadway
St. Louis, Missouri   63102
(314) 231-5555

Montana Industrial Waste Exchange                     Janelle Fallon
P.O. Box 1730
Helena, Montana  59624
(406) 442-2405

Northeast Industrial  Waste Exchange                   Lewis Cutler
90 Presidential Plaza
Suite 122
Syracuse, New York  13202
(315) 422-6572

Piedmont Waste Exchange                               Mary McDaniel
Urban Institute
UNCC Station
Charlotte, North Carolina  28223
(704) 597-2307

Southern Waste Information Exchange                   Gene Jones
Post Office Box 6487
Florida State University
Institute of Science & Public Affairs
Tallahassee, Florida  32313
(904) 644-5516

Tennessee Waste Exchange                              Sharon Bell
Tennessee Manufacturing Association
501 Union Building, Suite 601
Nashville, Tennessee  37219
(615) 256-5141

Western Waste Exchange                                Nicholas Hild,  PhD
ASU Center for Environmental  Studies
Krause Hall
Tempe, Arizona  85287
(602) 965-2975

                                       4-48

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1727s
                          Table 4-6  (Continued)
Organization/Address/Telephone                        Contact person
Materials Exchanges:

Alkem, Inc.                                           Alan W. Schneider
25 Glendale Road
Summit, New Jersey  70901
(201) 277-0060

American Chemical Exchange (ACE)                      Tom Hurvis
4849 Golf Road
Skokle, Illinois  60077
(312) 677-2800

Enkarn Research Corporation                           J.  T.  Engster
Industrial Commodities Bulletin
P.O. Box 590
Albany, New York  12201
(518) 436-9684

Environmental Clearinghouse Organization - ECHO       William Petrich
3426 Maple Lane
Hazel Crest, Illinois  60429
(312) 335-0754

ICM-Chemical Corporation                              Anthony L.  Tnpi
20 Cordova Street, Suite #3
St. Augustine, Florida  32084
(904) 824-7247

New England Materials Exchange                        David  Green
34 N. Main Street
Farmington, New Hampshire  03835
(603) 755-9962 or 755-4442

Ore Corporation, The Ohio Resource Exchange           Richard L.  Immerman
2415 Woodmere Drive
Cleveland, Ohio  44106
(216) 371-4869

Peck Environmental Laboratory, Inc.                    Oonna  Trask
P.O. Box 947
Kennebunk, Maine  04047
(207) 985-6116
                                       4-49

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1727s
                          Table 4-6  (Continued)
Organization/Address/Telephone                        Contact person
TECHRAD Industrial Waste Exchange                     Ernest L.  Koerner
4619 N. Santa Fe
Oklahoma City, Oklahoma  73118
(405) 528-7016

Union Carbide Corporation
(In-house operation only)

Zero Waste Systems, Inc.                              Trevor Pitts
2928 Poplar Street
Oakland, California  94608
(415) 893-8257 or (415) 893-8261
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available  or  wastes  wanted.   Rather  than  listing  the  names  of  participating
companies on the  exchange, most information exchanges simply list a "box number,"
a  procedure  similar  to   that   used   in  classified  ads.   This  system   ensures
confidentiality to  companies who fear  that an analysis of their wastes would reveal
proprietary  information   about  their   manufacturing   processes.   Information
exchanges may be  passive or active:

    Passive  Exchanges.   Passive  exchanges  serve  only   as clearinghouses  for
information that could  link two  potential  traders  together.  These exchanges work
by publishing listings, usually in  a quarterly bulletin.  Interested parties send letters
of inquiry  regarding wastes listed by the exchange, which are  in turn  forwarded  to
the originator of  the  listing.   The  generator and  potential  user  must negotiate
directly  to  determine   whether  each  party's  negotiating  requirements  can   be
arranged,  if  not  already  satisfied.  Passive  exchanges often  try to  track  the
subsequent transactions, but because companies are  often reluctant to reveal such
information, not all successful exchanges are recorded (Sloan  1985).

    Active Exchanges.  Active  information exchanges  take  an additional role  in
matching users and generators.   Introductions of parties  are  made  from  interviews,
during joint  meetings,  and through computer matching.  Such exchanges employ a
technical staff who attempt to "match  up" the waste  with a  use upon  its entry into
the system.   They contact companies  directly to see  if there is a  need  for the
wastes,  rather  than  waiting for responses to publication  of the  listings.   Many
information exchanges  that were passive are taking a more active role and  could
now  be  classified  as active exchanges  (personal communication  with   Mr.  Lewis
Cutler, Director, Northeast Industrial Materials Exchange, December 13, 1985).

    Sponsorship  and  Funding   of  Information  Exchanges.   Active  and   passive
information exchanges  operate  as nonprofit  and  nonregulatory entities.   Although
some  money is generated by the payment made by advertisers  to list their wastes in
the exchanges'  publications, the income has  not proved  sufficient  to  maintain
operation of the waste  exchange (personal communication, William Sloan,  Secretary,
Maryland Hazardous Waste Facilities Siting Board, October 15, 1985).
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    Funding  for both  active  and  passive  information  exchanges  generally  comes
from  both government agencies  and  nongovernment organizations.  Examples of
funding sources include the following:
    •   The  Northeast   Industrial  Waste   Exchange  receives  money  from  the
        Manufacturers Association  of Central  New  York, the  Central  New  York
        Regional   Planning   and  Development  Board,   the   New   York  State
        Environmental  Facilities  Corporation,  and   the   Ohio   Environmental
        Protection  Agency  (personal  communication  with  Mr.  Lewis   Cutler,
        Director, NIWE, December 13, 1985).
    •   The  Midwest  Industrial  Waste  Exchange  is  supported  by   the  State
        governments of Missouri, Kansas, and Arkansas, and by the Tennessee Valley
        Authority.
    At  one time,  the  U.S.  EPA had  a  role  in promoting  waste  exchanges  by
providing  information  and advice on their  operation to interested  parties.  EPA's
involvement took place during 1980, but did not continue  because  of  changes in
emphasis to different programs.  Recently, the Maryland Hazardous Waste Facilities
Siting Board  passed a  resolution (October  17,  1985) that requires the Board to
request  the U.S. EPA to provide  a portion of the funding required to maintain waste
exchanges in the U.S.

Material Exchanges

    There are two types of material  exchanges:  direct transfer  and  broker-assisted
exchanges. The activities of privately-owned brokerages supplement the activities
of material exchanges.

    Direct Transfer Material Exchanges.  Direct transfer material  exchanges are
arranged  by  chemical  companies large  enough  to  have departments  devoted to
maximizing  the recovery  of surplus and byproduct chemicals.  Such  companies
transfer their  wastes directly to  other companies, often  for a profit. Since  some of
these  wastes may require treatment before they are sold, legal staff support and an
onsite waste processing  facility may be required for this type of exchange.
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       One example of  a  direct  transfer  material exchange is the  agreement
       between  the  Andrews  Wire Company  of  Andrews,  South  Carolina,  and
       Diamond    Shamrock    Corporation.    Andrews   Wire   Co.    generates
       approximately  1.5 million gallons per year of waste pickle liquor containing
       10 to 15 percent ferrous chloride and 5  to  10  percent unreacted hydrochloric
       acid (HC1). In 1980, Andrews initiated a  waste  acceptance agreement with
       the  Diamond  Shamrock chromates  plant  in  Castle Hayne, North Carolina.
       By  this agreement,  Diamond Shamrock accepts the pickle liquor without a
       fee, provided  that  the  acid content  of the  liquor  exceeds  5  percent.
       Diamond   Shamrock   uses   the  liquor  to   reduce hexavalent   chromium
       compounds to  trivalent  chromium  hydroxide in   their treatment  system
       (personal  communication with Robert Johnson, Andrews Wire  Co., Andrews,
       S.C., December 17, 1985).

       There  are  numerous  other  examples  of  such exchanges  in  the chemical
       industry between  adjacent  plants  in which  waste acids or alkalis from  one
       facility are used  to neutralize  wastes  from the plant "next  door."   Other
       examples include  the  sale  of waste dilute sulfuric acid to nearby facilities
       for fertilizer production.

       Direct transfer material exchanges are most  likely  to occur between nearby
       facilities  that  have constant or nearly constant rates of  waste generation
       and  consistent waste compositions.
    Broker-Assisted Material Exchanges.  In broker-assisted material exchanges, all

materials transferred pass through the  exchange.   Revenues are generated  through

commissions  charged on transactions.  Wastes that cannot be recycled directly are
processed either by the material  exchange itself or by  a  third-party as arranged by

the exchange.   Wastes  that are difficult to  "match"  with  a  potential  user are
sometimes referred to a  third  party  bro-ker.  Alternatively,  the broker-assisted
material  exchange  may locate  a buyer  for a  batch  of  waste,  which the  buyer

purchases from the generator for  eventual resale.


    Brokerages.  Waste  brokerages augment the  activities of  waste  exchanges.
Brokers are specialized  in various waste  "territories"; for example,  some  may be

familiar  with  companies  that   use   metals,  while  others  may  specialize  in
off-specification   organic   chemicals.    In  addition   to  working  with  material

exchanges, a broker may negotiate  directly with  companies seeking  purchasers of

their wastes or by  others who will buy a particular type of waste.


    Although  the  efforts of waste brokerages may  seem to  duplicate  those of

information exchanges, the  services of brokers actually complement  those  of the


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 exchanges.  Because the  waste exchanges cover  wider  territories, the information
 provided by  exchanges often is  of  use  both  to  individual companies  and to waste
 brokers. At the same time, a broker may have local information about  companies or
 waste  streams  that  is  not  available  through  information  exchanges.  Brokers
 themselves  frequently  consult  the  waste exchanges  as sources of  information
 (personal communication  with Lewis Cutler, Director, Northeast Industrial Materials
 Exchange, December 13, 1985).

 Limitations of  Waste Exchanges

     Although waste exchanges provide  a mechanism  for the  direct  exchange  of
 wastes, there  have  been  some  problems with their operation.  Some generators  do
 not  use waste  exchanges  because they  are  concerned  about quality  control and
 long-term  liability.  Also, actual waste  transfers* may be unsuccessful because the
 quantity of the waste is inadequate, the quality is unacceptable, transportation costs
 are  too high, government regulations are prohibitive, or distance and availability
 make transportation difficult.

     Another problem with  waste  exchanges  has  been  the  lag  time  between
 publication  of  the listings and  successful transactions.  To  smaller companies,  a
 timely turnover of wastes is  important, since  storage of  hazardous wastes for more
 than 90 days onsite  could require the company to obtain  a TSD permit.  Dependency
 of transactions on the success of a quarterly publication could defeat the purpose  of
 recycling for such companies.

     Sloan (1985)  maintains that problems with waste exchanges may be attributable
 to both the "lack  of promotion by the Exchange and State  government [and] slowness
 on the part  of  industry."  Although some wastes are not suitable for trading  through
 waste exchanges because of low quality or purity,  there is some  evidence  that more
 types of wastes  could be exchanged than are now.  A recent statistical analysis  of
selected manifests conducted by  the Industrial Materials Exchange indicates  that
approximately  25 percent of wastes sent for land disposal in  1985 were suitable for
recycling (personal communication, Margo Ferguson, Director, Industrial  Materials
Exchange, January 3, 1986).
                                      4-54

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    The Industrial Materials Exchange  analysis does not  provide information on the
constituents  of the  landfilled  waste  streams;  volumes  of  waste  landfilled per
generator;  and  the distances from generator  to  available recycling  facilities.   Any
one of these  factors could cause a generator to decide not to recycle because of the
costs  involved   or  limited  technical  feasibility.   The  statistical  information  is
significant, however,  in identifying the fraction  of  wastes now landfilled that could
be recycled  and in  pointing  out the  role  that  a waste exchange  could  play  in
changing that pattern.

Future Development and Uses of Waste  Exchanges

    Existing  Information Systems.   The problem stated above  regarding  lack of
promotion  by  the exchanges themselves  is  beginning  to be  alleviated  by some
information exchanges' taking a more  active role  in  contacting potential  users of
the exchange system. Rather  than relying solely on the publication  of the quarterly
listings, some  exchanges  seek interested parties directly  (personal  communication
with Lewis Cutler, Director, Northeast Industrial  Waste Exchange,  December 13,
1985).

    On-Line Information  Systems. Another recent  development has  the potential to
advance significantly  the usefulness of waste exchange programs, namely, the use of
on-line computer services.  Currently,  both the Northeast Industrial Waste Exchange
and the Industrial Materials  Exchange use personal computers  to  maintain  listings of
wastes available and  wastes wanted;  these  computer listings can  be  accessed on
line.  Companies now can place their own  listings on the  computer system, and the
tracking  of wastes available and wanted can be maintained much more  accurately.
Users calling into the system are not  charged  a fee; fees  are charged  only for
companies  placing advertisements or listings with the  on-line computer system.  A
sample  printout  from  the  Northeast  Industrial Waste   Exchange  is  provided in
Appendix D.

    Listings  requested can  be sorted by region of the country and by type of waste.
One  drawback  to  the  system is  its  current limitation in  the size  and  number of
computers.  For example, the Northeast Industrial  Waste Exchange computer has a
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capacity for approximately 400  listings.   Another drawback  is that the system  is
capable of  accepting only one telephone call at a time.

     There  has  been general interest in the use of  this on-line system by other waste
exchanges  as well as by companies that have tried the system. Conversations with
waste exchange personnel indicate  that they eventually hope to expand the  capacity
of the system so that  more callers can be accommodated and more listings can be
maintained.  Since  listings are  not ' limited to  the geographical  area   that the
exchange serves, the development of a national computerized  waste exchange may
be  feasible through a  jointly operated network.  Furthermore, the  rapid  response
available via the  computer system  would alleviate  the  lag  time associated with
quarterly  publications.  Finally, the  attraction  of  more users  may  result in  an
increase in listings.  Higher volume use of the system potentially  could reduce the
number of  failed  transactions, since a greater variety of waste types  and  qualities
conceivably would be available to a  greater number of companies.

Cooperative Arrangements

     Companies may make cooperative  arrangements with each other  to facilitate
recycling  in  ways  other  than  the  commercial  batch-tolling  agreements discussed
earlier.  Some case studies document arrangements between plants that are  located
near  each  other, and  even between  plants at  some distance  from  each  other.
Stauffer Chemical's Baton Rouge plant furnishes  fresh sulfuric acid to the  Exxon
refinery  in  Baton  Rouge,  then  accepts  the  spent  acid,  reclaims  it   by
reconcentration, and sends it back  to  Exxon  (personal communication  with  Gordon
Jolley,  Exxon  Chemical  Americas, Baton Rouge Chemical  Plant,  Baton  Rouge,
Louisiana,  July  8,  1985).   An  interstate, direct-transfer  arrangement   between
Andrews  Wire  Company,  Andrews,   South  Carolina,   and  Diamond  Shamrock
Corporation, Castle Hayne, North Carolina, was discussed above.

     One example of a cooperative  offsite  recycling arrangement  is that organized
by  the  Neighborhood  Cleaners Association (NCA).  NCA  delivers waste recycling
"kits" to participating member establishments and, on a periodic basis,  arranges for
pickup of  the accumulated wastes by a commercial recycling facility whose trucks
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service   regular  routes.   Spent  solvent  (perchloroethylene)   is  recovered   by

distillation, cartridges are shredded, and any usable parts are recycled. Oily wastes

that  cannot  be recovered  are  incinerated.   The   average   cost  for  an  NCA

establishment  to  participate  in  this program  is $600 to $700 per  year  (World

Information Systems 1985).


    There are several  metal  recovery  cooperatives  in  operation that centralize

recycling and  other  waste management  by  small generators.  In  each  of  these

instances, a  distributor  or  offsite facility makes routine "milk runs"  to  numerous

small facilities to  pick  up  hazardous  wastes  and resupply  the facility with  waste

containers or other materials.  Examples include:
    •  The  Metropolitan Recovery  Corporation,  Minneapolis, Minnesota,  is  an
       organization of 20 printed circuit fabricators and metal finishing shops that
       will  jointly  manage  all  aspects of  waste  treatment  for  those  facilities,
       including recovery, reuse, and disposal  of metals and acid from wastewaters
       and finishing solutions.  Ion  exchange  canisters will be  provided to  each
       generator.  A public  notice of the RCRA Part B application for the recovery
       facility is scheduled to be released in late September 1986.

    •  A working  group of  30  generator  facilities in  the Cleveland, Ohio,  area
       selected  Tricil to operate a central ion  exchange treatment facility for their
       wastes in Columbus, Ohio. The  facility, scheduled  for startup  in late 1985,
       will  service the  Columbus  and  Cincinnati   markets  as   well  (personal
       communication   with   Donald Corey,  Chemical Waste  Management,  Inc.,
       Sommerville, Mass., August 9, 1985).

    •  Approximately 100 companies in the Metropolitan New  York area  (including
       Northern New Jersey and lower Connecticut) have formed a  Metal Finishers
       Foundation.   They  are   still  exploring alternative  technologies  to   ion
       exchange, and are actively negotiating for several alternative  sites to  locate
       the central metal recovery facility.  Their target startup date  is December
       1987.  Compliance schedules reflecting that date  have been drawn  up  by
       regulatory agencies for some  of the members.

       The group  feels that they will  overcome  facility  siting obstacles initially
       encountered.  Concerns  expressed  regarding  technical feasibility  of  ion
       exchange  will   presumably  be  addressed  in   their   current  technology
       evaluation  work  (personal communication  with  Donald Corey,  Chemical
       Waste Management, Inc., Sommerville, Mass., August 9, 1985).

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4.4       Future Extent of Recycling

     The previous discussion  of  recycling  suggests  that  there are companies  not
practicing  recycling, but for whom the  practice  would result in cost savings.  An
increase in  awareness of the  economics of recycling may contribute to an  increase
in its practice by such companies.

     One  important  factor  that should  result  in  an  increased  awareness of  the
economics of  recycling is HSWA.  The restrictions on  the land disposal  of certain
hazardous  wastes,  coupled  with  increased  technological requirements for new land
disposal units, landfills, and  surface impoundments, will limit the waste management
options available to generators.  For some  wastes, land disposal may not  be  allowed;
for others,  the  costs  of  land disposal may  undergo substantial increases.  These
changes   may   motivate  generators  to  consider  alternative  forms   of  waste
management, recycling among them.

     The potential for increased  recycling  will depend  on  the costs of  alternative
management  techniques, for  example,  incineration,  wastewater  treatment,  and
underground injection (the latter  may be allowed  in limited  instances).  If  treatment
and  disposal costs increase,  those companies for whom  recycling has  been only
marginally economical will find it becoming more  attractive.  Another reason for a
possible  increase in recycling is that some landfills may  be  closing because of an
inability to  comply  with  the   new  monitoring  and   technological   requirements
(personal commurrication  with Jacqueline Te-nusak, U.S. EPA,  Office of Solid Was-te,
January 12, 1986). The scarcity of  landfills, combined with the decrease  in  demand
for landfilling because of land disposal restrictions, is likely to result in an  increase
in demand  for  waste  management  alternatives;  the  increase  in the  costs  of
landfilling  may also contribute to the increase in demand for  other forms of waste
management.

     Other factors that may contribute to  an increase in recycling include:
    •  Feedstock Costs.  If feedstock costs rise, companies will tend to seek higher
       efficiency in the use of raw materials or will seek substitute raw materials.
       Major feedstock categories include:

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   -   Petroleum.  Costs are  not  expected to increase  and may decline in  the
       near term.

       Natural Gas.  The price of gas  may  increase  locally as old  contracts
       expire.  Prices for natural  gas  in  some  old contracts  are  as  low  as
       $0.50/per  million  cubic  feet (MCF).  Prices in new contracts may be in
       the  $2.00 to $3.00/MCF range.  Companies most  severely  affected would
       be chiefly Gulf Coast  plants holding long-term (10 to 20 years) contracts
       initiated in the 1960s and 1970s, which  are now expiring (Chemical \A/eek
       1985a, b).  The implication of  this development  is that there may be  an
       increased use of waste solvent burning for fuel and internal  recycling in
       processes that use natural  gas  as  a  feedstock, such as the production  of
       ammonia and hydrogen cyanide.

       Electricity.  Costs could rise because  of nuclear plant cost overruns and
       increases  in  natural  gas  costs   resulting   from  expiration  of  older
       contracts (Chemical Week,  1985a, b).   This would imply  that there  may
       be an  increase in internal recycling where such  practices would result in
       savings in energy  consumption, such as in the  chloraikali  industry and in
       other  industries (e.g., the aluminum industry)  having high electric power
       demands.  However, the recent drop  in oil prices  may offset this increase
       if it results in lower fuel costs.

       Metals.  Although the  market  for  some  metals is  currently  depressed
       (Chemical Week  1985c,d), a shortage could result in  substantial increases
       in costs.  This situation could provide  significant incentives for increases
       of in-plant and offsite  metals recovery.

•  Foreign Competition.  The  effects of increased  competition from  foreign
   products  could lead to greater domestic production, thus resulting in a need
   for  companies  to  enlist  cost  minimizing  measures.   Recycling  practices
   would be  one  avenue  to reduce costs, although this  approach may be offset
   by concern for product quality.  The use of recycled  materials may result  in
   an  inferior product (or one that is perceived to be so).  Some of the factors
   affecting  increased foreign competition include:

   -   New petrochemical plants  in the Middle East  and OPEC  countries have
       discounted feedstock costs  for crudes.

       Industrialization is continuing in developing countries.

       The U.S. dollar continues to be high abroad, but  is dropping against some
       currencies.

       Present  foreign  competition for  steel  and  manufacturing  segments  is
       strong.

•  New  Technologies.   The  increase in  demand  for treatment and  recycling
   technologies may also spur a growth in  the  development of innovative onsite
   technologies and alternative new  processes based on emerging technology
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        (e.g.,  membrane  separation).  The  demand   for  such  technology  would
        probably be  greatest  among smaller  businesses  who  may  lack in-house
        expertise to develop or  run such technology provided they have the ability to
        pay for  it.  Potentially, market competition may drive  prices down as well.
        The  market  for  innovative  recycling  technologies  would last until the
        market  was  saturated  or until  competition  from technologies other than
        recycling increased. At this point, prices would again increase.

        Replacements of Old Technologies. Old  processes, such as the  mercury cell
        process  for chlorine and caustic soda production, slowly are being phased out
        of existence as older plants are closed and new facilities based on  membrane
        cell technology  are opened.  The new facilities rely on  internal recycling as
        part of the production process and in some cases (such as the membrane cell
        process) do not  generate  any  hazardous  waste. Thus, the replacement of old
        facilities by new ones for this production process necessarily  results in  an
        increase in waste minimization.

        Illegal  Disposal.  Although  there may  be opportunities for an  increase in
        recycling, there may  also be  a potential  for  increased  incidents of  illegal
        disposal.  With  the cost  of  landfi.lli.ng potentially increasing  because  of
        increased technological requirements, generators may look to other options.
        In  conjunction  with increasing costs, treatment standards or bans may also
        be imposed  for  various hazardous  wastes.  Generators who are  concerned
        over  liability (due  to  the  court's interpretation of the  liability  provisions of
        CERCLA)  may  be  reluctant  to  ship  wastes  offsite  for treatment  or
        recycling.  However, some companies may not be  large enough  to afford to
        audit the treatment or recycling facilities. Being small, they may  also lack
        the in-house  expertise  to conduct such  practices onsite.  As a  result, there
        may be a class of generators for whom  illegal  disposal  may appear to be  an
        option.
    In  addition  to  possible  increased  investments  in  onsite  technology,  some
generators also are  likely to  form cooperative  waste "pooling"  arrangements in

which volumes of similar waste streams are combined to collect a sufficient volume

to make recycling economical.  Distance to  recyclers and small individual volumes
of waste materials may make it otherwise uneconomical for smaller companies to
recycle.  Furthermore, waste pooling cooperatives  could realize a cost savings in

joint auditing  of a commercial recycling facility.  For these reasons, there also may

be an  increased demand  for central recovery facilities for metal or  solvents, as
discussed in Section 4.3.


    Waste exchanges will continue to play a  significant role  in facilitating reuse of

wastes as  alternatives to  landfilling are sought; the  adoption of on-line computer

information systems by some waste exchanges is likely  to enhance their  role as well
as the overall  extent of recycling.

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    Finally,  companies'   concerns  over  increased  regulatory  requirements   for
recycled hazardous wastes and future liability for damage due to spills and accidents
during transportation or handling hazardous wastes offsite  may  result in an  increase
in   internally  recycled   waste  streams.  (The   relationships  among  regulations,
concerns for liability, and other factors  that affect the promotion or inhibition of
waste  minimization practices are  discussed in  detail in  Section 5j  The  increase in
such  practices  could  be   achieved by retrofitting  facilities.   Because  it  involves
changes  in  design  and   operation,  however,  retrofitting  existing  facilities  can
sometimes be more expensive than incorporating such features during  the design and
planning of a new plant.  In the  long term, it is likely that   the extent of  onsite
recycling will be dependent on the  replacement  of  older facilities by new ones.

4.5       Summary

    This section has identified  the distribution of hazardous waste recycling  in the
United States by industries and according to the types of  waste streams generated.
Considering  the  wide  range  of  available   technologies  for  reclaiming  many
metal-bearing  and corrosive solutions and spent  solvents,  the  patterns of recycling
such waste streams by high volume generator industries apparently are defined by a
number of  factors.  Distinctions  among major  industries that recycle  or do not
recycle their wastes can be made on the basis of the type of industry  (and associated
waste  generation  processes);   the   total  volume,  uniformity,  and  constituent
concentrations  of the waste streams; and the identification  of uses  or reuses for the
untreated or treated  waste or reclaimable constituents. Some  observations  made in
this chapter that highlight industry-specific factors include the  following:

    •   Three  manufacturing  industries, the  Transportation   Equipment   industry
        (SIC 37), the  Chemical  and  Allied Products  industry (SIC 28),  and  the
        Primary Metals industry (SIC 33),  accounted  for  89 percent of  the total
        volume  of hazardous waste recycled during 1981.  In contrast, generators in
        the Motor Freight  Transportation  (trucking)  and Warehousing   industry
        (SIC 42) did not report any recycling of their wastes either onsite or offsite
        (RIA Generator Survey).
    •   Of the  total volume  of  hazardous wastes recycled  by all industries  in 1981,
        approximately 81  percent were  recycled onsite and  less  than  19  percent
        were recycled  offsite.
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     •  The breakdown of volumes of hazardous waste  recycled according to onsite
        and offsite recycling (Table 4-1) suggests  that the volume of waste recycled
        onsite  increases  as  the  total  volume of  waste  recycle  increases  (i.e.,
        facilities that recycle larger volumes  of  wastes  are more likely to recycle
        onsite than offsite).  Small quantity generators,  on the other hand, are more
        likely to ship wastes offsite for recycling (Ruder et al. 1985).

     The types of hazardous waste streams that  are recycled in the greatest volumes
are  dilute  waste streams  whose  constituent  reuse is appropriate  in large-scale
applications within the generator industry. This is true for the three highest volume
waste streams recycled during 1981:

     •  Spent acids  and  alkaline solutions (corrosivity characteristic  wastes,  D002),
        recycled  in  large volumes by the  Chemical and  Allied  Products industry
        (SIC 28) and  the Machinery-Except Electrical industry (SIC 35);
     ••  Wastewater  treatment sludges from  electroplating (F006)  and chromium
        plating  solutions  (D007),  recycled  in   large   volumes  onsite  by   the
        Transportation Equipment industry; and
     •  Pickle  liquor (K062), a corrosive, metal-bearing  waste, recycled mainly  by
        the Primary  Metals  industry (SIC 33).
These four waste streams  together made up 49 percent of the total volume of waste
recycled during 1981 (RIA Generator Survey).

    The uniformity of a waste  stream is  an important  determinant  of  both  the
technical and economic feasibility of recycling and  reuse.  Generators whose spent
solutions or sludges are contaminated with multiple constituents that are difficult to
separate from each  other may  find  reclamation  impractical.  This problem  may
account  for the  relatively  low volumes of solvent  waste streams that are  recycled,
in  particular  those generated from  the cleaning  of  multiple  contaminants  from
equipment.  Similarly, constituents of halogenated  organic  waste streams, such  as
polyhalogenated   dibenzodioxins  and  dibenzofurans  that  are  toxic  at  very  low
concentrations, limit the recycling of some organic waste streams.

    Other  observations related to the  characterization of recycled  waste streams
include:
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    •   Market demand for and the purity of the recoverable  material determine the
        suitability of the waste for recycling; and
    •   The higher the weighted average concentration of known constituents in a
        waste stream,  the more probable  the  selection  of  recycling  as a  waste
        management  option.

    The technology-specific  profile outlined a number  of  physical  and chemical
treatment options.  The following technologies dominate the recycling profile:

    «   Distillation of solvent wastes;
    •   Dechlorination of halogenated (nonsolvent) wastes;
    •   Various  metal  concentration techniques used  alone  or in combination  on
        dilute metal-bearing waste streams; and
    •   Neutralization of corrosive wastes.

The technologies available for  cyanide/reactive wastes are limited,  although high
volumes of wastewater sludges from electroplating operations are recycled.

    Although not  as  common as onsite recycling,  offsite recycling is  the preferred
option  for  some  generators,  in particular the Primary  Metals industry (SIC 33) and
small   quantity  generators  (SQGs)  of  lead-acid  battery   wastes.   Commercial
recycling  facilities  operate  under a  number of  arrangements  with  generators
depending on the maTket value of the waste and other factors.  The offsite recycling
profile  includes  mobile  facilities  that  recycle  solvents  and  PCB-contaminated
wastes either at a central recovery facility or other commercial recycling facility.

    Transfer of wastes that are not of potential use to the generator but  may  be
suitable raw material for another industry is facilitated by the  listing of such wastes
in  waste exchanges.  Some features of waste exchanges highlighted in this  section
include  the following:

    •   There are two types of waste exchanges available:
        -   Information  exchanges  that  serve  as  clearinghouses  listing  "wastes
           available" and "wastes wanted."
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        -  Material  exchanges  that may  participate  in  the actual  transfer  of
           wastes.   Waste  brokers are  also  available  to  provide  information
           regarding wastes available and companies wanting specific wastes.

     •  Wastes  currently recycled  through  waste exchanges include  acids, alkalis,
        other  inorganic  chemicals, organics  and  solvents,  metal   wastes,  and
        corrosives.  Of the  total wastes listed, from 20 to 30 percent  are eventually
        exchanged.

     •  The  advent  of  on-line  computer  information  systems  by  some  waste
        exchanges  and  the  increasingly  active  role  of  information  exchanges  in
        locating suitable generators'and users of listed wastes indicate a potential
        growth in the types and volume of waste recycled via waste exchanges.


     A number of case  studies were presented,  which illustrate  the  potential  for

organized groups of  small  volume  generators  to recycle their hazardous  wastes  at

central recovery facilities.  Such cooperative  arrangements  benefit  the  individual

generators by spreading  out the capital investment and  operation costs  among them.


     The future extent  of recycling will  be  influenced  by  a number of economic,

technical, and regulatory  factors.   Among the  factors most likely to result in  an

increase in the volume of hazardous  waste recycled are the following:


     •  An increase in the awareness of the economics of recycling;

     •  Restrictions on land disposal imposed by HSWA;

     •  Increases in feedstock costs, including fuel and raw materials;

     *-  Increases In foreign competition;

     •  New  technologies to fill the  demand for onsite treatment technology;

     •  Replacement of older production technologies by newer  technologies that
        rely on internal recycling as  a component of  the production process; and

     •  Increased regulatory requirements for recycled hazardous  wastes shipped
        offsite.


     Contributing to a possible  decrease  in volumes  of  waste recycled  are  increased

regulatory requirements. The  increased requirements and liability issues may cause

some generators to view illegal disposal as an option.
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        5.  FACTORS THAT PROMOTE OR INHIBIT WASTE MINIMIZATION

    Many factors contribute to a company's decision to employ  waste minimization
practices; however,  the most notable pertain to (1) whether it is  economically viable
to do so and (2) whether such practices are technologically feasible.

    Another factor that is equally important is the support  for such programs within
the firm, particularly from  upper management.   To be  successful in  bringing about
changes  in   plant  operation and/or  design, policy-making and  implementation
processes within companies are largely dependent upon  upper management  support.
Pressure exerted by the public, who may perceive  that its health  is being threatened
by a company's operating practices, also plays a significant role.

    An industry's perception of  the laws and regulations  that govern it  is another
factor  in the decision-making process.  The  limitation of alternatives by  regulation
dictates  waste management choices, with the ultimate  decision being the one that
offers  (or is perceived to offer) the "greatest good."   The potential land  disposal
bans,  which are a direct result of  the  Hazardous and  Solid  Waste Amendment of
1984  (HSWA),  may  provide  major  impetus  for considering waste  minimization
practices.

    This section identifies and analyzes the  factors  that may  promote  or inhibit
waste minimization,  focusing on:
        Economic issues;
        Liability aspects;
        Attitudinal issues;
        Consumer awareness and public relations aspects; and
        Regulatory issues.
5.1     Economic Aspects and Technological Innovation

    In this section, the economic parameters affecting a firm's decision to invest in
innovative  technology  are analyzed, with an emphasis  on  investments  in  source
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reduction and recycling projects. The discussion will address both the incentives and
the disincentives for making these types of investments. The balance of this section
is devoted to:

    •   A firm's decision to invest;
    •   Investment in innovative technology; and
    •   Investment in waste minimization.

5.1.1      A Firm's Decision to Invest

    In the macroeconomic sense, there are two types of investment — investment
to  maintain   the  capital  stock and  investment   to  enlarge  the capital  stock.
Investments  to maintain the capital  stock are frequently associated with industries
in which no new technology is being developed. The definition of new technology
includes  innovations that reduce the  costs of production, improve product quality,  or
lead to  new products.   Investments  that  enlarge the  capital  stock are  often
associated with  industries in  which  research  and development, competition,  or
regulatory pressure  have fostered the  development of innovations that reduce the
costs of production or improve product quality.

    From  the point of  view  of  the  individual  firm,  the  ultimate   objective  of
investment activity is  to  increase  its earnings  and  thereby  increase  owner  or
shareholder wealth. The  decision  whether to inve-st is a function of,  among other
things, the investment's expected rate of return and the market interest rate.  All
other  things  being  equal,  a firm can justify an investment in  waste  minimization
technology if the present value of the resulting cash flow is greater  than the current
cost of  the  investment.   This  means that the firm  will increase its wealth  by
undertaking the investment.  The cost of the investment depends, in large part, on
the market rate  of interest.   As  the market  rate rises, investing becomes more
costly.

    Some  of  the  issues that  cloud  the decision-making  process  include  (l)the
ranking of investments in waste minimization in  the context of a limited supply
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of capital, (2) the ability of a firm to raise capital  for investment, and (3) the  true
cost of capital to the firm. The ranking  of alternative  investment opportunities is
frequently accomplished by calculating  the  payback  period, the net  present value,
and/or  the  internal  rate  of  return.   These  methods of  profitability analysis  are
described in Section 5.1.3.  Smaller  firms are  generally  not able to  raise  as much
capital as larger firms and thus face a greater constraint on their overall  investment
capabilities.

    To evaluate  a  firm's cost of capital,  it  is necessary to consider the  firm's
sources of  capital,  as  well  as its  capital  structure.  Sources  of  capital  for a
corporation include:
     •   Long-term debt or bonds;
     •   Preferred stock;
     •   Common stock; and
     •   Retained earnings (profits after taxes plus dividends withheld).
    There is motivation  for  investment in waste  minimization when the cost of
reducing waste is less than the cost of producing the present  amount of waste  minus
the cost  of  producing  a  lower,  future amount.   (Specific  cost categories  where
savings may  be  realized are outlined  in Section 5.1.3.) In other words, the cost to
the firm must be  less than the benefit  derived. Moreover, firms can  improve their
competitive  position  through  waste  minimization,  if   waste  generation  costs
represent a significant portion  of their manufacturing costs.

    The economic parameters influencing investments in source reduction programs
also influence recycling  investments.  As illustrated below,  however,  other factors
emerge as relevant to recycling program investment decisions.

    Economies of scale  (the reduction of unit costs of production through expansion
of the scale  of operations) invariably  have limited onsite  recycling to large  waste
volumes,  with small  quantities consolidated for recycling at  offsite  facilities.  As
offsite  facility  charges  rise  to  reflect  increased  operating  and  regulatory
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compliance costs,  generators  are  able  to  economically justify onsite recycling  of
moderate-volume streams.  At the same time, EPA's reduction  of the exemption
levels of  most hazardous wastes to 100 kg/month  has created a new class  of  very
small hazardous  waste  generators, who  must depend on offsite recycling facilities in
order to survive  economically.  In response to the new regulation  and in  order  to
create  economies  of  scale, the   Neighborhood   Cleaning  Association  (NCA),
representing  1,400  dry cleaning   plants, organized  a  recycling  program  for its
members.  The average dry cleaning plant spends  $600 to $700 a year on the NCA's
recycling  program. This program is described in further detail in Section 4.3.3.

     Small metal  finishing operations are another example of  small  waste generators
who have  implemented recycling programs by creating economies of scale.  For
these metal finishers,  it is  not economical to install  full  wastewater treatment
facilities  to meet industry pretreatment effluent guideline standards.  Instead, trade
associations in several geographic  areas are  attempting to set  up regional recycling
programs.   These  programs  will   concentrate hazardous waste,  using less costly
package equipment in each metal  finisher's shop for routine pickup and recovery by
an offsite recycling facility.

     Purity  requirements  for  chemical feedstocks  also have a  bearing  on the
acceptability  of  recycled  materials.   Those companies that  purchase the  higher
quality  chemicals are less  likely to attempt recycling efforts,  because the recycled
materials   may not  meet  their processing  specifications.  In  addition,  the small
quantities  of  waste available  from such generators are  of little  economic  value to
companies that  have  secondary,   less-critical process  uses.  An  offsite   facility
servicing  a large  number of those small generators could reclaim  a  product that was
reasonably consistent in quality, however.  The salient  market consideration would
then be whether  sufficiently large quantities can be processed to be of commercial
value to secondary users.
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5.1.2      Investment in Innovative Technology


    A firm's decision to  invest in waste minimization may involve the development

and/or application of innovative  technologies.  In  the  context  of  an  investment

decision,  the factors affecting  the development of innovative technologies are also

those  that  influence  the  application  of  existing  innovations.  These  factors  are

summarized below:
        Profitability  and  Risk.  Profit  and  risk  are  the  primary  factors  that
        determine  the  rate  of  investment  in  innovative  waste   minimization
        technologies.  If the  investment  presents  a  high  risk,  it  must  have  a
        corresponding  high  return  to  justify the capital  outlay.  The  first  firm  to
        develop and implement  a new technology may reap competitive advantages.
        The prospect of higher returns from competitive advantage  can serve  to
        justify  the  greater  risk of investing  in research and  development or the
        technological  risk  associated  with  adapting  a  new,  previously  untested
        technology.  Overall,  the higher the profit and the lower the risk associated
        with an innovative waste minimization technology, the  higher is its rate  of
        adoption.

        Cost of the Innovation. Cost  is also a major determinant of whether a new
        waste minimization technology  is adopted.  Expensive  innovations  are less
        likely to  be adopted, because  a firm  tends to be  more cautious  when it
        comes to making large capital expenditures (Mansfield 1982).  Alternatively,
        lower-cost innovations requiring less capital and involving less risk are more
        quickly adopted.

        Capital  Availability  Due  to  Competing  Investment   Opportunities.  The
        availability  of  capital  also  influences  a  firm's  decision  to  invest  in
        innovation.  Firms able to obtain sufficient capital at acceptable cost are in
        a better  position  to  implement  new  waste minimization  technology.  As
        noted above, more  innovation  will  occur  if the innovations are  relatively
        inexpensive  to adopt.

        Availability and Stage  of Development of the  New Technology. Sufficient
        supporting scientific  theory and  applied  research  help to encourage  the
        innovative process and can influence positively  the adoption and diffusion of
        an innovation.  If waste minimization  technology  exists and  can be easily
        adapted to the firm's production needs  and does not interfere  with  product
        quality, it is less costly and less risky than technology that  requires further
        development.  For  the existing  developed technologies,   the  problem  of
        technological  availability  translates into  a  problem   of  availability  of
        sufficient technical  information  detailing  the  engineering  description and
        application history.
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    •   Market and  Regulatory Factors.  To justify an investment  in a new  process
        or  product,  there  must be adequate  demand for the  existing or eventual
        product  in  the  marketplace.  In  most  cases,  if  product demand  is not
        adequate the firm has little incentive to invest in innovation.  A  decrease  in
        demand, however, also can lead  to investment  in innovation, especially  if
        the investment will reduce the unit cost of production and the decrease  in
        demand  is due to price competition from other firms.  In addition, a change
        in market requirements, such as the reality or the possibility of  an outright
        ban on  certain  chemical  constituents  in  the products,  can serve as an
        incentive to invest in waste minimization.  Generally, market forces, such
        as  inelastic  demand  for the product and price competition from  firms that
        have already invested  in the innovation, will provide an incentive to invest
        in  new waste  minimization technologies.  However, highly elastic  demand
        for the product, or the failure of other  firms to invest in the innovation, will
        tend to discourage investment in new waste minimization technologies.

    •   Internal  Production Factors.  These factors also influence  the  decision to
        invest in innovative waste minimization technologies. They  include:

           High  production costs/low profits;
           Equipment  age; and
        -  Problems with maintaining product quality.

        A  firm  may decide   to  invest in  an  innovation  if  it solves an  internal
        production   problem   and  improves  the  firm's  profits  and  competitive
        position.  If  a  firm's-capital equipment  is relatively  new,  the firm is less
        likely  to  apply new waste  minimization  technology  than if its equipment  is
        older and fully depreciated.  If the innovation  will lower production costs or
        improve   product quality,  the  firm has  an  incentive to  innovate.  These
        factors also  may be interrelated.  For  example, old equipment  may result  in
        quality  assurance  problems  and  high  production  costs.   These types of
        production problems tend to influence  the rate at which firms adopt existing
        innovations  rather  than  motivate  the  development of  new  te-chnical
        innovations, however (Rosenberg 1982).
    In summary,  the development or adoption  of  innovative  waste minimization

technology is influenced by a combination of factors, some of which are beyond the

control  of the  firm  and some of  which are  internal to the  firm.  The ultimate

decision by a firm  to invest, however, will be made only after a thorough analysis of

the profit and risks associated with the innovation.
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5.1.3      Investment in Waste Minimization

Identification of Specific Waste  Generation Costs

    One  of  the  compelling   incentives  for  investing  in  waste  minimization
technologies  is the increasing cost and, in some cases,  the banning  of land disposal
of hazardous wastes.  Costs associated  with  the  generation of hazardous wastes are
an element in  a  firm's  unit cost of production.  Waste  generation cost per unit of
output is  a function of waste generation cost  per unit of waste  generated and the
waste-to-output ratio, as follows:

      waste cost        y    unit of waste       =       waste cost            (1)
    unit of waste            unit of output            unit of output

    Equation (1) shows that a  producer can control the impact of waste generation
on unit  production costs by (a) reducing the cost associated with the generation of
each unit of waste,  or (b) generating  less waste per unit  of output.  If  the  costs of
waste generation lie, in large part, outside of the direct control of waste generators,
then  there   is  an  incentive  to reduce  the  ratio  of   waste  to  output  through
investments in waste minimization.

    The costs  of  waste generation are dependent on the costs of  its associated
waste  management.  The  balance  of  this section  provides an  overview  of the
potential  costs  incurred by a  firm  caused by hazardous  waste  generation.   These
types of costs are summarized in  Table 5-1.
    •   Waste  Disposal.  These costs  include  fees  charged by treatment/disposal
        facilities plus any  applicable State  fees and taxes.  Many States levy fees
        and/or  taxes that  may vary according to the volume and type of hazardous
        waste generated, the size  of the generator, and/or the method of  waste
        management.  Waste  reduction can produce  a direct savings in the  form of
        avoided facility  fees and avoided State fees and taxes (see  Section 7.4 for
        more information on State fee and tax systems).
    •   Waste  Transport.  Costs for  long-distance  hauls (excluding local  pickups
        within 25 miles) are generally in the range of $1.50 to $3.00  per  vehicle per
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1308s
        Table  5-1   Costs  Associated  with  Hazardous  Waste  Generation
                                                     Type of cost
    Waste generation cost category             Capital          Operating
Waste disposal (incl. fees and taxes)             X                 x

Waste transport                                   X                 X

Waste storage prior to transport                  X                 x
  (e.g., equipment and handling cost)

Environmental compliance equipment                X                 X
  and predisposal treatment

TSD permits (incl. cost of certifying                               x
  waste minimization)

Reporting on waste minimization activities                          X

Waste manifesting                                                   X

Emergency preparedness and cleaning               X                 X

Pollution liability                                                 X

Excess materials and processing costs                               X
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    running  mile, depending  on a number of variables.  This has the  greatest
    effect  on  small  generators  located  a substantial  distance from offsite
    facilities.  There  is,  in effect,  an  economic  barrier to offsite disposal and
    recycling for small generators—the relatively high unit cost of transporting
    small volumes of waste long distances.  For larger generators who  transport
    their  own  wastes,   the   transportation   costs   associated  with  waste
    minimization are lower per unit of  waste volume.

•   Waste Storage Prior to Transport.  Waste storage requires a commitment of
    labor, land,  and equipment resources  by the  firm.  Space, which could have
    more  productive  uses,  must  be  set  aside.  Machinery  and  personnel are
    required for collecting  wastes, moving drums within the plant, and loading
    them  onto  trucks.   Smaller volumes  of  waste can  mean fewer  resource
    commitments to  storage and handling operations.  It can also mean savings
    in cost from the avoided purchases of equipment, as discussed below.

«•   Environmental  Compliance Equipment and  Predisposal Treatment.  This
    category represents a significant  cost  of waste  generation. Cost  savings to
    the firm from waste minimization can take the form of  avoided purchases of
    compliance  equipment  or  of  lower   treatment costs  resulting   from the
    smaller  volume of waste to be treated.  For example, a manufacturer of
    stationary  power equipment  installed an oil  skimmer  and  ultrafiltration
    system that reduced  the organic load to the  wastewater  treatment system,
    resulting in  a $10,000 annual savings in treatment costs plus a savings in the
    form   of    avoided   installation  of  additional    treatment    capacity
    (Huisingh 1985).

•   TSD  Permits.  Obtaining  treatment,  storage,  or disposal (TSD)  permits,
    reporting  at  least   biennially  on  waste  minimization  activities,   and
    manifesting  waste are requirements imposed on firms by RCRA and HSWA.
    Firms have  to  commit  significant personnel and time  to  meeting  these
    requirements.  TSD permits can be avoided only if no treatment, storage, or
    disposal  activities take place within the battery limits, which implies that
    wastes must be  shipped offsite or recycled/reused onsite within 90 days.
    The reporting requirement remains  as long  as  a  firm is  a  designated
    generator.   The   preparation of manifests  and tracking of  waste can  be
    lessened if the volume of waste going to offsite facilities is reduced.

*   Emergency Preparedness and Cleaning. Firms must  carry fire and accident
    insurance,  employees must  be specially  trained  to  deal with  hazardous
    substances,  and  special  protective  equipment  may  be required.  As  an
    example  of cost savings  in emergency preparedness,  an  engine  painting
    facility switched to water-borne coatings to  reduce its solvent waste,  and
    ended up  reducing   its   fire insurance  premiums  as  well (Campbell  and
    Glenn 1982).

•   Pollution Liability.   Firms  qualifying  as  (TSD) facilities are required  by
    Federal  regulations  to  carry  liability  insurance  or to  maintain  sufficient
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        assets to handle claims independently (40 CFR 264.147(a) and (b)).  The cost
        of EIL coverage depends, therefore,  on the exposure  of  a  firm to current
        claims resulting from  past,  as well as present,  hazardous waste generation
        and  disposal practices.   Consequently,  firms  with  a lengthy  history  of
        landfilling persistent  hazardous wastes  should not  expect EIL premiums to
        fall in the short run on the basis  of  current  reductions.  The  potential for
        reducing premiums in the short  term through waste minimization is greatest
        where  the  generator's  facility  is  relatively new  and  free  from  latent
        liabilities (Humpstone
        Raw Materials  and Processing.  The reduction of waste also implies a higher
        product yield per unit  of input. For a given  production  level, less input is
        required, producing  a  savings in material purchases and processing costs to
        the firm.  Perhaps the most  familiar example of reduced  materials costs
        resulting from   waste  minimization  is  the onsite  recycling  and reuse  of
        solvents.  For  example,  a  manufacturer of  specialized  labels installed  a
        distillation  unit  to recover alcohol solvent  from waste inks. The unit, while
        reducing disposal costs by  74  percent, also  reduced raw materials costs  by
        16 percent (Huisingh 1985).
     Waste minimization projects may not affect all of the cost categories identified

above; rather, the identified categories should be used as a guide  to  where savings
can be realized through waste minimization.


Project Analysis


     The crucial question in  making  an  investment in waste  minimization is  "How
much will the investment return to the firm?"  To answer this question, methods are

required for evaluating the profitability of the investment and comparing  it to  other

investment opportunities.


     Three popular methods  for evaluating  a  project's profitability  are  presented:

payback  period method,  net  present  value method, and  internal rate  of  return (the

last  two methods  belong to the family of  discounted cash flow methods).  These are

discussed in further detail in  Appendix E.
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5.2       Liability Aspects

    The risk  of future liability plays a significant roie in the decisions  of  many
companies in  the  handling  of  their  hazardous  wastes.   Responses  by  company
managers  recorded  in  a  study  by Savant  Associates  (1984)  and  observations  by
participants in a  conference on recycling  and procurement (Kerr  1985a)  indicate
that managers  respond to the  perceived  effects of the  joint and several,  strict,
retroactive, and absolute liability  provisions employed under the Comprehensive
Environmental Response,  Compensation Liability  Act (CERCLA, commonly  known
as Superfund) (Sections 106  and 107) and  the  common  law doctrine.   Generators'
concern  over  future  liability (associated with  the liability provisions  of CERCLA)
may provide an incentive  for considering onsite recycling. Onsite recycling  may  not
be  viable for  companies  lacking the  in-house expertise to  perform such activities,
however.  Also, some companies may perceive  onsite recycling as an undesirable
venture into another business (National Research Council 1985).

5.2.1      Inability to Obtain Insurance

    Many  companies doing business with recyclers are concerned as to whether  the
recycling companies  have adequate access  to  potential liability  insurance.  This
concern  arises  because  an  offsite recycling  facility   could  cause environmental
damages resulting in liabilities in  excess of the recycler's financial  capacity and
insurance limits.  Under Section 107(a) of CERCLA, the generator potentially  could
be  subject to  pay for damages caused by  the  recycler.  Thus,  where recycling
companies are inadequately  insured, the potential future risk to companies sending
their wastes to  the recyclers increases. For those companies with the capacity  to
self-insure, there  is thus  a substantial incentive to dispose  of wastes onsite, rather
than to recycle offsite.

    Over the  past several  years,  the  cost  of  all  forms  of  commercial  liability
insurance  has  risen  sharply,  while  its   availability  has  been  sharply  reduced.
Premiums  have  increased  50  to  300  percent,  policies  have  been  cancelled
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even  where  loss ratios  have been excellent,  and many companies  have difficulty
obtaining coverage  at  any  price.  This  is particularly true  of pollution  liability
coverage (environmental impairment liability (EIL) insurance), which until  1985  was
a  popular financial  instrument used by generators and owners of TSDFs to protect
themselves  from third party and  government  claims  for  damages  resulting from
releases of  hazardous substances to the environment. During the past two years, the
number of insurance companies offering non-sudden pollution liability insurance has
been  reduced  from  14 to  7  (Telego  1986).   Of  those 7,  only 2  write  pollution
insurance on a  stand  alone  basis.  The other  carriers  write  pollution  on  an
accommodation basis through a pooling concept,  as a licensed single carrier, or as a
captive  insurance company.  Those  insurers  remaining in  the  market  have  both
reduced  capacity  and  substantially   increased   premiums  and  have  developed
restrictive terms and conditions within  their pollution insurance  policies.  Pollution
insurance markets  currently writing  third party  liability  insurance  on a monolme
basis  (stand  alone) for non-sudden/gradual and sudden and  accidental occurrences
include the  American International Group and St. Paul Fire and Marine Insurance
Company.  The Pollution Liability  Insurance Association (PLIA) (a  reinsurance pool
of  25 members), Travelers,  Aetna, Wausau  Insurance  Company (recently  merged
with Nationwide and also a member of PLIA), and  Firemans  Fund  are  the only known
carriers  that will write pollution insurance on an accommodation  basis for customers
who have other lines of  insurance  with  them  (Telego 1986, Telego  1985,  Finlayson
1985a  and  b).  PLIA  will provide  limits of pollution insurance only  for its member
companies and their clients.  Continental Insurance will  be  writing pollution liability
insurance on an accommodation basis in mid-1986.

    Analysts of  the  insurance industry  do not  see any  near-term prospects  for
improvement of  the  availability  of environmental impairment  liability  coverage
until mid-1988,  or not until  CERCLA  is amended  to (1) limit liability,  (2) eliminate
the joint and several liability interpretation, and (3) require some type of toxic tort
reform  in State common law.  With respect to item (3),  insurance  analysts would
want changes so that case law will  have a less adverse effect (in the opinion  of the
analysts and potential insured) on the insurance industry.
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    Insurance analysts attribute  the withdrawal  of pollution  insurance  from  the

marketplace   to   the   factors   outlined   below  (Telego 1985,   Telego 1986,

Finlayson 1985a  and b):
    •   Courts have and  continue  to  interpret  insurance  policies in favor of  the
        insured in a vast majority of coverage disputes.

    •   Courts continue to impose joint and  several, strict, and absolute liability
        under the doctrine of  common law and under Superfund (unless Superfund is
        amended).

    •   The  underdeveloped  actuarial  data  base  overlapping Federal  and  State
        statutes is affecting  underwriting procedures  and  results.  Primary  and
        reinsurance  carriers  experienced  their  worst underwriting results in 1984
        (loss of $3.5 billion) since 1906.

    •   Insurers exhibit little  confidence about the predictability  of  pollution  risks;
        therefore, underwriting is extremely uncertain.

    •   The lack of a  developed actuarial data base, (as perceived by insurers) from
        which to price and reserve against unforeseen  losses  leaves  underwriters
        with few options to protect net worth  and shareholder surplus.

    •   The   lack   of  technical   data,   uniform   risk   assessment   guidelines,
        industry-written underwriting guidelines, and the absence of  mechanisms  for
        transfer and use  of those  data to  insurers  regarding disposal of hazardous
        substances at treatment, storage, or disposal sites, increase  uncertainty  and
        potential liability.

    »   Adverse selection brings the most severe risks into the market.

    •   Possible  long-term  effects   from   long   latency   of  an  exposure   or
        environmental  damage increase uncertainty.

    •   The  multiple-exposure  effect  subjects  reinsurers   to   exposure  under
        numerous policies.
    The major reason for the current insurance capacity shortage  is the insurance
underwriting cycle.  In the late 1970s and early  1980s when interest rates were  at

their highest, two factors made  it possible  for insurance companies  to maximize the

range  of coverage  offered:   (1) the direct interest  earnings  of the  companies

themselves, and (2) the  volume  of  reinsurance  offered by  overseas  companies
                                      5-13

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attracted by the high U.S. interest rates. At  this time,  most of the reinsurance  was
retroceded to the London marketplace through domestic and foreign reinsurers.

     While interest rates  were  high,  many insurers  made  an  effort  to attract
customers by writing premiums and  policies that  were underpriced and inadequately
covered  by  reserves (cash flow underwriting).  Such policies  were secured against
losses suffered on those policies by high earnings  on  interest income.  When interest
earnings fell in late 1983 and early  1984, many companies were left with insufficient
interest earnings to offset their losses or potential claims/losses on such policies.  In
order to reduce their exposure, they simply ceased providing coverage where losses
seemed least predictable,  or where  the  premiums that would have to  be  charged to
protect against that uncertainty seemed too  high for the market to bear. Numerous
reasons caused reinsurers to leave the pollution marketplace. Among them were  the
decline  in interest rates  in  the  U.S.  and  the judicial  determinations on  old CGL
policies.  These factors directly  caused losses disproportionate to  the  amount  of
premiums retroceded because  of low primary retentions and low premium rates  for
higher layers.  The catastrophic nature  of environmental losses would  consume  the
excess or reinsurers' layers.  The  result was a substantial shrinkage in  the amount of
insurance capacity primary  carriers  could  offer  potential insureds.   Capacity
dropped  from  a high  of $165 million  in coverage  offered in 1983 to a maximum
$10 million  in  coverage today, with limited excess capacity. The  only  possible
excess capacity being developed  may be through offshore  captives (mutuals,  stock,
reciprocal exchanges, and future syndicates/pooling arrangements).

    While  none  of  these  difficulties  are  necessarily  irresolvable,  the apparent
tendency  toward  high  awards  and  broad judicial interpretations  of the extent  of
coverage in  liability litigation has made insurance companies increasingly  leery  of
such  policies.   There  have  been  recent  court  cases,  such  as  that  in  Jackson
Township, New Jersey, in which the potential for loss of quality of life (absent any
current  injury), provided  the  basis  for financial awards. Such decisions have made
many in the  insurance industry feel that  the potential exposure  is far too  high to be
met by any feasible premium level.

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    One possible result of  this.situation is that companies that can  self-insure  may
have access to stop-loss insurance, if it is available. Many recyclers, however sound
their operations, may  not  be large enough to be able to self-insure.  This  provides
generators with  an added disincentive to risk becoming involved  with an offsite
recycler.

    To  meet  this problem,  some  companies and  associations   are  attempting
innovative approaches to  secure  adequate  insurance.  Self-insurance is  only one  of
many alternatives, however. Companies are also looking  to form association stock
and  mutual captives,  risk retention  and  purchasing  groups,  self-funded insurance
with stop-loss excess insurance, and  retroactively financed  plans.  In one case,
members  of an association are approaching potential insurers to front their program,
hoping that the lure of the insurance  premiums/commissions from the  members will
provide adequate incentive for the insurer to write policies for each of the member
companies.  Ideally, this  could  involve an  arrangement  whereby  basic  coverage
would be  provided by  the captive, which  would purchase higher  levels of coverage
from  a reinsurer,  if  reinsurance can  be found.  The  reluctance  of  reinsurers,
however,  to deal with  environmental liability means that  such captives may have  to
be  fully  funded  up front  by  the company  or companies  involved, and  not  all
companies can  afford such  a  capital outlay. There are  also  other  difficulties
involving  capitalization,  loss reserving, loss prevention, and  general administration
to the captive.

5.2.2      Cleanup Costs

    As  discussed in the previous section, the cost  of cleaning up a hazardous waste
site  is  a  potential liability.  In  order  to  minimize  risks  of liability  for future
cleanups,  some  firms  may  be  encouraged to  invest  in source  reduction (which
reduces the amount of  waste generated and for which a  company  may be liable) and
onsite recycling programs  (which  reduce the amount of wastes shipped offsite).  To
determine the  extent  to which liability  for  cleanup  costs  promotes  waste
minimization, it is necessary to answer  two questions.   First,  how do firms perceive
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their  responsibilities  for  waste   minimization  in  light   of  current  Federal
regulations?   If firms understand  that the  law  will require  them  to clean  up
hazardous  wastes,  this  prospect  of  liability  for cleanup  would  be expected  to
promote  waste  minimization.  (This  question  is   the  subject  of   Section  5.3,
Attitudinal  and Organizational Aspects.)  Secondly,  what are the costs associated
with the cleanup of a hazardous waste  site?  These costs  must be clearly delineated
before they can influence investment decisions.

     Because  cleanup  costs  are  such  a  critical  issue for waste  minimization
investment decisions, it is important to develop a model of the  costs associated with
remediating a hazardous  waste site.  The diversity that exists among waste sites and
treatment technologies, however, makes it difficult to create  a  representative cost
model.  For example, in the past a large number of  waste sites  have  been landfills.
Relative to other  sites such as chemical or manufacturing plants,  landfills have  a
low  degree of  variation  in cost.  Nevertheless, there are  substantial differences
among landfills  in terms  of size, topography,  extent  of  subsurface  contamination,
leachate formation,  proximity to houses and wells, and degree of ground-water
contamination.

     In addition, there  exists a high degree of variation among  hazardous  wastes.
Wastes  can be  distinguished not only by quantity,  but also  by  biological impacts
(degree of toxicity, carcinogenicity,  mutagenicity, teratogenicity, and  subchronic
and  other  toxic  effects)  and by physical  and  chemical features  (such  as  their
physical  state,  mobility,  reactivity  to surrounding  chemicals,  ignitability,  and
corrosivity).

     Finally,   there   are   numerous   types   of  treatment   technologies.   These
technologies  can  be  classified  into   three  categories:  physical, chemical,  and
biological.  Table 5-2 lists some of the treatment technologies that were identified
in a  1977 EPA study (U.S.  EPA  1977).

     In light of these variations in hazardous waste site cleanup  costs,  the  balance of
this  section is devoted to  identifying  and  modeling  the  main elements  of cleanup
costs.
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1308s
                 Table  5-2   Treatment  Processes  Identified
    Physical
Biological
    Air stripping
    Suspension freezing
    Carbon adsorption
    Centrifugation
    Dialysis
    Distillation
    Electrodialysis
    Electrophoresis
    Evaporation
    filtration
    Flocculation
    Flotation
    Freeze crystallization
    Freeze drying
    High gradient magnetic separation
    Ion exchange
    Liquid ion exchange
    Steam distillation
    Resin adsorption
    Reverse osmosis
    Sedimentation
    Liquid-liquid extracting of organics
    Steam stripping
    Ultrafiltration
    Zone refining
Activated sludge
Aerated lagoon
Anaerobic digestion
Composting
Enzyme treatment
Trickling filter
Water stabilization pond
Pretreatment of
bulk sol ids of tars

Crushing and grinding
Cryogenics
Dissolution
    Chemical

    Calcination and sintering
    Catalysis
    Ctilorinolysis
    Electrolysis
    Hydrolysis
    Microwave discharge
    Neutralization
    Oxidation
    Ozonolysis
    Photolysis
    Precipitation
    Reduction
Source:   U.S.  EPA 1977.
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Factors That Influence Cleanup Costs

     We begin by listing the principal determinants of cleanup costs:

     •   Initial engineering feasibility study for remedial action;
     •   Site conditions;
     *  The nature and quantity of the wastes;
     •   Disposition and storage of the wastes at the site;
     •   Interaction of the wastes with the site and with  other wastes;
     •   The  type of  treatment,  haulage,  and disposal needed to  meet regulatory
        criteria (e.g., allowable residual  contaminant levels); and
     •   Closure and post-closure requirements.

     Based on these determinants,  a  matrix of cost elements for a typical cleanup
can be created.   One such matrix is listed  in Table 5-3". Most of  the  cost  elements
shown  in  this table can be broken down into  their constituent factors, such as raw
material  costs,  skilled  labor costs,  unskilled   labor  costs,  equipment  rentals,
insurance, taxes, and  permits.  To  obtain specific data  for  these  cost  elements,
research  focused on  the  following sources:  studies  on  site  feasibility,  vendor
quotations,   contractor  bids,   actual   remedial   construction  costs,  publications
describing hazardous waste cleanup projects, and in-house errgineering and cost data.

Cleanup Costs by Site-Type

     EPA  sponsored a 1983 study of  82 hazardous waste  site  cleanups (Wise  and
Amman 1983),  which examined the  cost elements listed in Table 5-3 in more detail.
As expected, they  found wide  variations in cleanup costs.  Not only did these costs
vary  according  to  the  factors  mentioned above  (waste   characteristics,   site
characteristics, etc.)  but  also by EPA  region.  For example,  they  found  that  the
average cleanup  cost  per  site for Region  1,  based  on data from seven sites,  was

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      1317s
                                       Table 5-3  Factors That Influence Cleanup Costs of a Hazardous Waste Site
                                                                        Elements  that  influence  cost
                                    Lab &
                                     eng.        Quantity    Waste   '   Site      Onsite                                                   Other
                                    studies      or size     type     features   treatment   Fence   Removal    Transportation    Disposal*   costs
on
i
Storage method
Drums
Tanks
a. Waste
b. Tanks
Lagoons, ponds, and pits
a. Liquids
b. Sludge

Y

Y
Y

Y
Y

Y Y

Y Y
Y

Y Y
Y Y

Y P Y Y Y

— P Y Y Y
Y _ — — Y

Y P Y Y Y
Y P — Y Y

Y

Y
Y

Y B,C
Y B,C
       Extent  of  contamination
Soil
Bui Idings
Leachate development
Ground water
Municipal wells
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
P
P
Y
Y
Y
Y
Y
Y
Y
Y
Y
—
Y
Y
—
Y
—
Y
—
—
Y
—
Y
—
—
C

M
M
M
       "Disposal  can  occur as  incineration, offsite treatment, deep-well injection, or landfill.
          Y -  Needed
          P =  Possible
       Other costs:
          B  = Backfilling
          C  = Capping
          M  = Post-closure  monitoring

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$6.9 million  for  capital  costs and  $0.3 million  per year  in  operating  costs.  In
Region 3,  the average  cost  per  site  was  $5.0 million   for  capital  costs  and
$0.3 million in annual operating costs.

     Table 5-4 lists  the average cleanup cost by type of site,  based on the 1983 study
noted  above.  Landfills had the highest capital costs, $7.55 million, and the highest
annual  operating costs,  $0.56 million.   Lagoons  had  the  lowest capital   costs,
$2.55 million, as well as the lowest operating costs at $90,000 per year.

     For the 80 cases studied, the weighted average capital cost was  $5.7 million  and
the weighted  average annual operating cost was $340,000. These weighted average
costs can  be  considered the "typical" cleanup costs of a hazardous waste site.  Two
points should  be kept in mind when evaluating these data. Sites on the EPA National
Priority List, on which the above cost study was done, are generally more  expensive
to clean up than  the "average" hazardous waste site.  This is offset, however,  by the
fact that the EPA is adopting more stringent  standards (e.g., lower  allowable levels
of residuals) for cleaning up these "average" sites.

     In  summary,  a  company  that  generates  hazardous  wastes creates  negative
externalities  (i.e.,   impacts  external   to   the   company).   Because  hazardous
waste-generating  companies may  be individually  and jointly  responsible for  the
cleanup costs of  hazardous  waste, waste generators shoulder the  social  costs of
generating  hazardous  wastes.  Consequently,  the  future  opportunity  costs of
generating hazardous  waste  have  risen  significantly for generators.  Opportunity
costs refer to those investments  and therefore those positive  cash flows that  are
foregone,  because the generators' resources are  being devoted to the cleanup of a
hazardous  waste   site.  This,  in  turn,  should provide  yet  another incentive  for
generators to invest  in technologies and processes that reduce waste at the source.
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1308s
        Table 5-4  Average Estimated Cleanup Cost by Type of Site
                                    Average  capital      Average  annual
                         Sample      cost  per  site       operating costs
                          size        ($ million)          ($ million)
Landfill
Wells
Industrial dumps
Chemical plants/
refineries
Manufacturing plants
Pure lagoons
Weighted average
30
7
25
10
4
4
80
7.55
4.76
4.26
6.58
3.51
2.55
5.7
0.56
0.49
0.13
0.26
0.20
0.09
0.34
Source:   Wise and Amman 1983.
                                  5-21  '

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5.2.3     Liability as an Incentive for Onsite and Offsite Recycling

     The  more sensitive a corporation is  to the potential for future environmental
liability, the more likely it is to look for ways to maximize control over the eventual
fate of hazardous wastes.  Where it is feasible to  recycle onsite, that is likely to be
a high priority.  Where recycling would  mean sending the waste offsite, other onsite
disposal alternatives  including landfilling  may be  preferred.  Under RCRA, oxvners
and  operators of TSD facilities  must  demonstrate financial  responsibility  (40  CFR
264  Subpart 4).  An offsite  recycling  facility could  cause  environmental  damages
resulting  in liabilities in excess of the recycler's  financial capacity and  insurance
limits required under  RCRA.  This may result in the firm's declaring bankruptcy.  As
a  consequence,  the  generator could  potentially  be  subject  to uncertain  future
liabilities under  the  court interpretation  of  CERCLA's strict,  joint, and several
liability provisions.

     Even  where  care  is  taken in  the   selection of  an  offsite  recycler,  many
companies indicate that,  since  the  generator remains responsible for  any waste
mishandled  by the recycler, the potential liability  far outweighs  any  short-term
economic  benefit.  A  lawsuit  or third   party  claim  could  hold  all  generators,
transporters, and recyclers joint and severally  and  strictly liable.  (Such  an attitude
could present a special  obstacle for those waste exchanges that actually buy and sell
wastes, since careful  pre-screening of  the eventual purchaser/user  of the  waste is
likely  to  be  problematic.  It would not, however, necessarily  preclude an expansion
in the role of active informational  waste exchanges, which  put the generating  and
purchasing parties together to arrange  any sale.)

     If a company that sends its wastes offsite  is aware  of this problem, it will  make
every  effort  to  pre-qualify  the offsite  waste   management  or  recycling   firm
involved.  Pre-qualification involves an examination of  the environmental, business,
and regulatory aspects of the recycling facility, as well as a review of the recycler's
pollution insurance contracts. The  fundamental question is how well any disposal or
recycling  service is equipped  to protect the original generator from  future  liability.
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This means analyzing the recycler's risk  management  and insurance situation, its
sales  volume,  its  loss control and  loss  prevention techniques, its  environmental
setting  and  site  characteristics, the  inherent  toxicity  or  hazard  potential of
chemicals  being  used,  as  well  as  their transport,  fate,  and persistence in the
environment,  and  the overall environmental  management practices relative to
pollution  control  technology  and potential  receptors  (e.g., population centers or
ground-water aquifers).

    To  some  degree,  the issue of liability can make offsite recycling preferable to
offsite  landfilling.  Generators  who  do not  have  the  facility  for onsite disposal,
treatment, or recovery are forced to consider offsite waste management.  Although
the options of  offsite recycling  and  offsite land  disposal both present risks, the
latter  alternative  may  be  seen  as  less  risky.   Offsite  land  disposal  offers the
potential  for improper landfill design,  and also  does not reduce the amount of waste
ultimately disposed of in this  manner.   Offsite recycling,  while  still presenting the
potential  for  improper management, affords  the  opportunity for a reduction in the
amount of land  disposed waste; in some instances,  there  is the possibility of  zero
land disposed  waste  if  no  reclamation  (causing residues  that are  hazardous) is
involved.  Familiarity with  the offsite  recycler  again plays a  role, as  does the
amount of waste generated  in making  this decision. If  the waste generated is below
the minimum amount  required  by  some  recyclers,  the  generator  is forced  to
accumulate and store it onsite, thus requiring  storage  permits  in many cases.
Permitting costs may preclude this  as an  option,  however  (see Section 5.5.6 for
further  discussion of this issue).  A critical factor in making liability  an issue in the
waste  management decision is  the  aggressiveness of  the  Federal  and/or  State
environmental policies, regulations,  and enforcement action plans that affect  both
corporate officer and corporation  liability.

    The increasing number of citizen suits and  community right-to-know laws  will
create  greater  incentive to recycle waste in order to  preclude real  or perceived
liability from the mishandling or mismanagement of hazardous wastes. Wastes sent
to a recycler, however,  frequently result  in  residuals  that are shipped offsite by
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the  recycler  (e.g., organic still bottoms). These residual  wastes may remain  the
responsibility of the generator,  however. This means that there are likely to be at
least two sites  (in addition to transport) where mishandling  could occur. Even if the
generator has pre-qualified the recycler, uncertainty about (or the  additional cost of
pre-qualifying)  the second  user makes  such  a  transaction  less attractive.  Onsite
disposal subject to the direct  control of the  generator  may  appear  to  pose less
future  risk.  For those companies with  the  resources and in-house expertise, onsite
recycling may be a preferred option.

     Another aspect  of the  effect  of liability  on  recycling  is its relationship  to
transporters.   A  transporter  involved  in  a  spill  of hazardous  wastes  faces  an
equivalent amount of financial liability as that  associated with  a  spill  of hazardous
materials that'  are not wastes.  The immediate  costs of  the transporter's  insurance
(assuming he can  obtain it) should be the same.  That is,  if  he is the carrier, he is
responsible  for  the  damages  caused by  spills of  either  hazardous  materials  or
hazardous  wastes.  Under  the  CERCLA statute,  however,  the  transporter  may
potentially be  held liable for damages caused by  subsequent releases  of hazardous
materials that are delivered  to facilities for treatment or disposal  (Section  107(a)(3)
and (4) of CERCLA).  Thus, if the company accepting the waste spills the  material,
or  the residues  from  the  reclaimed  solvent  are  deposited  in  a  landfill  that
contaminates  drinking  water in the future, the  transporter  may be  held financially
responsible,  depending  on   the  circumstances  and  the   outcome  of  the  court's
decision.  Conversely,  a  transporter  may deliver  virgin  solvent to a company  that
uses it in its manufacturing  process.  The company  generates a spent solvent that is
a  hazardous  waste  under RCRA.  The  transporter of the raw  material would not
generally  be  held liable  for damages resulting  from the subsequent  transport  or
management  of  the waste generated from processing the raw material.

    Presently,  transporters are able to  obtain  insurance for their  own activities.
Insurance for  future  liability  caused  by  others  is extremely  difficult,  if  not
impossible, to  obtain.   As  a  result, transporters  of hazardous waste, in  order  to
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ensure  financial  responsibility,  may charge  larger  fees  than  for  transport  of
hazardous  substances  that  are  not delivered  for  treatment  or disposal.  The  fee
charged would be to ensure  that the transporter could self-insure.

     The effect  of  this situation is likely to result in a preference for the use of raw
or virgin  materials in processes,  as opposed  to  materials that  may  need  to  be
reclaimed  prior to use, since the  cost  of transporting  raw  materials  would  be
cheaper. Spent  materials that could be used directly  without prior reclamation may
be  in  the  same category  as raw  materials  because  of  recent changes in EPA's
definition  of  solid  wastes  (as  discussed  in  further  detail  in  Section 5.5.2 and
Appendix  F).  Under the revised  regulations, materials that  are used as effective
substitutes for virgin materials without reclaiming prior to  or during the process are
not solid wastes.  As a result, these  materials are equivalent to raw materials, and
do not need to be manifested.

     Depending on the  nature of the  waste  to be recycled, therefore, raw  materials
may  be  less  costly  (and  thus   preferable) to  use  than  waste  materials in   a
manufacturing process.  Given a choice between a virgin materiel  and  a waste that
must be shipped and  processed prior to  use, a company  may prefer to use virgin
materials.   Liability may thus play  a role  in  this  cost  barrier  associated with
transportation.

5.3       Organizational and Attitudinal Aspects

     This section addresses  the organization and implementation of environmental
programs  within private  companies,  summarizes some  industry  perceptions  of the
regulation  of hazardous  waste under  RCRA, and touches upon some of the origins.of
opposition to change within  organizations.  Information for this section was gathered
primarily  from  sit-down  interviews  with environmental personnel in the  chemical
industry; from telephone  interviews  with environmental personnel in the  chemical
industry; from telephone interviews  with private companies and  trade  associations;
and  from  a  review  of  industry  questionnaires  summarized  in  the  materials
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distributed  at  the Woods Hole  conference (LWVM  1985).  Further insights  were
provided  by  examination  of  sources  dealing  with  organizational behavior  and
corporate environmental expenditure policy.

5.3.1      The Organization of Environmental Programs within Firms

    Corporate environmental departments began  to  appear in  the  1970s after the
Clean  Water and Clean Air Acts  had established guidelines for industry effluents and
emissions.  The concentration  of environmental expenditures at that time  was in
end-of-pipe  treatment  equipment,  which  reduced the  environmental  impairment
potential of industrial discharges into air  and water.  Waste reduction, within the
framework of  corporate policy,  was carried out more  from an  operating efficiency
perspective, however. The aim was to increase product  yield and reduce  material
costs  in  an effort to improve  profits; waste minimization  was  coincidental.  Waste
minimization also occurred during the energy crisis  of  the  1970s  when  rising oil
prices  were  having  an  inflationary effect on  manufacturing  costs.  As  a  result,
attention turned toward reuse of  fuels and incineration of wastes to  extract  energy
value,  which was previously uneconomical to recover.

    Corporate  waste  management policies were  redrafted when regulations were
developed  in 1980 to  enforce  provisions of the  1976 Resource  Conservation  and
Recovery   Act.   The  hazardous  waste  manifest  tracking  system and  new  waste
disposal   requirements   placed   heavier   demands   on   firms'    environmental
departments.   Strategies  were  revised  to  address  methods  of reducing  waste
generation  and  of optimizing the treatment or disposal  of  any  waste generated after
all  obvious waste minimization  steps  had  been taken.  These  strategies were
reinforced  in  1984 by:  (1) Section 224  of  H5WA, which required  that all  waste
manifests and  onsite TSD permits be accompanied by a  certification of efforts to
reduce the volume and/or toxicity of  the  hazardous waste generated;  (2)  the  land
disposal  restrictions  also  contained  in  HSWA;  and (3) the   potentially  severe
liabilities for hazardous waste generators and  disposers established under CERCLA.
The possibility  of being targeted  as a  "deep pocket" under the court's interpretation
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of the joint  and  several  liability provisions  of  CERCLA and  the  lack of any time
limitation on environmental impairment liabilities have contributed  to greater waste
minimization emphasis within companies.

    Many large companies organize their environmental efforts  in a manner similar
to the structure described in Figure 5-1.  A corporate environmental affairs office
is  located  at  corporate  headquarters   and  links  corporate  management  to  the
environmental  activities  of  the   operating   divisions  and   individual  plants.
Environmental  directives are issued by corporate management to the environmental
affairs office,  which develops  the environmental program  for  the company.  The
elements of the program are transmitted to the operating divisions via  instructional
memoranda  or guidance documents, and  the corporate environmental affairs officer
typically is  charged with  program oversight, assistance, and progress  review.  The
actual environmental projects are implemented  within  the  operating  divisions by
plant-level personnel.

    A  variation  on  this   approach  to  environmental  tasks  is  also   shown  in
Figure 5-1.  Here, a  task force is formed  consisting  of engineers with environmental
and  process experience.  The  task  force travels  from  plant  to  plant  to  review
production processes and operating procedures,  and  it recommends  improvements in
production efficiency  and waste minimization  to plant and corporate management.
Companies  using  this  approach  have  found  it more  effective  than relying  on
operating personnel to  initiate environmental  projects.  The approach  requires a
greater commitment of resources, however.

    The environmental responsibilities  for  smaller companies  and  businesses  are
usually  handled by  an  individual, often  the owner and/or general manager of  the
plant, who is primarily  concerned with overall plant operations  and profit margins.
Environmental  matters often are not of primary interest.  Examples of substantial
waste minimization  and cost savings can be  found  among smaller firms, however.
Attention is  turned  toward waste minimization when  costs must be cut and/or when
regulatory approval or interaction is involved.
                                      5-2"

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                         CORPORATE HEADQUARTERS
CORPORATE ENVIRONMENTAL
      AFFAIRS OFFICE
                                                             ENVIRONMENTAL
                                                           TASK FORCE/ADVISORY
                                                                COMMITTEE
        PLANT
PLANT
                                                              PLANT
                 Figure 5-1  Organizational Structure for a Typical
                        Corporate Environmental Program
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5.3.2      Company Pohcy-Making and Policy Implementation Processes

    Most major  corporations  have a formal environmental policy  statement that
includes  mention of  waste minimization or materials  conservation.  The statements
have  generally  been  formulated  by  corporate  management  (director  level)  and
endorsed by the chief executives.  At  some companies,  environmental policies went
into effect in the early part of this century, while at others policies are much more
recent.   Environmental  policies  are  updated  as  necessary   to  reflect  new
developments.

    Projects are  devised  by onsite plant  personnel  with  oversight and  assistance
from  the corporate  environmental  staff.  This reflects  the site-specific nature of
waste minimization  and other environmental  projects. Prior to implementing waste
minimization projects, company personnel will usually:  (I) set priorities for waste
stream reductions according to  the volume, toxicity, cost of treatment/disposal, and
waste-to-product ratios of each waste stream; and (2) establish waste minimization
goals, technical requirements, and time schedules for each waste stream.

    Operating  managers   are  held  accountable for  waste minimization  progress,
which  is  reported  to  corporate  management  at  regular intervals.   To  aid  in
monitoring  and  tracking   waste  minimization progress,   many  companies  have
constructed computer data  bases  containing information  on waste stream type,
RCRA waste code, and volume generated. Waste minimization statistics,  along with
other  environmental data,  are  sent   to  corporate  management  at  least  once
annually.   Standard  reports  to   management, which  are  influenced  by  waste
minimization statistics, include reports on operations improvement plans, product
yields, raw materials consumption, and employee suggestion  projects.

    Problems may arise in  larger  companies when environmental managers do not
communicate or interact effectively with their production-oriented  counterparts or
those  who  are  responsible for research and  development.  Engineers involved with
project development and process design  may not be familiar with the technical and
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regulatory problems associated with waste disposal or the economic, environmental.
and   public  relations   benefits   of  waste   minimization.   Moreover,   engineers
responsible  for production operations may not be fully  cognizant  of  the problems
associated  with   hazardous   waste  handling  and  disposal  and  the  potential
environmental liabilities associated with  generated  waste streams.  If  actual  costs
and  waste problems  are  communicated to these engineers and plant operators, the
rationale  for  applying  new  waste  minimization   technology  becomes  clearer.
Effective  communication  of  the  corporate  waste  minimization  policy  to  all
operations  levels  contributes  to  the  implementation  of  a  successful  waste
minimization  program.   Furthermore,   it  is often  helpful  for a  new  waste
minimization process or  method  to  be promoted by  a  "champion," a  high-ranking
individual who is actively committed to waste minimization and  who makes efforts
to overcome both  developmental problems and the  general  inertia that protects
existing, but highly waste-producing, practices.

     Some  companies have  employed  education  and incentive  programs to  raise
awareness about  waste generation.  Waste minimization newsletters,  cash awards,
and  certificates  are  used  to  increase employee awareness  and  motivation.  Trade
associations  sponsor seminars  and  workshops on  waste  minimization  in  which
member firms take part.

     In  smaller  firms,  pollution  control  policy  making  and  implementation  are
carried" out on a case-by-case (e.g., regulation-by-regulation)  basis.  Long-range
environmental planning is uncommon.  Small businesses regularly implement policy
by hiring  consultants in order to learn what is required and how to achieve  waste
minimization. The consultant's advice is acted upon by the owner/plant  manager,
who  usually  commits operating  personnel to these activities on a part-time basis.

     Some small  operations  concentrate   on  a common  sense/good  housekeeping
policy approach.  This  is  done in  industries  where  the production  technology is
relatively established and  readily  available,  e.g., in paint  manufacturing.  Trade
associations and  waste  exchanges  are valuable waste  minimization resources for
small businesses in particular.
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5.3.3      Industry Perception of RCRA

    Although government regulation of industry is not new, extensive environmental
regulation  is a  fairly  recent development.  The 1976  Resource  Conservation and
Recovery  Act  (RCRA)  and  the  subsequent  1984  Hazardous  and  Solid  Waste
Amendments (HSWA) set down  nationwide  requirements for industry.  Reaction to
the legislation  among  private  companies has been  mixed.  Congress is  viewed by
some   in   industry  as  having  mandated   strict  compliance  schedules  without
considering EPA's capability  to  implement  regulatory  programs  by the desired
dates. The result has  been uncertainty  over deadlines, changing requirements, and
complex regulations,  all  of which  create coordination  difficulties for company
planning.  An expression often heard is that companies must plan  around  a "moving
target."

    Furthermore,  some   companies   perceive   that   RCRA  is   implemented
inconsistently throughout the United States.  RCRA programs are viewed as  being
inconsistent or  lacking uniformity among EPA  regions and  among the States that
administer RCRA programs, causing  industry to  be  subjected to an endless process
of permitting  in order to comply  with both State and Federal regulations.  Industry
is concerned that  States administering  RCRA  programs cannot always be  objective
and nonpolitical in  their  decision-making  because  of local pressures against the
permitting and siting of TSD facilities.

    Complicated permit application and  information submittal procedures  mandated
under RCRA and HSWA are viewed as  making "good faith" compliance difficult and
costly.  Because of the  high cost  and  significant amount  of time associated  with
obtaining  RCRA  permits,  many  companies  are  reluctant  to  get  involved  with
hazardous waste treatment, recycling,  and  storage  activities.  As disincentives to
securing RCRA  permits, companies cite permit application costs up to $250,000 and
months  spent  interacting with EPA  officials.   In addition  to  these  disincentives,
generators  who  engage  in onsite  volume/toxicity  reduction  efforts  are  often
confronted, when applying for RCRA permits, with the following:
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     •   Possible exposure of proprietary technology;
     •   Possible adverse media coverage; and
     •   Continuing EPA compliance activities.
     Further barriers to obtaining RCRA permits have  been cited by  industry.  One
barrier,  which stems  from HSWA,  focuses on RCRA  Section 3004  (u), a provision
requiring that, as a condition  of a  RCRA permit, prior environmental  releases of
hazardous wastes  of  constituents  be  corrected or  cleaned up and  that financial
responsibility be assured for completing  all  corrective  actions.  This  "corrective
action" provision is viewed by industry to be a barrier  to  any company's attempt to
establish a waste treatment, disposal, or recycling business in an industrial area.

     Some companies believe that the recent revisions  to  the solid waste definition
in EPA's regulations under RCRA provide other disincentives to waste minimization,
most notably  in the waste recycling area.  To support  this contention, industry has
provided specific examples of  how EPA's January 4,  1985, definition  of  solid waste
tends to restrict the  recycling  of  certain types  of  wastes.  This  is described in
further detail in Section 5.5.2 as well as in Appendix F.

     Notwithstanding  the  uncertainties  and  possible  misinterpretations   of  the
definition of solid waste, the  increased number of wastes  requiring  manifests under
the  regulation relate  to  the  concern expressed over the  difficulty of delisting. In
particular, a waste sent to  an  offsite recycler would  yield a residual  for which  - if
not  delisted -  the original generator of  the  recycled waste could  bear liability.
Since  some  of these  wastes  were previously  exempted  from  the  manifesting
requirement, the number of waste streams for which delisting petitions may be filed
may increase.

     The following  is a  list of  other RCRA-related  issues  viewed by  industry as
disincentives to hazardous waste minimization programs:
    •   Permitting  requirements  -  Source  reduction  sometimes  requires  the
        installation  of  new  machinery  that  can,  under  RCRA,  be  considered
        "treatment."  This in  turn could require  a  generator to obtain a permit as a
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        treatment,  storage,  and disposal  facility (TSDF).  This permitting process
        can be expensive and generally requires  two  years  to complete.  In  addition,
        HSWA  Sections  3004 (u) and (v) require permitted  facilities to conduct
        corrective action to  clean up any  contamination that could have previously
        migrated from their facility.

    •   Storage  requirement - The  requirement that a permit must be obtained to
        store hazardous waste for longer  than  90 days is  a  disincentive to recycling.
        For some batch  chemical operations, wastes must be  stored longer than 90
        days in order to accumulate enough reactant  for the batch process.

    •   Mixture rule  -  Companies  have  questioned  the  RCRA  hazardous waste
        mixture rule,  which may allow small  amounts of hazardous wastes to render
        as  hazardous a large nonhazardous waste  volume  when  the two  components
        are mixed together.   From  an industry viewpoint, there is no justification
        for defining the  entire  waste  volume  as hazardous  when  the hazardous
        constituents are  fixated within  the  waste  and  the  leaching potential is
        minimized.

    •   Process   recertification  -  Firms may  not  be   motivated  to  change
        manufacturing processes to  achieve waste minimization,  if  recertification
        of  the new  process is necessary  to comply with TSCA and Food  and Drug
        Administration (FDA) regulations.  Modifying permits under  TSCA or FDA
        regulations  is costly  to industry  in terms  of time requirements. Companies
        indicated that it typically  takes from  six months  to  one year to  secure a
        permit modification.
    Companies  have  noted  that  HSWA  did  offer  some  incentives  to  waste

minimization.  As  a  result  of  having  to  certify  waste  volume  and  toxicity
minimrzation, some companies have  developed  data bases  and  records on waste

production processes, waste types, waste volumes, treatment and disposal methods,

and costs.  Several companies  are currently  maintaining  computerized hazardous
waste generation data bases, and  they feel  that  Congressional action  (the inclusion
of Section 224 to  the 1984 amendments) has justified their investment in the data
bases.


5.3.4      Origins of Opposition to  Change


    Waste minimization as an  operating practice is a relatively  new concept  for

industry; as noted  above, past reductions in waste generation were incidental to  the

realization of other goals, namely increased product yield  and  energy recovery.  The
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goal of reducing  the  waste generated by existing production processes poses a new
set of challenges to  industry  personnel.  They  may be  reluctant to confront these
challenges in part because of the habits and attitudes developed  through  experience
with existing production processes and waste management practices.

    The  effect  of  habit on  industrial  design  and management  practices  is  the
continuation of  old  designs  or of  existing  management  practices.  There  is  a
tendency  to preserve designs and practices that may generate relatively large waste
volumes but which have worked well  to  the  present, because  they provide ready
solutions  to the usual set of production problems.  This tendency  is more pronounced
in operations where  waste generation and/or  raw materials costs are  minor  in
relation to the value  of the final product, or are at least perceived to be tolerable.
Familiarity with  production techniques also  gives  rise  to  operational efficiencies
such  as lower  time  and  personnel requirements.  Management may,  therefore, be
satisfied with production operations as  they stand, even if large quantities of waste
are generated  (the  "if it  isn't broken, don't  fix it"  outlook).  This inhibits  the
development of initiative among managers to take waste minimization measures.

    Coupled with this  lack of initiative, familiarity with  existing operations and
unfamiliarity with innovative technologies or approaches create a tendency to reject
changes in existing techniques and to  develop  attitudes that  oppose change.  For
example,  there is the "can't be done" attitude, where a  concept  is dismissed before
it is-developed  to the point where it  can be  fully understood.  Management "policy"
may be at the root  of  the rejection,  or  it may be felt that the idea requires too
much  time or trouble  to investigate.  A  similar idea may have been tried under other
circumstances  and failed; hence, a new  idea is dismissed by association without  a
deeper, situation-specific  analysis.  Whatever  its  origins, the  "can't  be  done"
attitude can  present  a  powerful barrier to change, and previously has been identified
as such by practitioners of  value engineering, an engineering activity performed to
reduce cost without sacrificing  functionality of design (Zimmerman and Hart 1982).

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    Opposition to possible waste minimization  measures may arise out of a fear of
product quality detriment.  This is a  common  reason for not  reusing recovered
feedstocks,  as  they  are  typically  not up  to the  specification of  the  original
feedstocks.  Recycled feedstocks may be rejected out-of-hand for similar reasons.
In  general,  firms are reluctant to  pursue  waste  minimization  if they fear  that
customer  satisfaction may  be  jeopardized.  Also,  some  firms  may  not have  the
latitude to alter production  techniques  if the  mode of production is contractually
specific.

    Fear  of product  quality detriment is  only  one  of  several  factors that  may
dissuade individuals  from  pursuing new waste   minimization  methods.  Process
modifications   may  involve  protracted  production  downtime, which  impedes  the
fulfillment of  production goals  or contractual obligations.  In this context,  shutting
down   the   process  is  a relatively expensive  endeavor.   Also,  because  waste
minimization projects compete  with other projects for funding,  they  may receive
lower  priority,  particularly if  they   involve  innovative  technologies.   Greater
investment  risk is perceived, especially by  smaller firms, for technologies  whose
commercial feasibility  has not  already  been  demonstrated by  application in similar
production operations.  The  rate at  which the  project's cash  flows are discounted
would  then  be  higher  to reflect  the  higher risk,  and the  project would be  less
attractive.

    Even  in the  absence of countervailing  attitudes  within  management,  waste
minimization   may  not  occur   if  management   views waste  minimization (and
environmental  measures  in general) as  a service  function of low priority  in   the
production-oriented mission  of  the firm.  This  can result  in a  lack of  detailed
information on waste generation  as a  component of manufacturing  cost.  The
problems of generating waste cannot be addressed until waste generation costs  are
quantified in such a manner  as  to call attention  to their  significance.  Previously,
waste disposal  as  a "cost of  doing business" did not vary by much from year to year.
The  recent rise  in  disposal costs  has  had  an   inflationary effect  on  overall
manufacturing   costs, causing  managers in  some  companies to track  the cost
increases and to take action to offset them.
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     A related aspect is  the  availability of  needed information.  When the costs of
waste  generation  are- identified and made known to management,  quick,  decisive
action  is  often  taken.  The  key problem  in  such situations  is not  the lack of
managerial commitment to solve  the problem;  rather, it is  a  lack  of  initiative or
commitment to recognize and formulate a problem to be solved.

5.4       Consumer Attitudes and Public Relations Issues

     As discussed  in Section 5.3, one  deterrent  to  initiating waste minimization
practices is  the  risk that a change  in the manufacturing process  necessary to
achieve  waste minimization  may affect the quality  of the  final  product.   Also,
altering  the  specifications of the final product  to  accommodate  the use of  less
waste-producing raw ingredients  may  present problems  of customer acceptance of
the change in the  final product.  From  the standpoint of the manufacturer, product
change  or  substitution may not  be a viable waste minimization  option, since product
quality and specifications are established by consumer and market demand.

     Unnecessarily  tight  product   standards  can  contribute  to  increased  waste
generation.  For  products  already favorably accepted  by  the  consumer,  however,
resistance  to change in the quality of the product is likely. This option  might be
more effective if  a  program were begun that  would educate  the consumer on the
environmental benefits of supporting  lower  waste-producing products.  When the
changes affect consumers  directly, they are likely to respond to such programs.  For
example, the recent educational campaigns encouraging the reduction of  sugar and
cholesterol in the  diet  have resulted  in  consumer demand for foods  that are low in
sugar and  cholesterol.   Because  of this demand, food  manufacturers can target
certain  products directly toward  these  consumers, since they  are concerned  about
their health  but not necessarily about the process the manufacturer must use to
produce such food products.

     There  is a limit  to the response one might  expect from consumers for products
that have  indirect  effects, however.  Although  public education programs dealing
with the environmental benefits of certain  products  may motivate their purchasing
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 decisions,  overall  product  quality  and  costs  may  weigh  more  heavily  in  their
 selections.   In  particular,  if  the  purchase   requires   a   substantial  financial
 commitment, a  consumer is  less likely to decide to buy a product  that  would  yield
 only  an  indirect  effect.  For  example,  a  consumer  is unlikely  to  purchase  a
 particular computer simply  because the  computer firm  uses waste  minimization
 techniques in the manufacture of its printed circuit boards. The consumer's decision
 to  purchase  the computer  will,  instead, be based on the quality of the product and
 the price.  (In this instance, the quality of the  product is  not likely to be affected by
 the  waste minimization practice;  the decision  factors would then be  the  overall
 relative quality of  the computer  and the relative price.)

     The  degree  to  which  consumers  may  base  their  purchasing  decisions  on
 companies' environmental practices most likely would be dictated by how much such
 practices would  either (1) affect them directly or (2)  run  counter to how they  feel
 companies  should  behave.  At  the local  Level, this type of  public  behavior has
 manifested  itself  in  the  "Not  in  My Backyard"  reaction  toward  the siting of
 hazardous waste facilities.  Reaction  toward existing companies' pollution control
.practices, however, has not been expressed to the  same degree as that  toward the
 siting  of waste  facilities.  Boycotting of  products  has  been  less apparent than the
 objection of  people to the siting  of hazardous waste facilities in their  community.

     Reaction to a company's production practices generally will remain confined to
 the  immediate community  affected by  the  plant; a change in  consumer  demand
 because of  a plant's environmental practices is less  likely.  In this regard, public
 relations rather  than consumer demand determines the reaction. An  example of this
 type of public relations and public pressure is  reflected in  situations  such as that in
 the "Silicon  Valley" area of California.  Over the  last few years, the residents of this
 area  have  become  concerned  about   evidence  of ground-water   contamination.
 Coupled with this  was  the discovery of elevated  incidents of birth defects in the
 area.  Investigations  revealed that  the contamination  was  linked to the electronic
 and semiconductor manufacturers' storage of  waste chemicals below ground.  Public
 concern and the resulting  negative  publicity  have  caused the  electronic  firms to
 undertake investigations and corrective actions.
                                      5-3:

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     As a matter of policy, some companies undertake waste  minimization  and other
environmental  programs on their  own without public pressure. One example of such
a program  is 3M's Pollution Prevention  Pays (3P)  program that rewards employees
for suggesting  innovative cost-saving solutions to  environmental problems.  The size
of the  company  appears to be a  key factor in  determining  the  success of  such
programs.   As  discussed in Section 5.1, economies of scale are often a principal
factor in  a firm's  decision  to invest in technology.  The  public  image  or  public
relations aspect is  also important.  Companies that establish  good environmental
reputations are likely  to have  better  relationships with environmental agencies and
are better  accepted by the communities in which they are located.

     In  summary, consumer attitudes may  play  a role in  affecting a  company's
production  process:  (1) if the consumer is more aware of the environmental  effect
produced  by the product's  manufacture  and he/she has  a  desire to  improve the
environment; (2) if the consumer is willing to accept changes  in product quality; and
(3) if the consumer is  willing to give  up  the opportunity to purchase a  product that
may be cheaper and/or superior in  quality.  The third option  is more likely to occur
for products not  requiring a substantial  financial  investment; that is, environmental
concerns are more likely to  motivate a consumer to try a different paint,  but not a
different computer.  A  plant's  practices that affect a neighboring community  may
be influenced at the local level by public  relations  issues.  Public  relations may  also
play a role with respect to a  company's reputation.  Companies that actively seek
environmental  solutions  may benefit from being perceived  as conscientious by both
the community and  the agencies  that regulate them.  For both consumer attitudes
and  public  relations  aspects  to  influence   waste  minimization,  education  and
informational programs appear key  ingredients for the development of such changes
in attitude.

5.5       Regulatory Aspects

    The requirements imposed  by  RCRA and other regulations may both inhibit and
promote waste minimization  practices  or  may  be  perceived  by  the regulated
community to do so.  This may be particularly true of the  class of  generators  who
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once were exempt from regulation because they generated less  than  1,000 kg/month
of hazardous waste.  With  the lowering of the exemption limit to  100 kg/month, a
new  segment of  the  service  and  industrial  community is subject to  regulation, a
segment that must consider perhaps  for the  first time  the  various alternatives
available for waste management.

     At  the  same time, some regulations may provide incentives to  explore  waste
minimization options, since waste management alternatives may be limited.  With a
limitation of  choices,  the  economics  of  waste  minimization  may   then  become
redefined and what was once marginal  may now appear attractive.  For example, as
EPA implements restrictions or treatment standards for the  land disposal of various
wastes,  companies will necessarily  give more consideration to alternatives to land
disposal.

     This section explores some  of the regulatory issues   under RCRA  and  their
effect on industry with  respect  to whether waste  minimization  is  promoted  or
inhibited. Although the section  discusses the effect of RCRA only,  it should  be
noted that  the effluent limitations guidelines and  standards established  under the
Clean Water Act also result in source reductions  of waste.  The RCRA regulations
that directly affect hazardous waste minimization, however, are the  primary focus
for this  section.

5.5.1      Waste Minimization Certifications

     The regulations that most  directly affect waste minimization  activities are
those resulting from HSWA. In  response to these amendments, EPA has revised  its
Uniform Hazardous Waste Manifest Form (EPA Form 8700-22) so that  it contains a
certification by  generators regarding  their  efforts to minimize  the  amount and
toxicity of wastes generated. The certification statement now appears as Item  16
on the manifest form.
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     In  addition to  the  manifest  certification requirement,  generators  are  now
required to submit a report, at least once  every two years, describing their efforts
to minimize waste generation.  The current requirement for submission of a biennial
report  has  been amended  to  include  (1) a description  of the  efforts undertaken
during the  year to  reduce the volume and toxicity of waste actually achieved  during
the  year,  and (2) the changes in  volume  and toxicity  achieved  in  a given  year
compared with previous years.  The comparison  in item 2  is to  be made with respect
to previous  years  "to the  extent  such  information is available for years prior  to
1984" [40 CFR 262.41(a)(6) and (7)].

     Finally,  T5D  permits  issued on  or  after  September 1. 1985,  must contain  a
condition that the permittee certify annually that a waste minimization program is
in place. The  program must  "reduce the volume  and toxicity  of  hazardous  waste
that he  generates  to  the  degree  determined by the permittee to be economically
practicable;  and the proposed method of  treatment,  storage,  or disposal is  that
practicable  method  currently  available  to  the   permittee which minimizes the
present  and   future  threat  to  human  health and  the  environment"  [40  CFR
264.73(b)(9)].

     EPA's  concerns  will be limited  to permittees complying with  the certification
portion of  these regulations.  EPA  does not  have  the  enforcement  authority  to
ascertain whether  such  programs  are in  place or  whether they  qualify as  waste
minimization.  The  legislative history o-f these requirements states that the language
does not authorize EPA to interfere with or to intrude into the production process
by requiring  standards for  waste  minimization.  Determinations  of "economically
practicable"  and "practicable  method currently available"  are  to  be  made by the
generator,  not EPA (50 FR  28734).

     Even though EPA has  stated  that  it  will not  actively enforce  standards  or
guidelines for waste minimization (50 FR 28734),  the certification  program is likely
to make generators more aware of waste minimization, since  the act  of certifying
may by itself act as an incentive for generators to make  this effort. It is also likely
that some   generators will undertake   programs   that  involve  some  degree   of
                                      5-aO

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innovation.  Because of this, the program may have the effect of making some  waste
minimization  processes  more  widespread.  Waste   minimization  practices  that
involve process modifications or product substitutions, however, may be regarded as
proprietary.  In such  instances, that information would not be made  available to
others.

    Since EPA's involvement  in providing guidance is limited, companies may seek
to  do  only  a  minimum  in  order to  certify that  they  have instituted a  waste
minimization program.  On the other hand, EPA has officially responded to inquiries
as to  whether particular  practices may  qualify as waste minimization. Specifically,
EPA has  prepared responses in which it affirms that participation in waste exchange
programs and recycling in general are  considered to qualify  as waste minimization
practices (see Appendix G for EPA's correspondence).

    Therefore, the regulations may serve as an incentive to companies that  offer
services  that minimize waste  (such as recyclers, manufacturers, or vendors of  waste
treatment equipment or services) to obtain this recognition.  Such recognition  could
be  of  use  to companies in  marketing  their services  to generators.  For example,
offsite recycling firms can claim to offer not only a means  of waste management,
but also  a  means  to help  generators  certify that  they  have instituted a  waste
minimization program.  The same potential may exist  for marketers of a technology
or for firms that offer environmental auditing services.

    In addition,  the regulations  may result  in  some generators'  instituting  such
practices themselves, without going  to  outside vendors.  Thus, there  may  be an
increase  in  internal  environmental auditing departments to assess  the degree to
which waste minimization practices may be instituted.

5.5.2      EPA's Definition of Solid Waste

    EPA  published  a  revised version  of  the  definition of solid   waste  in  the
January 4,   1985,  Federal  Register.  The  definition  was  designed  to close  the
"loopholes"  that existed  in  the  RCRA  regulations regarding  recycling.  Although

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"sham"  recycling  has  always been illegal, the regulations  prior to the January 4,
1985, revision  allowed  characteristic  hazardous wastes and commercial chemical
products (listed  in 40  CFR  261 .33) to  remain unregulated provided that they were
being "beneficially used or  re-used  or legitimately recycled or reclaimed."  Thus,
generators did not need to manifest the exempted wastes that were being recycled.
There was no regulatory mechanism  for  ensuring  that  the  exempted  wastes were
actually being legitimately recycled.

    The revised definition  introduces  new  tests  by  which  a substance  may  be
deemed to be (Da  solid waste  and (2) legitimately recycled.  For materials being
recycled,  the revision asserts that RCRA jurisdiction  is determined by  what  the
material is and  how it is being recycled, unlike the  previous version that provided an
exemption-for certain  wastes regardless of the  method of recycling.  Because  of  its
complexity, this section presents  the  main provisions of the  definitions  and their
potential effects on industry. A detailed explanation of the definition of solid  waste
is provided in Appendix F.

    The central concept in the  definition of solid waste is that of "discarding" or
throwing something away.   If a  material  is  abandoned,  it  is  disposed  of,  and
therefore  a solid waste;  if it is not abandoned, it is  not a solid waste. The definition
expands the concept of abandonment to include (1) storing or treating the material
if the storing or treating occurs  prior to its being abandoned, or (2) certain types of
recycling activities.  The definition states that four  types of recycling  activities  are
within EPA's jurisdiction:

    •   Use constituting  disposal;
    •   Burning  waste  or waste  fuels for energy recovery or using wastes to produce
        a fuel;
    •   Reclamation; and
    ••   Speculative accumulation.
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    These four categories of  recycling  activities are further divided  according to
the type  of  material  involved: spent  materials, sludges (listed or characteristic),
byproducts  (listed  or  characteristic),  commercial   chemical  products,  or  scrap
metal.  Table 5-5  provides a  summary of which materials are solid  wastes when
handled in the respective activity areas.

    Wastes that are recycled by being used directly  are  not defined as solid wastes
if  reclamation  of  the  material does not occur prior to  - or as a condition  of - its
being used.   The definition specifies three situations in which the direct use of the
waste would exclude it from the solid waste definition:
    •   The  material is used as an  ingredient in an industrial process  to  make a
        product.
    •   It is used as an effective substitute for commercial products.
    •   It is  returned to the  process  from which it was generated, to be  used  as a
        substitute for raw material  feedstocks.
For each  of  the above situations,  reclamation must not occur prior to or during  its
use.

    An important  concept of the  definition is that qualification of a material as a
solid waste does not  automatically render the activity associated  with the material
subject to full RCRA regulation.  A solid waste  material  would be regulated only if
(l)the material is  a  hazardous waste and (2) the  activity  involving  the material is
subject to   the  RCRA  hazardous  waste  management  standards.   For example,
although some of the wastes recycled onsite  may qualify  as solid  wastes  under  the
definition, the actual recycling activity  is not regulated under R'CRA. If the waste
is stored  onsite for more than 90  days prior to recycling, or if it  is stored  for any
length of  time in a surface impoundment  or waste pile prior to recycling onsite, then
a TSDF permit would be needed for the storage  of  such waste.  In  such  instances,
the recycling activity itself still would not be regulated.
                                      5-43

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1268s
             Table  5-5  Waste Materials Defined as Solid Wastes under the Revised Definition
Waste materials
                                                                 Activi ties
Use constituting
    di sposal
Energy recovery
    and fuel
                                                                           Reclamation
Speculative
accumulation
Spent materials

SIudges (1i sted in
  40 CFR 261.31 or 262.32)

Sludges exhibiting
  a characteristic

Byproducts (listed in
  40 CFR 261.31/32)

Byproducts exhibiting
  a characteristic

Commercial  chemical
  products (listed in
  40 CFR 261.33)

Scrap metal
  Indicates material  is define^  as  solid waste.

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     The requirements that gJD apply for solid and hazardous wastes  are summarized
below:

     •   Notification procedures (recordkeeping)  for hazardous wastes generated that
        qualify as solid wastes regardless of whether they are recycled on or offsite.
     •   Manifesting for hazardous  wastes  qualifying  as  solid  wastes  under the
        definition and  that are shipped offsite.
     •   TSDF permits  for  storage  of  hazardous wastes qualifying  as  solid wastes
        under the definition if (1) stored by the generator for more than 90 days, or
        stored  for  any amount  of  time in waste piles or surface  impoundments, or
        (2) stored by the firm receiving the material for any amount of time.
    *   TSDF permits for the  treatment of hazardous  wastes qualifying  33  solid
        wastes under the definition.
     There is  some  confusion  over the  last item  above  regarding  treatment.  A
reading of the definition of "treatment" (40 CFR  260.10) shows that reclamation
qualifies as treatment.  Since treatment activities require  permits under the RCRA
regulations, one may also conclude  that any reclamation of a hazardous waste would
require a TSD permit.  Although reclamation is indeed a subset  of treatment, actual
reclamation activities are currently not  subject to regulation according to 40 CFR
261.6(c)(l).  The  confusion  arises because  the  definition of "treatment"  does not
cross-reference this provision.

     Because  of  this confusing aspect of  the  regulations, there have been  some
misunderstandings by industry of what  is required  and what is not. Some companies
believe that  any  type of reclamation activity (onsite or offsite) requires a permit.
These companies  may thus perceive the regulations to be more restrictive than they
actually are.   Discussions  with  State  personnel indicate also that  some  State
environmental agencies are making  the same misinterpretations (Kerr 1985b).  This
compounds the confusion  by reinforcing the  mistaken  ideas  through the States'
versions of the definition and through their enforcement policies. Thus,  a State that
believes EPA's regulations require TSD permits for reclamation activities may write
and enforce its regulations that way  (Kerr 1985b).
                                      5-45

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     Although the  reclamation activity itself may  not be regulated, storage prior to
reclamation  does  require  a  permit,  as  mentioned  in  the  third  item  above.  A
generator may store  his or her waste onsite for up to 90 days, and would not need a
permit.  Once the waste leaves the generator's site, however, storage  of the waste
for any  amount of time  by the receiver requires a TSD permit.  Thus, a  company
storing  waste prior to reclamation would need to obtain a TSD permit. This could
result  in the non-acceptance by some companies of the newly defined solid  wastes
for reclamation, since previously they did not need  to obtain permits.

     Besides  the   above issues,  other difficulties lie  in   increased  requirements
resulting from  the definition  that could result in disputes with EPA. One key aspect
of the regulations  is that generators will now have  to  manifest some wastes shipped
offsite  that, under   the  previous  set  of  regulations,  were  exempt from  such
requirements.  For example, a spent material (e.g., a spent solvent) that  is  both a
hazardous waste  and that is reclaimed prior to being recycled is defined as  a solid
waste.  If the generator were to ship the spent material offsite  to be reclaimed, a
manifest would be required.

     The manifest, in effect, places the generator's  name  on  the  waste -  a factor
that may cause reluctance  to ship wastes offsite to  be  recycled because of  future
liability, as discussed in Section 5.2.  To generators  who previously did  not have  to
manifest wastes when shipping  to  reclaimers, this is perceived  as a  constraint  to
recycling, since it is not  clear to  what extent  they may be  liable  for any future
accident or  leak.  Members  of the regulated community have  provided  specific
examples of  how this aspect  of the regulation may restrict recycling.  In one case,
for example, the spent catalyst from a chemical  process  was not returned  to the
catalyst manufacturer for regeneration because of the RCRA manifests required.

     One advantage   of this situation  is that there  is an increased  need  for the
generator to  know of  the reliability of the recycler to which  the waste is  shipped.
Thus, the definition  may  achieve  a decrease in  the number of "sham"  recycling
operations, if generators take extra care in finding  out  more  about  the  company
                                      5-46

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doing the recycling.  Smaller companies, however, may not be  able  to  assess the
adequacy  or reliability of recyclers.  Larger  companies, such as IBM for example,
conduct audits of  the companies to which they send wastes for recycling.  A small
company may not have the expertise available to make such an assessment.

     Although the  new  definition  may  be  needed to  prevent abuse of  recycling
operations,  it  may  be  seen  by  some  companies as  discouraging  recycling  and
resource recovery  efforts.  The  definition at  this  time contains no mechanism for
consideration of equivalent uses  of waste materials.  In this regard, the definition
may carry with it some  of  the  inequities and biases  that  may  be inherent  in the
RCRA statute itself.  For example, Section   3014(a)   of  RCRA  states  that  any
regulations  governing  the recycling  of used oil "do not discourage the recovery or
recycling  of  used  oil consistent ' with the  protection  of  human  health and  the
environment."  As a consequence of this  language, regulations  relating to the  use of
used oil as a  fuel do not require "full" compliance with the manifesting requirements
of RCRA (50 FR 1704 and 50 FR 49196).

     No such  privileges are granted  at this  time  toward other recycled substances.
Products and raw materials (as opposed to waste products and spent materials) that
may be as,  or more hazardous than, comparable waste  streams are not required to
obtain the same degree of permitting, tracking, review,  and  regulation as the  waste
streams.  Storage of virgin  trichloroethane, for  example, does not require  a TSD
permit, but  storage of spent trichloroethane by a generator for more than 90 days
does need such  a  permit, even if it  is to  be sent to a  solvent  recovery facility for
reclamation.

     On the other hand, byproducts that are used directly in other processes without
additional reclamation are excluded  from the  definition of solid wastes.  Problems,
however,  center  around   what  is  considered to be reclamation.   As  an  example,
placement  of  a  liquid in a  tank  for settling may result in a  liquid  free  from
impurities and amenable for  reuse.  Yet  there  is  some  question as to whether  the
settling is a  "treatment" step (subject to regulation), or a "reclamation" step (which

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is not  regulated). Again, some of the confusion could be attributed to the definition
of "treatment" itself.  Other problems  include the fact that  the ultimate end  use  of
the product  in  which the waste  material is introduced determines whether it falls
under  the solid  waste definition.   For  example,  a  waste  used directly  as   an
ingredient or feedstock in a process is not a solid waste, unless the product  in which
it is introduced is ultimately placed on the land  or  burned.   Thus, wastes  that are
introduced as  ingredients  for  fertilizer  would be  solid wastes,  and  shipping such
wastes offsite to the fertilizer  company would require a manifest.  As a result, the
regulated community  may  be more concerned with escaping regulation even when
the opportunity exists to recycle.

    In  summary,  the  definition  contains  both  constraints  and  incentives   to
recycling. It  may  be perceived  mostly  as a constraining  mechanism,  which,  in
tandem with other aspects  such as liability,  siting,  and  permitting, may contribute
to a general negative attitude toward consideration of certain recycling practices.

5.5.3      Land Disposal Restrictions

    HSWA focus on the restrictions on land disposal of hazardous waste by imposing
bans and  limitations on the  placement of bulk or noncontainerized  hazardous (and
eventually nonhazardous)  liquids  in  landfills.   The  amendments   also add new
technical requirements for  land disposal facilities such  as requirements for double
liners,  leachate collection systems, and other corrective actions.

    HSWA allow EPA to place  further restrictions on specific wastes not only from
landfilling, but also placement in surface impoundments, waste piles, injection  wells,
land treatment facilities, salt dome formations, salt bed formations, or underground
mines  or  caves.  The  wastes subject  to  these restrictions are (l)all solvent- and
dioxin-containing hazardous wastes;  (2) liquid  forms  of   hazardous wastes that
contain certain metals, free cyanides,  or PCBs at specified concentrations as well as
acid liquid wastes and any  hazardous wastes that  contain halogenated organics at
specified      concentrations     (the      California     List);      and      (3) all
                                      5-a8

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remaining listed hazardous  wastes, with high volume/high hazard wastes considered
first and low volume/lower hazard wastes considered last.

     With the exception  of landfilling liquid hazardous wastes, EPA is responsible for
establishing exceptions to the prohibitions on the other land disposal methods for the
wastes  mentioned  above.   The  exceptions are  to  be in the  form of treatment
standards (Section 3004(m) of RCRA as amended by H5WA).   A standard  may  be  a
constituent  level or a method, either of which  reduces  the toxicity  of the waste or
its  likelihood to  migrate.  The  result  is the protection of human  health and the
environment (RCRA,  Section 3004(m)(D).  As  shown in Table  5-6, the legislation
sets forth a  series of deadlines under which  EPA must establish treatment standards
for these hazardous wastes.  If EPA fails to make a determination  on restricting or
establishing a treatment standard for any of the wastes by the respective deadline,
that waste  is  automatically banned from land  disposal.  This automatic banning
mechanism  is  termed the  "hammer provision" of HSWA.   For the solvent- and
dioxin-containing hazardous  wastes and the "California  List"  wastes, EPA must also
make a determination regarding their  disposal  by underground  injection  into  deep
injection wells. EPA has until August  8, 1988,  to make such  determinations.  Thus,
unless  EPA  makes  a  determination  beforehand, these  wastes may  be  disposed via
this method  until that date.

     After the  effective  date of  a prohibition,  wastes may  be land disposed (except
for landfilling of liquid wastes)  if they comply  with the  treatment standard.  For
some wastes, there may  be  no standard or no form of land disposal that can satisfy
that requirement.  In such cases, the  waste would be banned from land disposal.  For
wastes  that  are  banned or  for  which  treatment levels are  established, EPA  may
allow a two-year extension  for  land disposal  if  it is demonstrated that  treatment
technology  and/or  capacity  to  accommodate  such wastes are  limited.  After the
two-year time period, the ban and/or treatment standard are in effect.  Presumably,
Congress,  in  allowing  such  extensions,  expects  that   advances in  treatment
technology and/or increases  in treatment capacity would occur during the  two-year
period  to accommodate such wastes after the extension has expired.

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1267s
            Table 5-6  Timetable of Land Disposal  Restrictions
Deadline
                                                 Action
November 8, 1986
July 8, 1987
Treatment standards for land disposal of
dioxin- and solvent-containing hazardous
wastes (except for underground injection
into deep injection wells).

Treatment standards for land disposal of
California List wastes (except for
underground injection into deep injection
wells).
August 8, 1988
Treatment standards for land disposal of at
least one-third of all listed hazardous
wastes.
August 8, 1988 -
Treatment standards for underground
injection of solvent- and dioxin-containing
hazardous wastes, and California List wastes
into deep injection wells.
June 8, 1989
Treatment standards for at least two-thirds
of all listed hazardous wastes.
May 8, 1990
Treatment standards for all  listed hazardous
wastes and all wastes identified as
hazardous based on a characteristic.
                                     5-50

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    H5WA  also  allow  EPA  to  approve,   for  a  specific  restricted   waste,   a
site-specific  petition.   The  petition   must  demonstrate  that  there  will  be  no
migration from the  disposal unit for as long as the waste remains hazardous.

    In the May 31,  1985  Federal Register, EPA proposed a schedule  for land disposal
restrictions  (50 FR 23250).  As  required by RCRA Section 3004(g), the  schedule
divided the waste streams listed in 40 CFR 261  into thirds based  on  intrinsic hazard
and volume  disposed, with highly  toxic and high volume wastes scheduled first.  EPA
proposed that each listed waste stream be ranked  according to  the product of its
toxicity   and  volume   scores.   The   toxicity  score  represents  "the   inherent
toxicologicaJ properties  of hazardous constituents in the waste." The volume score
represents "the volume of  the  hazardous  waste disposed  of in  or on the  land"
[Environ  Corp. 1985]. Recently, EPA has proposed regulations (January 14, 1986)  in
the Federal  Register  that  establish procedures (l)to set treatment standards for
hazardous wastes; (2) to  grant nationwide variances from  statutory effective dates;
(3) to grant  extensions of effective dates on  a case-by-case basis; and (4) for EPA  to
evaluate  petitions that "continued land  disposal  is protective of  human health and
the environment" (51  FR  1602).  Also,  EPA has proposed treatment standards and
effective dates  for  certain solvent- and  dioxin-containing hazardous wastes.  The
regulations would  prohibit land disposal of  such  wastes unless treatment standards
are achieved.  The  treatment standards would not apply  to the disposal  of these
hazardous wastes in underground injection wells (proposed  40  CFR 268. l(c), at 51 FR
1760).  Finally, EPA has proposed a two-year extension (until  November 8,  1988) for
the prohibition  of  disposal of these wastes in  landfills or surface  impoundments,
provided  such facilities meet  the  minimum technological  requirements of  proposed
40 CFR 268,4(i)(2) (proposed 40 CFR 268.3 Kb) at 51 FR 1764).  Table 5-7 presents a
list of  the wastes for which EPA has proposed these restrictions.

    The  overall effect of the land bans on waste minimization is not  definite at  this
time; however, the  prohibitions limit waste management alternatives by eliminating,
or greatly restricting, one  of  the most  inexpensive,  and  therefore  most  popular,
management  methods:  land disposal.  Generators of hazardous waste are forced to
examine  other waste  management alternatives,  recycling  and  source  reduction
                                      5-5:

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1291s
   Table 5-7  Solvent- and Dioxin-Containing Hazardous Wastes for Which
             Land Disposal Restrictions Were Proposed by EPAa
Waste code                               Description
   FOOl             The following spent halogenated solvents used in
                    degreasing: tetrachloroethylene, trichloroethylene,
                    methylene chloride, 1,1,1-trichloroethane,  carbon
                    tetrachloride, and chlorinated fluorocarbons; all
                    spent solvent mixtures/blends used in degreasing
                    containing, before use,  a total of 10 percent or more
                    (by volume) of one or  more of the above halogenated
                    solvents or those solvents listed in F002,  F004, and
                    F005; and still  bottoms  from the recovery of these
                    spent solvents and spent  solvent mixtures.

   F002             The following spent halogenated solvents,
                    tetrachloroethylene, methylene chloride,
                    trichloroethylene, 1,1,1-trichloroethane,
                    chlorobenzene, 1,1,2-trichloro-l,2,2-trifluoroethane,
                    ortho-dichlorobenzene,  and trichlorofluoromethane;
                    all spent solvent mixture/blends containing, before
                    use,  a total  of  10 percent or more (by volume)  of one
                    or more of the above halogenated solvents or those
                    solvents listed  in F001,  F004, and F005; and still
                    bottoms from the  recovery of these spent solvents and
                    spent solvent mixtures.

   F003             The following spent nonhalogenated solvents; xylene,
                    acetone, ethyl acetate, ethyl  benzene,  ethyl ether,
                    methyl isobutyl ketone, n-butyl  alcohol,
                    cyclohexanone., and methanol; all spent  solvent
                    mixtures/blends containing solely the above  spent
                    nonhalogenated solvents;  and all spent  solvent
                    mixtures/blends containing,  before use,  one  or  more
                    of the above  nonhalogenated  solvents, and a  total of
                    10 percent or more (by volume) of one or more of
                    those solvents listed  in  F001, F002,  F004, and  F005;
                    and still  bottoms  from the recovery of  these spent
                    solvents and  spent solvent mixtures.
                                  5-52

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1291s
                           Table  5-7 (continued)
Waste code
                      Description
   F004
The following spent nonhalogenated solvents: cresols
and cresylic acid and nitrobenzene; all  spent solvent
mixtures/blends containing, before use,  a total of  10
percent or more (by volume) of one or more of the
above nonhalogenated solvents or those solvents
listed in F001, F002, and F005; and still bottoms
from the recovery of these spent solvents and spent
solvent mixtures.
   FOOS
   F020
   F021
   F022
The following spent nonhalogenated solvents: toluene,
methyl ethyl ketone, carbon disulfide,  isobutanol,
and pyridine; all spent solvent mixtures/blends
tuntaTnttrg, *efx>re use, a total of ID percent or more
(by volume) of one or more of the above
nonhalogenated solvents or those solvents listed in
F001, F002, and F004; and still bottoms from the
recovery of these spent solvents and solvent mixtures.

Wastes (except wastewater and spent carbon from
hydrogen chloride purification) from the production
and manufacturing use (as a reactant, chemical
intermediate, or component in a formulating process)
of tri-, or tetrachlorophenol, or of intermediates
used to produce their pesticide derivatives.  (This
listing does not include wastes from the production
of hexachlorophene from highly purified
2,4,5-trichlorophenol.)

Wastes (except wastewater and spent carbon from
hydrogen chloride purification) from the production
or manufacturing use (as a reactant,  chemical
intermediate, or component in a formulating process)
of pentachlorophenol, or of intermediates used to
produce its derivatives.

Wastes (except wastewater and spent carbon from
hydrogen chloride purification) from the
manufacturing use (as a reactant,  chemical
intermediate, or component in a formulating process)
or tetra-,  penta-,  or hexachlorobenzenes under
alkal me conditions.
                                  5-53

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1291s
                          Table 5-7  (continued)
Waste code
                                         Description
   F023
   F026
   F027
   P022

   U002

   U031

   U037

   UOS2

   U057

   U070
Wastes (except wastewater and spent carbon from
hydrogen chloride purification) from the production
of materials on equipment previously used for the
production or manufacturing use (as a reactant,
chemical intermediate, or component in a formulating
process) of tri-, and tetrachlorophenols.  (This
listing does not include wastes from equipment used
only for the production or use of hexachlorophene
made from highly purified 2,4,5-tnchlorophenol.)

Wastes (except wastewater and spent carbon from
hydrogen chloride purification) from the production
of materials on equipment previously used for the
manufacturing use (as a reactant, chemical
intermediate, or component in a formulation process)
of tetra-, penta-,  or hexachlorobenzene under
alkal me conditions.

Discarded unused formulations containing tri-,
tetra-, or pentachlorophenol, or compounds derived
from these chlorophenols.  (This listing does not
include formulations containing hexachlorophene
synthesized from prepurified  2,4,5-trichlorophenol as
the sole component.)

Carbon disulfide

Acetone

n-Buty7 alcohol

Chlorobenzene

Cresols and cresylic acid

Cyclohexanone

o-Dichlorobenzene
                                   5-54

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1291s
                           Table 5-7 (continued)
Waste code
                   Description
   U080





   U112





   U117








   U121





   U140





   U1S4





   U159





   U161





   U169





   U196





   U210





   U211





   U220





   U226





   U228





   U239
Methylene chloride




Ethyl acetate




Ethyl ether







Trichlorofluoromethane




Isobutanol




Methanol




Mettiyl ettiyl kettwre




Methyl isobutyl ketone




Nitrobenzene




Pyridine




Tetrachloroethylene




Carbon tetrachlonde




Toluene




1,1,1-Trichloroethane




Trichloroethylene




Xylene
a January 14, 1986 at 51 FR 1763;  40 CFR 268.30(5).
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among  them.  The  phased  aspect  of  this  RCRA  provision  encourages  waste
minimization by  allowing EPA and the regulated community to focus on particular
waste  streams  and potential  waste  minimization  technologies en  masse.   The
program, as proposed in the January 14, 1986 Federal Register,  may have the effect,
however, of  channeling solvent- and  dioxin-containing  wastes into deep  injection
wells via underground injection, at least until such activity is prohibited. If the cost
of such  a practice remains competitive with source reduction or recycling, it is not
likely   that  the  program  would  cause   an  increase  in   these  practices  for
solvent-containing  hazardous wastes.  On  the other hand,  time constraints  may
leave insufficient  time  for research and development and may result in a shortage of
treatment and storage capacity.  On  the  whole, however, the increased restrictions
are certain  to  cause some  companies to choose  source reduction  and/or recycling
where the economics of such  a practice warrants it.
5.5.4      Technological  and  Other  Requirements  for  New  and   Existing  TSD
          Facilities
    HSWA impose conditions  for  all  TSD  facilities  through  the  RCRA  permit
programs.  These provisions apply immediately to facilities in all States, whether or
not the State  is authorized to administer its  own hazardous  waste program.  Key
features of the requirements are summarized below:
        All  Treatment, Storage, and Disposal Facilities.  In order for owners  and
        operators to obtain  a  final  permit for approved operation,  the owners  will
        need  to  take  corrective  actions  for  releases  of hazardous waste  (or
        constituents) from any solid waste management unit on the property.  This
        requirement applies regardless of when the waste  was placed  in the unit, or
        whether the unit is closed.  Owners  and operators are also  required  to
        provide financial  assurance  that  they can complete  the  needed corrective
        action.
        New  and   Expanded  Landfills   and   Surface   Impoundments.  All  new,
        replacement,   and  lateral  expansion  units   of  landfills   and   surface
        impoundments  will require ground-water  monitoring  and installation of  two
        or   more  liners   with  leachate  collection  above  or  between liners,  as
        appropriate.
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    •   Landfill and  Surface  Impoundment Exposure  Information.  After  August 8,
        1985, each application for interim-status operation must  be accompanied by
        exposure information.  This information must  address potential  hazardous
        waste releases in the course of transportation to or from the waste disposal
        unit.  It  must  also  address  normal  operations  and  accidents,  and  the
        potential pathways, magnitude,  and  nature  of  human  exposure  to such
        releases.

    •   Existing Surface Impoundments.  For  interim-status surface impoundments
        that  were  in  existence  on November 8,  1984, two or more  liners with
        leachate collection between the liners must be  installed. Also, the owners
        and operators must  monitor ground water by November 8, 1988.

    •   Waste Piles.  Interim-status waste piles that receive waste into  new units or
        lateral expansion  or replacements of existing units on or after May 8, 1985,
        must  meet  the  standards in  40  CFR Part  264  for  liners  and leachate
        collection systems.  These standards are more encompassing than those in 40
        CFR Part 265 with which such units previously had to comply.
    The requirements for new and expanded landfills and new surface impoundments

may be waived by EPA as long as the  alternative design,  operating  practices, and

location characteristics prove equivalent in the prevention of  leachate migration.


    As in the case of the land disposal restrictions discussed  in the previous section,

the technological and  other requirements  for  TSD  facilities  contribute  to the

limitation of waste management alternatives.  The  above requirements are likely to

result  in an  increase  in  the cost of land disposal.  In  addition, there  may  be  an

increase in closures of land disposal facilities, since some operators/owners may not

be able to comply with the new requirements. Costs of landfilling may also  increase
because  of  the difficulty of obtaining  liability  insurance  (see  Section  5.2.1  for a

discussion of this issue).  Because owners of land disposal facilities must be  able to

demonstrate  financial responsibility, fees that generators pay  for disposing  of the

waste  may be increased to cover such  financial  assurance (personal communication

with C. Ray Hanley,  Project Manager, Geysers Project, Pacific  Gas and  Electric
Company, San Francisco, California, January 24, 1986).  A decrease in the number

of landfills combined with increased costs of land disposal could result in  an increase

in waste minimization practices.  The  technological requirements  coupled  with the

land disposal  restrictions are  likely to  cause  generators  to consider other waste
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management alternatives, among them  source  reduction and recycling. An increase
in onsite treatment may also be a result; to some extent such onsite treatment  may
be an integral part of a source reduction strategy.

5.5.5      Siting

    Despite  the problems with environmental liability insurance discussed in Section
5.2, the potential for increased offsite recycling still exists, given the potential  land
disposal  bans and other  factors such as possible  increases  in  virgin materials and
costs  of  treatment and incineration.  An increase  in offsite  recycling  may  create a
need  for additional  facilities; however,  recyclers  share  the  difficulties  of other
hazardous  waste businesses in finding new sites and  obtaining timely approval of
permits.   The siting problem is the familiar one of  "not in my  backyard."  It  would
seem  particularly counterproductive to block construction of recycling and recovery
facilities,  when   the  principal  alternatives  may  be  more   detrimental to  the
environment  and create more potential risk to human health.  But  those objecting to
the siting  are unlikely  to reject that argument  in  the  abstract —  only in  the
concrete as  it relates  to a local  site.  In  addition, the  past   history of  recycling
facilities  is  not  unblemished.   Superfund  sites  have  been  designated  where
underfunded,  technically deficient, and/or unscrupulous  "recycling"  operations of
years  past  left  chemical  disaster  areas  behind  when  they  closed  or  declared
bankruptcy.  Convincing  a  community that recyclers  who want to build a facility
near them will somehow be  different is not  an uncomplicated  task.

    Most States that have  undertaken the task of siting any of the various types of
waste  treatment facilities,  or expressed  interest  in  its outcome,  have  not  been
notably successful.  New York State,  for example,  had to  back down  on a proposed
site when unable to  overcome local opposition.  Massachusetts, while  indicating to
solvent recovery companies and waste management operators  its interest in having
them  build a facility or facilities  in the State, has not been successful  in gaining
local support for the sites proposed.
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     There  are,  however,  two   notable  examples   of   success  in  siting  waste
management facilities  in very  different circumstances,  one  in North Carolina and
the other in Arizona.  In  Arizona, the State selected  a site  on  State-owned  land
(purchased  from  the  U.S. Bureau  of Land Management) and then advertised for the
design and construction of a waste management complex.  The Arizona Department
of  Public  Health Services  originally  identified three sites that appeared  to  meet
optimal geological, economic, and political criteria  for  development of hazardous
waste  management  facilities. (The site finally selected, for example, although the
least remote of the three, was six  miles away from the nearest population center, a
town with  a population  under  100.)  Because  of   the  political importance and
difficulty of the issue, the final selection was made by the State legislature.

     The final siting decision  was controversial, in  spite  of the  remoteness of the
sites from major population centers.  The battle in the State  legislature over which
site to choose was fought  with  considerable intensity.  Whatever  the disagreement
over particular  sites, however, there  was  substantial agreement in the  legislature,
with  strong support  from  the  Governor's office   and  the State  Chamber  of
Commerce, that  a site had to be  chosen, and that only the direct  involvement of the
legislature  would make that possible.   As a  result, the  final   vote  was  almost
unanimous.

     The siting of a  waste  treatment  facility  in North  Carolina  was far different
from that in Arizona, and may  be a more  useful model  for heavily  populated and
industrialized States  that lack remote  land areas.  Rather than being sited far  away
from  any center of  population,  this  facility  is to  be  within the city limits  of
Greensboro,  in the middle  of a heavy  industrial zone  in which  there  presently is
substantial  chemical  manufacturing.   Institutional  factors  that appear  to  have
contributed to the success of this siting effort include the openness of the waste
treatment  company  to  thorough  discussion  of all aspects of the  plan with  the
community,  the  existence  of a  well-informed, broadly representative  community
task force that had successfully tackled other environmental issues in the past, and
the support of the Governor's Waste  Management Board  for both the need for and
the location of the facility.
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    A number of  factors  are  cited by  those  who  have been involved in the less
successful efforts at siting elsewhere.  To say that  the problem is due to the "not in
my backyard" syndrome is both accurate and unilluminating.  It is  arguable that, by
any reasonable definition, Arizona avoided everyone's backyard; North  Carolina, by
contrast, managed  to find an acceptable — and accepting — backyard.  The factors
most  frequently  noted  include  poor  communication   and  education,  poor  site
selection, lack of clear purpose and leadership by State  governments, and distrust of
both  the  Federal  and  State governments and  of the   potential   operators.  With
respect to  communication and education, many of  those involved in different efforts
noted a failure of either  the  State or local governments to educate the community
on the costs and benefits of the site  and on its  relation to the local  job base.  In
other cases, the prospective  operator  seemed unwilling to  enter  into an  open
dialogue  with  the  community  about  the prospective  facility  and its design and
operations.

    Two examples  of  poor site selection were  noted  in New  England by some of
those involved, one due  more to  the nature of the site,  the  other  to the  lack of
coherence  and credibility in  the  process.  In  one  case, the developer proposed a
small  landfill  for  sludges,  but  the  landfill  was  adjacent  to a  swamp,  and  the
townspeople objected to the  danger of contamination.  In a case involving a  solvent
recovery facility, three potential  sites in the prospective host town were nominated
as being appropriate  by  the responsible  State authority,  but a  fourth  site  was
selected  instead  at  the urging  of the  State's turnpike  authority.  This created
skepticism  as to whether relevant  health and safety criteria were used in making  the
decision.

    A few  State government and industry representatives have raised  the question
concerning whether it  would ease siting  for  recycling  facilities   if  there were a
change in the labeling of the permits  for such facilities. In California,  for example,
the State created three categories of resource recovery facility permits.  The first
is  essentially  equivalent  to  RCRA permitting, while  the  other   two  involve less
stringent  requirements  for  those facilities  recycling  non-RCRA  wastes.  (See
Appendix  J for  further  information on  California's programs.)  One of the  State
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officials involved in designing the program noted that the reason for establishing the
first category of permits was to provide recycling  facilities with a  more  positive
label  than that  of  a nonrecycling TSD  facility (personal  communication with Eric
Workman, Engineer, California Dept. of Health Services, August 21, 1985).

    Some reports have cited statistics that indicate  overall national capacity for
recycling is  sufficient to  meet  current demand (Engineering  Science  1984).  The
implication of such  statistics is  that obstacles to  siting and expeditious permitting
do  not  result in any inadequacy  in the  availability  of recycling capacity.  Such
national capacity figures are misleading for three reasons:
     1.   It is difficult to say whether changes in the prices of  virgin products, or in
         the cost of  other  forms  of  waste  treatment  and disposal,  might make
         recycling more attractive for materials currently not recycled.
     2.   Overall  capacity  figures do not  provide  adequate perspective on discrete
         capacity with respect to specific  types of waste streams.
     3.   National figures  do  not indicate  the adequacy  of geographic  distribution.
         Transportation  costs  (and  risks)  make  it uneconomic  to  move wastes for
         recycling  over   great  distances.   What  distance  would  be  reasonable
         generally will depend on the  volume  of material to be transported and the
         economic  value  of   the  recovered  product  relative  to  the  cost  of
         transportation.
    Several  States  have  created  boards or commissions with mandates to locate
sites for hazardous waste  management activities, and to identify private operators
for such sites  or, if that  fails,  to plan for a more direct State role.  Despite such
efforts, siting seems likely to remain a significant obstacle  to the  development of
expanded  treatment and resource recovery capacity.  The creation of a commission,
as many States have discovered, is not sufficient.  The rare successful  siting efforts
resulted  where there  was  consistent  government  leadership and  some  form  of
effective  public education and participation  with respect to  the  need and  criteria
for siting.  The safe and successful operations of those new  facilities sited  thus far
may, in the long run, assist future siting efforts.

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5.5.6      Permitting Issues

    Companies  involved  in  source  reduction  or  recycling are concerned with the
long and, especially,  unpredictable delays  that  are  often  encountered in the quest
for multiple permits.  The  uncertainty involved can detract from the economic
viability of a project. The complaint of uncertain delays in obtaining environmental
permits is common to most industries; it is, however, particularly problematic when
it  results in the use of  alternatives for waste  management that are detrimental to
the environment.

    Numerous  permits may  be required for a new facility  that will be recycling
hazardous wastes—Federal,  State,  and  local.   Such a facility is likely  to require
RCRA Part A  and Part  B permits  for storage, and, where appropriate,  disposal of
hazardous wastes.   Similarly, the  addition  of equipment for  source reduction may
require  permits  for "treatment" of waste.  These permits (called treatment, storage,
and disposal or  TSD  permits) must  be in  hand before construction of the facility
begins.  The  permit program may be  administered  directly by EPA  or, if the State
has its own approved program, by that  State.

    The requirement for  permitting treatment  facilities  under RCRA also creates
difficulties for  portable (mobile) treatment facilities.  Such mobile  units are moved
to  a new site frequently (every few hours or days). Presently,  EPA defines the term
"facility" as limited to  fixed sites;  consequently, .the EPA's permitting program
requires the owners of the  portable units to obtain new permits each time the units
are moved.   The  Hazardous  Waste Treatment Council (HWTC) argues  that  such
permitting takes  up  to  two years  and  costs  more  than   $200,000  (Inside  EPA
January 17,  1986).  The  HWTC has asked EPA  to adopt an expedited  permitting
procedure for portable  units based on  the development  of  design and  operating
standards.  Portable units meeting these standards  would be  permitted "by rule" by
virtue  of  conforming to  the requirements  rather than undergoing  a case-by-case
evaluation (see Section 4.3 for a discussion  of mobile treatment systems).
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    Small quantity generators also face  difficulties because of the need to obtain a
TSD permit  for  onsite  storage.  Although  some  of  the  wastes generated may be
amenable for recovery, most recovery operations will accept  a  minimum amount of
wastes.  Thus,  generators are forced to store wastes onsite in order to accumulate
enough  to  be accepted.  Under EPA's regulations, small quantity generators (i.e.,
below  1,000  kg/month, but greater than  100 kg/month) may  store onsite for  up to
270 days  without a permit. This length  of  time may  still be too short for  some
generators.  For  example, an electroplating  operation in St. Louis, Missouri, finds it
more  economical to landfill the waste  they  generate than to  send it to a recovery
operation because  of the  costs  and  time  of  permitting.  To ship  to a recovery
operation,  the  electroplater  would need to  pay $6,000  for  80  drums  (personal
communication  from  Robert  Kirk, Fin-Clain  Corporation, St. Louis, Missouri, to
Industrial Material Exchange, Springfield, Illinois; January 15, 1986).  To  ship to a
landfill, the cost is $5,788  for 80 drums.  The electroplater has stated that the firm
would prefer to pay the extra cost to  ship to the recovery operation,  thereby  being
relieved  of potential landfill  liabilities (see Section 5.2.3  for a  discussion of the
liability  aspects).  The  waste in this  example is F006, which is a  sludge  from
electroplating operations. An analysis of the waste shows that it is not hazardous by
characteristic of EP-toxicity.' (See Section 5.5.7 for a discussion of delisting issues.)

    In addition  to the specific  RCRA  permits, numerous other  permits may  be
required under  Federal  law,  although  these may be  administered  by the States.
NPDES permits (administered by the States) will be required to meet direct effluent
discharge requirements into waterways and pretreatment discharge requirements for
effluents going to wastewater treatment plants.

    A variety of air permits may be required, depending on the air quality status of
the area in  which the facility is  to  be located  and on the pollutants  to be emitted.
Under the New Source Review (NSR) permitting program, if the facility is located in
an attainment area for a particular criteria pollutant, it must go  through the  State
and/or EPA-administered PSD  (Prevention of Significant  Deterioration) permitting
process to ascertain  that,  in  addition  to not causing a violation  of  the air quality
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standards,  it is not causing a violation of the  increment of increased concentration
of that pollutant  allowed in  the  area.   If the  facility  will emit  relatively small
quantities  of  the pollutant,  the  emission sources will only be required  to  meet
applicable   NSPS  (New  Source  Performance  Standard)  requirements.   Larger
facilities  may  be  required  to install  more stringent BACT (Best Available Control
Technology). If the  facility is in  a nonattainment  area for one  of the pollutants it
will emit,  it must go through the nonattainment  NSR permitting program, which will
involve meeting either NSPS  or more stringent LAER  (Lowest  Achievable Emission
Rate)  requirements,  and possibly getting  approval  for  offsetting  reductions  from
other facilities in  the  area.  Although this program  is administered  by the States in
many cases, in numerous instances the State nonattainment NSR programs have  not
been approved, and direct EPA approval  of permits must be sought.  If the facility
will emit any of  the  toxic air pollutants regulated under  Section 112 of the Clean
Air Act, a NESHAPS (National Emissions  Standard  for Hazardous  Air  Pollutants)
may be required.

    In  addition,  as   noted  in 40   CFR  270.3,  it  may  be   necessary in some
circumstances  to  demonstrate that  the  facility  causes  no  violation  of  Federal
requirements for endangered  species,  State coastal zone management requirements,
national  historic   preservation   requirements,  or   national   and  scenic   river
requirements.

    States may have their  own additional permitting requirements,  either involving
matters  such  as  water usage, land  use, or  highway  right-of-ways, or  involving
requirements other than  those in the Federal environmental programs.  California,
for example,  requires recycling  facilities to  obtain  resource recovery  facility
permits. Local governments may require  zoning,  building, or special  use permits.

    Any or all of these permit requirements may  be time-consuming, especially in
cases  where there is  little coordination  among  the  various units  of governments
involved.  The opportunity for expediting  the process is best where a State has made
a commitment to make the siting and  permitting  of resource recovery (or  treatment
and disposal) facilities a priority.
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    In Arizona, for example,  because the development of a waste  treatment and
disposal facility is  considered  a State priority by both the Governor's office and the
legislature, the coordination and processing  of permits  at the State level for a new
TSD facility  at  a  recently-approved  site  will be  expedited.  The  State  has also
involved  EPA from the outset to  make sure that the handling of  permitting  at the
Federal  level  will  be  fully coordinated  with  the  State's effort.   The State was
therefore able to  ensure prospective waste  management contractors that  there
would  be no  unnecessary step in  obtaining permits  and  licenses.  There will  be
central coordination  to  keep all  phases  of  the  approval process on-track (with  a
target date of becoming  fully operational by  mid-1986).

    In North  Carolina,  the  State  had  a  similar  commitment  to expedite the
permitting of a treatment facility in Greensboro.  Only one  year elapsed  between
application submittal and approval.

5.5.7      Delisting Issues

    The   difficulty  of  delisting  RCRA  wastes is often noted  as an  obstacle  to
recycling some materials that do  not create any significant threat to health  or the
environment.  Some of the residual wastes  from recovery operations, in particular,
are listed as hazardous  in  EPA's  regulations.   Thus,  disposal  of  some  of  these
residuals  is subject to  RCRA  requirements.  In  addition, some residual  wastes may
be listed as D-code wastes (wastes having one or more  characteristics of hazardous
wastes).   Treating  D-code wastes  so  that  they  no longer possess  the particular
characteristic of  hazardousness (e.g., neutralizing a corrosive  waste), would exempt
the waste from RCRA regulation upon demonstration  to the EPA that  it no  longer
bears the characteristic.  On the other hand, listed wastes (F-, K-, LJ-,  and P-code
wastes),  in addition to being  treated to render them  nonhazardous, must  undergo
review by EPA via the delisting process.

    To get a  particular  waste at  a  particular  facility delisted, a  company  has two
options.  First, it can show that the  waste does  not contain any of the Appendix VIII
RCRA toxic substances (either those that caused it  to be listed or any others), and
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that it does not meet  any  of the characteristic waste  criteria.  Second, in the case
of Appendix VIII substances, it may show  that, while the waste contains traces of
such substances, it does not pose any threat to health or the environment.

     Delisting  a waste  is a regulatory action and therefore requires a  full regulatory
review, proposal, and  promulgation. In  the past, this difficulty has  been somewhat
mitigated by EPA's ability to  provide temporary exclusions and/or informal waivers
from enforcement.  But under  the 1984 RCRA amendments, all such actions must be
finalized  by November  1986.   EPA has,  by  January  1986,  granted  three  final
exclusions for  the approximately  631  petitions submitted;  however,  it has only
approved  20 final delistings (with an  additional  72  proposed and 26 currently written
up for notice).  Over  113  have been withdrawn, and  99  have  become moot for a
variety of reasons.  The vast majority of the remaining petitions did not contain  all
the information EPA required to make the decision. In the case of some  of the older
petitions, this  is compounded by the  increased informational requirements under the
1984  RCRA amendments—for  example,  that the analysis must look at all hazardous
components in the waste stream, not just those for which it was originally listed.

     In an effort to expedite  the  processing  of  delisting  petitions, EPA has  taken
several actions. The Agency has provided a guidance manual  (early  in  1985),  which
for the  first  time  clearly stipulates for  petitioners  the information  they  must
provide EPA in order  for  EPA to make its decision.  It is also in  the process  of
developing models (one of  which  has been proposed in the Federal  Register) that
provide a way for  a  company to  assess  whether its wastes are likely to  meet the
Agency's criteria for delisting before they go to the effort of submitting a petition:
Finally, the Agency has augmented  the staff  for handling delisting petitions from 2
to 11.

5.6       Summary

     The  decision to employ waste  minimization, although  primarily  an economic
one, is also based on  a company's awareness of alternatives and its perceptions of
what  such alternatives may entail.  Until recently, landfilling  offered  the  cheapest
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and most  convenient  method  for  handling waste.  The  restrictions  of  the  recently

promuglated  HSWA  may  change  this by increasing the economic  viability of waste

minimization.  Despite  incentives associated with these regulations, some barriers

exist  to  waste  minimization,  mainly  because  of  the  economic  difficulties  in

investing  in  waste minimization  technologies;  the  economic/financial difficulties

caused by  regulatory requirements;  real or perceived  problems in  complying with

regulations associated  with implementing  waste  minimization practices;  real   or

perceived  technological  barriers; and  lack of  in-house  expertise to implement

existing technologies or methods. Summarized below are elements that are key  to
either promoting or inhibiting  waste  minimization:


    •  Economic Issues

           A  company  can justify  an  investment  in  waste  minimization if the
           present value of the resulting cash  flow is greater than the  current cost
           of the investment.  Smaller firms are generally not able to raise as much
           capital as larger firms  and thus face a greater constraint on  their overall
           investment capabilities.

           When  the  cost of  reducing waste is less  than the cost of producing the
           present  amount of  waste minus  the cost  of producing a lower, future
           amount, there is no motivation for investing in waste minimization.

           Distance to a recycling  facility  and the  costs of transportation play a
           major role in the decision to ship wastes  offsite for  recycling.  In order
           for  offsite  recycling to  be cost-effective,  sufficient  volumes must  be
           recycled;  in  some  cases,  recyclers  will  not accept amounts  below  a
           minimum  amount.   Small-scale  generators  may  not  generate  enough
           waste and must, therefore,  store  it onsite  in order  to' accumulate  a
           sufficient  amount.  Storage for more than 90  days  (270  days for small
           quantity generators) requires obtaining a TSD  permit, which  is both  time
           consuming and costly. Thus,  landfilling may be  a less costly (and thus
           more attractive) waste  management alternative to recycling  in  such
           instances.   Where  it  is  possible  to  do so, however, small-scale waste
           generators  have  initiated recycling programs by  consolidating  their
           wastes, thus creating economies of scale that make recycling  economical.

           Investment in  innovative  waste  minimization technologies is influenced
           primarily by the profit and risk  associated with  the innovation.  Other
           factors  include  cost,  capital   availability, the adaptability  of  the
           technology,  market  and  regulatory  factors,  and  internal   production
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       factors.  A  major  incentive  for   investing  in   waste  minimization
       technologies is the increasing cost and/or  the  banning of land disposal of
       hazardous waste, due to the requirements of HSWA.

•  Liability Issues

   -   Under  CERCLA, generators  may  be  held  liable   for  damages  from
       subsequent  treatment, storage,  or disposal of their  wastes.  The risk of
       future  liability resulting  from  disposal of  hazardous waste thus  may
       serve   as  an  incentive   for  instituting  onsite   waste  minimization
       practices.  Factors  associated  with  this  liability  issue  include   the
       inability  to obtain liability insurance  and potential  liability  for cleanup
       costs.   Because  owners  of  landfills  must  demonstrate  financial
       responsibility, under  RCRA  disposal  fees  may  increase  to  cover what
       insurance normally provided.

       Raw materials may be less  costly than recycled waste materials because
       of the effect of CERCLA  liability on  transportation costs.  The liability
       of a transporter of a hazardous substance generally ends  upon delivery to
       its destination, provided it is not  delivered for treatment  or disposal.
       Conversely, a  transporter  delivering  hazardous substances that may  be
       recycled  may be liable  for  damages from subsequent handling of  the
       waste material or its residue.  As  a  result,  transporters  may  charge
       higher fees for delivery  of hazardous wastes  that  are  to be used  in a
       process than for delivery of raw or virgin materials, since the former  are
       not being delivered  for "treatment or  disposal,"  but rather for direct  use
       in a process.  The higher  fees would  be charged  because  of  potential
       liability   costs  that  the transporters'  insurance may not  cover.   This
       presents an inhibition against using  recycled  materials,  because of  the
       costs involved. An  exception may exist for recycled materials that  are
       used  directly  without prior  reclamation,  since under  EPA's  revised
       definition of  solid wastes  such  substances  would not be  required to  be
       manifested.

       For companies that  lack in-house expertise, onsite  waste minimization
       may not be an option.  Liability issues may present a disincentive to  ship
       offsite because generators  may not know of the reliability  of recyclers
       and  may fear  future costs  they  may  incur for  damages caused  by
       subsequent handling of their wastes. In such instances, liability serves to
       inhibit such waste minimization practices.

•  Company Attitude/Awareness Issues

   -   RCRA,   HSWA,  and   CERCLA   have   influenced  corporate   waste
       management officials to  consider methods of  reducing hazardous  waste
       generation.
                                  5-68

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   Corporate  policies  can  influence  waste  minimization  practices.  To
   increase  awareness  and  motivation,  companies  may  provide   waste
   minimization  newsletters,  cash  awards,  certificates,  seminars, and
   workshops.  Without upper management support, however, companies are
   unlikely  to  change.  Many attitudes serve as  disincentives  for   waste
   minimization.  These include  lack of familiarity with current  production
   techniques,  resistance to change, fear of product quality  detriment, and
   management's  view  that  waste minimization is a service  function of low
   priority.

   Many RCRA-related issues have been viewed by industry as disincentives
   to  hazardous  waste minimization programs.  These perceptions include
   inconsistent implementation;  complicated and costly permit application
   and   information   submittal  procedures;  time-consuming   delisting
   processes; and  storage requirements which do not  allow enough time  to
   accumulate  a  sufficient  volume of waste to recycle without the need for
   a  TSD  permit.   Other  RCRA-related  issues include  waste  stream
   analysis, mixture rule, and process recertification provisions.

Consumer Attitude and Public Relations Issues

   Consumer attitudes  may  play a role in affecting a company's decision  to
   practice waste minimization if (1) there is an increased  awareness  of the
   environmental  effect  the manufacture  of  the  product  may  have, along
   with the consumer's  desire to  improve the environment;  (2) the  consumer
   is willing to accept whatever changes  there may  be in product quality;
   and  (3) the  consumer  is willing to  sacrifice purchasing a product  that
   may be cheaper and/or superior in quality.

   Consumers may be more  likely to purchase  products that  are made using
   waste  minimization  processes if  they  do not  require  a  substantial
   financial investment.  Thus, as  an example, consumers  may  be willing  to
   try  a  different  paint,  but  not   a   different   computer   based  on
   environmental issues alone.

-  Public relations may play a role with respect  to a  company's reputation.
   Companies that actively seek environmental solutions may benefit from
   being perceived as conscientious by both the community and by agencies
   that regulate them.

Regulatory Issues

   The  requirements imposed  by  RCRA  and  other regulations  may both
   inhibit and  promote  waste minimization practices.  In  particular, the
   HSWA requirements  for  land  disposal restrictions,  treatment  standards,
   and  technological  requirements  for  landfilling  (including  corrective
   action for prior releases) may  act as a significant impetus  for companies
   that otherwise  may not have  considered waste minimization methods and
   techniques as an alternative.

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The   revised  Uniform  Hazardous  Waste  Manifest  Form  contains  a
certification by generators regarding  efforts to reduce  the  volume  and
toxicity of wastes generated.  The act of certifying, by  itself, may cause
some companies to consider and implement waste minimization measures.

Increased  requirements and misinterpretations of the definition of solid
waste  may  be  disincentives  to recycling.  For  example, many wastes
recycled offsite and that must  undergo reclamation  prior to  reuse  must
be manifested.  Because  of  liability concerns, some generators may be
reluctant  to do  this.  Also, some members of  the  regulated  community,
as well as some State environmental agencies, have misinterpreted  the
regulations and  feel  that  reclamation  activities, by virtue of their being
forms of treatment, require TSD permits.  Companies, therefore, may be
reluctant  to  practice  onsite reclamation, feeling  that  to do  so would
require  permitting.    States  who  misinterpret the  regulation  in  this
manner   may   compound  the   difficulty   by   incorporating    the
misinterpretation of  their version of the regulations.

Technological and other requirements imposed by  HSWA on  all  new  and
existing TSD facilities will likely lead to an  increase  in the cost of land
disposal and an increase  in  closures of  land  disposal  facilities;  thus,
generators are more  likely to consider  waste minimization practices.

The problems associated with the siting of a waste treatment  facility  are
significant  obstacles  to  expanding  treatment  and  resource  recovery
capacity.

The  possibility that  a source  reduction technique  may require a TSD
permit may  constitute a significant barrier to such practices because of
the time-consuming and costly  nature of permitting.

The  uncertainty and  unpredictable  delays  associated  with obtaining
appropriate  permits   from  State  and  Federal  agencies may  reduce
interest  in   waste   minimization  alternatives  that  require   (or   are
perceived  to require) RCRA permits.

The  difficulty   of delisting  RCRA wastes  has  also  been  cited  as  a
disincentive to recycling some waste materials.
                           5-70

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            6. INDUSTRY EFFORTS TOWARDS WASTE MINIMIZATION

    Sections  3  and  4  of  this  report  characterized  both source  reduction  and
recycling  practices from the technological standpoint, as well as in  terms of the
current and  potential  future extent of waste reduction.  Section 5 characterized
economic, motivational, and  regulatory factors associated  with the promotion or
inhibition  of waste minimization activities  by industry.

    This  section  provides  a summary  of general observations derived from  the
analysis of 115 cases of waste minimization reported  in  the literature.  The same
literature served as an  information resource for  Sections 3, 4,  and  5 as well.  This
compilation represents,  for the  most part, successful  waste minimization histories.
The  full  compilation  is included in Appendix H.  A  more exhaustive search may
reveal more cases in which such  practices were not enlisted; however, the literature
tends to emphasize successes rather than  failures. Future surveys may be necessary
to more fully represent cases of  failures.

6.1        Description of Information Base

    The available data  sources (LWVM 1985, Huisingh et al.  1985,  Campbell  and
Glenn  1982,  UN  Compendium 1981-1985,  Kohl et al.  1984, Garrison 1985, Sabrino
1985, 3M  Corporation 1985) were reviewed; this review  yielded a compilation of  115
distinct cases of waste minimization, which has the following characteristics.
    •   Ninety-four different  U.S. companies  provided  115  waste  minimization
        cases.
    •   For the most  part (77 cases),  the sizes  of the 94  companies  were  not
        reported; of the 17 that provided  size data,  12  companies listed more than
        10,000 employees and 5 listed less than 10,000. Judging by the nature of the
        product  and other provided information,  however, it is likely that 35 of the
        77  companies that provided no size data are small- and medium-sized firms.
    •   Of  the 58  companies  that listed  their  SIC  codes,  14 (24 percent)  listed
        multiple SIC codes.
    •   Of  the  total of 89  different SIC codes reported,  37 (42 percent) were in the
        Chemical and  Allied  Product Industry category  (SIC 28).  The  remaining
        reporting industries included Electric and Electronic Machinery (7 percent),
        Primary Metals  (4 percent),  Fabricated  Metal   Products  (4 percent),  and
                                      6-1

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        Petroleum/Coal  Products   (4 percent).   Also  represented  were  textile,
        printing,  rubber  and plastic, and non-electrical  machinery manufacturers.
        None of these categories exceeded 10 percent  of the total respondents.
6.2       Observed Trends in Industrial Waste Minimization Efforts


    The  following observations summarize  the  analysis of the compiled 115 cases
discussed above.
     1.   Most of the reported  waste minimization efforts were initiated after  1976.
         Of the  31 cases for which the initiation date was provided, 25 (81 percent)
         were started after 1976 and 17 (55 percent) after 1980.

         Discussion;  This   observation  is  consistent   with  the  trend noted   in
         Section 5.3, i.e., that  corporate  environmental departments began to  form
         in  the  1970s in response to the  regulatory pressure provided by the Clean
         Water Act, Clear  Air  Act,  and RCRA.  Additionally,  the  great  majority of
         the waste minimization  efforts (81 percent) were  initiated after 1976, the
         year RCRA was authorized.

     2.   There are 53 cases for which the  original objectives were stated. Of these,
         39 (74 percent) reportedly were initiated  with the  primary objective of
         minimizing waste generation.  The remaining  14 cases were initiated  with
         the original objective of increasing yield or profit, e.g., by raw materials
         savings.

         Discussion:  This   finding   appears  to   contradict  the  general  notion
         consistently expressed by  the participants of  the  Woods  Hole  conference
         (LWVM 1985) and others that waste minimization activities are synonymous
         with the  efforts to increase yield and reduce  raw material cost. However,
         it must be  noted that all of the  compiled cases were originally identified,
         characterized,   and selected  in  the  course  of an  information gathering
         process  specifically  focused  on  waste  minimization.   This  may  have
         reduced the amount of information provided about cases where the initial
         motive was yield maximization.

     3.   For many  cases,   more  than  one type  of waste  minimization technique
         employed  was  listed;  a  total  of  268  waste minimization  techniques  were
         reported for the 115 industrial waste minimization  cases.  These techniques
         were categorized as shown in Table 6-1.

         Discussion:  Process modifications and  recycling appear to be the  most
         popular techniques. Again, the results seem to contradict the expectation
         that  better operating  practices  (good  housekeeping) would  be the  most
         popular waste  minimization option, because  of its low  cost  and ease  of
         implementation.   Perhaps the reason  for this is that good housekeeping  is
         often  the  least  effective  option in  terms  of  the  amount  of  waste
         minimized; it is also the least-documented option.


                                      6-2

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1311s
   Table  6-1   Characterization of  Reported Waste Minimization Techniques
                                                   Total reported
   Type of technique                      Cases                    percer







Process modifications                      113                        42



Better operating practices                  27                        10



Product substitution/reformulation          13                       	£







Recycling                                   83                        31







Treatment                                   32                        12



                         Total             268                       100
                                   6-3

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     4.   Within the cited recycling efforts, most were performed for onsite solvents
         recovery,  followed  by  metal recovery, heat  recovery,  and  the  sales  of
         waste for  reuse in other processes.

     5.   Reduction  efficiency was  reported  for  108 cases or individual techniques.
         The following statistics were obtained, as shown in Table 6-2.

         Discussion;  Since  in  the  majority of cases,  waste reduction "efficiency"
         was not formally defined, some uncertainty  exists as to  the meaning and
         interpretation of "percent reduction." Still, it is observed that for a large
         number of cases (37  percent) a high percentage reduction (> 90  percent)
         was reported.  This observation  appears to be  consistent  with the  previous
         observation that process  modifications  (usually  the  most effective means
         of waste minimization) are a dominant practice.
    In  addition   to   the  quantifiable   information   given  above,  the  following
qualitative observations were made:
    6.   Large companies (cited in LWVM 1985) generally  reported having internal
         waste minimization  programs  established as  a part  of formal corporate
         policy.  Typically,  the overall monitoring  responsibility for the  waste
         minimization program  was assigned to the corporate  environmental staff,
         with  the initiation  and implementation of  the program  assigned  to the
         management of individual manufacturing facilities.

    7.   Most  responding companies (LWVM 1985) consider technical elements  of
         their waste minimization programs to be proprietary information.

    8.   Internal  economic constraints are perceived to be the dominant "barrier"  to
         waste minimization.   This is  closely  followed by  regulatory  constraints
         (RCRA  permit requirement   for  recyclable  waste,  the  complexity   of
         regulations,  hazardous  waste definitions, etc.). Technological constraints,
         e.g., lack of  ready-to-use  technology, rank third.  Motivational constraints
         are rarely mentioned.
6.3        Capital Outlays, Annual Savings, and Payback Period


    Cost  information was provided for 40 waste minimization cases.  For the vast
majority of  cases, the financial data numbers indicated that the  waste minimization
efforts have been highly profitable. Additional observations are given below.
     1.   Reported capital  outlays vary  widely  between  zero  and $4,300,000.   The
         breakdown within  the 22 cases analyzed is shown in Table 6-3.
                                      6-4

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1311s
            Table  6-2   Characterization of Reported Efficiency
Waste reduction efficiency
(Percent)
> 90
70-90
50-70
< 50
Total

Cases
40
18
21
-23.
108
Total reoorted
Percent
37
17
19
_22
100
                     Table  6-3  Capital Cost Outlays

Capital cost
< $10,000
$10,000-$100,000
$100,000-$! ,000,000
> $1,000,000
Total
Total reported
Cases Percen
10 45
6 28
2 9
_4 18
22 100
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     2.   Reported  annual  cost savings  for the 40 cases range  from $6,000/yr to
         $6,184,000/yr, with the following breakdown as shown in Table  6-4.  Most
         savings  were from  lower disposal costs, lower raw material requirements,
         and sales of  wastes.
     3.   Payback periods were observed to be less than 5  years. For  28 cases where
         the payback periods  were reported,  the  range  was  between zero  and
         5 years, with the breakdown as shown in Table 6-5.

     The compilation  of cost  statistics  excluded  the data from IBM Corporation
(LWVM 1985), which provided an extensive list of waste minimization cases, mostly
dealing with solvent recovery  and  mostly profitable. The  data  were excluded to
avoid biasing the statistics  toward solvent recovery.

6.4       Summary

     Waste  minimization by industry historically has been accomplished through
efforts to maximize product yield and reduce the cost of raw  materials.  However,
more recent efforts,  in response to  regulatory pressure, have been directed toward
making waste  minimization  a primary  project objective  and  a part  of formal
corporate policy.

     Process modification  appears  to  be  the  most  frequently used  technique,
followed  by recycling and  waste  treatment.   Better  housekeeping (or improved
operating practices)  were  reported  rather  infrequently.  The  majority of  cases
reported  high  waste  reduction  efficiencies in excess of  70  percent.   Economic
constraints are perceived to be the principal barrier to waste  minimization, followed
by regulatory constraints and technological constraints.

     Waste minimization  appears to  be profitable, with over  80 percent of the  cases
for which data were obtained reporting payback periods less than or equal to  three
years.
                                      6-6

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1311s
                      Table 6-4   Annual  Cost  Savings
        Annual  savings
                                                   Total  reported
Cases
        <   $50,000





        $50,000-$100,000





        $100,000-$200,000





        $200,000-$1,000,000





        >   $1.000,000





                          Total
  17





   2





  10





   6





 _5





  40
43





 5





25





14
                                                                    100
                        Table 6-5  Payback Periods
Payback period (years)
< i
1-2
2-3
3-4
> 4
Total reoorted
Cases Percent
15 54
6 21
2 7
3 11
_2 7
                       Total
                                            28
                                                                    100
                                    6-7

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                7.  GOVERNMENT AND NONINDUSTRY EFFORTS
                        TOWARD WASTE MINIMIZATION
    The Hazardous and Solid Waste Amendments of 1984 (HSWA) require that EPA's
Report  to  Congress  address  the  desirability   and  feasibility  of  performance
standards,  or management practices prescribed to  effect the reduction of hazardous
waste treatment,  storage, and  disposal.  Initially, hazardous  waste  legislation  and
regulation  in the  United  States addressed  the problem  of  hazardous  waste  through
control  of  its disposal.  Now, however, States and nongovernmental entities have
begun  to  recognize the  need to examine  alternative  waste  management methods
that reduce waste generation,  or its  subsequent  treatment, storage, and disposal.
This  recognition  can  most  probably be  attributed  to  the  waste minimization
provisions in HSWA, as well as to an increased awareness of  the issue itself.

    This section summarizes representative  Federal,  State,  and  local efforts  to
implement  recycling  and  source  reduction as waste  management alternatives.  In
addition, the  section  presents  a summary  of  nongovernmental and nonindustrial
research into and promotions of  waste  minimization.

7.1       Congressional Initiatives

    The primary initiative undertaken by  Congress to  promote  waste minimization
was embodied  in HSWA (see  discussion in Section  1).  In addition to this legislation,
other activities  include studies conducted by Congressional agencies, including  the
Congressional  Budget Office  and the Office of Technology Assessment  in response
to requests from members of  Congress.

7.1.1     Congressional Budget  Office

    The Congressional  Budget  Office  has analyzed  alternative  waste  control
strategies proposed to achieve the national goals  of  the 1984 RCRA amendments.
Waste-end  tax  systems were specifically  considered as a method  of encouraging a
reduction in the  amount  of  hazardous waste  generated.   Three basic  alternative
forms of waste-end taxes  were identified:
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     1.   Taxes based on waste treatment or disposal technology;
     2.   Taxes based on waste hazard; and
     3.   A flat tax based on unit of waste generated.
    Each of the alternative waste-end tax forms would increase the costs of  waste
disposal, thereby encouraging reductions in hazardous waste generation.  By varying
the tax structure according to the treatment or disposal  method,  Alternative  1
would  provide  the  most effective  means  of promoting the best treatment/disposal
methods available.  Alternative  2  would  provide  the  most  effective  means  of
reducing the  generation of targeted wastes.  Alternative 3 would not change relative
waste management costs, and thus would not encourage the reduction of one type of
hazardous waste over another.

    The waste-end  tax is a mechanism  for shifting  the  costs  of  hazardous  waste
generation to those who most directly benefit from hazardous  waste  production:  the
waste-producing  company  and the  consumers  of  its product.  Waste-producing
companies would  face  increased  costs,  which  would  in  turn result in  reduced
company  profits, increased consumer prices, or both, depending upon the ability of
the hazardous waste producer to pass cost increases along to those consuming  the
associated product.

7.1.2      Office  of Technology Assessment

    The  Office  of  Technology  Assessment  (OTA)  of  the  U.S.  Congress  has
performed studies on the  technologies  and management strategies involved in  the
treatment of hazardous wastes,  including efforts to  reduce  their generation. The
OTA's analyses,  findings, and  conclusions are used to complement other research
efforts  in  the  hazardous waste management  field.  The OTA information transfer
has indirect effects on  the reduction of hazardous waste  generation  nationwide  as
well, as research  is applied in industry and in State and Federal legislatures.

    OTA  specifically addressed the potential of end-product substitutions to reduce
the quantity  of  hazardous  waste generated. Five case studies  were  performed  of
specific end-product substitutions  that were successful in reducing the amount  of
waste   generated.   These  studies  lend  insight  not  only   into  the   particular
                                      7-2

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substitutions studied,  but  also  into  the  general  implementation  problems  and
potential  waste reduction  benefits resulting from  end-product substitution.  OTA
estimates that  end-product substitutions could  reduce  hazardous  waste generation
by 20 to 80 percent, depending upon the end product  (OTA 1983).

     OTA  is currently conducting a study on source  reduction in response to requests
from the  following Congressional Committees:  Senate Committee  on Labor  and
Human  Resources, House Committee  on  Small  Businesses, House Committee on
Science and Technology,  House Committee on Energy and  Commerce,  and  the
Senate Committee on Environment and  Public Works.  As  part of this study, OTA
will  (1) examine the state  of technology  available  for source reductions; (2) assess
the  level  of effort in promoting  source  reduction  in  States and their programs, as
well as current  Federal efforts; (3) assess  information needs  from the perspective of
government  and  industry;  and (A) provide  policy options of  what   the  Federal
Government  can  do  to  enhance source reduction.   The  last  item   will   include
evaluations  of regulatory,  nonregulatory,  and legislative options, as well as a review
of what the Federal  Government can  do to complement State efforts to  reduce
waste generation.  The  report will be published in fall  1986 (personal communication
with Kirsten Oldensten, OTA, January 10, 1986).

7.2       National Research Council

     The  National  Research  Council was established  by the National  Academy of
Sciences  to  associate  science  and  technology with the  Academy's  purposes of
furthering knowledge  and advising the  Federal Government. The  Council  recently
prepared  a  report  analyzing   actions  that would  accomplish  the  reduction in
hazardous  waste  generation called for  in the  RCRA reauthorization  (National
Research  Council  1985). The report centered on nontechnical, institutional factors;
its conclusions are listed below.
     1.   Most waste reduction efforts in  the U.S. are in their  early stages.  Many
         opportunities exist for reducing the generation of hazardous waste.
     2.   Substantial  waste generation reduction  can  be  achieved by employing
         relatively   simple   methods   (typically   emphasizing   engineering   or
         plant-specific circumstances) that entail modest capital expense.

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     3.   The increasing costs of land disposal  for hazardous waste are an extremely
         important impetus to companies implementing waste reduction programs.

     4.   The  dissemination  of  information  about  successful  waste  reduction
         techniques and programs is an essential first  step toward  reducing  future
         waste generation.

     5.   Waste reduction approaches other than  direct regulation of manufacturing
         processes are needed.  Regulations that are adopted should  be administered
         consistently  and predictably, and  should  be  flexible  enough to encourage
         the use of methods that reduce the generation of hazardous  waste.

     6.   In  the  long  term, as  implementation  of  newer, more capital-intensive
         technology becomes necessary  to  further reduce  waste  generation, public
         policies  will  have to  adapt  to  different  considerations.  Industry  may
         require  subsidies to  help  defray  research  and development  and capital
         costs.   Long  research  and   development   lead  time   necessitates   an
         immediate beginning of research and  development efforts.
7.3      Federal Agencies


    The   Federal   Government   has  promoted   waste   minimization  through

(1) legislation  that  directs  various  agencies  to  carry out  specific  mandates, and

(2) appropriations that fund national environmental activities.  Although numerous

studies on  recycling and source  reduction have  been undertaken,  the  focus of this

section is on a  representative  selection of the agencies and  programs involved with
hazardous waste minimization.  These are  as follows:
    •   The Environmental Protection Agency;
    •   The Department of Energy;
    •   The Department of Defense; and
    •   The Tennessee Valley Authority.
7.3.1      Environmental Protection Agency


    The   Environmental   Protection   Agency   (EPA)   is  responsible  for  the

implementation of laws, policies, and regulations associated with the major  pieces

of Federal environmental legislation. The  Resource Conservation and Recovery Act

(RCRA)  and  the  Comprehensive  Environmental   Response,  Compensation,  and

Liability   Act  (CERCLA)  or  Superfund  are the  enabling legislation  for  EPA's

hazardous waste programs and regulations.

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    While  no program  within  EPA is specifically geared  to  source  reduction and

recycling,  the  Office  of  Solid Waste (OSW) has become the program  most directly

involved in waste  minimization issues since  the passage  of HSWA.  Other  programs

within EPA that either directly or indirectly  influence waste minimization are the

Office of Water (OW),  the Office of Research and Development (ORD), the Office

of  Policy, Planning  and  Evaluation  (OPPE),  the Office  of  Emergency  Response

(OER), and EPA's involvement with  the  United  Nations Economic Commission for

Europe.
    •   Office  of Solid  Waste.  The Office of Solid Waste  (OSW) is charged with
        developing  and implementing  RCRA and  its amendments,  which  promote
        waste minimization directly by  mandating:

        -  The   inclusion   on  hazardous   waste   manifests  of  the  generator's
           certification  that  waste quantity  and  toxicity  are reduced  to  the
           maximum degree economically practicable;

           The inclusion of descriptions of  the generator's efforts to reduce waste
           volume  and document  actual  reductions achieved in biennial  reports to
           EPA;

           The   requirement  that  generators  certify  annually  that  they  are
           minimizing waste quantities and toxicity to the extent  feasible,  as a
           condition  of  all  treatment, storage,  and disposal  permits issued after
           September 1, 1985;

           A provision for  controlled  correspondence  to  inquiries about  whether
           particular  activities  may  qualify  as  waste  minimization  practices.
           (HSWA  do not   permit EPA  to  interfere with  or  to intrude into  the
           production process by requiring standards for waste  minimization.  OSW
           has taken action in responding to  specific inquiries about these practices,
           however); and

           The  preparation  of   a  Report  to  Congress  on the  desirability  and
           feasibility of instituting  performance standards, management practices,
           or other  actions to  "assure such  wastes  are managed  in  ways that
           minimize present and future risks to  human health and the environment."
    Waste minimization is indirectly promoted as well by land disposal restrictions

and by  increased  technological requirements  for new TSD  facilities  (discussed in
Section 5.5).
                                      7-5

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•  Office  of  Water.  The  Office  of Water (OW) has controlled wastewater
   pollutants  by requiring  in-plant  (source) reductions in several industries.
   Under the Clean Water Act  (CWA),  effluent limitations  guidelines  and
   standards  are  issued  to control discharges of  pollutants from  industrial
   facilities (or point sources).  The bases for  the limitations in some  of the
   guidelines  and  standards are chemical use minimization or substitution and
   water use reductions,  which  in  turn reduce  pollutant discharges.  Although
   the  wastewater  itself  is  not  a RCRA  hazardous waste,  sludges  from
   wastewater treatment often are; thus, the effluent guidelines  may serve to
   reduce some  RCRA hazardous wastes associated with wastewaters.

•  Office of Research and  Development.  The major activities of ORD in waste
   minimization  include  a  small   business/small  quantity  generator  research
   program in  ORD's  Office  of  Environmental  Engineering  and Technology
   (OEET),  an outreach program run by ORD's Regional Services Staff (RSS),
   waste reduction research conducted by the Hazardous Waste Environmental
   Research  Laboratory  (HWERL),  and   Congressional  appropriations  for
   research administered  by ORD.

       The  OEET Small Business/Small Quantity  Generator Research Program
       provides  financial  support  for  research  and  information efforts  of
       agencies  or   associations working  directly  with  small businesses. Its
       current efforts  include two main  focuses:  (1) supporting  the  research
       efforts of  State  technical  assistance  programs  (providing  financial
       support to North  Carolina's  PPP program)  and (2) providing  funding to
       the Governmental  Refuse Collection and Disposal Association to set up a
       clearinghouse to furnish  information  on  waste  management  options to
       small businesses.

       The  RSS  serves as a clearinghouse for the regions and States to  field
       requests related to technical information or technology transfer that do
       not   fall   within   other  avenues  of  inquiry  within   EPA regions  or
       headquarters  (these  are  usually  questions  that involve more  than  one
       media or  discipline within EPA). RSS has also entered into a cooperative
       agreement with the  National  Governor's Association to help  formulate
       priority needs for EPA's long-term  research  program.

       HWERL in  Cincinnati  is undertaking research on waste  reduction and
       recycling  technologies  used  by  various   industries,  with   particular
       emphasis  on  the printed circuit board industry  and on solvent and  metal
       recovery.  HWERL is  conducting  additional  research  on  performance
       data  of treatment processes, which  include  some  recycling processes.
       Technologies  examined  include  sodium  borohydride metals  reduction,
       electrolytic recovery of  in-process plating bath solutions,  and  activated
       carbon treatment of plating baths for reuse  of bath materials.

       Congressional appropriations  for research  are administered  by  ORD,
       although  the  research  projects  are  carried  out  by  EPA-recognized
       "centers of excellence" at  selected universities in  the  U.S.   One  such
       project is concerned  with waste  minimization (among other issues) and is
       being  carried out  by  Tufts University's  Center  for  Environmental
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        Management  (CEM) in cooperation with EPA's Office of Solid Waste.  CEM
        has proposed  to  address foreign technologies and strategies  to reduce waste
        generation, as well as to  examine the  technical and regulatory  aspects  of
        waste minimization in the U.S.  The study will also focus on  economic issues
        such as the relation between policy decisions affecting the use of particular
        waste management options and market responses (e.g., insurance providers
        not writing policies for  non-sudden environmental  damage  resulting  from
        land disposal  of hazardous wastes).

     •   Office of  Policy, Planning and Evaluation.  The Regulatory  Reform Staff  of
        OPPE, in  conjunction with the  Office  of  Enforcement and  Compliance
        Monitoring,   recently  issued   a   policy  statement   (50  FR   46504)   that
        encourages environmental auditing - an  idea  that may  indirectly  promote
        waste  minimization.   Environmental  auditing  is  a   systematic,  objective
        review by  companies  themselves of their operations  and practices.  Among
        other things,  the  approach could  be  designed to assess the  potential for
        initiating  waste  minimization practices.  (Appendix  I contains  this policy
        statement.)   Also,  the   Integrated  Environmental  Management  Division
        (IEMD) has developed a computerized  hazardous waste  management model
        that assesses the  risks  inherent  in current hazardous waste management
        practices.   It also  evaluates  the  potential  changes  in  risk  resulting  from
        alternative waste management strategies.

     •   Office of  Emergency Response.  Another  of  EPA's  responsibilities is the
        implementation  of  CERCLA,  known  as  the Superfund program.   Because
        generators may  be held  liable for the costs  of future  cleanups  under the
        liability provisions  of  CERCLA,  the   legislation  provides   an  indirect
        incentive to reduce the generation  of hazardous waste.

     •   United Nations  Economic Commission  for Europe.  EPA  participates  in
        international  efforts to minimize wastes produced by  industry.  The United
        Nations  Economic   Commission  for  Europe (UNECE) currently  provides  a
        compendium  of  low- and  non-waste technology  to  serve  as a  means of
        promoting   process  technology changes that  eliminate or  reduce  wastes,
        energy usage, or natural  resource  usage.  The  U.S. EPA has supported  this
        effort by contributing five descriptions to the compendium and assisting the
        UNECE staff  with other information as needed.
    In   addition  to  the  above   program   activities,  EPA  is  funding  some
State-conducted  research  on  waste  minimization,   including  research  at  the

Industrial Waste Elimination Research Center  at Illinois Institute of Technology and
the Technical  Assistance Program at Georgia Tech. EPA is currently considering a

request made  by the State  of Maryland Hazardous Waste Facilities Siting Board to

fund 50 percent of  the cost of waste exchanges in the  U.S.  (see Section  4.3.2 for

further information on waste exchanges).
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7.3.2      Department of Energy

    The Department of Energy (DOE) is involved with research and development on
the combustion of wastes as fuels, as  well as in the design of systems that conserve
energy. DOE, through the Office of Industrial Programs (IP), executes the Industrial
Energy  Conservation  Program, which  promotes and sustains  cost-shared research
and development (R&D) to improve the  efficiency of industrial energy  use.  The
program was created  under  the  mandates  of the  Federal  Non-nuclear Energy
Research and Development Act of 1974 (PL 93-577) to carry out the national energy
policy,  which emphasizes that energy  conservation is an important resource  and a
vital component of a balanced and diverse energy supply system (DOE 1983a).

    Within the  IP,  there  are two  major divisions:   (1) the  Division  of Improved
Energy  Productivity, which conducts  R&D  in  designing new systems that conserve
energy, and (2) the  Division of Waste Energy Reduction,  which  is involved with  the
combustion of  wastes as fuels.  The first concentrates on improving the in-process
energy  efficiency and  productivity.   Since  ash from  some  of  these  combustion
processes  is  hazardous, improving the  energy efficiency  of  a system  would also
result in a reduction in the generation of hazardous waste, i.e., source reduction.
The  Division of  Waste  Energy  Reduction  supports  R&D  of  energy-conserving
technologies to recover and utilize energy from waste materials.

    Some examples of recent projects undertaken by DOE include:
        Concentration  of  Electroplating  Waste  Rinse  Water:   Process  Uses Energy
        Efficient   Low-Temperature   Evaporation.    A    vapor-recompression
        evaporator  is being developed for use by the  electroplating  industry;  the
        system has potential application for any industry using a high-temperature
        evaporative process (DOE 1983b).
        Energy  Recovery  from  Industrial  Solid  Waste:   Boilers  with  Multifile!
        Burners  Can Use Refuse-Derived  Fuel.  Boilers retrofitted  with  multifuel
        burners  that can  be  fired with industrial wastes  as  substitutes  for  or  in
        combination with  fossil  fuel have  been studied  for  use  in industries  that
        generate more  than 10 tons/day of combustible waste (DOE 1983c).
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        Energy Recovery from Waste Plastic:  Converting Atactic Polypropylene  to
        Fuel Oil.  A pyrolytic  process that converts atactic  polypropylene waste  to
        fuel  oil has  been developed for  use   by  polypropylene  producers  in the
        plastics industry;  the  process has potential application  to  other types  of
        plastic waste, including waste polyvinyl chloride (DOE 1983d).
These  examples  are  not  necessarily  concerned   with  processes  that generate
hazardous  waste;  however,  their  results  may  have  applications that  extend  to
processes that do generate such wastes.

7.3.3      Department of Defense

    The Department  of  Defense  is  involved in a  wide  variety  of  activities  that
parallel  many industrial operations  in  the private  sector,  such  as  electroplating
operations, painting and coatings, paint  removal, degreasing, metal fabrication, and
explosives.  The nationwide practices of these activities  make the Department  of
Defense  (DOD)  one of the largest  generators of hazardous wastes in  the country.
DOD's waste minimization efforts thus  may serve as a model  for generators in the
private sector.

    Since the passage of HSWA, there has been increasing  awareness in  all  sectors
for the need to  properly manage  hazardous  waste.  As a hazardous waste  generator,
the DOD has made it a policy, since  1980, to limit  the generation of  hazardous
waste  through  alternative  procurement policies and  operational  procedures and,
when practical, to reuse and reclaim wastes for the conservation of raw materials.

    DOD's  environmental  efforts  take place  within different  portions  of  this
agency.  The major environmental activities, as disclosed in conversations  with DOD
personnel, are:
     1.   The Defense Environmental Leadership Project (DELP) - an office created
         in  1983 to develop innovative  solutions to the environmental  problems of
         the DOD;
     2.   The Defense Logistics  Agency (DLA) - an office within DOD that provides
         field  support  (such  as  hazardous waste  disposal services)  to  the various
         DOD installations; and
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    3.   The installations themselves  within  each  of the  services  that  develop
         solutions and procedures  for handling environmental problems at the  base
         and service levels through the service's "Logistics Commands."

    Below are  descriptions of  each of these DOD entities, their functions, and their
activities as they relate to waste minimization.

Defense Environmental Leadership Project

    A recent DOD initiative was the establishment of the Defense  Environmental
Leadership  Project  (DELP).   DELP was created  in  1983  to  develop  innovative
solutions  to  the  environmental  problems for DOD,  with emphasis   on  improving
compliance  and  minimizing wastes.  One  of  DELP's  efforts  was  to  sponsor a
three-phased project to evaluate current minimization attempts  and  to recommend
future strategies to achieve hazardous waste minimization.  Phase I  of the project
involved  the  evaluation of 40  case studies of industrial process modifications.  In
Phase II, DELP will  select 18 of these cases for a detailed review.  Finally, in Phase
III,  DELP will  choose three  cases called  "projects of  excellence,"  which  will be
promoted within the  DOD (Higgins 1985).

    An evaluation  of  40 cases  illustrating  DOD's  efforts at  hazardous  waste
minimization  revealed  three   factors   that  contribute  to  successful   process
modifications (Higgins 1985):
    •   There tended  to  be a  "champion"  promoting the  project, allowing  it to
        overcome technical  or developmental problems and  the inertia  that tends to
        protect existing processes.
    •   Support  for modifications  was provided  at a  sufficiently high level of
        command to affect population and environmental policy decisions.
    •   Successful  modifications usually required  the reallocation  of funds  from
        operations or production activities to environmental protection.
Process modifications resulted in multiple advantages. In addition  to reducing the
amount of  hazardous waste  generated, other desired effects included improved
product quality  and production rates,  reductions  in  overall costs, and  decreased
manpower requirements.

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    DELP recently published the report "Recovery, Reuse and Recycle of Solvents,"
which  relates to solvent use and recycling (Boubel  1985).  The report serves as a
guide  for  service facilities and personnel to help  increase use of solvents. Included
in the  report are case examples of successful solvent use by  both service and civilian
facilities.

    DELP also  promotes  a program,  administered  by  the  Defense Productivity
Program  Office (DPPO), that  provides  up-front  money  to  purchase such items as
solvent stills and  collection systems for hazardous  waste  reductions or  recycling
activities.  The program,  known  as  "Productivity  Enhancing  Capital  Investment
(PECI)," also provides incentives to  allow the benefits, in excess of the cost, to  be
used by the  installation commander (Boubel 1985).  The DPPO operates under the
Assistant  Secretary of Defense Manpower.

    The PECI program was established  primarily as a means to "encourage  waste
recycling  and  reduction by setting up  a  system  that  rewards  DOD installation
commanders"  (Boubel   1985).    According   to   Carl  Schafer,   Director  of  the
Environmental   Policy  Office   of  the  Secretary of  Defense,  base commanders
presently  have  no incentive to save money through waste  reduction, because  the
base's  budget will be cut or the savings would  be  returned to  the U.S. Treasury
(interview with  Carl Schafer in Inside EPA, January  4, 1985).  By returning  the
benefits to  the  installation commanders, there is an incentive to  initiate recycling
and waste  reduction  activities.  To  qualify to  receive  the  benefits,  the  base
commander   would  have to  specify  how   the  money  would be  spent, but any
"reasonable, legal use would be acceptable"  (Boubel 1985). This would result  in less
reliance  on  the services provided by DLA,  which are described  in further  detail
below.

Defense Logistics Agency

    DELP's efforts often require coordination with both the  procurement and  waste
generating activities of DOD.  DOD delegated the responsibility for procurement  of
materials  and disposal of almost  all excess  hazardous property  to  the Defense

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 Logistics Agency (DLA).  DLA's field support, the Defense Reutilization  Marketing
Offices  (DRMOs), provides  free  disposal  service  to  the generating  installations
(bases).

     Material  sent to DRMOs must  first be  screened for possible  use  by other  DOD
activities.  This reutilization  phase  of the disposal cycle can  involve  activities such
as precious metal recovery from scrap metals.  Materials  that cannot be  reutilized
are either transferred, sold, donated, or disposed.

     An example of a recent effort to enhance this disposal cycle is the Used Solvent
Elimination (USE)  program.  The  goal  of  the  USE program is  to   eliminate  the
disposal  of recyclable solvents as wastes by October 1,  1986.  The program will  shift
the burden of disposal back to the generating installations or bases.   The  preferred
mode of disposal will be to recycle the  solvents either  on  or  offsite.  To  encourage
reuse, small stills  will be used for  such  practices  as paint-gun  cleanup  (resulting
after solvent evaporation, in some  cases,  in a dry cake  of  almost  pure pigment,
which the paint  manufacturers are interested in  reobtaining),  while larger  stills will
be available for large-volume recycling of  such materials as  Stoddard solvents and
freon. In addition, there will be an emphasis  on waste  stream segregation in order
to increase the percentage of recoverable  solvent.  Analysis has shown that many
reclaimed solvents are capable of meeting  military specifications.  According to the
USE  program guidelines, however,  the DRMOs  should be used only when  there are
overriding  reasons  that  rule  out  recycle.   Thus,  decisions to  dispose  of solvents
through  a  DRMO would have to be  reviewed by higher  headquarters (a  flag officer
command) (Boubel 1985).

    For  the small fraction of  solvents and still bottoms that cannot be recycled, the
DRMOs  will provide  the traditional  means of disposal.  The USE  program guidance
would also  allow disposal of small volumes (less than 400  gallons per year total of all
solvents  generated  at  one  installation).   The  disposal  of   these  small  volumes,
however, must be "by sale to a resource recovery facility   or by  transfer to an
approved hazardous waste  disposal  facility"  (Boubel  1985).  The USE program allows
the bases to devise their  own  waste management  strategy.  DRMOs  would  only
handle the surplus that is nonrecyclable.
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     One  disadvantage  to' the  DRMO service is  that,  since  the  DRMOs collect
hazardous waste from DOD  facilities, "the true disposal costs [are] hidden from the
user because  they are  paid  by the DRMO, not the  facility" (Boubel  1985).   This
practice  may  discourage the  implementation  of  source reduction  and  recycling
modifications,  since  any minimization costs are charged  to  production activities.
The  USE  program eliminates some of this, but the  problem of nonsolvent  hazardous
wastes remains.

     To  some extent,  the PECI program mentioned above  may  serve to alleviate this
problem.  At one  time, a plan similar in  intent to the PECI program was  developed
within DOD as an economic  incentive for the  bases  to  minimize waste.  The  plan
provided  that  allocations   would be made  to bases  for  the  cost  of  disposal.
Theoretically, if the  bases were able  to  manage the waste for less money  than  the
allocation, the  extra money would still go to  the  base.  The  plan  was not found
acceptable at  that time  and  was not  implemented (personal communication with M.
White,  Defense  Environmental  Leadership   Project, Washington,   D.C.,  October
11, 1985).

     Another possibility  under investigation  by  DLA is  the  initiation  of  a  waste
exchange  service implemented through the DRMOs.  Waste exchanges would enable
different  bases, or even different functions  within  the  same  base,  to  learn  what
wastes are available  or  wanted.  The system would facilitate the exchange  of wastes
that could be reused directly  or with a minimum  of processing.  The waste  exchange
function  would  be operated through  the DLA and, as currently  conceived,  would
involve  only  intra- or inter-service  exchanges  as opposed to trades with private
sector generators.  It is  possible,  however, that  this program  could coordinate with
the  other nonprofit  waste  exchanges   providing  services  to  industry  (personal
communication  with  David  Appier,  DLA,  December  20,  1985, Cameron  Station,
Virginia).

Installation Efforts

     Hazardous  wastes   produced   at   DOD  facilities  largely    result  from
metal-finishing  operations,   which include  paint  and   metal  stripping,  surface
cleaning,  metal  plating,  and  painting.  Modifications  investigated to  reduce overall
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waste  generation from metal-plating  operations  include: reducing  dragout  from
processing  baths,  reducing  rinse  water  flows,  improving  rinsing  efficiency,
recovering metals from rinse waters, and  making raw  material substitutions.  Waste
disposal  associated   with  solvent cleaning  has  been  reduced by  segregation  and
eventual  distillation.  The  implementation  of  promising  new  developments	
water-borne coatings,  dry  powder coatings, wet  electrostatic painting, high solids
coatings,  improved painting  techniques, and robotics — has greatly reduced wastes
and emissions associated with painting.

     Paint  stripping  procedures for aircraft typically  involve the spraying  of  acidic
methylene chloride or phenolic strippers and subsequent washing of the paint/solvent
mixture  into  the wastewater collection  system.  This produces large volumes of
spent solvents and wastewater.  Stripping via dry  media blasting using recoverable
plastic  media  has  yielded  some  positive  results.  DOD  has  estimated  that
$100 million  could  be  saved  annually  and  millions  of  gallons  of   hazardous
wastewaters  per  day  could be  avoided  by switching  to  all plastic media paint
stripping.

     Despite the  efforts  of  DELP,  the military  services  that  implement  DOD's
efforts tend to remain  individualistic and depend heavily on the  management  at the
particular  base.  The base commander  may feel that he has little incentive to save
money on  daily operations such as disposal  and environmental  matters,  which are
considered service functions subordinate to the facility's commission  (Boubel  1985).
There are  many  creative  ideas  for  minimization,  but the  lack of rapid  technology
transfer  may  contribute to reluctance  to  adopt  these  ideas. One major obstacle to
effectively instituting  waste  minimization at  DOD  facilities is  the difficulty of
altering past practice.  For  example, in spite of the  greater cost-effectiveness of
plastic media  paint stripping, and the elimination of the risk of damage to the plane,
some bases are still building  wet paint stripping hangars.  Another example  is that of
spray-rinse versus standard  rinse systems.  Use  of spray-rinse systems  instead of
standard rinse systems not only cuts costs,  but also reduces the usual  rejection rate
for chrome plating from 40  percent to just 2 percent.  Some bases continue to build
the outmoded  metal plating facilities, however.
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     Another  area   with  a  potential   for   increased   waste   minimization  is
procurement.  Procurement management often acts without  considering recycling
options,  however.  For example,  large quantities of hazardous waste  on military
installations actually are outdated  virgin  materials.  Stringent  purchase and use
specifications of DOD policy could also be  a major  contributor to this  problem, as
illustrated by the used oil specifications.  DOD's used oil specifications require the
performance of an engine sequence  test on re-refined used oil for each different
source of batches processed. This requirement increases the cost  of the used oil and
makes it noncompetitive with virgin oil products.

     DOD's  procurement policies also may contribute to a lack of interest in waste
minimization within  government-owned, contractor-operated  facilities, since  they
award no incentives  for waste minimization. For example, military contractors in
the  aerospace industry  operate on  a cost-plus basis.  A  higher rate  of  profit is
achieved  for using  high  cost virgin materials as  opposed  to low cost  recycled
materials.

     These  situations may  be  changing,  however,  because of the adoption   of a
DOD-wide waste  min-irnization  strategy.  Because HSWA require  the generator to
certify  on manifests that a waste minimization program is in place, the DOD has
recognized the need to plan such a  strategy.  As a result,  the Joint Logistics Chiefs
(JLC) of  the Logistics Commands of the services developed a coordinated plan for
hazardous waste  minimization.  In  December 1985, the  JLC presented a briefing to
key  DOD staff, at which the provisions of the waste  minimization program  were
explained. Major  elements of the  program include: (1) development of  an accurate
reporting system,  (2) a  review  of  existing procedures  and  equipment for  broad
application, (3) improvements in the acquisition (procurement) process, (4) increased
research  and  development, and (5) inter-service  information  exchange  (technology
transfer).

     One  interesting  aspect  of  the  briefings  concerns  the   Air  Force  Systems
Command (AFSC). According to  the briefing package, most of the AFSC waste is
generated by its government-owned, contractor-operated industrial plants. AFSC
has therefore retained a  consulting firm  to  evaluate  the operations of  these plants
and  to  recommend  alternatives for  waste  minimization.  So  far the  study  has
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revealed that alternatives  to  land  disposal  exist  for  over  90 percent  of wastes
generated.  The  AFSC  anticipates the  initiation  of  actions  to  implement study
recommendations during  FY 1986.

    For goods or services produced for the various installations, waste minimization
efforts  may thus be implemented not only at the installation level,  but at the DOD
contractor services level as well. A similar idea is developed as a strategy option  in
Section 8.7.  Considering that DOD  is one  of  the  largest generators of hazardous
waste   and  exerts  substantial  market  influence   by  its  purchasing  decisions,
implementation of  the various waste minimization strategies of DELP, DLA, and the
Logistics Commands of the various services has  the potential to yield substantial
reductions  in waste generation.

7.3.4      Bureau of Mines

    The Bureau of Mines within  the Department  of Interior funds a  research effort
primarily  intended to recover "critical  and strategic"  metals.   The  Extractive
Metallurgy Technology Division is one of two division's responsible  for the Mineral
and Materials Research activity within the Bureau of Mines.  Research is  conducted
largely  in-house  at seven research centers  to  obtain  information  to  improve unit
operations  such  as grinding, flotation,  roasting,  leaching, and  solvent  extraction.
The work produces data  that  may lead to  improvements in  resource  recovery and
productivity.

    Specific research  conducted  includes   the  development  of  processes  for
extracting  cobalt, precious  metals, chromium, and titanium. The principal focus for
the research program  has been the  recovery of mineral  values  from  low-grade,
complex domestic ores.  The research has led to processes that  involve recovery and
reuse.   For  example, one research project  concerned  the recovery and  reuse  of
chlorine from ferric chloride  in the chlorination of leucoxene-type ilemite. Ferric
chloride is produced as  a byproduct  in  this process.  Recovery and reuse  of  the
chlorine content of the  ferric chloride is desirable for economic reasons; the action
also reduces the amount of waste disposed.
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    In addition, the Bureau of Mines examined the chrome etching process, with the
initial  goal of  reducing the  amount of  chrome used  in the  process.  The etching
process involves dipping chrome-plated materials into  an acid bath in order  to add
shine.  The acid eventually becomes too  impure  to accomplish its purpose and must
be discarded  as  waste.  The Bureau of Mines research  has led to an on-line process
that removes  chromium impurities from  the acid, allowing the acid to maintain the
necessary qualities longer.

7.3.5      Tennessee Valley Authority

    The Tennessee Valley  Authority  (TVA)  has  implemented  a  Waste Management
Program to minimize the  adverse effects of hazardous waste  on the environment
and the  community.  The  purpose of  the program  is  to reduce  waste  generation,
improve   waste  collection  and  transportation techniques, and enhance   waste
utilization as a resource in  the public,  private, and commercial sectors.  It also
seeks to improve the efficiency of treating  and  delivering water to consumers. The
program receives  $1.5  million  in Federal  appropriations per year.  Project  staff
members are experienced in many areas, including the following:
    •   Community-based materials recycling;
    •   Municipal   energy-from-waste   (incineration,   cogeneration,   anaerobic
        digestion);
    •   Agricultural applications and  fertilizing properties  of  waste  (e.g.,  animal
        wastes, sewage sludge);
    •   Power plant and incineration residues and ash utilization research;
    •   Environmental control technology and environmental effects;
    •   Community and economic development aspects of waste management;
    •   Municipal waste composting;
    •   Integrated solid waste management system planning;  and
    •   Chemical waste handling, treatment, and/or cleanup.
    TVA activities address solid and hazardous waste,  water supply, and wastewater
management problems through direct  technical assistance to municipalities, county
governments,  industries,  educational  institutions, and  planning and  development
districts.  These  activities focus on improving the management and enhancing the
efficiency of local solid waste, water supply, and wastewater systems.
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     The  program  features  include  rural  solid  waste  collection,   multipurpose
collection  vehicle  design, organic waste  utilization,  materials  recycling, energy
from waste,  wastewater treatment operator training, regional waste exchange,  and
public participation in regional  hazardous  waste management planning.   Technical
assistance  is provided by TV/A specialists in engineering, environmental and  health
sciences, community development, and planning.

     Upon  request,  TV/A staff will  initially  assess the local situation, including  the
diagnosis  of  special  problems  and identification  of   opportunities.   Conceptual
solutions are developed for potential adaptation to local  circumstances.

     TV/A   selectively   enters formal  partnerships with  local   governments   and
community-based groups  to  demonstrate  solutions  having  regional  or  national
significance.  The monitoring and evaluation  of  the performance of demonstration
projects is intended to produce  information that is available  and useful  to others
considering similar  solutions to similar problems at other locations.  The goal of this
program is to allow  effective  solutions  to  be  eventually  incorporated  into   the
marketplace.

     Emphasis  is placed  on  developing and  implementing practices  that embody
resource conservation  in  waste and  wastewater  management   and  that involve
acceptable ways  of reducing  the  amount of waste and wastewater  flow to treatment
and disposal facilities. For example, the program encourages wastewater and  waste
management  techniques that  use land treatment, aquaculture, onsite waste disposal,
waste stream separation, recycling, and other appropriate technologies.

     The benefits of this program include avoidance  of unnecessary expenditures,
reduced  consumer  costs,  energy  and water  savings,  maintenance  and  repair of
existing  systems, and  improved service  to  the public.  The program  aims  at
long-term economic development and environmental protection.

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7.4       State and Local Efforts

    Many State and a few local governments have encouraged waste  minimization
by  establishing various  programs  and/or  by  funding  mechanisms  that  promote
recycling and source reduction. These strategies fall under six general categories:
        Regulatory programs;
        Fee and tax incentives;
        Loan and  bond assistance;
        Grant programs;
        Information programs  (information transfer, technical assistance, and waste
        exchanges); and
        Award programs.
    The  following section  describes the strategies in general and includes examples
of various State programs, with observations on  problems and achievements where
possible.   In addition,  more detailed descriptions of the programs for 11  States are
provided   in   Appendix   J.    The  States  are:   California,  Georgia,   Illinois,
Massachusetts, Minnesota, New  Jersey,  New  York, North Carolina, Pennsylvania,
Tennessee, and Washington.  These States were chosen  because  they appear to be
most actively  involved in waste minimization.  They by  no means represent the  only
State waste minimization efforts in the  U.S.

    Rating the effectiveness of each type of program relative to the others is  not
always possible, since  in many  cases it  would be premature.  The effectiveness of a
program  refers to what  degree the program  influences (1) the generator or TSDF
community,  (2) the cost  efficiency of  "preferred" waste management practices, or
(3) the  overall  reduction of the  hazardous waste generation rate.  Since most of  the
programs are  still in  their infancy and thus  have not  reached  full potential,  this
study cannot provide an evaluation of their effectiveness.

7.4.1      Regulatory Programs

    Regulatory programs in  the various States are in most cases modeled upon  the
Federal  RCRA  requirements.  In  some  States, such  as  Texas and Arizona,   the
Federal regulations  are  adopted directly as the State  hazardous waste  regulatory
                                     7-19

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 program with little or no modification.  In order for  a  State to obtain full authority
for implementing its program, its regulations must be  at least  as  stringent as the
Federal  laws and  regulations.  Table 7-1  presents a summary of  the  types  of
regulatory  programs in  the  United  States  that  encourage  waste  minimization.
Table 7-1 also indicates  the 40 States (as of  May  1986) that  have received  full
RCRA authority and those that are in the process of receiving it.

    Waste minimization  practices are encouraged through State regulations in two
ways: (1) through exemptions from or relaxation of regulatory requirements if waste
materials are  recycled  and (2) through restrictions  applied  to land disposal  for
certain waste materials and management practices.

    For most  States,  exemptions for  recycling practices are  the  same  as  the
Federal  requirements.   Under the Federal  regulations, for  instance, the  actual
recycling practice  does  not  require a  TSD permit.  (See Section 5.5.6 for  further
details  on this issue.)  The  shipping  of hazardous wastes offsite for recycling  may
require a manifest, and  the storage of wastes for longer than 90  days, even  if wastes
are to  be  recycled,  may   require a  permit.   The  practice  of recycling  wastes,
however, is not a regulated activity (40 CFR 261.6 (c)(D).

    The difference  between  the State  exemption  provisions  and  the  Federal
regulations lies, for the  most part, in how the regulations are phrased. The Federal
regulations are  phrased as  requirements  that apply  or  do  not apply  to  specific
activities.   Under  some  State  regulations,  however,  the   nonapphcability   for
recycling is presented as an exemption and is sometimes listed in  a separate  section
called  "Exemptions." For example, Wisconsin's regulations provide exemptions from
licensing  as  a  treatment   facility  for legitimate  reclamation or recovery  of
hazardous wastes,  beneficial use or reuse,  energy recovery,  and other innovative
recycling  activities  (Wisconsin  Department  of  Natural Resources  (DNR) n.d.).
Similarly, hazardous waste in Minnesota that is  to be  "beneficially used, reused, or
legitimately  recycled  or  reclaimed"  is  exempt  from  many  of   the  standards
applicable to generators for  other management practices and  from  most of the
Minnesota Pollution  Control Agency's  permitting requirements (Minnesota  Rules
Part 7045.0125).   New  Jersey  operations that recycle  or re-refine precious metals
                                      7-20

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ALABAMA
ALASKA
ARIZONA
ARKANSAS
CALIFORNIA
COLORADO
CONNECTICUT
DELAWARE

FLORIDA
GEORGIA
HAWAII
IDAHO
ILLINOIS
INDIANA
IOWA
KANSAS
KENTUCKY
LOUISIANA
MAINE
MARYLAND
MASSACHUSETTS
MICHIGAN
MINNESOTA
MISSISSIPPI
MISSOURI
MONTANA
NEBRASKA
NEVADA
NEW HAMPSHIRE
NEW JERSEY
NEW MEXICO
NEW YORK
NORTH CAROLINA
NORTH DAKOTA
OHIO
OKLAHOMA
OREGON
PENNSYLVANIA
RHODE ISLAND
SOUTH CAROLINA
SOUTH DAKOTA
TENNESSEE
TEXAS
UTAH
VERMONT
VIRGINIA
WASHINGTON
WEST VIRGINIA
WISCONSIN
WYOMING




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1
:J
Table 7-1.  State  Regulatory Programs and Final  Authorization  Status
             as of September  16,  1986a
       aSource of Final Authorization Status: State Programs Branch, Office of Solid Waste, USEPA.

       Sources State Statutes and Regulations, Personal Communications with State Personnel

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will be excluded in early 1986 from the  State's definition of "major hazardous waste
facility,"   making   it  unnecessary  to  obtain  that  type  of  permit  (personal
communication  with  Kurt Whitford,  Division  of Waste Management,  New Jersey
DEP,  on September  16, 1985, with regard to New Jersey Admin. Code 7:26-1.6).  In
Missouri, certification by  the Department of National Resources  suffices  in lieu of a
recycling  permit  (Wisconsin  DNR  1983).   In each  of these instances, the State
exemption essentially provides what the Federal regulations allow.

    In  situations  where  State  regulations  may  be   more  stringent than  Federal
regulations and  may require permits  for recycling, relaxed requirements may apply.
In the State of  California, three classes of resource  recovery permits are available
(see  Appendix J.I).  The  degree of information  required in permit applications and
the extent of processing requirements are related to the degree of hazard posed by
the waste handled.  This  is intended  to reduce the time needed  for permit issuances
and also to lessen the paperwork required of facility operators.

    A similar situation exists in Keptucky  where the law requires  a hearing by the
host local government before a  permit can be issued  for a hazardous waste disposal
facility. A  recycling  facility permit can be obtained  directly through  the State
government,  however,  thereby  expediting  the  process (Kentucky Rev.  Stat.  Sec.
224.855).

    Just as the  relaxation of procedural requirements may act  as  an incentive for
certain activities,  the siting  procedure itself  can  also  be  modified  to promote
minimization.  For example, California changed  the name of facilities that recycle
hazardous waste from "hazardous  waste  facility" to  "resource  recovery facility."
The new designation is intended to reduce the stigma attached  to the former title,
making siting less of a problem.

    Another approach, which attempts to  reduce the  effects of local opposition,  is
being  tried in Minnesota. The  Minnesota Waste Management Board  has selected
"preferred  areas"  in response to the State's Waste Management Act of 1980.  If  a
private developer  submits a proposal  for  operating  a  hazardous  waste recycling
facility, the Board is empowered to mediate disputes between the developer and the
                                     7-23

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local government as  long  as the  proposal  has  been  approved by  the Minnesota
Pollution  Control Agency (personal communication with  Wayne  Sames, Minnesota
Waste Management Board, January 7, 1986) (see Appendix J.5).

     Although State  and Federal requirements are generally  the same  with respect
to recycling,  some  State disposal  restrictions may be more  stringent than those of
EPA. Such restrictions may include:  (l)bans on  certain  waste  materials  and/or
types of management, (2) facility  standards (e.g., liner requirements, ground-water
monitoring),  and  (3) requirements that  an  approval  be  obtained  from  the regulatory
agency  before disposing of  a particular  waste  stream.  Land  disposal restrictions
indirectly encourage waste  minimization,  since the limitation  and costs of waste
management  practices  force  generators to  consider  other  methods, including
recycling and  source reduction.

     Kansas, Illinois, and New York are examples of States that prohibited the  land
disposal  of  various  solvents, dioxins,  and other hazardous  organics before  HSWA
called for  land disposal restrictions on these substances.  Wisconsin,  like  several
other States, does  not  allow certain  management practices such as  underground
injection  or  land   treatment  (personal  communication  with   Barbara  Zellmer,
Wisconsin DNR, December 10, 1985).

     As  facility standard requirements tighten,  regulatory compliance  necessitates
the implementation  of more  sophisticated technology.  EPA  has developed specific
performance standards for each type  of  TSD facility regulated under RCRA.  All
State facilities must meet these Federal standards.  Some States apply  even  more
stringent  specifications  for  liners, leachate  collection systems, and ground-water
monitoring.  New Jersey, for  example, requires landfills to be  "constructed such  that
any  leachate  formed  will flow  by gravity into collection  sumps from which  the
leachate will  be  removed,  treated, and/or  disposed" (New Jersey  Admin. Code
7:26-10.8(d)l.v.).  There is no such specification in HSWA.

     Restrictions  may be imposed not only  by waste bans and facility standards, but
also  by  the requirement  for  approval plans that allow the State  agencies to screen
wastes  and  waste  management  alternatives.   For  example,  at  Chem-Security
                                      7-24

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Systems, Inc. in Arlington, Oregon, a waste sample and profile sheet is submitted to
the facility operator, who proposes the best method for waste to be managed. This
proposal is then sent to the State agency  for  approval  (Moellendorf  1985).  Other
States using this process are Illinois,  which operates a Supplemental Waste  Stream
Permit  Program (see Appendix J.3), and Kansas, which has  a  similar waste  stream
approval system  (Wisconsin  DNR  1983).  Agencies may demand  that the generator
explain  why wastes with potential for  recycling and source reduction have not been
similarly managed.  This is the case in California where hazardous waste regulations
contain a list of recyclable wastes.   Generators who  fail to  recycle  those  wastes
must  provide written  justification  to  the  Department of  Health Services (see
Appendix J. 1).

    Two local governments in  California, Santa  Cruz  and Sacramento Counties,
have proposed regulations that may require generators to employ  special consultants
or inspectors to conduct environmental audits.   The audit would include a  facility
evaluation   and  management  recommendation  that  would  then  have  to  be
implemented unless  the generator supplies  sufficient  justification for  not doing so
(see Appendix J.I  for a more detailed discussion and Appendix K, which contains the
proposed regulations of  these two counties).

7.4.2      Fee and Tax Incentives

    Many States  currently offer several  fee and tax incentives that may encourage
preferred waste management alternatives.  These financial incentives include:
     1.   Assessment  of  permit fees  for  the operation, treatment,  storage,  or
         disposal of hazardous waste;
     2.   Assessment of fees or taxes on the volume of hazardous waste generated or
         disposed (waste-end taxes); and
     3.   Assessment  of  taxes on  raw materials used  in  processes  that  generate
         hazardous wastes (feedstock taxes).
In  some  States, additional  incentives  are provided by  allowing  exemptions  and
reductions from  these  assessments,  as well as  reductions and  credits  on  sales,
income, or property taxes for using more desirable waste management methods.

                                      7-25

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    Waste  fees and taxes serve not only to generate revenues for various purposes,
but  also   in  many  instances  to  provide  indirect  incentives  for  using  waste
management alternatives such as recycling and source  reduction,  both  of  which
ultimately  reduce  the amount of  waste that is land  disposed. The National Research
Council (1985) reports that this is because they act as "mechanisms for making other
waste management options more competitive with use of landfills for some  waste."

    Fees and taxes function in the same manner and often the two are synonymous,
although they are usually implemented through  different programs. For purposes of
this discussion, a fee  is a payment (generally associated with a permit) made to the
State  or the owner/operator of a TSD  facility for the  generation, transport, storage,
treatment,   or disposal  of hazardous  waste.  If  paid  to  the  TSD  facility by the
generator,  the  fee covers costs  reflected by State  compliance requirements, the
regional demand  for service, and operational expenses, which include fees charged
by the State to the facility owner/operator for permits, licensing,  and  renewals.
Taxes are generally levied by the  State treasury departments.

    Fees can be "flat" (a single rate  based on  volume alone or even  independent of
volume) or  graduated, according to the type of waste  and/or the waste  management
practice employed.  The graduated fee  would  thus reflect the potential  hazard of
the waste   or  its management  method.  In  this  respect,  fee reductions  and
exemptions  are  similar  to the graduated fee,  because they lessen  costs  for using
desirable waste management  practices.

    Among the  States,  several  kinds  of  hazardous  waste  taxes  are  in  place:
feedstock   taxes,  flat  waste-end  taxes,  and  graduated  waste-end  taxes.   The
feedstock tax  is a tax paid by the producers of chemicals and other  raw  materials
that,  when used  in  the production  process,  result in  hazardous substances  and
hazardous waste (GAO 1984). Currently,  no States  directly tax the manufacture of
such  feedstocks, although four   States,  Florida,  Maine, New Hampshire,  and New
Jersey, impose a tax on the transfer of petroleum  and chemical feedstocks (personal
communication  with  Mike  Northridge,  Office   of  Solid  Waste,   U.S.  EPA,
February 7, 1986). The Federal Government has also used  the feedstock tax to fund
Federal cleanup  efforts  of hazardous  waste  disposal sites as mandated  by  the
                                     7-26

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Superfund  legislation  (the  Comprehensive  Environmental  Resource  Compensation
and Liability Act (CERCLA) (42 U.S.C.  9601-9657)).  The feedstock tax is a reliable
source of revenue, but has been criticized because it  produces few or no incentives
for waste minimization (GAO  1984).

    Unlike  the feedstock  tax, the  waste-end tax  is levied on the  generator  or
disposer of hazardous waste and can be flat  or  varied according to the hazard posed
by  the  waste  and/or  its  management  method.  The Congressional Budget Office
(CBO),  in its  report "Hazardous Waste  Management: Recent Changes and Policy
Alternatives"  (CBO  1985),  examines  the use of waste-end taxes to  promote waste
reduction.  Four waste-end tax structures  are analyzed  at  the  Federal level with
regard  to ease of administration,  ability to provide stable revenues, and  effect  on
waste minimization, as follows:
     •   Tax System  1 varies taxes only on the basis of waste treatment or disposal
        technology,  with  a  tax  structure designed to encourage a shift away from
        certain  undesirable land disposal  techniques  and  toward  more  advanced
        treatment methods.
     •   Tax  System  2  is graduated on  the  basis  of  waste hazard,  management
        technique, and disposal method.  Tax  rates  are  designed to discourage the
        pairing of certain wastes with certain treatment methods depending on the
        hazard potential of the pairing.
     •   Tax System 3 (proposed by the Administration) also  differentiates simply on
        the  basis of  management technology,  but unlike  Tax System 1, tax rates are
        increased each year to help assure a stable revenue stream.
     •   Tax System 4 makes no distinction among waste hazards  or disposal  choices,
        but simply places a flat tax on each unit of waste generated (CBO 1985).

     The CBO analysis can be partially extended  to State  waste-end tax systems.
When  comparing  them,  Tax  Systems  1, 2,  and  3   appear  more  effective  in
encouraging waste reduction and management  shifts, because Tax  System  4  would
affect  only those industries with  dilute, high-volume waste streams (CBO 1985).

     CBO  (1985) emphasizes  that waste-end  taxes serve both to generate revenues
and to  encourage waste reduction.   These two goals potentially conflict with one
another, because States may  lose a significant source of revenue if  land  disposal
                                     7-27

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were severely discouraged.  This conflict, however, would be  diminished if proceeds
were required to go toward promoting waste minimization (CBO 1985), for example,
in funding grant programs to companies investing  in new equipment that results in a
reduction of  waste.  In  this case, decreased revenues would indicate that  industries
have reduced the amount of  waste generated or switched to  alternative disposal
technologies.  This  scenario assumes, therefore, that waste minimization would have
taken place, and the need for revenues would be diminished.

    In theory,  waste-end taxes should provide an  economic  incentive  for more
desirable  waste management  practices,  and also generate monies,  either for State
Superfund cleanup or waste minimization efforts.  Information to support this  theory
is not yet available, since many such programs are so new that  reductions in waste
volume have  not yet been directly  attributed to them.  A study of waste-end  tax
systems  in New York,  New  Hampshire, and California was  conducted by GAO in
1984, but no  definitive  conclusion was  drawn  on  whether  waste-end taxes have
achieved  either  objective.  Despite  the  lack  of direct evidence,  however, many
States are adopting such  tax systems. In 1984, 20  States imposed waste-end taxes
on hazardous waste  generators (CBO 1985).

    Other strategies  to promote  minimization  are  reductions, exemptions,  and
credits on property, income, and sales taxes, either for purchasing pollution control
equipment or for implementing some form of minimization  technology  (Wisconsin
DNR  1983).   As in  the case of fee  and tax assessments,   their effectiveness is
dependent  upon the  overall  economic  effect  on  companies that  make such
investments.  For example, resource recovery efforts that increase the product yield
will also  increase profits as well as the taxes on those profits.  This increase in taxes
may offset the benefits  gained by tax credits.  Another  critical  factor affecting  the
success  of such strategies is that  companies are aware  that these incentives exist.
Proper publicity is often a point of concern with  those  involved  in promoting  waste
minimization.   Because  generators  tend  to  choose  the lowest cost options  in
managing wastes, assessing fees and taxes and granting reductions, exemptions, and
credits  do not guarantee  that  preferred  waste  management  practices will   be
employed.  Levies and  their relaxations, if not sufficient to  justify a  preferred
alternative, may encourage improper or illegal disposal (CBO 1985).
                                     7-28

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    Table  7-2 summarizes fee and tax incentives employed by the States.  Brief
descriptions of programs that are unique or representative follow:
        Alabama
        Arkansas
    •   Connecticut
    •   Florida
    •  Indiana

    •  Iowa
       Kentucky
-  $l/ton  monitoring  fee  imposed  on  hazardous waste
   received for land disposal (Alabama Code 22-30-4(6X3)).

-  $2/drum,  $5/ton bulk  weight local fee  on hazardous
   waste entering  one facility  (personal communication
   with Daniel Cooper, Alabama DEM, November 22, 1985).

-  Set  fee  corresponding  to  quantity  range  assessed on
   in-State generators and persons accepting wastes from
   out-of-State (Arkansas Laws Act 479, Sec. 7).

-  $0.05/gal,  $3.50/cu  yd imposed   on  hazardous  waste
   facility owners/operators for land  disposal (Connecticut
   Gen. Stat. Sec. 22a-128).

-  Four  percent excise tax on price  of disposing, storing,
   or treating  wastes paid by generators "for  privilege of
   generating   hazardous   waste"   (Florida   Stat.   Sec.
   403.725).

-  Tax    exemption    allowed    for    wastes   sent   to
   State-certified   recycling  facilities  (Wisconsin  DNR
   1983).

-  Feedstock tax on petroleum products entering State.

-  Fee exclusions for companies engaged in recycling.

-  $10/ton fee  for  wastes  transported offsite, excluding
   water tonnage of wastes to be treated or recycled.

-  $40/ton fee  for wastes land disposed offsite.

-  $2/ton fee for wastes  destroyed or  treated to render
   nonhazardous.

-  No  fee  imposed on  waste  reclaimed or  reused  for
   energy  or  materials  (Iowa   Code  Title   XVII  Sec.
   455B.424).

-  Waste-end  assessment  paid by generators  for  wastes
   being treated or land disposed offsite.

-  Wastes   treated   onsite   charged  one-half   offsite
   assessment.
                                     7-29

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     Louisiana
  •  Missouri
  •  New Hampshire


  •  Ohio



  •  Oregon
- Fee  exemption for  companies  engaged  in  recycling
  (Kentucky Rev. Stat. Sec. 224.876(7)).

- $5/ton fee for onsite land disposal.

- $10/ton   fee  for   offsite   land   disposal   (personal
  communication  with   Bill   Deville,  Louisiana   DEQ,
  July 12, 1985).

- $25/ton  fee  for  land  disposed  hazardous  wastes  or
  $2/ton fee  for all  other hazardous wastes  transported
  offsite.

- $l/ton generator fee.

- Exemption  for  wastes reclaimed or reused for energy or
  material values.

- $2/employee head tax assessed on companies  generating
  hazardous  wastes (Missouri  Rev.  Stat. Sees.  260.475,
  260.380(10), 260.478).

- Recycled wastes  exempted  from  quarterly  fees  (New
  Hampshire RSA 147-13:8).

- Waste-end   tax  on  commercial  disposal  facilities  for
  6 percent of each  charge,  which  varies  according  to
  disposal method (GAO 1984).

- Tax  credit  on excise tax liabilities for corporations, on
  income tax  liabilities for individuals  and  partnerships,
  and  on property  tax  for nonprofit organizations  that
  produce  energy or  reclaim  substances  of   economic
  worth  from  hazardous  wastes;  50 percent  of  capital
  expenditures  minus  return   on  investment  may  be
  credited  over facility lifetime or 10 years, whichever is
  shortest (personal  communication with Maggie Conley,
  Oregon DEQ, October 10, 1985).*

- Flat fee  based  on volume of  hazardous waste generated
  per year, i.e.,  no  fee for generating  less than  100 cu
  ft/year; $100 for  35-99  cu ft/year; $350 for 100-499 cu
  ft/year;  $625  for   500-999   cu  ft/year;  $1,500   for
  1,000-4,999  cu ft/year;  $3,500  for 5,000  to 9,999 cu
  ft/year; and $5,000 for over  10,000 cu ft/year (Oregon
  Admin. Rules 340-102-060).
Few applicants have applied for the tax  credit because resource recovery usually
results in net gains in  profit,  thereby  weakening any  gains  from tax credit,  as
discussed  above   (personal  communication  with  Bob  Brown,   Oregon   DEQ,
July 12, 1985).
                                   7-30

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       MINNESOTA
        NEW HAMPSHIRE
        NEW MEXICO0
        NORTH CAROLINA
        NORTH DAKOTA'
        SOUTH CAROLINA
       WESTVIRG1NIA
      Table 7-2   Fee and Tax  Incentives to Minimize Waste for Hazardous Waste
                    Generators and/or Disposers
aAssessed on Generators or Disposers by the State on a Waste Basis and Does Not Include Permit Apphcatio
bReceived for Implementing Source Reduction or Recycling.
cSources Identified No Fee and Tax Incentives That Promote Waste Minimization
Exemption Is in Form of Fee Waiver if the Waste Is Rendered Nonnazardous Onsite

Sources C8O 1985, EPA 1984, GAO 1984, Wisconsin DNR 1983, Bulanowskt et al 1981, Various State
        Statutes and Regulations, and Personal Communications with State Personnel

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        South Carolina
    •   Vermont
    •   West Virginia
                   Higher  land  disposal  fee  imposed   on  out-of-State
                   generators; in-State  fee  of $5/ton is raised to $7.50/ton
                   or  higher  as  necessary to  equal  disposal,  fee  in  State
                   where  waste  originated  (Code  of  Laws   of  South
                   Carolina Sec. 44-56-170).

                   $0.07/gal tax assessed on liquid, $0.009/lb  tax assessed
                   on  solid  hazardous  waste  destined  to be  reclaimed,
                   recycled, or recovered.

                   $0.14/gai  tax assessed on  liquid, $01.7/lb  tax assessed
                   on  solid  hazardous waste  destined  for most forms of
                   treatment.

                   $0.28/gal  tax assessed on  liquid, $03.4/lb  tax assessed
                   on  solid hazardous waste destined for land disposal (10
                   Vermont Stat. Chap 237.  Sec. 10103).

                   Base  waste-end  fee  reduced  to  25  percent  for  those
                   generators rendering  wastes nonhazardous onsite.

                   No fee imposed  on wastes beneficially used, reused, or
                   legitimately recycled or  reclaimed (West Virginia Code
                   Sec. 20-56-4(a)).
7.4.3
Loan and Bond Assistance
      Credit  assistance,  whether  through  direct  State  loans,  guaranteed  loans,

subsidized  interest payments for private  loans, or bond  financing,  is  a means of

reducing the cost to firms of obtaining capital to make an investment. A State's

objective in sponsoring any type of credit assistance program is threefold:
      1.   To  minimize  the  adverse  economic   impact  on  target
          investment expenditures;
                                                            firms  from
      2.   To make funds available to those companies having trouble obtaining loans
          from the private market; and

      3.   To achieve a specific policy objective.

The overall policy objective  in this case is waste  minimization.   Credit  assistance

through some  form  of  subsidy  from the  State  can promote source  reduction  and

recycling  when used to purchase waste  reduction equipment or to  build and operate

recycling  facilities.
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      A  business, whether  a  generator or a recycler of hazardous waste, will  not
 implement  waste   minimization   technology  unless  the  venture  promises  to  be
 profitable or is required by law. Frequently,  such a venture has profit potential,  but
 purchasing and operating costs may pose  a significant  financial strain,  especially in
 the initial investment stages.  If  implementation were  required by law, a company
 simply may not have the money to comply and thus would be forced out of business.
 Loan and bond  assistance alleviates  the financial  difficulties  by  supplying  the
 borrower with up-front  capital, to  be  paid back over a period of time, usually out of
 earnings.

      Private  market loans  could  provide  credit  assistance,  but  the  price  is
 sometimes unaffordable to those  who  would  need such services — generally small-
 and  medium-sized  companies.  The market  rate of  a  loan  is  dependent  on  many
 factors,  including the term and degree of liquidity of the loan, the rate of inflation,
 the degree of risk  of the loan, and the loan  placement costs.  The last  two  factors
 are  responsible  for elevating the  interest  rates for small- and  medium-sized
 companies.  Such companies may not have  an  adequate credit history from which  the
 banks  can  evaluate -their risk  in  lending,   and   thus  the  risk premium  is  high.
 Additionally, the cost of investigating  the credit history may  be high  compared  to
 the profit the lender anticipates from the loan.

      A  State-sponsored program  may  be  able  to  offer  more affordable credit
 through  private  loan  interest subsidies,  loan  guarantees,  or  direct  loans.   Each
 results in a lower  cost  loan because it ultimately  reduces the  interest  rates.  With
 interest subsidies, the State helps to pay all or part  of the interest  payment.  With a
 loan guarantee, the State government  insures the private lender against default by
 the borrower,  making the loan a contingent liability of the  State.  This  reduces the
risk to the lender,  who is then able to  lower the risk premium.  With a direct  loan
the State loans its own funds.  Since the State is more interested in carrying  out  its
policy  objective  than in making  a  profit,  it  can charge  a  relatively affordable
interest rate.

     Private  loan  subsidies and  loan guarantee  programs  place the  burden  of
administration  and  funding on the  private sector,  while still enabling  the State to
specify standards for making the loan available. Such programs offer an advantage
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over direct'loan programs by enabling the States to reduce  their annual  costs  by
passing  on  all loan placement  expenses to the financial  community.  The private
institution,  however,  makes  the ultimate decision of whether or not to make  the
loan; it  also has the power to set the interest rates.  Thus, these programs may not
help the intended  beneficiaries. Thus far, California  subsidizes  interest  rates for
purchasing  waste-reducing equipment;  no States  have actually  established  a  loan
guarantee program (personal communication with Jan  Radimsky, California  DHS,
July 10, 198-5).

     In a direct loan situation, the State disburses funds and manages the program,
giving immediate  control  to  the government  and allowing  greater  administrative
flexibility.  The State  will set the interest rate, offer the optimal number of loans in
optimal amounts, and  choose the loan recipients after reviewing  loan applications.
Minnesota  and New York grant credit  assistance in the  form of direct  loans for
pollution control equipment,  which generally includes recycling  and source reduction
investments.
                            6
     Funding  for loan assistance may come from three sources:  (1) appropriations,
(2) special   revolving   funds  established   for  the   specific  purpose  (e.g.,  waste
minimization), and (3) revenue bond  financing.  Funding through  appropriations
occurs  as  a result of  periodic  legislative  budget directives.   In  California,  for
example,  $5.2  million  was set aside for  the Hazardous Waste  Reduction Incentives
Account;  half  of  "this  amount  was  allotted  to  the Pollution  Control  Financing
Authority to grant  credit to  small- and  medium-sized generators (California Health
and  Safety  Code,  Sec.  44558).  A  revolving  loan  plan  requires  a  large  initial
investment, perhaps  through  an appropriation,  but can  be self-sustaining since
repayments would  enter the  fund.   The  New  York State  Environmental Facilities
Corporation  (NYSEFC)  is considering  such  a  plan  for  that  State's  small-  and
medium-sized companies.  Loans initially would be  funded by  the  State  or  from
NYSEFC fees, and repayments would enter a trust fund (NYSEFC 1985).

     The  third  funding  source, revenue  bond financing,  appears to be the  most
widely practiced of the  three  funding mechanisms.  Several States  have programs
that use revenue bond  financing to assist firms with the purchase and installation  of
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pollution  control  equipment.  In most cases, the  financing  extends to  facilities
related to  the  recycling  and source  reduction  of hazardous  waste. Missouri has
found  that  bond  financing  enables  the  State to  offer  larger  sums of  money  at
competitive  rates, since the purchasers receive preferential  tax treatment on the
earnings.  The Missouri Environmental Improvement and Energy Resources Authority
(EIERA) has operated a successful bond program for over a decade (over $1.5 billion
in  financing  was provided  for  energy  development   and  pollution  prevention
projects).  That  State is  constantly  looking  at  innovative ways to use industrial
revenue bonds.  For example, bonds could be  issued strictly for  waste minimization
efforts, with proceeds going to a single recycling facility  or into  a  fund accessible  to
many borrowers. These monies would be covered by company revenues and  potential
savings.   Missouri  has  the  ability at this time  to issue  bonds  for $750  million
(personal  communication with  Steve  Mahfood, Missouri EIERA,  October 7,  1985).
Several  other  States  have  the authority  to issue  industrial  revenue  bonds that
potentially  provide   funding  for   waste   minimization  efforts.   These  include
California,  Florida,   Georgia, Illinois, Minnesota,  Mississippi,  New York,  North
Carolina,  Tennessee,  and Wisconsin.

      The credit  assistance programs in  California, Illinois, Minnesota,  New  York,
North  Carolina,  and  Tennessee are  discussed  in  further detail  in  Appendix  J.
Sections J.I, J.3, J.5, J.7, J.8, and J.10.

7.A.A      Grant Programs

      Waste minimization grants  are monies awarded to hazardous waste generators,
processing facilities,  and  other  public and  private  organizations  to  support  waste
minimization  efforts, including  research   and   development   activities   and/or
demonstrations of recycling and source  reduction technology.

      State  grants   are  a  direct   method  for  investigating  new  and  existing
technologies.   They   may  support  projects   in   full  or   match  the   monetary
contributions  of  the  beneficiary.   "Challenge  grants"   (a   term  coined  by North
Carolina's Pollution Prevention Pays Program for its matching funds) are a means to
stimulate  generators  in particular to investigate source reduction and recycling on a
plant-specific basis, especially small- to medium-sized generators.
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     Supporting research, development, and demonstrations with  grants  allows  the
State to  dictate what the work will address, as for example, specific State problems
that may be neglected  by the commercial and industrial  sectors.   Project results
generally are  made  available to  other  companies.   The  principal advantage  to
offering  challenge grants is that  use  is  made  of  available  in-house generator
expertise.

     The large investment  required to implement grant projects and the  need for
annual appropriations are negative aspects of  grant programs. Moreover, the return
on expenditure is  uncertain; the work is often  time-consuming  and  may  not always
have practical applications.  Generators  also may delay spending their own  funds  on
waste  minimization in the present if there is a possibility of obtaining a grant in the
future.

     California,  Georgia, Illinois,  Minnesota,  North Carolina,  and  Wisconsin  offer
grants  for  projects  involving  research,  development, and/or demonstrations  of
source reduction and recycling technology (for programs in the  first  five States,  see
Appendix J, Sections J.I, J.2, J.3,  J.5, and J.8).

7.4.5     Information Programs

     Information  programs gather,  evaluate, catalog, and  disseminate information
that will assist industry in source reduction and recycling  of hazardous waste.  Such
programs serve to educate hazardous waste generators and handlers and the general
public  on improved hazardous waste management. Information programs typically
fall  into three  categories:  (1) information transfer;  (2) technical  assistance; and
(3) waste exchanges.

Information Transfer

     An  information  transfer program  works  through  such vehicles as  studies,
conferences, workshops, telephone hotlines, information clearinghouses, and training
programs.   These  mechanisms help  industry  and  the  general  public  alike  by
                                      7-37

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(1) recommending  source reduction, recycling,  and  other  treatment  and  disposal
alternatives; (2) providing regulatory assistance; (3) studying hazardous waste issues:
and (4) performing technical and economic feasibility studies.
                                                                                is
     One  example  of  what initially  started as  an  information transfer  program
North Carolina's  Pollution  Prevention  Pays  Program, which has since grown to
include grant and technical assistance strategies as  well  (see  Appendix J.8).  New
York, California, Massachusetts, and  New  Jersey, along  with several other States
presented in Table  7-3, also have some form of information transfer.

Technical Assistance Programs

     Technical assistance programs (TAPs) provide technical  assistance to hazardous
waste generators in  all areas of hazardous waste management.  One advantage of
this type of information program is that it can  be easily geared to  a  particular group
of generators (e.g., small  quantity generators  or metal waste producers). Technical
assistance usually is provided in the  form of  an onsite  consultation, although  in some
instances such assistance can also be furnished  by  telephone.  The consultation may
consist of an assessment  of a  facility's  operation,  which includes such items as
environmental compliance or specific advice  on how a process could be altered to
reduce waste  generation.  Because such consultations involve specialized knowledge
of  various  industrial  processes, qualified experts  are needed, resulting in a  high
initial cost  of implementation.  The  qualified experts are necessary, however, in
order for the State to ensure  that  the TAP provides sound and accurate appraisals
and advice.

     The  TAP is a specialized information program that generally involves more  than
just  offsite  and onsite  consultations.  Typically, seminars, technical workshops,  and
training  programs  are integral  parts  of  a  TAP.   Because  most  small-   and
medium-sized companies lack funds and expertise to investigate waste minimization
on their own, the TAPs have generally been most helpful to this group.

     Disclosure of  violations discovered  during  a  consultation  would certainly
discourage  the use of TAP services  because  of the fear of regulatory action  or
                                      7-38

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ALABAMA
ALASKA1
ARIZONA
ARKANSAS*
CALIFORNIA
COLORADO*
CONNECTICUT*
DELAWARE*
DISTRICT OF COLUMBIA*
FLORIDA
GEORGIA
HAWAII*
IDAHO*
ILLINOIS
INDIANA*
IOWA*
KANSAS
KENTUCKY
LOUISIANA
MAINE"
MARYLAND
MASSACHUSETTS
MICHIGAN
MINNESOTA
MISSISSIPPI*
MISSOURI
MONTANA
NEBRASKA*
NEVADA*
NEW HAMPSHIRE*
NEW JERSEY
NEW MEXICO"
NEW YORK
NORTH CAROLINA
NORTH DAKOTA*
OHIO
OKLAHOMA"
OREGON*
PENNSYLVANIA
RHODE ISLAND*
SOUTH CAROLINA*
SOUTH DAKOTA*
TENNESSEE
TEXAS
UTAH
VERMONT*
VIRGINIA*
WASHINGTON
WEST VIRGINIA*
WISCONSIN
WYOMING
•



•





•


•


•
•
•

•
•

•






•

•
•

•


•



•




•

•
•




•





•


•









*








•
•




•












1

•

•




•



•








•


•
•



•

•
•









•
•






Table  7-3.  Information Programs That Promote Hazardous Waste Minimization
aSources Identified No Information Programs That Directly Address Waste Minimization Within These Sta





Sources  State Publications and Personal Communications with State Personnel

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fines.   Generators  may  also   fear  the  exposure   of  proprietary  information.
Consequently, States operating TAPs  have ensured that their programs  are distinct
from  their  regulatory  agencies and  promise  strict  confidentiality  of generator
information.  Effective outside assistance  requires  complete  knowledge  of  the
production technology, which some  industries  may prefer not to disclose.

    As  presented in  Table 7-3, seven States have some form  of  a TAP program.
These are discussed in  detail  in  Appendix J,  Sections J.I, J.2, J.3, J.5, J.7, J.8, and
J.9.

Waste Exchanges

    The waste exchange, a third category of information program, is  a means  of
connecting  wastes via  a matching service that companies can  employ to advertise
available  wastes or to find waste materials they can use.  In  addition to helping  to
minimize  the entry of  wastes  into the  environment, waste  exchanges  can reduce
disposal costs, save raw materials, and save  the energy necessary  to  process  those
raw materials.

    There are two basic  types  of waste exchanges:  (1) information exchanges and
(2) material exchanges.  Information exchanges,  the most  prevalent, serve to  match
waste generators  with potential users. Generators list the wastes to be transferred,
and potential users list the  materials  desired.   Material exchanges, in  contrast,
actually receive and handle wastes after playing a major role  in arranging transfers.
They are generally profit-oriented and are operated by private industry.

    Information  exchanges  can be  classified  as passive  or  active.  A  passive
exchange  will usually issue a  newsletter  containing confidential listings  of suppliers
and users, potentially  linking  companies together.  Most passive exchanges  lack the
resources, expertise, and legal  authority to actively enter the marketplace seeking
business.  Letters  of inquiry from potential users are forwarded  to  the originator  of
that listing. The originator initiates  contact for the exchange to occur.  The two
parties  then make  arrangements for the  transaction, reaching agreements  on such
things  as quality,  quantity, costs, and transportation without assistance from the
passive  exchange service.

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Active waste  exchanges take a  more visible role in transferring  wastes between
generators and users.  Introductions are  made through interviews and joint meetings
held by the exchange or  through  computerized  matchings.  The  waste exchange
itself may sometimes provide information on  an available waste  by assessing  its
potential to be recycled.  Such an assessment may  include testing services  as well as
technical and  marketing analyses.

     Waste exchanges have rarely been operated by State governments alone because
of  industry's  reluctance  to  provide information  voluntarily  to  State  regulatory
agencies.   Companies  feel that an  analysis of  their waste and desired wastes may
reveal proprietary information  about their manufacturing process, and may disclose
possible violations  that could bring about regulatory action.  Consequently,  waste
exchanges  often   are  operated  under  the  auspices  of  universities,  business
associations,  and nonregulatory State programs  on a regional basis, and are funded,
in part, by State governments.  To ensure  a degree of confidentiality, the  exchanges
use  codes  rather than the  names  of generators and  users.  More information  on
waste exchanges is  provided in Section 4.3.2.

     State-supported  waste  exchanges  are located  in  12  States  as  presented  in
Table 7-3. Appendix J,  Sections J.I, J.3, J.6,  J.7, and J.8, provides more specific
information on exchanges  found in  California, Illinois, New  Jersey,  New  York,  and
North Carolina.

7.4.6     Award Programs

     Award  programs  are  low-cost  strategies  for  recognizing  and  honoring
individuals,  companies,   and  institutions  that  have  demonstrated  outstanding
achievement  in  hazardous  waste   management.   North Carolina,  Minnesota,  and
Alabama each have an award program in which  projects eligible for nomination are
those that reduce wastes,  recover energy or usable material from wastes, or reduce
the amount of waste  destined for  treatment  or  disposal  facilities.  Projects  are
judged on  the criteria of  environmental  benefits,  economic benefits (profits, annual
savings, and  payback periods),  technological importance, and applicability to other
industries  and organizations. Georgia grants an award for  achievement in resource
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 recovery.  The  publicity  associated with an  award provides a waste  minimization
 incentive to  public and  private institutions  seeking  favorable exposure.  In  North
 Carolina, Minnesota, and Alabama, projects are  publicized in booklets, and winners
 are presented with  certificates and tokens of achievement.

     The award  programs of Georgia, Minnesota,  and North Carolina are described to
 a greater extent in Appendix  J, Sections J.2, J.5,  and J.8.  Alabama  presented its
 first  awards  in October 1985 during  its  first  annual  Pollution  Prevention Pays
 Symposium.   Descriptions of  Alabama's  winning  projects are  published  in The
 Governor's  Award  for  Outstanding  Achievement in Hazardous Waste  Management
 (State of Alabama 1985).

 7.5       Nongovernmental. Nonindustrial Efforts

     Nongovernmental and nonindustrial  organizations  have also examined the issue
 of waste minimization with varied approaches and  degrees of effort.  For the most
 part, they are nonprofit institutions funded in a variety of ways, including receipt of
 money from State and Federal governments.  The following  are a small sampling of
 those  organizations  that  have made  efforts to  promote  recycling   and source
 reduction of hazardous waste.

 7.5.1      League of Women Voters
     1730 M Street, N.W.
     Washington, DC  20036
     Contact:  Ms. Sharon  Lloyd, Project Manager, Citizen Involvement
      on Hazardous Waste Management
     (202) 429-1965

    The  League of Women   Voters  sponsors  a  campaign  to  increase  citizen
 involvement  in  several areas,  including  that  of  hazardous waste management.  In
 1985, the third  year of  the program, hazardous waste  minimization was  a  major
 focus.  Hazardous   waste recycling   and   source  reduction received  substantial
coverage in The  Hazardous Waste Exchange, a  quarterly newsletter published by the
League and  circulated to  approximately  10,000  League members and  industry
representatives.
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    Hazardous waste minimization  was also the topic at  conferences sponsored by
individual leagues on the State and local level and attended by business, government,
and public interest groups.  Video tapes and slide shows were used to present  case
studies  of successful  waste minimization  practices.  The  New  Jersey  League
sponsored a conference specifically  for small businesses.  In Maryland, a conference
stressing regional  cooperation  in minimization  was held;  nine  states  participated.
The League of Women Voters of  Massachusetts  presented  a conference in the spring
of  1985  in  Woods  Hole,  Massachusetts, dealing  with  waste   minimization  and
recycling.  This was sponsored and  funded  by  the U.S. Environmental  Protection
Agency in  the amount  of  $33,000.  Information presented in the  conference  was
gathered from a survey of 21 major companies on  their waste reduction plans and
policies.  The results of  the survey were compiled in the booklet, "Waste  Reduction,
The  Untold  Story"  (League of  Women  Voters of  Massachusetts  1985).  Another
conference on waste minimization was held by the League in June 1986.

7.5.2      Pollution Probe Foundation
     Pollution Probe Foundation
     1 2 Madison Avenue
     Toronto, Ontario
     Canada M5R 251
     Contact:  Ms. Monica E. Campbell
     (416)978-6155
    The Pollution  Probe Foundation  is  a  public  interest  group  responsible  for
research, education,  and positive  policy  advocacy geared  toward  protecting and
improving the Canadian environment. Funding is  provided through private donations
and grants from  other  foundations.  It currently  is working to develop a regulatory
program aimed at  solving the problems of  acid rain,  drinking water quality, and
pesticide safety.  In the areas of hazardous waste management and toxic substances
control,  the  organization has recognized waste  minimization  as  a  key strategy  in
combating problems inherent to each area.

    In  1982,  Pollution  Probe published  the  book Profit from  Pollution  Prevention
(Campbell and Glenn  1982).  A guide to  industrial waste reduction and recycling, it
is a compilation of case histories that seeks to disprove the  notion that reduction is
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technically impossible or prohibitively expensive.  It  is  hoped that the  book will
encourage  producers  and regulators to investigate alternatives to  traditional  waste
disposal.

    The group  also presents ideas on  waste  minimization at conferences, seminars,
and symposiums.  In an effort to reach a broader audience than those already aware
of the alternatives, Pollution Probe arranges presentations at industrial  conferences
focusing on matters  other  than  pollution  control. Breaking the Barriers (Adamson
1984), a report  on why Canadian industry has not embraced waste  minimization, and
a video tape are tools developed for use  in these presentations.   Pollution Probe's
efforts  extend to  the  international  level;  the  group participated  in   the  OECD
environmental  economic conference  held  in France  and is  currently involved with
the UN  environment program symposium on clean technologies in West Germany.

7.5.3      INFORM
     381 Park Avenue, South
     New York, NY 10016
     Contact:  Mr. Dave Sorokin
     (212)689-4040
    INFORM examines business policies and practices as they affect specific issues
in which business and the  public share a  mutual interest. Research  efforts include
problems of land use, water quality and conservation, energy technologies, pollution
and toxic waste  management, and safety and  health in the workplace.  INFORM's
staff consists of 30 people, dedicated to issues dealing with the source reduction  of
toxic   waste  streams.   Funding,  predominantly  from  foundations  and individual
donations, amounts to approximately $100,000 per year.

    INFORM  has  completed  a  study on  waste  minimization,  which  examined,
evaluated,   and  compared  the  waste  management  practices  of  29 chemical
manufacturing  companies within three States (Ohio,  California, and New  Jersey).
The study  focused  on the  degree  to which information about wastes within a plant
directed the plant managers' efforts to change waste management practices.  The
underlying  premise  of the study  was  that  knowledge of the chemical substances'
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entering and leaving a plant necessarily directs decisions  regarding the minimization
of  waste products, whether  as air pollutants,  water effluent, or solid/hazardous
waste.  The study contends that if companies do not  have information on  this mass
balance, waste management practices are unlikely to change.

     The  results of  INFORM's  study  have  been  published  in the book Cutting
Chemical Wastes  (INFORM  1985).  The study concludes  that  those 29 companies
usually  considered  waste reduction as  a "last resort" item. The lack of interest in
waste  reduction was  attributed  to several  factors  including costs,  government
regulations, technological  barriers, and liability risks.  Another factor was lack  of
awareness of the possible benefits (e.g., potential costs savings).

     The study also identified examples of waste reduction and cited such cases  as
having prevented  the  generation of at  least seven million  pounds of wastes, with a
corresponding cost savings of  over $800,000 per year.   Environmental  regulations
were identified  as significant  factors for  both  promoting  and  inhibiting  waste
reduction practices.

7.5.4     Environmental Defense Fund
    Environmental Defense Fund
    2606 Dwight Way
    Berkeley, CA 94704
    Contact:  Mr. David Rowe
    (415) 548-8906
    The Environmental Defense Fund (EOF) is a national environmental group that
conducts  research  on  environmental  matters  and  monitors  the  activities  of
environmental agencies and private sector companies. The nonprofit organization is
funded through membership dues and other revenue-raising projects.  EDF has five
offices  throughout the country,  with  the office in New York City serving as national
headquarters.

    EDF  recently  completed  a  draft  study   on  State  programs   for  waste
minimization.  This  report, "Approaches to Source Reduction: Practical Guidelines
from Existing Programs and Proposals," is expected to be available in final form by

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February  1986.   This  study  examines  both  current and  proposed  programs  that
encourage waste  minimization  in approximately 25 States,  focusing more closely on
those States with the largest  and most active programs.  Based on the analysis,  EOF
suggests recommendations to improve waste minimization practices.
7.5.5      German Marshall Fund
    German Marshall Fund
    11 DuPont Circle, N.W.
    Washington, D.C.  20036
    Contact:  Maryanna Ginsburg
    (202)745-3950
    The German Marshall  Fund is an organization that sends interns from  the  U.S.
to Europe  to  study  various aspects of European policy,  including hazardous waste
issues such as  treatment practices, economic incentives, and transportation.

    A  recent  study  on waste  minimization  found  that  European  governments,
specifically Denmark,  France,  West Germany, Sweden,  and The- Netherlands, are
eager to use financial incentives to encourage waste reduction.  These governments
are active in  sponsoring research and  development and  in providing  technological
assistance  to  companies producing toxic and hazardous  wastes.  The findings  and
recommendations of this study will be available in  the forthcoming report,  "Lessons
from Europe."

7.6       Summary

    Government programs  at  the  Federal  and  State level to  encourage  waste
minimization  include many different efforts such  as  exemptions or relaxations of
requirements for certain recycling activities, funding programs  (such as  grants  and
awards) to promote innovative  solutions for reducing waste generation, information
exchanges, technology  transfer  programs,  technical  assistance  programs, and  a
variety  of studies on  the subject. Nongovernmental organizations are  involved  to a
lesser degree  than Federal and State agencies, being concerned  more  with  studies,
conferences, and recommendations.  Their activities provide significant information
that can be useful to governmental agencies, however.

                                     7-47

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    Summarized  below are key elements  of  Federal. State, and  nongovernmental
programs relating to waste minimization.


    •  Congressional Initiatives

       -   HSWA require  that EPA prepare a Report to Congress on the feasibility
           and desirability of performance standards, management  practices, and
           other actions to require waste minimization.

       -   The Congressional Budget  Office  (CBO) and  the  Office  of  Technology
           Assessment (OTA) have undertaken studies relating to waste reduction.
           CBO's study  examined different types of waste-end  tax systems as a
           method for encouraging waste  reduction. OTA performed case  studies
           on  end-product substitutions as  a means  to reduce waste  generation.
           OTA is currently  conducting a  study  on source  reduction,  which  will
           examine State  and Federal  activities and provide policy options on what
           types  of  programs the Federal Government can implement  to enhance
           source reduction.

    •  National Research Council

       The National Research Council produced  a  report  addressing nontechnical
       and institutional factors that  influence waste reduction efforts.

    •  U.S. Environmental Protection Agency (EPA)

       Several programs  within EPA  are  involved with  waste  minimization.   The
       Office  of Solid  Waste (OSW)  promotes waste  minimization directly  and
       indirectly through  its regulatory programs mandated under HSWA (e.g., land
       disposal   restrictions,  increased   technological   standards   for  landfills).
       Effluent guidelines and standards prepared  by the  Office of Water also may
       serve to reduce some RCRA hazardous wastes associated  with wastewater.
       The Office  of  Research and Development (ORD) is conducting  studies  on
       waste  minimization.  The  Office of Policy Planning and Evaluation (OPPE) is
       undertaking a risk analysis of waste management  practices.   EPA  also is a
       member of  the UN  Economic  Commission  for  Europe, which  provides a
       compendium  of process technology changes  that reduce waste, energy usage,
       or natural resource usage.

    •  Department of Energy (DOE)

       DOE's   Office  of   Industrial   Programs  (IP)   promotes   research   and
       development  to  improve the efficiency  of industrial  energy use.  The  IP
       consists  of  two  major  divisions:  (1)  the  Division  of  Improved Energy
       Productivity, involved in  designing  new  systems  to conserve energy,  and
       (2) the   Division  of Waste  Energy  Reduction, involved  in  using  wastes as
       fuels.  Current  research projects include (1) concentration  of  electroplating
       waste  rinse  waste;  (2) energy  recovery from industrial  solid  waste;  and
       (3) energy recovery from waste  plastic (converting atactic polypropylene to
       fuel oil).

                                     7-48

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•  U.S. Department of Defense (DOD)

   DOD has  made it a policy, since  1980, to limit the generation of hazardous
   waste through alternative procurement policies and operational procedures.
   These waste minimization activities are implemented through the  Defense
   Environmental Leadership Project,  the Defense  Logistics Agency,  and the
   efforts of the individual bases or installations themselves.

   -   Defense  Environmental  Leadership  Project  (DELP).   DELP  develops
       innovative solutions to DOD's environmental problems, with emphasis on
       improving compliance and minimizing wastes. They recently published a
       report on  recovery and reuse  of solvents  to serve as a guide  for service
       facilities and personnel to help increase complete use of solvents.  They
       are also promoting  a  program that provides money to bases to purchase
       solvent  stills, collection systems,  and  other  related  equipment  for
       hazardous waste reductions or recycling activities.

   -   Defense Logistics Agency (DLA).  DLA is responsible for procurement of
       materials  and disposal of almost  all excess hazardous  materials.  DLA
       provides  a  free  disposal  service  to  generating  installations  via  the
       Defense Reutilization Marketing Offices (DRMO).  Materials turned into
       DRMOs  are screened  for possible  reuse  by  other  DOD activities: this
       practice  is  being enhanced  by  the  Used  Solvent  Elimination  (USE)
       program, with the goal of eliminating the disposal of recyclable solvents
       as wastes by  October  1,  1986. DLA is also investigating the possibility
       of initiating  a  DOD-wide  waste  exchange  system  to  facilitate  the
       exchange of wastes that could be reused on both  an  intra- and inter-base
       and service basis.

   -   Installations.   Individual   bases   are  practicing  waste   minimization
       methods  and techniques including  bead  blasting,  use  of  water-borne
       coatings, dry powder  coatings, high solids  coatings, waste segregation,
       and others. Adoption of these practices has been slow, however, because
       of the difficulty  associated with altering  past practices.  This situation
       may  change  with the  adoption  of  a DOD-wide  waste  minimization
       strategy developed  by the  Joint  Logistics Chiefs (JLC) of the services.
       Major elements of this program  include (1) reporting system, (2) review
       of procedures  and   equipment  for  application,  (3) improvements  in
       procurement  process,  (4) increased  research  and  development, and
       (5) inter-service information exchange/technology transfer.

•  Bureau of Mines

   Waste minimization  activities primarily focus on resource  recovery and
   reuse. The  research  program  is  directed  toward  the  recovery of  mineral
   values from low-grade complex domestic ores.
                                 7-49

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Tennessee  Valley Authority (TVA)

TVA  receives  $1.5  million  in  Federal  appropriations   per  year  for
implementation  of  its  waste  management   program.  This  program  is
designed  to  reduce  waste  generation,  improve  waste   collection  and
transportation techniques, and enhance waste utilization as a resource in the
public, private, and commercial sectors.

State Programs

State and local governments encourage  waste  minimization  by establishing
and  funding various programs.  The  effects  of these  programs on  waste
minimization  are  not  always possible to  quantify, but  they are likely to
result in some increase in such  activities.

-  Regulatory.  State regulations  encourage  waste  minimization  through
   two   strategies:   (1) exemptions  or  relaxations  of  requirements  for
   recycling hazardous wastes, and (2) restrictions applied to land disposal.
   The  exemptions  or relaxations  in  many  State  regulations do  not  differ
   substantially  from the  Federal  regulations,   except that   the  State
   regulations (and descriptive literature about the regulations) are  phrased
   differently and  are  presented  in  a manner  that  promotes  recycling.
   Fifteen  States  employ  exemptions or relaxations of requirements for
   recycling;  13 States'  regulations contain  restrictions  for land disposal of
   hazardous  wastes more stringent than those of EPA.

-  Fee  and Tax Incentives. For fees and taxes to serve as incentives to
   minimize waste, they  either may be (1) assessed for wastes generated or
   disposed, or (2) reduced or not applied on  the  basis of  using preferred
   waste management methods.  In some States, the second option may also
   include  exemptions from or reductions or  credits  in  sales, income,  or
   property taxes.  The  immediate  objectives  of State  fee and  tax systems
   are to generate revenues and to make land  disposal the least preferred
   alternative.  At  least  28 States impose  waste fees  or  taxes; 4 States
   impose  feedstock taxes; 11  States grant  exemptions  or reductions from
   such  fees  or taxes on  the  basis of use of  preferred  waste management
   methods; and 4 States grant exemptions from or reductions or credits in
   sales, income, or property taxes.

-  Loan and  Bond   Assistance.   To  minimize   the  economic  hardship
   associated with source reduction and recycling, some States  offer credit
   assistance  through  interest  subsidies for private  loans, direct State loans,
   or bond  financing.  Loan  guarantees, another type  of credit  assistance,
   currently are not available  in the States for costs associated with waste
   minimization efforts.  Four States presently have  direct loan  programs;
   10  States  authorize  revenue  bond  financing potentially  applicable  to
   waste minimization projects.

-  Grant Programs. Waste minimization grants are gift monies that  serve
   as   incentives    for   research   and  development   and   technological
   demonstrations  for new and existing  waste  minimization technologies.
   Six States offer such grants.

                              7-50

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-  Information  Programs.  Information  on waste  minimization  is  made
   available  through different  types of information  programs.  The three
   most  common  programs  are  (1) information  transfers,   (2) technical
   assistance   programs  (TAPs),  and  (3) waste  exchanges.   Information
   transfer  programs  consist of  publications,  conferences, and  telephone
   hotlines.  Nineteen  States  currently  have  some  form  of information
   transfer.   TAPs provide  hazardous  waste  generators  with  specific
   technical advice on  how their  processes could be altered to reduce waste
   generation.   Seven  States  operate   active  TAPs.   Waste  exchanges
   facilitate recycling  by matching wastes available to materials wanted by
   companies.  The objectives  of  an  exchange  are  to  help  minimize  the
   entry of  wastes into  the  environment, reduce disposal  costs, conserve
   raw materials, and conserve  the energy necessary  to  process  those  raw
   materials.   Currently,  12  States support waste exchanges within their
   boundaries.

   Award Programs. Four  States currently operate  award programs that
   provide recognition  and  honor  to individuals, companies,  and institutions
   that have  demonstrated outstanding achievement in  hazardous  waste
   management.

Nongovernmental, Nonindustrial  Efforts

Nongovernmental,  nonindustrial organizations  promote waste  minimization
in various  ways.  Many instill  public awareness and serve as sources of
information.    Organizations  involved   in  waste  minimization  include
INFORM,  the  League of  Women  Voters, the Environmental Defense  Fund,
the Pollution Probe Foundation, and the German Marshall  Office.  Reports
on waste minimization  are published by  some of  these organizations  based
on research  including:  case  studies of  industrial processes and  practices;
case studies  and surveys  of industrial plans and  policies; studies of  State
efforts; and studies of practices  used in foreign  countries.
                              7-5:

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      8. POTENTIAL STRATEGIES/OPTIONS FOR FURTHERING THE GOAL
                           OF WASTE MINIMIZATION
    Section  224(c) of the Hazardous and Solid Waste Amendments of 1984 (HSWA)
requires EPA to report  to Congress  on the  "feasibility  and  desirability" of new
requirements that would "reduce the volume  or quantity and toxicity" of hazardous
wastes or "assure such wastes are managed in  ways that minimize present and future
risks  to  human  health  and  the  environment."  The  report is to  include  any
recommended  legislative  changes  that  would  further  the  realization  of  these
national policy  goals (as established under Section 1003(b)  of  RCRA).  The section
specifically refers to  the  possibility either of establishing  standards of performance
or other additional actions to require generators to reduce hazardous wastes.  It also
refers to required  management practices or other requirements to  assure the safest
handling of hazardous wastes.

    The Senate Report on HSWA  explains "standards  of performance" as "...similar
to those under the Clean Air Act  which would require  all  generators in a certain
category to reduce the volume or quantity  and toxicity  of their hazardous waste at
least  as  much as  could be achieved through  the  application of measures that  are
available  to  generators in that category."  Other methods to be reviewed  would  be
any additional  options available for requiring such reductions  under  Subtitle C  of
RCRA,  including changes to  the newly established HSWA certification and reporting
requirements  to Sections  3002 (standards  of generators) and  3005  (TSD permit
requirements) of RCRA.

    The "management practices,  or similar  measures" are  described in  the Senate
Report  as  including steps beyond  the land  bans  enacted in HSWA.  They  would
include  "establishing  preferred or  required management  practices [to]  assure  that
hazardous wastes are  managed only in  those ways  which  the  Agency determines are
most protective of human health and the environment."

8.1        Identification and Organization of Options

    The options that follow  have been developed as possible  means to meet the
national policy  objective of waste  minimization added to  Section 1003 of RCRA by

-------
HSWA.  These options include actions  that would require amendment  of  authorities
available  to EPA  under RCRA,  as well as actions that could  be  mandated by
regulation through current EPA authorities under RCRA  and/or other  environmental
laws.  As  part  of  the  assessment of  the  desirability  of  new  binding  legal or
regulatory  requirements  to  further  the goal  of waste  minimization,  nonregulatory
strategies for meeting that goal have also  been developed.

     Some  of  these options  are  based on  existing programs at State and county
levels, while others  have  analogs  in  existing  requirements  under  other Federal
environmental laws.  Still  others  arose out  of  information and  analysis developed
during the  course of this study, and from recommendations and concerns expressed
by  those   involved  in  government and   by environmental  and  industry groups
concerned with various aspects of hazardous waste management.

     Where the options relate  directly  to  existing non-Federal  waste minimization
programs,  references  are  made  to sections elsewhere in the  report where  those
programs  are  discussed  in  greater  detaij.  For example, where  a State  program
contains elements that are the model for  an option, reference  is made  to the section
of the study where the  nature of  the State  program is discussed in more detail.
Referenced sections  of  the  report will also  provide, to  the  extent available,
evidence as to the effectiveness of the  particular program at the State  level.

     The potential strategies for furthering waste minimization are organized on the
basis of the means by which  they would affect generator activities in  reduction,
reuse, and recycling of wastes, including:
    •   Changes in the  scope  of  applicability of  hazardous  waste management
        requirements (8.A);
    •   Performance  standards,  whether directly  imposed  or  indirectly effected
        through a vehicle such as marketable permits (8.5);
    •   Changes in management practices (8.6); or
    •   Creation of economic or other incentives to encourage  waste minimization
        investments or other activities (8.7).
                                      3-2

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    An  additional  option  is simply  to  implement  currently  mandated  HSWA
requirements, such as the land bans, and then to review how generators alter their
waste generation and management practices in response  (8.3).

    The section  on the scope  of  applicability of hazardous  waste management
requirements (8.4) considers  the option of potential  changes to  the definition of
"solid  waste."  Two  of  the changes  considered involve  only clarifications of the
intent  of the  definition, while  a  third  would  involve some  possible  substantive
revisions.

    Options involving performance standards (8.5) would impose  direct requirements
on some or all  waste generating activities  in each  industrial  sector  individually.
They  also  would  set  general targets  or  limits for  waste generation, or for the
characteristics  of  the  waste  generated.    The  management  practice  options
considered  (8.6)  include  requirements  restricting particular  disposal  practices,
requirements  related to the handling of  wastes  as  they  are generated,  and
requirements  related to management  control  of the  waste  generation  system.
Beyond direct  management or performance requirements, there  are  a  number of
options that primarily would be intended to create economic incentives for desirable
waste generation and waste  management behavior (8.7).

    Some of the potential strategies for furthering waste  minimization  may require
new  legislative authority  or  regulatory action  by the  Federal  Government, while
others  involve  no  new  Federal  requirements.  Several  options  "would  require
amendments to RCRA  to  provide  EPA  with the necessary legal authority, while
others could be  handled by  regulation  under  authority  already granted  to  the
Agency,  either  under RCRA or under other  statutes (e.g., TSCA).  A number of
other options could  be implemented as policy  by EPA without legislative action or
regulatory  rulemaking, either  because they are essentially nonregulatory, or  because
EPA's role would primarily be one of supporting  State efforts. The lines separating
these categories, however, generally are not absolute. In  some  cases, for example,
it is  ambiguous whether EPA  has the necessary  statutory  authority to implement  a
strategy.
                                       3-3

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    In a number of options, the primary role envisaged  for the Federal Government
involves only informational and analytic support to State governments; thus, no new
Federal regulatory or  legislative action is needed.  There are distinctions  between
options that  are  genuinely   nonregulatory  from  the  perspective  of the  State,
generator,  and/or  TSD  facility, and  those  in which  the State  develops  its  own
legislative  or regulatory requirements for generators  and facilities (even though not
as part of a required State program).

    Ultimately, even a program that is nonregulatory in its operation (for example,
an awards  program) requires  some form of legislative authorization  for its funding
and  operation   by  whatever  governmental  entity  is   directly   involved  in  its
implementation.  Direct implementation of  a technical assistance program at the
national level by EPA would require  legislative  action  to appropriate  funds, as do
similar programs currently operating at the State level.

    Table  8-1   provides  a list of the  options  considered  in  this chapter, and an
overview of  the major way in which each would be likely to  initiate or  enhance
waste  minimization activities.  It also summarizes  the type of Federal  or State
action (whether legislative, regulatory, or nonregulatory)  most likely  to be  required
to effect  each option.   The   options are categorized  according  to   their primary
characteristics. For example,  even if a marketable permits program  limiting waste
generation  sets limits based  directly  on performance standards,  it also creates an
economic incentive for waste  minimization.  For the purpose of the table,  however,
it would be classified under performance standards.

    As noted above and indicated in Table 8-1, the determination of which options
are legislative, regulatory, or  nonregulatory for Federal or State governments often
depends on whether the  focus of implementation  is State or Federal, and how clear
the Federal statutory  authorities are.  On the legislative/regulatory  section of the
table,  therefore,  options are  marked  with  respect  to  the  most likely  route of
implementation,  as discussed in  the  option.  For  example,  the  Federal role in
developing  tax  incentives  is likely to be limited to analytic support for State efforts,
but a direct Federal  role  is  at least conceivable and  would  require  legislation.
Enforcement bounties, on  the  other hand, are  almost  certain not to be implemented
                                      8-4

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OPTION
RELIANCE ON AUTHORITIES AND
REQUIREMENTS DEFINED BY HWSA
MODIFICATION OF DEFINITION
OF SOLID WASTE



PERMIT PROGRAM
OF SPECIFIC WASTES

FOR GENERATORS

OR DEL S ONS
REQUIRE .NFORMAT.ON FROM
USES AND DISCHARGES

PER GENERATOR
REQU.RE SEGREGATED WASTE STREAMS


WASTE REDUCTION POTENTIAL

RECYCLABLE WASTES
DEVELOPMENT OF INFORMATION AND
TECHNOLOGY TRANSFER NETWORK
PROCUREMENT PRACTICES


HON TAX FINANCIAL INCENTIVES
TAX INCENTIVES
WASTE END TAX
FACILITY PERFORMANCE

HECYCLEHS

EXPEDITED DEL 1ST ING PETITIONS




SECTION
B3
8 a
85 1



853


855





863





87 1
872
873

874
875
876
877


879
87 10
8711



PAGE NO
W
8-15
8-12


8-18
B-32


8-24





8-30


6-33

6-34
B-35
MO
8-46

8-48
8-49
8-52
8-55


8-59
fr€1
fr61


NO ADDITIONS TO
CURRENT HSWA
REQUIREMENTS
•



































SCOPE OF
APPLICABILITY


•

































PTI N CATEGORIES
PERFORMANCE
STANDARDS



•


•
•


•


























MANAGEMENT
PRACTICES
















•


•

















ECONOMIC
OR OTHER






















•
•
•

•
•
•
•


•
•
•


REQUIRES NEW
FEDERAL

„„

YM


Miybfl






























REQUIRES

N.
,„



{Under TSCA)
(Under TSCA)


Y*



Miybe
(Under TSCA I
Y«


•r>1 Program







YM if
F«i*r»l Program
YM, i* FtcUril b



V.




NON-REGULATORY






















YM
V.





YM



Y«


D L STATE 1
PRIMARY
PROGRAMS











F.d.,.1
or Stile





Y«


V..



YM
YM
Both F«J«f»|
ind Stit*





Y«

ROGRAMS
STATE PROGRAM
AND/OH LEGISLATION












Y«





Y*s






Yw
YM
YM





YM


NON REGULATORY
STATE
PROGRAM





















YM












•REFERS TOHEGULATIONS BEYOND THOSE REQUIREDBY HSWAIW
                                                                                  Table 8-1  Categories of Waste Management Options and Their Relationship to Federal and State Programs
                                                   8-5

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at  the  Federal level.  Where  the option is primarily for consideration  of  Federal
action,  no indication  of  State requirements  is  given  (though,  of  course,  nothing
precludes States from implementing options that exceed Federal requirements).

     It is  important  to note that neither the particular options nor the categories of
options should be considered individually exclusive.  Any number of  combinations of
options would  be  possible  and  might  be desirable.  Many States,  for example,
currently  have programs that include waste-end  taxes, a variety  of  tax and  non-tax
financial  incentives,  and  a substantial  information and technical assistance program
(see Section 7.4 on State  programs).  All of these could be combined as well with a
marketable permits program  oriented  towards generation (8.5.2) or disposal (8.6.2)
of  wastes,  or both, or  with  specific   performance  standards (8.5.1).  Choices  of
various possible combinations of options would be based,  just as  for  individual
options, on program  objectives.

     Ultimately, even a program that is nonregulatory in its operation (for example,
an  information exchange or  awards program)  requires  some  form  of  legislative
authorization  for  its funding  and operation  by whatever governmental entity  is
directly involved  in  its  implementation.  Direct  implementation  of a  technical
assistance program  at the national level by  EPA  requires  legislative  action  to
appropriate funds, as do similar programs currently  operating at the State level.  In
organizing options by the  kind  of  action  necessary for implementation, therefore, a
major  consideration  has  been  the role  that EPA would be likely  to play.  To the
extent that EPA's role under  an option  would  be limited  to  providing information
and  technical  assistance to  the  States, rather than setting the  legal basis and
determining the regulatory parameters for a program, the options have been listed
as nonregulatory.

8.2       Potential Criteria for Deciding among Options

     The objective  in identifying options  is to  provide  a wide  range of possible
approaches to achieve the goal of waste minimization.  The strategies suggested  in
the various options vary widely in scope, complexity of implementation, and nature
of the  effect  on generators and TSD facilities.  Not  all are mutually compatible  or
                                      8-7

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consistent.  Some  may further a particular facet of waste minimization, but have

dubious or  negative effects  on  others.   Such  considerations, as  they apply  to
individual options, are noted in the relevant discussions.


    A number  of potential  general  criteria  can  be  of use  in  evaluating  and
establishing priorities among the options presented, including:


    •  Likelihood  of  achieving the desired  waste  minimization objectives  based,
       where possible, on available evidence from  existing programs,  and analysis
       of relevant economic, engineering, and/or legal factors;

    •  Possibility  of  unintended  adverse  effects  on  other aspects of  the  waste
       minimization program or on other environmental objectives;

    •  Ease of  initiation — both  for the Federal Government  and, where relevant,
       for  State  and  local governments — including  the  demand on both political
       and administrative resources to develop  and  gain approval for the program;

    •  Complexity  of  implementation,  including  administrative  burdens for  all
       levels of  government  and compliance  burdens  for the  affected/regulated
       community;

    •  Successes  and difficulties of analogous efforts in other programs;

    •  Cost of implementation, insofar as any reliable data or experience exist  for
       projecting such costs,  including direct  costs to government, and  direct and
       indirect costs to  industry;

    •  Ease  of  enforceability  for   maximizing  compliance  with   regulatory
       requirements;

    •  Probable degree  of  acceptance by implementing  agencies  or institutions,
       regulated (or otherwise affected) community, and the general public; and

    •  Degree  of flexibility  provided  the  regulated  community  in  meeting  the
       established environmental  objectives.
8.3       Reliance on Authorities and Requirements Defined by the Hazardous and
          Solid Waste Amendments of 1984
    HSWA require  a  wide range  of  changes in management  practices  for handling

and disposing of hazardous wastes (see Section 5.5 for a discussion of requirements

under   HSWA).   More   importantly,   for   purposes   of   waste   minimization,

-------
numerous small  generators are brought within the  RCRA regulatory framework for
the first  time.  Also, a  variety of  new  restrictions  are  imposed  on  disposal  of
hazardous wastes  to  try  to reduce  current dependence on disposal techniques that
pose significant  risks, present or long-term, to  human  health and the environment.
In  addition,  generators  are  required  to  certify,  both on  the hazardous waste
manifests and in biennial  reports to  the State or Administrator on the quantity and
nature of hazardous wastes generated, that they have programs in  place  to reduce
the volume or quantity and toxicity of hazardous wastes, and that the/ are choosing
the most environmentally  sound method of treatment or disposal.

    Given the  broad scope  of HSWA,  considerable  time  may  be required  to
determine the effect of the changes,  particularly the land  bans, on the practices  of
generators, and  specifically the extent  to  which they  will  undertake new  efforts  to
promote  source reduction  and recycling.  One option open to EPA  would  be to  focus
its current efforts strictly on implementation of the mandatory provisions  of HSWA,
and then, after  there has  been time  to  review the effects of those provisions,  to
examine  what additional  requirements would be needed to  bring about greater waste
minimization. One element of such  a decision might be to spend all  available
resources,  beyond  meeting   the  HSWA  deadlines,  on vigorous enforcement,  to
attempt  to eliminate noncomphance  to  the  greatest extent possible.   A particularly
intense effort could be made  to bring the  newly-included  small quantity generators
into compliance  as scon as possible.

Observations:
        Regulatory  changes  currently required by  RCRA  might  be  sufficient  in
        themselves   to  encourage  firms  to  minimize  wastes,  because  of  the
        increasing costs of disposal as landfilling  restrictions  come into place and
        because   of  the  increasingly obvious  risks  of  long-term  environmental
        liability.  But even  if the decision  were  to  impose no  new  regulatory  or
        legislative requirements  for the  present, EPA might still consider the need
        for informational  and technical  assistance  to small  businesses.  Many  of
        these  small  businesses   lack  the   resources  to  determine  what  waste
        minimization  opportunities are available, even  where there  might  be  an
        immediate profit from such investments, or at least a very short time period
        before  investment costs were  recovered.  (For  more on the  information
        needs of small businesses, see Section 8.7.1.)
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    •  A  number of generators and recyclers  contacted for  this study emphasized
       that more stringent and aggressive enforcement would  greafly  encourage
       increased reduction, reuse, and  recycling.  A  few stated that  regulations
       were not nearly as important as enforcement, and that current enforcement
       was too lax.

    •  Despite  the long-term  liability risks, many firms, especially smaller ones,
       are primarily  concerned with short-run cash flows.  Waste minimization may
       not  always be the  lowest-cost, short-term approach.  In  the  absence  of
       either   additional  regulatory  requirements  or  financial   incentives  for
       installation   of   necessary   equipment,   therefore,  companies  may  not
       undertake it.

    •  Companies mainly  concerned with  avoiding long-term liability rather than
       minimizing immediate expenses, may choose to use  incineration to destroy
       wastes rather than looking  for opportunities to reuse or  recycle.  While this
       may solve the individual firm's long-term  liability problems,  it will not lead
       to achievable  reductions in virgin toxic  materials in use.
          The Scope of Applicability: Modification of Definition of Solid Waste and
          Associated Regulations
    The  scope of the  RCRA  hazardous  waste regulations  is  determined  by the

definition of what is to be called "solid waste," as well as by any exemptions from

regulation for materials encompassed by  the definition.  A certain  difficulty arises

from  the  need to write a definition that prevents hazardous wastes from escaping

the regulatory system and being  mishandled, while at  the  same  time developing a

definitional  and  regulatory framework that is not counterproductive with respect to

waste minimization  and recycling.  (For a detailed  discussion and  summary of the

revised  (January 4,   1985) definition of  "solid  waste,"  see  Appendix F.) Changes

made from  the  proposed  definition (48  FR   14472,  April  4,  1983)  to the  final

definition (50  FR 614, January 4, 1985) considerably restrict the  classes of materials

that  can  escape  regulation.  The  definition   itself  was  designed  to  close  the

"loopholes"  that  existed in the RCRA  regulations.   Although "sham" recycling has

always been illegal,  the regulations prior to the January 4,  1985  revision  allowed

characteristic hazardous  wastes and  commercial chemical  products (listed in 40

CFR 261.33) to remain unregulated, provided that they were being "beneficially used

or re-used or  legitimately recycled  or  reclaimed."  Thus, generators did not  need to

manifest the exempted wastes that  were being recycled.  There  was no  regulatory
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mechanism for ensuring that the exempt wastes were actually  being  legitimately
recycled.  EPA stated that such mechanisms were  necessary  to  ensure that human
health and the environment are protected (50 FR 618, January 4, 1985).

    The  option presented  here involves  the  question  of whether  there might  be
changes to the definition  that  would provide greater  encouragement for recycling
without increasing risk to human health  or the environment.  The first  two  possible
changes involve what may be only a clarification of the relationships of treatment
and  reclamation  and  of  ingredient  and feedstock  with  respect  to regulatory
requirements. The  other raises the  question of whether, under some circumstances,
it  might be preferable  to  use a lesser  degree of  regulation for  recycling  waste
materials that are,  for all practical purposes, equivalent to the  virgin material.

8.A.I      Clarification of Relationship of Treatment and Reclamation

    Under the final rule, the process of  reclamation itself is currently  unregulated.
Thus, the fact that a facility  carries on  reclamation does not  necessarily subject  it
to a requirement  to obtain  a  TSDF permit.  Reclamation .is defined in  40  CFR
          "A material is 'reclaimed' if it is processed to recover a usable
          product, or if it is regenerated.  Examples are recovery of lead
          values  from   spent  batteries  and  regeneration  of  spent
          solvents."
          "Treatment" is defined in 40 CFR 260.10:
          "'Treatment'   means   any  method,  technique,  or  process,
          including   neutralization,  designed   to  change  the  physical,
          chemical,  or biological  character  or   composition  of  any
          hazardous  waste so as  to  neutralize such waste, or so as to
          recover energy or  material resources from the waste, or so as
          to render such waste nonhazardous,  or less hazardous;  safer to
          transport,  store, or  dispose  of;  or amenable for recovery,
          amenable for  storage, or reduced in  volume."

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    Discussions with  both  generators  and  State officials  indicate  considerable
concern  as to the  intended relationship between these  two concepts.  There  is
particular concern that the intent of the definition  is to  leave  reclamation  activities
unregulated  only   when  they  can   somehow  be  considered  not  to  constitute
treatment.  Reclamation is simply a subset of treatment, however.  The concern  of
both generators and State officials is that,  while reclamation  as such may not  be
regulated,   treatment   is  regulated,  thus  implying   that   facilities  involved  in
reclamation will be subject to TSDF  permit requirements because they are carrying
out  treatment.  This  confusion  may  discourage  generators   from   undertaking
recycling   activities,  which  they  believe   will  subject  them   to  TSDF  permit
requirements for treatment.  In fact, the act of reclaiming  is exempted explicitly  in
40 CFR 261.6(c)(l).  This  confusion  could be  alleviated by cross-referencing this
part of the regulations in the definition of "treatment" in 40 CFR 260.10.

8.4.2      Clarification of Relationship of Ingredient to Feedstock

    A second  area where confusion   on  the  part  of States  and  generators  could
possibly . be  eliminated  by  further  clarification   is  the  relationship   between
"ingredient" and "feedstock."  Under 40 CFR  261.2(e)(l), two of  the exclusions from
the definition  are for (unreclaimed) materials  that are:
          (i)...used or reused as ingredients  in an  industrial  process  to
          make  a product,  provided  the  materials  are   not   being
          reclaimed....
and
          (iii)...returned  to  the  original process  from  which they  are
          generated, without first  being  reclaimed.  The material must
          be returned as  a substitute for raw material  feedstock, and the
          process must use raw materials as principal feedstocks.
     There is  no  distinction, however, between  materials  that  are  ingredients and
materials that are  feedstocks.  The ambiguity of  the  relationship  is  illustrated by
one  of  the examples provided in the  supplementary  information  in the Federal
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Register notice:  "An example of the  former practice — i.e., use as an ingredient —
is the use of chemical industry still bottoms as feedstock"  (50  FR 63*7, January 4,
•1985; emphasis  provided).  This  confusion could be alleviated by using one term or
the other.

3.4.3      Greater Use of Concept of Equivalence  in Determining Which  Recycled
          Materials Should Be Subject to Regulation

    The final  rule on  the  definition of "solid  waste"  established some conditions
under which recyclable materials may  be excluded from regulation (see Section 5.5.2
                                                            *
and  Appendix  F for further  information on this  definition).   This option would
exclude from the definition  additional  materials that are recycled if it can be shown
that (1) the recycled materials  function as raw materials in normal manufacturing
operations or as  products in normal commercial applications; and  (2) the  materials
will  be  used within  a reasonable period of  time.  An additional condition would be
that,  where the  ultimate use  involved  burning  for  fuel  or placement  on land  of
commercial chemical products  (e.g., as  a  constituent  of fertilizer), it  would  be
necessary  to  establish  that the  raw material  which the  recycled  material  was
replacing  typically was used  for  that  purpose.  Additional  restrictions  might  be
necessary to ensure adequate environmental  protection, but they would still be short
of the full requirements that result from regulation under the definition.

    Principal  areas  where consideration of equivalence might reduce barriers to
recycling  are the following:

    •  Materials that  were  recycled  through  reclamation  could be  excluded
        (without  requiring  a  variance for  such exclusion)  from the definition  and
        exempted from  regulation when reclaimed by the  generator  for use  at the
  Additional   exemptions  were  considered  in  the  proposed   rule,  including
  (1) hazardous waste being reclaimed by the generator or by a reclaimer  for  the
  reclaimer's own  subsequent use,  and (2) hazardous  waste being  reclaimed under
  batch-tolling agreements.   Where a  waste was reclaimed by the generator at  a
  single  plant site  for return  to the original process in which it was generated,  the
  proposed  definition would have excluded  it from  the definition  of "solid waste"
  (see 48 FR 14477, April 4, 1983).
                                      8-13

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       plant site at which  they  were generated  (even if not  in  the  original
       production process).  (The  Agency, to some  extent, has already modified
       the  rules  to  exclude from regulations  those  materials reclaimed  in  a
       closed-loop tank system; see 40 CFR 261.4(a)(8) in  51 FR 25471,  July  14,
       1986.)

  •    Materials that are  reclaimed under batch-tolling agreements,  or similar
       leasing  or processing agreements, could be  excluded  from the definition
       provided that a daily log of  materials processed under such contractual
       agreements,  at  both  the generator and the reclaimer, was both accurate
       and  sufficiently detailed.  Time limitations would be  the  same as in the
       proposal.*

  •    With a  regulation as  complex as the definition of solid waste, the clarity
       of interpretations can be of major importance.  The more conjectural the
       interpretations  of  States or generators  as to meanings and requirements
       under the regulation,  the greater the possibility of results that are neither
       desired nor anticipated, either with  respect to environmental  protection
       or  commercial  efficiency.  Attempting  to  predetermine  each   case,
       however, could eliminate flexibility.

  •    Enhancing protection of the environment and human health depends both
       on reduction of  exposure to hazardous wastes and reduction of exposure to
       nonwaste toxic  materials.  The objective of reducing potential exposure to
       wastes  tends to  focus attention  on  prevention of  any possibility  of "sham"
       recycling  or carelessness  in  waste  management.   But  elimination  of
       exposure to virgin  toxics may provide a reason  for greater  emphasis on
       recycling and reuse  of  waste materials.  The proposed rule established a
       significantly different balance with respect  to  these  considerations than
       did the final rule,  raising some question  as to whether there were feasible
       intermediate  steps.  The question could, therefore, be  one of  emphasis.
       Should  the rule  be  written  to cover standard practices,  with  flexibility to
       curb  infrequent  abuses or should the rule  be written, as it currently  is, to
       cover every  contingency, with flexibility to exempt those that can  prior
       demonstrate the impossibility of such  abuses?
In  addition to the rules against over-accumulation and speculative accumulation,
the proposed  rule established time limits, for example, for the applicability of the
batch tolling exemption.  The generator was required to  send the materials to the
reclaimer within  180 days, and the reclaimer to return reclaimed  materials to the
generator within 90 days (48 FR 14495).
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    •  While the regulations  may  provide  increased  impetus for a preference for
       virgin  materials  over  those that are recycled, this may  reflept a tendency
       built into  RCRA  and  CERCLA.  Specifically,  these  laws  create  a
       differentially  greater  liability for  mishandling recyclable hazardous wastes
       than toxic virgin materials. This liability is reflected, for example, in the
       higher  transportation  costs  for  hazardous  wastes.  (The  possibility of
       creating a further impetus for  recycling by means of a Recycled Substances
       Act is considered in Section 8.7.9.)
8.5        Performance Standards
8.5.1      Performance  Standards Limiting Volume and/or Toxicity of  Wastes for
          Generators
    Regulations could impose performance  standards limiting  the volume and/or
toxicity of waste  generation  allowed per unit  of  production.  The standard  would
apply  either  to  specific  industrial  categories,  or  to  specific  waste-generating
operations  that may be a component  of an industry. For example, a standard ma/ be
established for the electronics manufacturing industry for specific  solvent wastes.
Another standard  for  solvent wastes may be established  for degreasing operations.
In the latter example, standards for degreasing operations are not limited to any one
industry.

    Precedents  for  implementation  of such a regulation  exist within  the  programs
associated  with the Clean Air  and Clean Water Acts.  Under the Clean Air Act, New
Source Performance Standards (NSPS) for new stationary sources of air pollution are
established.  The  NSPS  are emission limitations  that  apply to  new  or  modified
                                      3-15

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"sources" of air pollution in  specific industrial categories.  Some  of  the  standards
apply to pieces of equipment that are not specific to any one industry,'such as fossil
fuel-fired boilers.  Other standards apply  to  equipment that  is  industry  specific,
such  as particulate  emissions from  fluid catalytic  cracking units  in petroleum
refineries.  Emissions may  be expressed in terms  of pounds per million BTLJ  heat
input, or as a concentration  limit of the .total stack gas volume being emitted (e.g.,
5 ppm).  Some of the NSPS are expressed in terms of a  practice  rather than  a
standard;  for example,  some volatile organic liquids  are  required to be  stored in
floating roof storage tanks; other liquids must be stored in pressure  tanks with  vapor
recovery.

     Under the Clean  Water Act, effluent limitations are  established  in  a similar
fashion  for various pollutants under specific industrial categories.  In both  instances,
standards,  effluent  limitations,  or  management practices are  based  on  the best
available control technology, with  additional conditions  (depending on  the statute)
that  it  must  have  been  demonstrated  in  operation   and/or  be  economically
achievable.   Each set of standards  may be revised based on  a  periodic  review of
what constitutes  "best" control technology;  thus,  standards  for  new  or  modified
equipment  may become more stringent over Time,

     This option proposes a  similar approach:  limitations on volume and toxicity of
hazardous  wastes would be established for specific  industrial  categories.   These
would be expressed either as a function of unit of production or  of virgin  materials
introduced to a process or  facility.  The former standard may be  more appropriate
for  process/product-oriented  operations,  such  as  production of  printed circuit
boards.  In  this instance, the  standard  may  be  expressed  as pounds of  a  particular
solvent component disposed per unit  of product made.  In the  case  of degreasing
operations,  the standard may  be  expressed  as  pounds of solvent (or component)
disposed per pounds of solvent used in the degreasing operation.  Like  the air and
water  programs,  the  standards  would   be based on  an  evaluation  of   waste
minimization practices and technologies available.   This option would be  applicable
to existing as well as new or modified facilities or pieces of equipment.
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    While  this  option  could be  implemented under  Section  6(a)  of  TSCA,  the

authority   for  this  type of  action  is ambiguous  and  implementation  might  be
unwieldy.  Specific legislative authorization would probably be desirable.


Observations:
    •   This  approach  would  establish  standards  for  all to  follow,  eliminating
        uncertainty  as  to  what  constitutes  waste  minimization.  If  effectively
        enforced,  it  would  contribute   to  waste  reduction.  If  not  effectively
        enforced,  however,  the  program is  likely to have the  perverse  effect  of
        spurring illegal dumping.

    •   This  approach has  met  with some degree  of  success  in air and water
        programs; such  programs  are  comparable  to this option in  that  emission
        limits were  established for specific industries based  on industry  practices
        and best  available  control  technology.  Comparison with  air and water
        programs  is not  entirely appropriate, however.  Air and water  effluent
        streams  are  more  easily  categorized  and   generalized  for  purposes  of
        establishing standards because (1) there are fewer pollutants of concern, and
        (2) end-of-the-pipe effluents are more amenable to prescribed technologies
        and limits than in-plant processes. There are some industries, such  as the
        chemical industry, that use such a large variety of processes and equipment
        to  make  the  same product  that a  uniform  set of  effluent  limits  or
        standardized management practices would be  impossible to prescribe for the
        entire  industry.   Multiplicity  of processes and  products  in  the  chemical
        industry  has  also  proved to be a problem for  effluent  guidelines, as was
        evident in the initial proposal for the organics  and plastics  industry.  In some
        instances, this approach would  be  most  appropriate for companies  that are
        small  to  mid-size  within  an  industry that  is  fairly  homogeneous  in  its
        operating  and production  practices.  For other  industries,  however, the
        opposite  may  be  true.  For example,  standards  may   be  more  readily
        established for some  electroplating  operations  that  are  captive  to  large
        companies. Small to mid-sized  plating shops, on the other hand,  may not
        lend themselves  as readily  to regulation, since  they are more of a batch type
        operation that generate waste streams  with unpredictable  components.

    •   Since  the  overall objective is  to reduce human risk, it  would serve  little
        purpose  to achieve  a  reduction of volume   that  results in a net  toxicity
        increase  —  a problem that could occur with  some product  or   process
        changes.   To  avoid  this,   one   should  be  able  to  measure toxicity  of
        alternative waste streams  against some  common standard (as  reduction  in
        toxic  effluents  is   measured  by  using  copper as  the   standard  for the
        cost-effectiveness evaluations  for  effluent guidelines).  This  would  be an
        extremely complex undertaking,  both scientifically and administratively.

    •   In order to develop  such standards, it  almost certainly  would be necessary  to
        first  gather  the  kind of  detailed   information  requested  in  industrial
        mass-balance surveys,  such as those in New  Jersey  (see  discussion  in
        Section 8.6.1).

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       This  approach might  be most  readily  implemented,  at  least  initially,  if
       limited, to  new or  modified  facilities or pieces  of equipment,  or  to highly
       standardized and commonplace industrial operations.
8.5.2      Waste Generation Marketable Permit Program

    A waste generation permit program would involve granting permits to individual
facilities  to  generate  stipulated  volumes of  wastes.  The  amount of wastes that
could be  generated could then  be  held constant  as the  industrial base increased
either by (1) holding constant the  volume of waste that could be generated under any
permit and  requiring  that new facilities buy permits  for generation from  existing
facilities, or (2) allocating a certain volume of generation each  year  to  permits
issued to  new facilities,  while proportionately  reducing  the  volume  of  waste that
could be generated  under existing permits so that there would be no net increase.

    To achieve a gradual reduction in the total amount of waste generated, a small
percentage reduction  could be applied each year to the volume of waste allowed to
be generated under any  existing waste  generation  permit.  If,  for  example, the
objective  were  to achieve a two percent reduction nationally in waste  generation for
a given year, a two  percent or greater reduction would be required  in  the amount of
waste  allowed  to  be generated  under  all  permits currently   held  by  existing
generators.  The  extent to which reductions  beyond two percent would be required,
would depend on the  volume of  new  source  generation permits granted during the
year.

    A permit system  could be designed either to deal solely with waste  volumes or
to deal with toxicity  as  well.  To deal with the problem  of relative toxicity, the
most  manageable option probably  would be to create two or three classes  of  more or
less  toxic wastes,  with specific  permits (noninterchangeable) for  each class.  In
principle, it might be possible to develop specific  toxicity weightings for  each  waste
stream relative to  waste  chosen  as the standard (as, for example, copper is used as
the standard for weighting reduction  in  toxic effluents  in  the cost-effectiveness
analyses  carried  out   for the effluent guidelines).  A specific  marketable permit
would then allow a toxicity-weighted  volume of  waste generation, and   the volume
allowed under the permit would vary with the toxicity of  the waste stream. Such a
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system would  require a level  of scientific precision that may be  unattainable (and
open to  court  challenge).  It  would also require  a degree of detailed oversight of
every change   in production  or  process at each  generator  and  of  every  market
transaction  involving  the  permits.  These requirements  are likely  to  render the
system unworkable.

    The  permits allocated  to  facilities  in such a system could either  be  marketable
or nontransferable.   A system  of nontransferable permits has many of  the  same
features, advantages,  and  problems as  a  marketable  permit system.  It lacks the
flexibility that enables facilities to  sell or purchase permit allocations according to
their specific  needs, however. Therefore, this option  assumes that the system will
be based on  marketable permits.

    Marketable permits would  allow  a facility  to generate a specific volume of
waste during the course of a  year.  In  the event that  a given generator  carried out
waste minimization efforts so that it no longer anticipated requiring the  full  volume
allowed  under its permit, it could  transfer  or  sell that  allocation  to  another
generator. It  might,  however, prefer to hold its allocation in anticipation  of future
requirements  created  by  annual percentage reductions  applied to  waste volumes
allowed under the permits. Generators unable to reduce their  wastes to the extent
required  by  subsequent  annual reductions,  for either technical or economic reasons,
would  be able  to  purchase  additional  waste generation allocations  rather  than
reducing production.

    In order for such  a permit system to be more than  a paper exercise, there would
have to be a significant penalty applied to any generator (and adequate enforcement
to detect violations) for any volumes of waste  generated in excess of those allowed
by the permits.

    One of  the necessities to make such a system viable would be accurate data on
actual  volumes  of waste  generated.   It would therefore  be desirable  to provide
incentives to generators to produce accurate data on waste volumes.  One possibility
would be  to allocate a  small  percentage increase  in  the  volume of waste allowed
under permits at any  facility  that had  an environmental auditing program that would
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verify  the accuracy of waste generation data. Such an auditing program would have

to meet requirements predetermined by EPA. It  might be desirable to require that,

for purposes of  receiving  the  additional allocation, the  audit  would  have to be

carried out by an independent contractor and periodically  verified  by EPA review.


    It  would probably be necessary to go to Congress  for authorization  to initiate a

marketable permit system.


Observations;


    There  are  a  number  of  equity  issues, technical  difficulties, and  structural
problems that must be addressed if such an approach is chosen.


    •  Equity issues include the following:

       -   How  are past efforts by generators to  minimize wastes to be treated?  Is
           credit  to  be  given for such past reduction and, if so, on what basis?  If
           permit levels  are allocated strictly  on  the  basis of  current levels of
           waste  generated,  those generators  who  have  made  efforts  to  reduce
           waste in the past will be at an unfair disadvantage.

           Any efforts to credit past waste minimization  will  necessarily have to be
           judged on a  case-by-case basis.  Since most  facilities are likely to apply
           for  such credit, the administrative  effort  required  to evaluate  such
           claims could be overwhelming.

           If  permits are allocated  to  existing  facilities, and new facilities  must
           purchase waste generation permits from the existing ones, there  may be
           some  potential  for  exercise of  market  control  by existing generators
           against new entrants.

    •  Among  the technical difficulties  that   will  require  resolution  are  the
       following:

       -   How  should the  baseline be established for allocation of waste generation
           levels under permits?  It could be based  on current or current-adjusted
           (for  past  minimization efforts) generation levels.  This,  however, may
           involve data and criteria problems noted below.  It  could also be based on
           performance  standards  for  each industrial  category.   The  technical,
           administrative, and  time requirements for  creating  such  performance
           standards may   be  substantial,  however,  as was  the  case   in  the
           development of  appropriate requirements for  permits  under the  NPDES
           program.
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   Even if existing facilities  receive  waste  generation  permits based  on
   current generation  levels,  some  other method  will be  necessary for
   allocating permit levels to new facilities, unless these facilities are to  be
   required to purchase permits from  existing generators, which raises the
   potential equity issue noted above.  Should waste  generation permits for
   new facilities be allocated on  the basis of performance standards, or  on
   some other basis?

   How difficult will  it be administratively to  distinguish aqueous treatment
   systems that should be included  under RCRA  from those  that should not
   (e.g., D002 corrosive wastes that may  have  been  included by a facility in
   its  list of  hazardous wastes generated,  but  which are treated under  an
   NPDES permit)?

-  What time period should be used  for determining  the baseline  for  an
   individual facility?  Short  time  periods using the  most recent data may
   alleviate the problem  of evaluating questionable  data, but may  distort
   typical waste  generation  figures  for  a  facility because of peaks  or
   valleys in  the  business cycle.  Facilities  could  be permitted  to  choose
   whether  to  use recent  or long-term data, but this  may   compound
   administrative  problems,  and  still  leaves unresolved the  adequacy  of
   older data.

The  major structural problems are the geographic decision level  for  permit
allocation and the  potential  administrative complexity of the program.

   Will permits  for new generators (or  expansions),  if they  are  not  to  be
   purchased from existing generators, be  allocated on a national, regional,
   or  State  basis?  One  possibility  that would  be  consistent with  State
   delegation,  yet would  seem  to  alleviate some  of  the  limitations  on
   industrial  development that might follow if each State were given  a  rigid
   allocation, would  be to create a national pool from  which  each could
   draw annually.   It  would be  necessary to set  procedures for determining
   the drawing rights for each  State.

   Should permits be marketable only  within a particular State or region  or
   nationally?  Nationally  marketable  permits would provide  the greatest
   flexibility, including allowing  for  transfer of permits  to facilities  in
   areas with rapid development.  But  nationally marketable permits might
   lead to substantial  reductions  in waste generated in  some parts of the
   country, while  other parts  of the country  experienced no reduction,  or
   even an increase.

   How would the permit program be paid for? A generator permit program
   has significant  resource  implications.  EPA estimates that there will  be
   189,000 generators  above  the  100 kg/month  small generator  limit (EPA
   Hotline).  To meet  the  funding and staffing requirements for such  an
   effort, it  would probably be desirable  to charge  a  fee for each permit  to
   cover the  administrative costs.
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8.5.3      Prohibit or Restrict Generation of Specific Wastes

    EPA could use its powers under Section 6(a)  of  the Toxic Substances  Control
Act (TSCA) to ban or otherwise restrict the manufacture, processing, or distribution
of a chemical substance, or to regulate "any manner  or  method of disposal" or  any
chemical substance or mixture that "presents, or will present an unreasonable risk of
injury  to  health  or  the  environment."  These  powers could be  aimed  at  the
feedstocks that  are responsible for  particular waste streams, as well as at the  waste
streams themselves.   In  promulgating such  regulations,  the  Administrator  must
assess  the  degree of health risk and the extent of human  exposure, the benefits of
the substance  and the  availability of  alternatives   for  beneficial uses,  and  the
economic consequences of the regulatory action.

    In principle, EPA could use this authority to specify  overall waste  limitations or
concentrations for manufacturers  generating  certain  types of wastes.  One example
of the use  of  Section 6(a) authority  is the  ban  on  manufacture  for  most  uses of
chlorofluorocarbons for  aerosol propellants.  A similar type of authority has been
invoked in  a nonfederal context by California's  South Coast Air Quality Management
District to ban any emission of certain air toxics.

    Section 6(a)  authority is chemical- or  waste  stream-specific,  and Section 6(a)
rules have  been developed for only  five chemical substances (including PCBs,  which
was mandated by statute).

Observations:
        Use of Section 6(a) of TSCA could force the use of  less toxic substitutes in
        any phase of production,  or  limit the  volume or rate  of  generation  of any
        particular toxic waste, but the chemical-  or waste stream-specific  nature
        of  Section 6(a) regulations limits the effect of individual regulations,  except
        in cases where the substances are widespread.
        Attempts to use this authority on a  wide-ranging  basis would be likely  to
        produce  resistance   and   litigation,   particularly  with   respect  to  the
        requirement of Section 6(c)(l)(D)  that the Administrator determine  that the
        risk of injury  to  human health  and  the environment could not be reduced
        using any other regulatory authority.
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8.5.4      Use of Effluent Guidelines to  Increase  Source Reduction and  Recycling
          (CWA)
    Under the Clean Water Act,  EPA  issues  effluent  limitations  on wastewater
discharges from various industrial  categories.  In particular, Sections  301, 304, and
307 of the Act (as amended in 1977) require EPA to develop effluent limitations
guidelines, new source performance  standards, and pretreatment standards based
upon  determination  of  the  Best  Available  Control  Technology   Economically
Achievable  (BAT) for  toxic pollutants.  In addition,  Section 402(a)(i) of the  Act
requires EPA  to develop effluent guidelines for point-source  categories using best
engineering judgment.  In  making  these  determinations,  EPA  considers  various
technical  alternatives,  taking  into account  economics  and  technical  feasibility.
Included in these determinations are process  modifications that reduce water usage,
minimize  wastewater generation, and/or substitute chemicals to  reduce  pollutant
concentrations in wastewater.  This option  proposes that the effluent guidelines and
standards  be reexamined for additional consideration of the  use of internal recycling
and source reduction measures to  effect reduction in RCRA hazardous  wastes in
addition to wastewater per each industrial category. Effluent limitations could then
be revised to effectively require the use  of additional  source reduction/recycling
within the process, and result in reduction of hazardous waste generation.

Observations:
        The reexamination  and  reworking of the  present  effluent limitations  are
        probably a costly and time-consuming effort that may take several years to
        implement, especially since such a reexamination would have to be made on
        a process-specific basis.
        This option is likely  to be met  with  resistance from industry, particularly in
        cases in which potentially expensive  process changes  may  be  involved  and
        where modifications have already been made to meet previous guidelines.
        With  the exception of a few  industrial  categories, the  revised regulations
        would probably  not  reduce significantly the  hazardous  and  solid  wastes
        generated, since the  limitations  address wastewater discharges,  which  are
        frequently independent of solid  waste discharges. For example, wastes such
        as still bottoms, tars, and baghouse  dusts are not materials recovered from
        wastewater  treatment.  Of the  wastes  that  do result  from  wastewater
        treatment, many are not suited  for process reuse.
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    •   This option may lead to  substantial reductions in waste generation in only  a
        few industries; however,  for many industries  the  result may be marginal
        reduction of waste generation rates, despite increases in  onsite recycling.  A
        study  to  identify potentials  for substantial  reductions in waste  generation
        appears necessary as a first step if this option were  to be carried out. With
        respect to  increases in  internal recycling, such recycling is limited by  the
        degree of contamination of the wastewater.  Excessive contamination would
        prevent effective treatment.
8.5.5      Establishment of Toxicity Levels for Delisting Petitions

    EPA could set predetermined numerical  levels for  toxicity of  wastes or levels
of hazardous constituents  in wastes  below  which a  waste  would be  considered
nonhazardous.  (For a  discussion of the  current process and status  of  delisting
petitions, see Section 5.5.7.)  (For a discussion of the possibility of simply expediting
delisting of residuals from reclamation, see Section  8.7.10.)  The limits  would be set
to represent  levels below which  human health and the environment  are not believed
to be  threatened.  This option  would  be   a  departure  from  the  case-by-case
evaluation  of petitions  that  occurs now.  Generators or facility  owner/operators
might only have to certify that the  waste characteristics do not exceed  the  formally
established  thresholds.  These  thresholds  would  provide  a  basis  not  only  for
establishing  that a waste was  not hazardous by reason of the constituents for which
it  was originally listed, but also for determining (as  required  by HSWA) that there
are no  other factors in the  waste that should  cause it to continue to be listed (e.g.,
toxic  solvents  found  in  wastewater treatment sludges  from  electroplating  that are
largely free  of the heavy metals which resulted in listing in the  first place).

    Possible approaches to this objective would be either to  establish specific limits
for all hazardous  waste constituents (listed in Appendix VIII to 40  CFR  261), or to
set specific  limits  for each of  the constituents that could be  contained  in a specific
waste stream on a RCRA waste code basis.  In the second case, a petitioner wishing
to have a K062 waste delisted,  for example, would need  to  demonstrate  that  the
constituents  in the  K062  waste  are  below the  limits established  for  it.  This
approach would be based on  the presumption that the  same constituent may elicit a
different degree of concern  depending on the waste stream of which it is a part.
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    The  objective of this approach to delisting would be to develop a quicker and

more  efficient delisting  process, to the  extent that  this can be done consistent with
the protection of human  health and the environment.


Observations:
    •   Since  residuals  from reclamation  operations  are  hazardous  wastes until
        delisted,  greater speed  and predictability in delisting might  increase  the
        incentive for reclamation, especially onsite reclamation by generators.

    •   Specific toxicity limits  might encourage generators to  reduce hazardous
        levels in their wastes to meet  the specified  targets, but it may be difficult
        to  ensure  that  such  limits  are  maintained  consistently  over  time.  The
        enforcement effort to assure that waste  streams were remaining within  the
        established limits could  be  substantial (although this problem also exists  for
        petitions considered on a case-by-case basis).

    •   The effort to establish such levels  is likely to involve intensive use of both
        time and resources, and individual  decisions could  be  controversial.  The
        case-by-case approach  was adopted because hazardous waste  or hazardous
        constituents  behave  differently  in  different   environments  and  in   the
        presence  of  other  wastes  or  constituents.   The  setting of a worst case
        numerical  level  might result  in a  threshold  so  low that virtually  no one
        would be able to certify, and case-by-case considerations would still almost
        always be' required.  The analytical  difficulty might be mitigated, however,
        by  tieing such an effort  to the establishment of treatment or pretreatment
        standards, which must be established to continue to allow  wastes to be land
        disposed under the restrictions imposed by HSWA.
8.6       Management Practices
8.6.1      Require  Information  from  Generators  on  Material  Inputs,  Uses,  and
          Discharges
    Under Section 8 of TSCA, EPA has authority to gather extensive information on

chemical  substances.   Specific reference  is  made, among  other things,  to  total
amounts manufactured and processed, and a description of the byproducts generated

by  manufacturing,  processing,  use, or disposal.  The Administrator  may require,

however,  such  other  information  as may  be necessary for administering the Act.

(Small businesses are exempt from this requirement.)
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    This  authority   appears   sufficient   to   provide  the  opportunity  for  the
Administrator to require a complete mass-balance analysis of chemical inputs, uses,
and discharges or disposals.  Requiring such information could provide an  incentive
for waste minimization.

    New Jersey's Industrial Survey  Project required a comprehensive report of such
information from each plant covering each chemical in a survey completed in  1982.
A  second survey was supposed to  be undertaken in  1984, but was delayed because  of
a legal challenge to  the State's right-to-know law.  The State still intends to carry
out another survey,  and perhaps to  institute them on  a biennial basis, but the timing
depends on legal and legislative action.

    In California, both Santa Cruz  County and Sacramento County  plan to  require
comprehensive mass-balance information on a continuous  basis.  (For more detail  on
the planned  requirements of  the  two counties, see  Section  7.4.1.)   Sacramento
County's  zoning agreement, applicable to new  facilities,  includes the requirement
for generators  to provide  a  method to  monitor and  account  for all hazardous
materials at  all times.   This would  include  their arrival onsite through ultimate
disposition,   including material  storage,  movement,  processing   or   fabrication,
analysis, waste storage, treatment, discharge, product storage, and shipment offsite.

    Sacramento  plans  to  require  not only  basic process information,  but  regular
updating of inventory, disposal, and other  relevant  records. In addition, generators
will be  required to  monitor and  report  to  the County  any unexpected  losses  of
material from any point in the process.

    For each facility, Santa Cruz  County  will  require comprehensive  mass-balance
environmental audits and  regular  reports.   The  Santa  Cruz  draft  ordinance  on
hazardous materials  is provided  in  Appendix K.  Parts V through VII of this ordinance
address  the  hazardous  materials  management  plan,  the  hazardous  materials
disclosure form, the  responsibilities  of generators, and inspections and records.  The
hazardous materials  management plan is to provide an audit that  will include:
     •  A complete list of hazardous materials that will be stored, produced, or used
        in production, assembly, and cleaning processes;
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    •   Diagrams  and   descriptions  of  all   hazardous  materials   flow-through
        processes, waste generation, and treatment; and

    •   Estimates of the  type  and volume of  hazardous materials   that  will  be
        incorporated into final products, discharged into the sewer, released into the
        air, or transformed into hazardous wastes (Santa Cruz  draft ordinance).
    Both  counties  hope that  the  result  of requiring this information  will  be

substantial minimization of waste from the generators.


Observations:
    •   Requiring companies to manage information about hazardous materials with
        more precision than would  otherwise  happen could make companies more
        aware of  inefficient  use  of raw  materials.  It could lead to  efforts  by
        generators to reduce these material losses — especially where the materials
        have significant value.

    •   Tracking  actual disposition  of  all  pollutants  and wastes  into  the  various
        media encourages  attention to  the  overall  environmental  impacts of  a
        particular  manufacturing process, rather than isolated consideration  of each
        separate impact.

    •   Since companies will  be  aware  that regulatory agencies will be reviewing
        their disposal and discharge  records, they are  likely to be more careful in
        management of wastes in order to avoid regulatory problems.

    •   Regulatory agencies would be able  to gain a better grasp of where  an area
        faced environmental hazards, or  where  a  facility appeared  to have material
        losses that were not accounted for. For sources with enormous quantities of
        materials  throughputs, however, the  benefit  would  be  lessened.   In such
        cases, minute inaccuracies in percentage estimates and measurements could
        result in  substantial  variations in unaccounted for materials.

    •   Regulatory agencies could  also more effectively project disposal,  treatment,
        and recycling facility capacity requirements.

    •   A single  comprehensive data  collection of this kind, such as that carried  out
        by New Jersey, would be a  massive effort at the Federal  level. For  EPA to
        gather  information  with  the  frequency  proposed   by   the  counties  in
        California  is probably not  feasible.

    •   Enormous resistance could be predicted from industry  to  any collection  of
        this   kind  of  information, including likely  challenges as  to  whether  this
        extensive a collection of  information is  really  necessary to carry  out  the
        purposes of TSCA,  or whether it might be prohibited  under the  Paperwork
        Reduction  Act.
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    •  Such  information could provide  both  technical assistance programs and
       regulatory agencies with the kind of information needed  to  enhance their
       efforts.   Technical  assistance  programs,  for  example,  might  gain  more
       awareness of how  best  to  target their  efforts  to achieve  maximum waste
       reduction  in a  State.   A  large proportion of  the  information  gathered,
       however, might not be usable because of  confidentiality concerns.

    •  Rather than initiating  a Federal program, EPA  could work with State and
       local  governments to  determine to  what  extent  the  gathering of such
       information by those agencies might be  useful, and how such programs could
       be  most effectively designed to meet particular State or  local needs.   If,
       eventually, a significant proportion of State  and local governments  decide
       that such information is of value,  industry might prefer  standardized data
       gathering at the national  level.  Standardization, however, still  might not
       meet State- and county-specific needs.
8.6.2      Use of Permits to Limit  Amount of  Waste  That Can Be Land Disposed,
          Incinerated, or Otherwise Disposed of or Treated per Generator
    This  is  a  variation  on  the  preceding  option ("Waste  Generation  Permit

Program"), and  many  of the  considerations  developed  there  also  apply  to  this

option.  It does not require permits for the generation of waste; rather, the  permits

would apply to the amount of waste that can be managed in  certain ways.  Thus,  the

generator is  free  to generate  any amount of  waste, but the limitations on waste

management  alternatives will force consideration of waste minimization measures.


    The  limitations on amounts of  waste  that  may be disposed by  any specific

method  would be on an annual  basis.  They could be  based  on some typical ratio of
waste types and volumes to production for typical processes.  It would be possible to
set an initial baseline  for the allocation, and then to shift  the allocation over time

from less desirable to  more desirable disposal alternatives,  as  well as  to  require
overall  reductions.  Such  a  waste management marketable permit system could
either supplement, or be used instead  of,  the waste  generation permit system in  the

previous  option.  It could also be used to supplement the land  bans  required under

HSWA, by  gradually reducing  the total  volumes of  wastes permitted  to be land

disposed.


    A  company  would be able  to  landfill (or incinerate, or otherwise  treat) its

permitted allotment in whatever time period it chose, so long as it did not  exceed
its  annual apportionment.  It would be possible to design such a  system either with

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strict limits, which would apply on a nontransferable basis to  each company,  or with

permits that  could  be sold or  traded  between  plants.  The primary  benefit of a
marketable  permit is  to  increase  flexibility  and avoid the  necessity  of  a  waiver

system for each facility with a slightly unusual waste management problem.


Observations;


    •  Such an approach, if implemented,  could be used to encourage substantial
       reductions in the production of unrecyclable waste.

    •  In principle, it would be possible  to allow a standard proportion  of each type
       of  waste  produced by a company to  be permitted for incineration, land
       disposal, or other treatment method.  But in  addition to the technical and
       administrative complexity  of such an approach, such a strictly proportional
       allocation   method  would  provide   little   or  no  incentive   for   waste
       minimization  at  the source. It  would,  however, encourage recycling of the
       wastes produced.

    •  Implementation of such limitations would allow allocation of waste disposal
       between allowable treatment and disposal  methods according to ratios and
       criteria determined to be most  acceptable on  either  a regional or national
       basis.

    •  If limitations  were implemented on a plant-specific basis  rather than on a
       regional basis, two problems could be avoided:

       -   There  would  be no problem  of new entrants, since  each  new  entrant
           would  automatically  receive its  own  proportional allotment of disposal
           allowances, depending on the  products  and processes involved.

       -   It  would not  be necessary to determine how  to  allocate the allowable
           total limits among facilities  at the outset of implementation, since each
           facility would receive an allocation based  on  its  past waste generation
           record, or on  the basis of the  type of facility.

    •  If permits were allocated on a geographical basis, all the equity difficulties
       related to  original distribution and  later entrants would arise.

    •  Even if  developed  on  a plant-specific basis,  however, there are significant
       informational and implementation problems:

       -   There  would  be enormous practical  difficulty, both administratively and
           technically, in  establishing  appropriate  allocations of  permits   for the
           various treatment/disposal alternatives for different types of generators.

       -   There  would  be substantial  questions, with respect  to  both equity and
           feasibility, in determining whether  to differentiate  allocation rates on
           the basis of  size, as  well as type,  of operation, in order to recognize
           scale efficiency problems both of unit operation size and company  size.
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    •  Instead of criteria based  on the  type  of facility, allocations for each waste
       management  or  disposal  method could be based on  past  waste generation
       records for each facility  (as in the  other  marketable permits option, 8.5.2),
       and  an arbitrary  division  of permits  among  the various waste management
       alternatives,  based on national objectives.   Trading of  permits  between
       facilities  (in a permit market) would  then be the method of reallocation to
       more closely  match  final allocation  to  actual  facility  needs.  This could
       create  some  initial  advantage  for facilities with a lower proportion of
       wastes to be landfilled.

    •  The  number of facilities for which permits would have to be  determined on a
       generator-by-generator basis  would  require a  substantial administrative
       effort.

    •  Some companies (especially smaller companies)  may be unable to meet the
       permit limitations.  If  implemented  with tradeable permits, the  system
       would be  flexible enough  to allow for such less efficient operations.  Still,
       finding permits for sale could  be difficult, since companies might decide to
       retain excess  permits until late in the  year to ensure that their own  wastes
       are  covered.  It may, therefore, be  necessary for EPA to decide whether to
       close  such less  efficient  facilities,  to  charge  a  fine   high  enough  to
       discourage  avoidable  noncompliance,  or   to  create  special  classes  of
       exemptions  for  certain  types  and  sizes  of  smaller   facilities.   The
       determination of  appropriate  exemptions or fines would require significant
       additional administrative  effort.

    •  Companies already  faced  with the  need   to  respond  to  the  disposal
       limitations imposed  in the  1984 amendments to  RCRA  are likely  to  find
       these additional, and  far more complex, limitations especially burdensome.

    •  Further  limitations  on waste disposal  could well  be  attractive  to  the
       concerned general public.  But  if tradeable permits are used, the general
       public might focus on the  license-to-pollute appearance  of  the  trades rather
       than on the inherent limitations provided for by the permits.

    •  The  cost  and complexity of  meeting these  requirements may discourage
       small quantity generators from compliance and lead to more illegal dumping.


8.6.3      Require Segregated Waste Streams for Potentially Recyclable Wastes


    This  option  would  ban the  mixing of  waste  streams  that are  potentially

recyclable.  EPA could decide when waste stream segregation  will be required on

the basis of the same kinds of technology  evaluations and economic  analyses that

are  currently   used  to  make  the   technology-based   performance   standard

determinations under the Clean  Air  and  Clean  Water  Acts.   Internal  or  onsite

recycling  potential could  be determined through industry  analyses; information on
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what  materials  could be  recycled offsite  could  be  developed  through  industry

analyses  and  data  obtained  through  waste exchanges.  While  such  a  regulatory

requirement might not specifically require recycling of the streams once they are

segregated, it would make recycling  more  feasible by resulting  in waste streams

that are  relatively uncontaminated (by virtue of not being a random mixture), and
thus  more  amenable to  subsequent  recovery.  In addition,  the  remaining (not

recycled) segregated waste streams  will often  be  easier and safer  to  treat and

dispose of than would combined waste streams.


    As discussed elsewhere  in this report,  there are a number of processes  where

the potential for recycling  would  be  substantial  if  appropriate  wastes   were

segregated. The following  are examples:
    •  In the production of inorganic pigments, segregation and reuse of some of
       the  wastewater streams are feasible.  Rinsewater from  equipment cleaning
       baths could be reused as process  water during subsequent batch productions
       of the same product.  "Strong acid" could be recovered and reused during
       production  of  titanium  dioxide  if  impurities such  as iron  were removed.
       While  much of  the  industry has  already  taken  steps to segregate  wastes
       (e.g.,  many   producers  of  cadmium  pigments   practice   wastewater
       segregation), significant additional reductions appear feasible.  An inhibiting
       factor is  the substantial investments already made in wastewater treatment
       facilities.   (See  Table  9-1  of  Appendix B-5   of  analysis  on  inorganic
       pigments.)

    •  In   metal   surface  finishing,  segregation  of  spent  bath  solution   from
       rinsewater makes the recycling of the spent bath solution more feasible.  In
       addition,  segregation  of  the  rinse  streams  from  the various  coating
       operations  makes  the  reclamation  of  metals   from  each  stream   more
       practicable, as  well as the recycle of  the streams themselves.  While there
       is currently some limited  use  of  segregation, greater application potential
       exists.  (See  Table  9-1   of  Appendix  B-6  of  analysis of  metal  surface
       finishing.)

    •  While disposal of containers and bags accounts for only  a small fraction  of
       the  total  waste  from  the  manufacture  of  organic dyes  and  pigments,
       segregation  of  bags  containing  toxic  materials  from those  containing
       nonhazardous substances, which  is  not  frequently  done,  would decrease
       substantially the total volume  of  hazardous waste from  this  portion  of the
       process.   (See Table  9-1  of Appendix  B-7 of analysis of organic dyes and
       pigments  manufacture.)

    •  In the manufacture of printed  circuit boards, segregation of  the chelated
       waste streams (from  catalyst application and electroless plating) from other
       metal-containing waste streams could prevent problems in precipitation and

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        recovery of the metals.  In spite of the general  application of segregation of
        hazardous  waste streams  within  the  industry,  separation of chelated waste
        streams generally is not done.  (See Sections 9.1.2, 9.2, 9.3, and Table 9-1 of
        Appendix B-II.)

        Further examples  of  current  or potential applications  of waste  stream
        segregation  may  be  found  in   the  analyses   of   paint   manufacturing
        (Appendix B-8),  petroleum  refining   (Appendix B-9),  printing   operations
        (Appendix B-12),  wood  preserving   (Appendix  B-18),   paint   application
        (Appendix B-21), and equipment cleaning (Appendix B-22).
    Some solvent recyclers contacted  for  this  study  noted that, although some

generators have improved their waste segregation efforts dramatically over the last

few years as disposal  costs have  increased, many other generators —  even fairly

large  and otherwise  sophisticated  ones — continue to do a poor job of  segregation.

A principal  problem  appears to be inadequate  training  of  those  responsible for the

final steps of waste disposal.


Observations:
    •   Requiring  segregation of  wastes could  lead  to  substantial increases  in the
        volumes of wastes available for recycling.  In  some cases, sensitivity to
        purity requirements may inhibit use  of recycled materials (see, for example,
        the  discussion in  the  sections  referred to above  on printed circuit  board
        manufacturing).

    •   Requiring  the segregation of wastes  would force generators to become more
        conscious of opportunities  for  recycling.  A  generator who  undertakes the
        engineering and personnel training costs necessary to ensure segregation will
        be much more interested in recouping costs and reducing disposal expenses
        by trying to recycle wastes whenever possible.

    •   Requiring  segregation  of wastes  could  facilitate  waste  exchange efforts
        (such as that  in Illinois) by expanding the market  for purchase  and sale of
        recyclable wastes.

    •   Even  after   a  segregated  waste  stream  has  been  determined   to  be
        "potentially recyclable," the recycling will depend  on  market, geographic,
        and  technical factors, which are subject to substantial variability.  In some
        cases, facilities and/or markets  for recycling may be unavailable, while the
        costs of having segregated the waste  streams  may be substantial.

    •   Implementation and enforcement may require substantial resources.
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        New prohibitions on land disposal and  dramatically  increased  costs  for  all
        forms  of  disposal,  coupled with substantial efforts  to increase industry
        awareness of recycling  possibilities, may provide adequate information  and
        incentive  for  waste  stream segregation  without requiring  such  action  by
        regulation.
8.6,4      Require Technical Audits to Identify Waste Reduction Potential

    Firms could  be  required to carry out technical audits to identify possibilities for
reduction and/or recycling  of wastes.  Information from such audits could  be made
available  to  EPA to determine whether generators are  doing all  that is possible to
minimize  wastes.  Alternatively,  firms might  simply  have  to  meet  the auditing
requirement,  with  the  information retained for their own use, on the  assumption
that identification of opportunities for  waste  reduction  (and elimination of product
and/or raw material losses) would  provide sufficient incentive for the firms to take
corrective action.

    EPA  has  chosen a  voluntary approach to  environmental  auditing in  its interim
guidance  (50  FR 46504,   November  8,  1985):   "Because environmental  auditing
systems have been widely adopted on  a voluntary basis in  the past,  and because audit
quality  depends  to  a  large degree upon genuine  management  commitment  to  the
program and its objectives,  auditing should remain a  voluntary activity."  A possible
exception  to  this  voluntary  approach  would  be in  enforcement actions "where
auditing could provide a remedy for identified  problems and reduce the  likelihood of
similar problems  recurring in the future."

    In addition, the Agency states in the interim  guidance that it generally will not
request reports  on  audits  that  firms   carry  out.  "EPA  believes routine  Agency
requests  for audit reports  could inhibit  auditing in the long run, decreasing both the
quantity  and  quality of audits  conducted."  On the other hand,  the Agency  may
request reports "on a  case-by-case  basis where  [it] determines  it needs  an audit
report, or relevant portions of a report, to accomplish a statutory mission...."

    Although  the required  audit  option  is not  entirely in  keeping   with  EPA's
emphasis  on  voluntary  audits, its scope is limited to an  analysis of available waste
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minimization  alternatives,  rather  than  the  full  gamut  of  activities  normally

incorporated in an environmental auditing program.


Observations:
    •   Requiring  such  limited  purpose and  specific environmental audits would
        increase  the attention  of  generators  to  the possibility  of  reducing  or
        recycling  waste  streams.   Whether,  without any  further requirements,
        facilities  would  take  action   on   the   waste  minimization  alternatives
        identified  would depend primarily on the economic benefits and costs of the
        alternatives.

    •   Environmental audits of the type required for this  option might provide  EPA
        with  more information  on the  use  of processes  and materials that would
        facilitate  reduction  or  recycling   of  hazardous  waste.   But  requiring
        technical  audits  for  the specific purpose  of  identifying  the potential for
        waste reduction or recycling could be an  extremely cost- and time-intensive
        way to meet this objective.

    •   If the information gained from such audits  were to be used for enforcement
        purposes rather than as a confidential internal management tool, it seems
        unlikely that generators  concerned  about legal liability would be hesitant to
        develop and use  the  audit  as  a real management  tool.   There  would  be
        considerable  fear, dependent on the treatment of proprietary  information,
        that such an audit requirement might effectively confiscate trade secrets.
8.6.5      Ban the Landfilling,  Treatment, or Incineration of Potentially Recyclable
          Wastes
     Under HSWA, specific hazardous wastes are  banned from landfills, based on the
threat to human health and the environment that continued use  of  such disposal
practices would pose.  The availability of alternative  methods of waste management
may be taken into account to a limited extent.  This option expands the principle of
banning  inappropriate  disposal of wastes by prohibiting the disposal, either through

landfilling or other methods of disposal, of any  waste  that is potentially recyclable.

A  similar program is in place in California, and a related requirement is planned in

Illinois.  Under the California hazardous waste regulations, there is a  list  of wastes

deemed  to  be recyclable.   A generator  who  does not  recycle such wastes must

provide justification for the choice  of waste management method.

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    The implementing regulation would be predicated on the  development of a list

of waste materials that are recyclable.  Like the California rule, this regulation
would  allow  an  appeal  procedure for generators  who  demonstrate that  recycling

would be technically or economically infeasible.


Observations:
    •   One  of  the major  problems  to  be resolved to  make  such  a requirement
        workable is the development of a  market for recycled materials equal  to the
        supply  that could  be created. One possible  factor  in  the development of
        such  a market  could be the expansion of  the current waste exchange system
        to  include  larger segments of the  private secondary materials market, and
        the  development   of   the   capability   for   improved   efficiency   and
        responsiveness by  waste  exchanges (see discussion of waste exchanges,
        Section 4.3.2).

    •   If EPA could readily identify appropriate industries and  waste streams, this
        approach would  have  the potential  for  substantially  reducing disposal of
        wastes.  But recyclability  of  nominally  similar waste  streams  may  differ
        because of variations in  industrial processes and waste  stream components,
        and such identification may be difficult.

    •   Implementation may be difficult,  even for a limited program.  California has
        made very  little  use   of  the  mechanism  requesting  justification  from
        generators for  failure to  recycle  wastes  considered recyclable by the  State.
        The  review  of manifests  to  identify such opportunities has ceased to be
        actively  pursued.  More  detailed  examination  of  California's  recycling
        program would be in order before  deciding to adopt  this regulatory approach.
8.7       Economic Incentives


8.7.1      Development of Information and Technology Transfer Network


    EPA could undertake nonregulatory programs to assist in the development and

exchange  of  information on waste  reduction and recycling and to provide  technical

assistance  to  generators  on   how   best  to  realize  waste   reduction   goals.
Alternatively, or in  addition, EPA could  play an increased  role in  facilitating the

development  of State programs through provision of  technical assistance, funding,

and/or  central  coordination.   For  funding  and  technical   assistance  for  State

programs, the question to be considered  would  be  the extent to which increased

support would achieve useful waste minimization results, since EPA already provides
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some  support for  specific State technical assistance  efforts.  Providing  a  central
source  of   information  for   technical  assistance,  including   coordination  and
dissemination of the results  of  various State activities, could involve a significantly
expanded EPA effort with respect both to role and resources.

    Several  States  have  already developed a variety of information exchange and
technology transfer programs  to encourage and  educate generators —  especially
smaller  generators —  to  take  the steps  necessary  for  greater recycling and
minimization of waste generation.  At  present, the  most extensive  State effort is
North  Carolina's   Pollution  Prevention  Pays   program.   (See   Section 7.4  for
descriptions of  general State programs;  Appendix J-8  contains descriptions of North
Carolina's program.)

Information Exchange

    To facilitate   the exchange of  information, a  central  clearinghouse could  be
organized by EPA  to track all available  information on source reduction, reuse, and
recycling.  In addition, it would include successful  results and examples produced
through the  on-going  State technical  assistance  programs.  A  central  library  of
information and an  inquiry  center could be maintained, and the information could be
accessed  directly   by  State agencies,   generators,  or  the  public.  Several  State
agencies (e.g., New York,  Illinois) are  currently developing information centers of
their  own  for  use  by  generators in  the  State.  The  center could  facilitate  State
efforts and make  them more cost-effective.  Information developed and gathered by
the  center  also  could   be actively  disseminated   through agency  publications,
seminars,  direct   mailings,   local  educational  programs,  and  the  media,  in
coordination with State public education efforts.

    To increase the awareness of  the  availability   of  such information, and  the
cost-effectiveness of waste  minimization for generators,  EPA  could develop (or
assist  the  States  in developing)  mass  media advertising,  contests, or awards  to
provide recognition and  financial reward for  waste  minimization achievements,  and
mailings of information  likely  to be  of specific interest  directly to the generators.

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If any of these efforts were to be done on a national basis (e.g., media), tag lines in
each State  with technical assistance  programs could identify the appropriate State
contacts.

    For these efforts to be genuinely effective, the information center could not be
passive.   It  would  need  to  have  a  follow-up capacity  to  provide assistance in
interpreting  and utilizing  the  information  and  to  link  generators making  such
inquiries to  the technical assistance programs to the appropriate State offices.

    Numerous States,  including  Massachusetts,  New York,  North Carolina,  and
Pennsylvania, currently operate programs with substantial informational  components
(see Appendix J, Sections J.4, J.7, J.8, and J.9).  Massachusetts, for example, has
held several conferences and  seminars directed at providing  information that would
lead to  technology transfer on waste  minimization.  New  York's Environmental
Facilities Corporation will perform information searches  for generators through  its
extensive data base on  hazardous  waste; the corporation also publishes a quarterly
newsletter.  There is substantial diversity  in the range of  services currently offered
by various States.

Technical Assistance Programs

    EPA could  increase  funding for  State  technical assistance programs.  It could
also provide  an information center  that  could track  the  variety   of  efforts
undertaken  in such  State programs, evaluate the success of those diverse efforts,
and provide some analysis of  the factors  contributing to  success  or lack of it.  In
addition,  EPA  could rapidly  disseminate  among  States  the  technical  information
developed through each of these programs, thus increasing the cost-effectiveness of
individual State efforts.

    Several  States  have developed direct technical  assistance programs,  most  of
them recently.  These technical assistance programs involve  both  direct work  with
individual generators  to assist them  in  determining how best to  achieve  waste
minimization within their own facilities, and more generic efforts to find workable
technological  alternatives to  advance  waste minimization for the  more important
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industrial groupings within the State.  The technical assistance component of North
Carolina's Pollution Prevention Pays program involves technical advice provided by
phone or during onslte visits to plants.  Comprehensive plant audits often  take as
much as a  week, and review  possibilities  for changes  in production  materials,
process  modifications, waste stream segregation, and greater recycling and reuse of
waste materials (either  by the plant itself  or through sales  to other  facilities).
While the officials representing the North  Carolina program cannot  make specific
recommendations, they do review with the generator the  various  options  and their
economic implications, including  the  costs  and payback periods of  purchasing any
necessary capital  equipment.  They can  also assist  in  finding  consulting  engineers
who  can  help plan  and  manage   waste  minimization technical  changes  for the
generator.

     Several other States have begun programs with similar elements.  In Minnesota,
the  State hires summer engineering interns who spend up  to half of their time for
ten  weeks  at an  individual  facility, assisting  the  generator  in  managing the
identification and implementation of waste  reduction alternatives and technologies.
In still other States,  technical assistance programs are managed  through university
centers   such as  those  of  the  Georgia  Institute of Technology  and  Penn 'State
University.  Many  of these State programs receive at least partial funding from EPA.

Research and Development  Linked  to  Informational and Technical  Assistance
Programs

     EPA could expand funding  of research and development efforts  linked to State
technical assistance  programs. It  could  also,  additionally or alternatively,  provide
coordination between on-going State efforts.  There are numerous possible elements
to such research and development  components.

     Illinois provides  one  example  of  a  State R&D effort. It is starting  its own
research and development  into waste minimization  technologies  and alternatives
that might be used by generators in the State.  This effort will be funded by a tax on
land  disposal  of  wastes.   R&D  elements   in  some    States   are   primarily
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university-based,   often   partially  Federally-funded.   In  Illinois,   there   are

university-based  R&D efforts at the University of Illinois and the Illinois Institute of
Technology.


    Some  States  provide  incentives to  companies to  carry out  development  or
implementation   of  new  or  innovative  technologies  in their  own facilities.   In

Minnesota, generators or groups of  generators may receive  up  to $30,000  from  the

State for new  applications of existing technologies for waste minimization, or for

research on untried methods.  In North Carolina, the State will provide  matching

grants of up  to $5,000 for new implementations of waste reduction technology; while

these grants  are  primarily limited  to small  businesses, they are also available  for

larger companies to fund clearly transferable innovations.


Observations:
    •   While  there  is little hard evidence  available, many  believe that the initial
        impact of the various ingredients of State technical assistance programs has
        been substantial  and positive, especially for small businesses.  It is difficult,
        however, to  assess the impact and evaluate the cost-benefit ratio for such
        programs,  or to  ascertain  whether costs are  high  or  low  relative to the
        reductions achieved, particularly  for the  labor-intensive direct  engineering
        assistance programs.  Meaningful  data may be difficult to generate until the
        State programs have a longer operating history.

    •   The savings possible through waste minimization are not always apparent to
        plant  managers,   but  programs of  this kind  can  make  them  aware of the
        benefits of reducing, reusing, and recycling their wastes.

    •   Even though  such  programs may be extremely  cost-effective, start-up funds
        may be hard  to come by, especially at the  Federal level.

    •   Creating central  information systems  accessible to generators at the State
        level lowers  the costs and  increases the incentives for those  generators who
        lack  the engineering  expertise  or  access  to  information  to  investigate
        alternative technology  and management approaches to waste reduction  and
        recycling.  Even  technical assistance in the form of referrals to consultants
        can help to reduce waste and industry costs.

    •   Creating a central information exchange at the  Federal  level would provide
        a means of  facilitating the development of State information centers at the
        lowest  overall cost, and  expedite the  rapid  dissemination  of information
        developed through technical  assistance and research  programs in one State
        to other States.
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    •  Provision of  engineering expertise in waste reduction by the States, whether
       directly  or through university centers, fills a gap  in  expertise in industrial
       and chemical engineering, especially for smaller companies.

    •  Demonstration  grants  can assist in  proving  "paper"  technology,  and  are
       therefore an  extremely cost-effective form of R&D.

    •  Government  funding of R&D ensures public access.

    •  Matching grants for R&D spread the costs  for government and  make possible
       R&D projects by firms that would not otherwise undertake them.  But R&D
       expenditures still yield uncertain returns.

    •  The  publicity generated by such  programs makes  the  public aware of  the
       environmental   efforts  of  government,  and   simultaneously   encourages
       nonadversarial,  mutually beneficial contacts  between government agencies
       and companies in the  pursuit of environmental objectives.

    •  Winning  challenge grants and  other types  of awards is the favorable kind of
       publicity that many firms will seek.

    •  Processes differ to such an extent within  single industries that  the kind of
       generic  information  available  through clearinghouses or developed through
       demonstrations may have limited value.

    •  Confidentiality  of production  technology could  become  an issue,  since
       effective outside  assistance  requires  thorough knowledge of the  process.
       The  incentive for  firms to develop  innovations  over which  they  will  not
       retain proprietary control may  be  extremely limited.

    •  This may be  a difficult program for which to find  a  home within EPA.  The
       complexity of measuring results at the generator level may make it  difficult
       to define  and meet  clear performance standards.  This problem could be
       particularly  difficult  if EPA  were to undertake  as  its  major  role  the
       development of a  central  information exchange,  with  special emphasis on
       coordination  of information and efforts among State programs.
8.7.2    Establish Preferred Procurement Practices


    Government  procurement   practices   could  be   changed   to   encourage:

(1) additional  recycling  of  waste materials  in  certain  types  of   products,  and

(2) greater  emphasis  on waste  minimization in the  manufacture of  particular

products.


    Where  products  could  contain   specified  optimal  percentages  of  recycled

materials, one option  would be to specify required  levels; this  option  is the first

discussed  below.  Where  the objective  is to change materials management  practices

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in the manufacture of a product, even though the material characteristics  of the end
product are essentially indistinguishable, the problem  is more  complex;  this is the
second option discussed below.

Procurement Guidelines Based on Materials Content of Product

     The purpose  of a government  procurement program focused on  the  materials
content of products is to create additional demand for products made with relatively
less  harmful  materials,  or  for products  with  a  higher  proportion  of recycled
materials.   Such   an  effort  may   either  involve  direct  requirements  for  or
encouragement  of Federal  Government procurement  of  desirable  products (as
required  by  the  1984  RCRA  amendments  for   recycled paper), or  indirect
encouragement of changed buying patterns  by  State  and local  governments and/or
private  businesses (as in the "buy quiet" program).

     The most obvious places where  such a  policy could be effective would be where
the government itself is a high-volume buyer and could change the economics of the
marketplace strictly  through   its  own  behavior.   There  are  fewer such  areas,
however,  than  might be anticipated.  In the case  of  paper, for example,  direct
government procurement accounts for only two percent of paper  purchases.

     There  are   also   indirect  vehicles   for  influencing  markets  beyond  the
governmental  market.  In  the  case  of paper, for example, the State government
program in Maryland  requiring the purchase of increasingly large percentages of
recycled paper has had the effect, over  several years, of creating  enough demand
for recycled paper that it  is  no longer a high-priced specialty product for the State,
and now actually costs  the State slightly less  than  paper  made with virgin  stock.
This could lead gradually to  increased use of paper  from recycled stock  by private
industry in  the  State,  creating  increasing  cost reductions resulting  from better
economies of scale.

     Examples of  areas in which revised  procurement guidelines for product content
specifications  might be explored  are the more limited use of cadmium-plating  on
products that  do  not require its  material qualities, the substitution of high-impact
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rubber for chrome on  bumpers for government-fleet  automobiles,  the  purchase of

paints with less toxic fungicides  and mildewicides,  and the use  of less toxic wood
preservatives.


There are a number  of possible options for encouraging recycling or the use of  less

toxic materials (or  materials that leave  less toxic wastes after manufacture or
processing) through procurement policies. They include:
     1.   Direct  Federal  Government procurement guidelines or regulations, such as
         the   EPA   guidelines  recommending  purchase  of   cement  or  concrete
         containing fly ash, or as mandated by RCRA for paper (see Section 6002 of
         RCRA).

     2.   EPA  promotion of specific types  of  guidelines for use  by  State  and  local
         governments and/or private businesses,  as  in the "buy quiet" program.  In
         the case of the "buy quiet" program,  many local governments incorporated
         noise  standards into their procurement  operations, granting  points  in
         procurement  competitions for  quieter   machines,  or setting   minimal
         noise-reduction standards.

     3.   Establishment  of  an EPA  information center  for encouraging  changes in
         State, local, or private  procurement.  With respect to private procurement,
         this would be of use primarily where there would be a clear  cost-savings to
         business.

     4.   Development   of  a  cooperative  arrangement with  the  Department  of
         Defense, since DOD  has the largest  procurement operation of any single
         source  in  the  country.  EPA  might  work  with  DOD (perhaps formalized
         through a  Memorandum of Understanding)  to assist in identifying  both
         opportunities    for,  and    management   approaches   to   enhance   the
         effectiveness  of,  appropriate  modifications  in  selected  procurement
         standards on an ongoing  basis.
Observations:
    •   Where the Federal market  leverage is proportionately large, either in  total
        percentage of product purchases or on a  scale adequate to affect pricing,
        the  advantages  of  direct  Federal  procurement guidelines or  regulations
        could  be  substantial.   Direct  Federal procurement will  often not  be of
        adequate dimensions to change the market significantly, however.

    •   EPA promotion  of  guidelines  for  State   and  local governments  has  the
        advantage of potentially affecting decisions involving a larger percentage of
        purchases than those involving  the Federal Government alone.  The success
        of  the EPA  collaboration  with  State  and local  governments in  the "buy


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        quiet"  program illustrates the  potential.  Because of  the resource-intensive
        nature  of such an  education  and information effort,  it probably would be
        most fruitful  to  focus on materials where it  has been determined that a
        Federal procurement guideline  or  regulation is necessary,  or at least  for
        materials where the approach and objectives are readily understandable.

     •   Changes  in procurement practices  under which a single large buyer such as
        the  military  changed  its procurement   practices  to  encourage  waste
        minimization (for example, by changing military  specifications to allow  for
        the use of recycled solvents for operations and processes not  requiring pure
        virgin solvents) could have a significant impact on waste reduction  in some
        areas.

     •   It  will  often be  difficult  to  determine  (or to  achieve agreement among
        responsible parties) exactly what qualities  in a product are  necessary if the
        product  is  to  serve  its  function  safely  and effectively,  and  yet  that
        determination is  essential  for substitutions to be  feasible.   Some attempted
        substitutions of  alternative  platings  for  cadmium  on a  pilot  basis  on
        moderately sensitive uses have not been notably successful (see discussion of
        product substitution for electroplating,  Appendix 8-3).

     •   Cost savings  alone will  not  necessarily  persuade  private  businesses  to
        substitute less  toxic or recycled materials, even  if product quality  appears
        unchanged,  if  they fear  their  major commercial  customers   would  be
        concerned by any  alteration.
Procurement Guidelines Based on Process Used


     The procurement  guidelines to be  considered here  involve  a  more  difficult

problem than  those in the preceding section.  The objective is to create a preference

for  purchase  of  products  which,   though  essentially   identical   in  material

characteristics to a  competitor's  products,  are  manufactured  with  processes that

minimize the volume  and/or toxicity of wastes.  For example, a manufacturer could
produce a  product and practice waste  segregation at  its  facility.  Although  the
practice of waste segregation would not alter the quality of  the final  product being

manufactured, it  would contribute to  minimizing  wastes, and  thereby  qualify  the
manufacturer for favorable procurement consideration.


     Since  specifications  of products   for  procurement  usually focus   on  the

characteristics  of  the  product  and  not  the  processes  by   which  they  are

manufactured, there  might  be both  legal  and procedural  difficulty  in trying  to

incorporate  process  waste  minimization requirements directly  into  procurement
guidelines.

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    One of the qualifications  on  which procurement  for  such  products could  be
based  would be  a  voluntary  agreement  by the  manufacturer to  certify to  the
purchasing agency that a waste  minimization program has been  instituted  at  its
facility,  and that  this should be made a part of  the contract with the purchasing
agency.  The  certification  statement could  be   the  same  as that  required  on
manifests under HSWA,  and would certify that such a program  is instituted  to the
degree that is economically practicable. One major difference,  however, would  be
that the contract  would allow the purchasing agency  to  check to see that such a
program  were indeed being carried out.

    The  voluntary agreement to submit to the requirement of certification as part
of the purchasing contract would not  guarantee procurement.  It would only be one
of the factors to be weighed by the purchasing agency.  Cost and performance or
quality  criteria would still  be the most  critical factors.  In  a tight  competitive
market, products for which the  manufacturer submits to such a voluntary agreement
might have  an  advantage.  Also, since there  would be no legal requirement to make
such  an agreement, firms  that  do  not  participate  would  not  necessarily  be
eliminated from competition.

    In order for such a program to be effective,  however, there would need to be a
method to ensure that waste minimization was indeed instituted at  the facility.  One
approach would be an environmental audit conducted by the purchasing agency or by
auditors  hired   by  the  agency  for  all  applicable   purchasing  contracts.    The
installation  of  an auditing function would require  a substantial commitment of time
and resources  in an area in which few agencies  have experience.  Unless such a
function were already  instituted within an agency, it is unlikely  that many would be
willing to commit to such an investment.

    Such an auditing mechanism does exist  within DOD;  thus, this  option is more
viable for that agency  than  for those that  would  have  to  develop  the auditing
function.  The  Defense  Contract Administrative Services  Regions (DCASR),  which
reports to the  Defense Contract Audit Agency, performs  this auditing function  for
DOD.   Briefly, it  ensures   that  product  quality  control,  as  well   as  contract
conditions,  is  being met.   The audit  teams may receive training by  specialists,
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depending  on  the  nature  of  what  is  to be  examined.   Thus,  this option, if

implemented by DOD, could entail training  in environmental  auditing, with special
emphasis on waste minimization practices for the  particular industry being audited.


    This raises the  question  of  what  criteria  would be  used to judge whether a

practice qualifies as  waste  minimization.   As  mentioned  in Section  5.5.1,  the

legislative  history of  HSWA makes clear that EPA is not  to prescribe standards or

guidelines for waste  minimization.  On the other hand, it may be possible for EPA to

cooperate with  DOD in establishing guidance and standards.   Such  standards would

then be limited only  to those companies  voluntarily agreeing to a condition in their

contract requiring them to  certify that they have instituted a waste minimization

program.  Failure  to meet the  guidelines or standards would not result  in  any EPA

enforcement actions;  rather,  it would  remove  them from consideration   for  any

established special procurement consideration.


Observations:
    •   Initial targeting of products for such  a waste  minimization  procurement
        strategy would  be  most effective for products purchased in fairly substantial
        volumes,  and for which waste minimization practices are  well documented
        or studied.  For example,  the DOD (for whom this option appears to be most
        suited at this time) is  a large purchaser of printed circuit  boards, which  are
        purchased from various manufacturing contractors.  (See Appendix B-ll  for
        further information on printed circuit boards.)

    •   DOD's current auditing function, carried  out by  DCASR, is motivated by a
        concern  for product  quality and proper  contractual  management (pricing,
        hours, and  related issues).  The ultimate quality of the product would  be
        unaffected  by waste  minimization  practices.  At this time, the purchasing
        officer would  probably  not give  consideration  or  special  weighting  to
        manufacturers who voluntarily  agree to  submit  to  contractual agreements
        that  require them  to   certify  that  they  are  enlisting waste minimization
        practices.  There is the possibility,  however, that the various environmental
        channels within DOD  (e.g., Defense  Environmental  Leadership  Project,  the
        Defense  Logistics  Agency, and the environmental divisions of the services)
        may  be able  to promote  the  idea  to purchasing officers.  Since  DOD is
        developing  a waste   minimization  strategy (see Section   7.3.3  for  more
        information), part of that strategy could  include adoption of this option by
        purchasing  officers,  with cooperation between  the DCASR  and  EPA.  In
        particular, the Air  Force Systems Command (AFSC) currently is retaining a
        consulting  firm to  evaluate  the   operations  of  its  government-owned,
        contractor-operated   industrial  plants.   The   firm  is  to  evaluate   the

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       operations of  these   plants  and  to  recommend  alternatives  for  waste
       minimization.  The AFSC  anticipated initiating actions during  FY  1986 to
       implement study  recommendations (see Appendix I,  Briefing  Synopsis  of
       JLC).

    •  Because   this  option  is  based  on  voluntary  agreement  to  submit  to
       contractual requirements to  verify that  waste minimization is taking place,
       it  will be very difficult  to get the relevant  bureaucracy to incorporate such
       considerations  in  actual  procurement   decisions  without  the  force  of
       legislation.

    •  It  is not  clear how great the DOD market  share  may be for products with
       respect to whether this option would have any appreciable effect on industry
       practice.

    •  One  key  ingredient  to the  successful  operation  of  this option  is  the
       development of  waste minimization  guidelines and/or  standards  that  the
       auditors could  use. It is not clear to what extent they could be developed or
       accepted  by  industry.  If  guidance  is  developed  and  consideration  of
       voluntary agreements is included  in purchasing decisions, this could create a
       growing  incentive  over time for companies  that  compete in  the DOD
       marketplace  to adopt waste minimization practices.  The success of such a
       purchasing  program   may   increase  its  use  over   time   and  could   be
       implemented by agencies other than DOD.

    •  EPA may be able to  play a role  in developing this option. EPA's role might
       be  to  create  a model  for its implementation, and to  bring together  and
       encourage some  of the parties who could be most usefully involved in a pilot
       effort. EPA's involvement, however, is contingent upon the  degree to which
       it  agrees to  develop waste  minimization guidance.  It is not clear whether
       EPA's involvement in developing  such guidance may  be construed to be in
       opposition  to   the  intent  of  Congress in  its  requirements  for   waste
       minimization.  The legislative history indicates that EPA is not to  intrude in
       nor  interfere  with  the  production  process, and that  determinations  of
       technical and economical practicability of waste minimization practices are
       in the domain  of the generator, not EPA. Thus,  EPA's role  may be  subject
       to debate both within and outside  the Agency.


8.7.3   Develop Improved  Waste Marketing Capability  for Hazardous Wastes of the
       Military Services
    Included  in  the  enormous  volume  of  hazardous  wastes generated by  the

facilities  of the Department  of  Defense  (the  nation's  largest  hazardous  waste

generator) are a substantial proportion of wastes that could be reused or reclaimed.

While some of these wastes are currently recycled  both within and outside of the

services  (e.g., outdated  paints  from  the Norfolk  base are  bought and used in

substantial  quantities   by  Virginia,  Wisconsin,  and  other  State   and   local


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governments), the opportunities for  recycling could be substantially  expanded. (See

Section 7.3.3  for a description of DOD  waste minimization efforts  and  Appendix I.

For information on waste exchanges, see Section 4.3.2.)


    A central  DOD  waste exchange service would be  able  to expand the scope  of

recycling  by  DOD facilities, both by interfacing with the industrial markets (perhaps

working with  existing regional  waste exchanges) and  by expanding  the reuse and

reclamation of hazardous wastes  within the services.


    To facilitate the creation of such a waste exchange capability, and to provide

DOD  with the  technical and market information  available  to EPA,  DOD and EPA

could develop a memorandum of understanding under which the  Department and the

Agency would  work  together to  plan for and to  implement such a  waste exchange

capability. The waste exchange  service would be housed in the appropriate office  of

the Department of Defense.


Observations:
     •   Creating  such  an  exchange  could  open  substantial   new  markets   for
        recyclable hazardous wastes  from the military services,  and thereby reduce
        substantially the wastes sent  for disposal.

     •   By creating a  financial return  instead  of  a  loss  for  some  segment  of
        hazardous waste disposal, such an exchange might make  more acceptable to
        the Services a change (previously rejected both by the Services  and by  the
        Defense  Logistics  Agency)  under which the  costs  of  disposal  would  be
        allocated to the base of  origin for the waste, rather than being  provided  as a
        free  service by the Defense Reutilization and Marketing Service  (formerly
        the Defense Property Disposal Service).

     •   Such  an initiative  might contribute to efforts  to change DOD's procurement
        practices to include greater emphasis  on recyclable materials.

     •   For some industries and/or geographical  areas,  the  greater  availability  of
        reclaimable or reusable  materials might provide a lower  cost alternative to
        virgin materials.
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8.7.4      Non-Tax Financial Incentives

    Direct loans,  defrayal of loan  interest, loan guarantees, or bond issues could be
used to provide direct financial support to generators for installation of  equipment
for reducing or recycling hazardous  wastes.  The  effectiveness of such programs
could be  enhanced  by  Unking  them  with  informational  and  technical  assistance
programs.  (For discussion  of current State loan and bond programs, see Section
7.4.3.  Other  non-tax financial  incentives,  though  not  so generally available to
generators or specifically tailored to  include  equipment purchases, are the  awards
and grants provided as part of the technical  assistance programs.  See the summary
of State programs, Section 7.4, and the option (8.7.1) discussing such programs.)

    Given the  current  status of the  Federal budget, the  establishment of any new
loan programs  seems extremely  improbable.   Even  the  continued availability of
funding by  means  of  industrial  development  bonds is  uncertain in  current tax
legislation.  It would be possible, however, for  EPA  to assist the States in designing
effective  non-tax  financial assistance programs.  There is  a great deal of variety in
current State financial incentive programs, and EPA could  assist in  an informational
and analytic capacity in reviewing these State efforts and their results.

    Funds for  loans or  loan  guarantees for pollution control, waste  reduction, or
recycling  facilities could be  directly appropriated on  an annual basis, with receipts
from   repayments  returned  to  the  State   treasury.    Alternatively,  directly
appropriated funds could be repaid to a revolving fund, which would  be supplemented
with further direct  appropriations only as necessary.  Several States, however, have
linked   together   bond  and  loan  programs,   eliminating the  need   for   direct
appropriations  (though  the nature  of bond-financed programs in the  future  may
depend on revisions  made in the  Federal  tax  code).  New York's  Environmental
Facilities  Corporation,  for  example, uses  funds  raised  from  special   obligation
revenue bonds to provide loans for up to 40 years for investment in  pollution  control
and  waste  minimization  equipment,  with  no  ceiling on the  amount. Missouri
provides greater  access to the  loan market for  such projects through  a revolving
fund that is used as collateral for the purchase of loan insurance (increasing  both
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availability  of  funds and attractiveness of interest rates).  Such  a  revolving  fund
provides very  high  leverage with  limited  funds.  Availability of funds from  such

programs is often limited to small businesses.


Observations:
    •   Availability  of loans, or  reduced interest  on  loans, can  be a factor in  the
        affordability of  new  equipment  for many small generators. It is not clear
        exactly, however,  what the impact of such programs  is on  waste reduction
        activities, since  other factors such as productivity  and product-specification
        requirements are major influences on investment decisions

    •   An important factor in designing  such a program is the criteria  for deciding
        which projects are  eligible.  One way would be to provide eligibility  only for
        investments  undertaken  strictly  in  order to reduce  or  recycle  wastes.
        Another  option  would  be  to  provide  financial  support  as  well  to  any
        investment  that will result  in some waste reduction  or  reuse, even  if its
        main purpose is  productivity- or quality-related.  If access to funds is to be
        limited  to  single-purpose  investments  in waste   minimization,  eligibility
        determinations  may become  a  major obstacle, and ancillary waste reduction
        opportunities might be lost.  A  broad  interpretation  of   purpose, however,
        might dilute such  a program's objective  by providing loans for  investments
        in production-related equipment with limited environmental  benefits.

    •   To the extent that eligibility determination must be made, the  demands on
        technical staff for verification of eligibility could be substantial.

    •   To  be most effective,  loan  programs  should be  an  integral part of  a
        comprehensive information  and  technical assistance  program.   Otherwise,
        generators  may  not take advantage of  the programs  because  they  are  not
        aware of them.

    •   The  practices of  the larger generators  are  unlikely  to  be  significantly
        affected  by  most  State loan programs,  since the financial  benefits  are
        relatively small.

    •   EPA could serve a  useful  role for the States by providing a central source of
        information  on  the design of various State loan programs, and  by analyzing
        their effect.
8.7.5    Tax Incentives


    There are  a number of tax and tax-credit options, in addition to the waste-end

tax discussed in 8.7.6, that could provide  economic incentives for  waste generating

firms to implement  source reduction measures, or reduce incentives for use of virgin

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materials in preference to equivalent recycled  materials.  (For discussion  of  State

fee and tax incentives, see Section  7.4.2.)  While some of these (such as elimination

of depletion credits for raw materials) could be enacted  at  the Federal level,  the

most  feasible  role for EPA might be to provide analytic support and review of  State
efforts.


    •  Waste use taxes:   These are  intended  to induce water conservation, and
        could  lead  to  reductions  in water  use,  and corresponding reductions  in
        generation  of large-volume  aqueous waste  streams  (such  as  corrosive
        characteristic wastes (D002)).  Such taxes  are common at the State or local
        level,  although the  rates   for  industrial  users  may  not  be  designed  to
        discourage use and encourage alternative waste control strategies.

    •  Capital  investment  tax  credits  and  deductions:   Tax credits  could  be
        targeted on  investments  in equipment used to reduce or recycle wastes.  In
        Minnesota,  for example, there  is a  10 percent credit for the net cost  of
        waste  processing  equipment  and a  5 percent credit  for  the  net cost  of
        pollution  control   equipment.   In  Wisconsin,  the  cost  of investment  in
        pollution treatment equipment is 100 percent deductible.

    •  Tax exemptions:  Exemptions from  taxes that would  normally  be  levied on
        capital equipment could be provided for equipment used to reduce or recycle
        wastes.  A  strategy  of this kind,  currently used in  Wisconsin, provides an
        exemption from property taxes for equipment  used to treat  industrial wastes
        that would  otherwise contaminate  surface waters.   Minnesota  provides an
        exemption  from  sales   taxes  for  waste  processing or  pollution control
        equipment.

    •  Accelerated depreciation: Many States  allow  faster depreciation  on capital
        equipment for pollution  control or waste  minimization than on most other
        classes of capital  equipment. The depreciation is taken as a  deduction.

    •  Tax credits  for waste  reduction:  Credits against various taxes  could  be
        provided for measured declines in  waste generation.  Such credits would not
        be linked to capital investments in equipment.  A schedule of credits tied  to
        specific quantities of waste reduction  would have to be developed.

    •  Elimination  of special  tax  benefits  for raw  materials:  Reduction  or
        elimination  of  the  various  depletion  allowances  and  other  special  tax
        benefits for  production of raw materials would make reclamation and reuse
        of  materials  from  waste   streams  more   financially  competitive   and
        attractive.
    Combinations of  tax incentives may  be  useful  to  provide  the  necessary

encouragement to generators  to invest in waste minimization.  As noted above, for

example, Minnesota provides both investment tax credits and  exemptions from the
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sales tax for investments in  waste processing or pollution control equipment, while

Wisconsin  offers  tax  deductions  and an  exemption  from the  property tax  for

equipment  to treat industrial wastes.


Observations:
    •   Different  tax  incentives, or combinations of  tax  incentives, could affect
        different aspects of generator activity.  The water use tax, for  example, is
        obviously more useful  for aqueous than for nonaqueous wastes.

    •   Tax incentives should  not  be looked at in  isolation.  They are  part of an
        overall system of incentives, which include  non-tax financial incentives and
        technical and informational assistance.

    •   The benefits of any tax incentive have to be  substantial enough for people to
        participate,   or   to  encourage   them   to  overcome  other  obstacles  to
        investments  in waste  minimization reduction.  In California, a  tax credit
        was a significant factor in enabling  metal finishers to meet pretreatment
        standards  (personal   communication   with   Mr.  Bill  Wiggins,   President,
        Automation  Plating, Glendale, Calif., September 30, 1985).  In  Oregon, on
        the other  hand,  very  few firms have  taken advantage of  a  tax credit  for
        investment in reclamation  equipment, which  deducts  from  the credit any
        financial return  gained from the investment.  Its unpopularity is due to the
        fact that many resource  recovery  investments result  either in a very limited
        net loss  or  in  a net profit (personal communication  with Bob  Brown,
        Hazardous and Solid Waste Division, Oregon Dept. of  Environmental Quality,
        July 12, 1985).  An  IRS ruling provided  that  special depreciation  rules  for
        pollution control equipment  (which have now been rescinded) could  only be
        used if  the equipment had  no  benefit  other  than pollution  control.  This
        provision virtually eliminated the utility of the  benefit.

    •   Restrictions on  tax benefits that  limit their use to investment  with no net
        returns may not adequately take  into account  the  cash  flow limitations of
        smaller  generators.   Even  though  a  resource  recovery  investment  may
        eventually be  fully recovered, a tax incentive  may be  required  to  make  it
        feasible for the generator to make  the initial investment.

    •   It  would  be  advantageous  to   link  tax   benefits  with   a  technical  and
        informational assistance  program,  so that generators are both aware of the
        possible waste reduction  and recycling investments they could make, and of
        the tax benefits  to make  them more feasible.

    •   Accelerated depreciation can provide a major benefit to large corporations,
        which can take full benefit  of the tax deduction involved,  though it may be
        of  limited value  to smaller firms.

    •   While  credits  for actually-measured  waste reduction have the  benefit of
        being  targeted  on actual  accomplishments,  determining  the baseline and
        actual level of reductions is  likely to prove complex.

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8.7.6      Waste-End Tax

    A  waste-end  tax  is  a tax assessed  at  some  point in  the  management of
hazardous  waste.   In  addition to  any waste-end  tax passed by  Congress  during
amendments  to  the Comprehensive  Environmental  Response,  Compensation  and
Liability Act, EPA  could provide a service to the States by providing information on
alternative waste-end  tax structures, and an on-going  analysis  of the effects of
these  alternatives  on  waste  reduction, reuse,  and  recycling, as well as on State
revenues (for a discussion of current State waste-end taxes, see Section 7.4.2).  This
would provide a  better information base for  the States to use in  making decisions in
light of their own objectives.

    Depending on  the  type   of   waste-end tax,  and  the  point  in  the  waste
management  system where it is  applied, a  waste-end  tax  can  be used to  create
incentives for reduction in waste generation and/or for preferred  waste  management
practices.

    There  are three basic  points in the hazardous waste management chain where a
waste-end tax can be assessed. These are  the point  of hazardous waste generation,
the  act  of   hazardous  waste  transport,  and  the  point  of  hazardous  waste
management.  A generator  tax is a  tax on companies  that produce hazardous  waste.
If  "generator" is defined by the RCRA system, certain exemptions would apply, the
most  notable being the small quantity exemption.   A  transporter tax would be
assessed on  those  who move  hazardous  waste  from  the point  of generation  to a
facility or  from  a storage  treatment  facility to  a disposal facility.  A  facility tax
would  apply  to storage, treatment, and disposal facilities.  If the  RCRA system is
used,  certain  facilities may be exempt from a facility  tax (e.g.,  generators  that
store  hazardous  waste  for  fewer than 90 days, or  generators that use pretreatment
facilities prior to discharge to  a POTW).

    There  are a number  of options  in the type of waste-end  tax or  fee  that  is
assessed.  These  can be broken down into the following  categories of  taxes: a flat
rate,  a  rate graded by type of management,  a rate graded by degree of hazard, a
surcharge or  tipping fee, a permit or manifest fee, or any combination of the above.
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     1.   Flat rate.  This is a flat tax on a per-ton, per-gallon, or per-barrel basis.

     2.   Rate  graded  by  type  of management.  This  is  a tax  rate that  varies
         depending  on  the type of facility to which the  waste will  be  sent.  For
         example, a graded tax rate  might place  a  higher rate on  land  disposal
         facilities  and  a  lower rate  on  resource  recovery facilities.   New  York
         charges $12/ton for land disposal and only $2/ton for onsite incineration
         (GAD   1984).   In  other instances, a  State might  charge for land  disposal
         exclusively and  levy no  fee  on other forms  of  treatment  or disposal.
         Missouri,  for  example,  levies  a $25/ton  fee on  wastes  that are land
         disposed.  It   is   designed  to  encourage/discourage  certain  forms  of
         hazardous  waste management.

     3.   Rate  graded by degree of hazard.  The tax rate  is based on the hazardous
         characteristics of the  waste (usually toxicity).  The  more  hazardous the
         waste, the higher the tax.

     4.   Surcharge/tipping  fee.   The   tax  is  a surcharge  based on  the value  of
         managing the  waste. In some  States, such as Ohio,  facilities act as "an
         agent  of the  State," collecting a surcharge on all waste received at the
         facility and paying it to the State. The rate  in  Ohio is  6  percent of the
         charge paid to  the facility for hazardous waste disposal.

     5.   Permit or  manifest fee.  A fee is charged to an application  for a hazardous
         waste  permit or is assessed on  the basis of the manifests required by  RCRA.
    It would  also be  possible  to charge  a tax  based  on the  total  volume, or

toxicity-weighted volume,  of  all  hazardous  material  inputs  that  are  neither

incorporated in the product nor used up in a chemical reaction (i.e., on all materials

discharged,  emitted, or disposed  of).  A credit against  the tax  could be given for
recycled materials.


    Finally,  any combination  of  these  taxes  could  be  used.  The State  of
Washington, for example, has risk classes for both  generators and treatment/disposal
facilities based on the type of waste management/disposal practiced, and the degree
of hazard of the waste streams generated or managed.


    As of December  1983,  34 States had set up their own "Superfunds" to  address

problems related to emergency cleanup and abandoned sites.  Of  these States, 23

adopted waste-end taxes in some form, 8  utilized flat  rates, 7 graded  the  fee by

type of  hazardous waste management  activity, and 7 used  revenues from permit or

transfer  fees.  Grading by  degree-of-hazard and surcharges or tipping fees were
only utilized in 4  States each.

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    In all cases, revenue was the primary goal of the  funding mechanism.  Revenue

needs  are  usually estimated  and the  tax  rates developed to  achieve that goal.

Incentives, however, are built into some systems, particularly those  that grade their

taxes based on waste management type.  Use of the RCRA definitions for generator

taxes also works to create incentives for recycling through  RCRA's exemptions for

this practice.


    With  respect to revenue generation as  the  goal of this  type of tax, CBO (1985)

has stated that such a goal is in conflict with  that of waste  reduction.  (See Section

7.A.2).  They  suggest  elimination of  this conflict  if proceeds  from the tax were

placed in a fund dedicated to  grants for projects that promote  waste minimization.

Such a fund would need to be only  as  large as the demand for such  projects.  As the

projects were  implemented, wastes would decrease and the fund would diminish.


Observations:
    •   A waste-end tax imposes the cost of cleaning up spills and abandoned  sites
        on  the industry that produces and/or manages this hazardous  waste.  It may
        also  create  economic incentives to  encourage  proper   hazardous  waste
        management.  At exactly  what level  this incentive  works' is less certain.
        One study (Haas 1984) noted that the difference  in cost/ton for  the  lowest
        cost  disposal alternative (landfill or impoundment) and the next best for a
        variety of different wastes  ranged from as little  as $5.89/ton (for corrosive
        lead  wastes using  vacuum filtration)  to as  much  as $1,075.52/ton (for
        incineration  of small volumes of formaldehyde).  It concluded that shifts in
        waste management  practices because  of  fixed waste-end  taxes  would  vary
        across industry classes and types of waste streams.

    •   A  generator's  tax will cover  a  comparatively  large population  and  will
        establish  economic incentives discouraging waste generation.  A transfer tax
        (although  adding  to  the  cost  of  hazardous   waste  management)  will
        discourage the transport of  hazardous waste.

    •   Taxes  on facilities   will  discourage  certain  types  of  hazardous waste
        management.  For example, a  degree-of-hazard tax  on disposal  facilities
        will usually  be designed  to discourage land disposal of highly toxic wastes.
        Lower taxes or tax incentives can also be  used to encourage  certain forms
        of  hazardous waste management (recycling, treatment, incineration).

    •   In  theory, the tax schedule could be set high enough to cause considerable
        waste minimization.   In practice, States  are unwilling to  agree to such  a
        system because the revenue  is needed  for their "Superfund" activities.  A
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        successful  waste  minimization/recycling  program  jeopardizes  funding  for
        these other activities.  (If  Congress were to  relax  the Federal preemption
        language of CERCLA during reauthorization, States might be able to move
        to  feedstock  taxes and  use  waste-end  taxes solely  as  an  incentive
        mechanism.)
        Using the waste-end tax as a revenue generator may result in conflict with
        the goal of reducing wastes for  reasons  discussed  above.  CBO's proposal
        (CBO 1985) to use the tax  to  fund  a  grant program that  promotes  waste
        minimization  may  alleviate the  conflict in goals  and  may  also serve to
        combine several incentive programs productively.
8.7.7     Rating Outstanding Recycling Facility Performance

     One possible  approach to strengthening  both  the  marketability and insurability
of offsite recycling operations might be to develop a voluntary  certification system
for recyclers, through a consensus process involving representatives of all concerned
parties (recyclers, generators, insurers,  and governmental and independent  experts).
This  would  involve  the creation  of  a  rating committee  that  would issue to  a
recycling  firm,   meeting  an  extremely  high  standard  of   management  and
performance, a certification of the high  quality of its operations.

     Such a certification could be advantageous to  the firm's marketing efforts  by
alleviating some of the uncertainty faced by generators trying to determine whether
to  use  an  offsite  recycler.  It  might  also  be  of  benefit to  recyclers  seeking
environmental liability insurance in the current shrinking insurance market.

     The  appropriate  vehicle for determining  the basis for such certification would
be  an organization  that is involved  in  voluntary standard-setting, such  as ASTM
(formerly called the  American  Society of Testing and Materials) or the National Fire
Protection Association.  ASTM, for example,  is a nonprofit organization specializing
in  the  development  of  voluntary  consensus  technical  standards,  test  methods,
service  methods,  and performance  standards. Membership  on  ASTM's  technical
committees (over  150) and subcommittees is voluntary,  but  all  committees  must
have  at  least as many representatives  of nonproducer as of producer interests.  A
clear majority of participants  must approve  the standard, and  an effort is always
made to consider and accommodate the concerns of all  participants.
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     The consensus standards  established through such a process  would be voluntary
in operation (although  the market pressures  for a recycler to  meet such standards,
once developed, would be substantial).   Actual determinations of whether individual
recyclers  meet  the  standards could  be made by  approved  third-party  auditors.
EPA's  role  would  be   to   help   initiate   the  process  with  an  appropriate
standard-setting  organization,  to  assist in  exploring  whether adequate interest
exists  among  interested parties to  support  the development of such  certification
standards,  and to provide staff support to the  effort.

     Many   generators  with   reclaimable materials  are  uncomfortable  with  the
prospect of using offsite recyclers to handle  their wastes because  of  the danger of
long-term  liability.  As a result, some  firms  may prefer, where possible, to dispose
of materials onsite rather than recycling offsite.

     There   are,  of course, existing mechanisms through  which  generators  could
obtain some information on the quality  of operation of a recycling facility, in order
to reduce the level of uncertainty. The large  and sophisticated  generator frequently
does its own audit of the recycling  firm and  its operations.  For generators lacking
substantial  technical  and financial resources, however,  this is  not  usually  feasible.
They could  contact other generators to  learn  something of the recycler's reputation,
contact the State agency  to  determine  whether there  were  any  present or  past
enforcement actions against  the generator, and  do a  walk-through  of the facility to
try to  detect any obvious bad management practices.  Nonetheless, a firm without
the  capacity  to  run  its  own  audit on the  generator  may  still  find  itself  with
substantial  uncertainty with respect to  a  decision  that  could involve substantial
long-term  financial risk.  The certification procedure outlined  above is  designed to
meet the generators' concerns.

Observations:
        Many generators who  would otherwise choose methods  involving less waste
        minimization might choose  to  use  a  certified recycler, thus increasing the
        rate of recycling.
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     •   A recycler  meeting the certification  standards  would have  a competitive
        advantage over recyclers failing to meet that standard.  The result might be
        a major market incentive and  market  reward for those recyclers with  the
        most  environmentally sound  operations.  Some of the recyclers contacted
        during this  study  felt that unless recycling  facilities were able to satisfy
        standards  more  stringent  than  those  imposed  under  RCRA, they  were
        unlikely to go out of business. This was not a unanimous view, however,  and
        many recyclers  might be  very  reluctant  to  participate in  such a voluntary
        standard-setting  process.  Some recyclers indicated  that  it  would  not be
        possible  to   meet  any standards  stricter or  additional  to  those  already
        necessary  for Part  B permitting, while still others asserted that there were
        no significant market problems for recyclers.

     •   Recyclers  meeting such  standards  might  have  greater  access  to  the
        dwindling supply of environmental liability insurance.

     •   Establishing such standards  might be a long and difficult process, even with
        the  enthusiastic participation of the recycling industry.

     •   While the  involvement of insurers in the process would seem to be a primary
        attraction for the recyclers, there might be little incentive for the insurers
        to commit  themselves to  treat  certified companies any  differently  from
        companies  currently  holding  environmental  liability  insurance.  Even  if
        access to insurance were improved, the cost of insurance might not be.


8.7.8     Reduced Liability for Generators Using Specially Permitted Recyclers


     The objective of this option would be to encourage recycling by shifting liability

for wastes sent to specially certified recycling facilities from the  generator to  the

recycler.  To  be  certified, the recycling facilities  would have  to meet stringent

management, operational, and financial standards  beyond those otherwise required
for TSD facilities.  Generators would be  willing to use such  facilities for recycling

their wastes, because  they would  no  longer  need to be  concerned  about future
liability resulting  from  failure of the recycling facility to safely manage the wastes
sent to  them.  To  make  such an  option possible,  legislative  changes  would  be

required that would  exclude the  future  application of  the strict, joint, and several

liability  provisions  of  CERCLA  to  generators  for  those   wastes  sent  to  such
specially-certified  facilities.  (For  a  discussion   of  liability  concerns  raised  by

CERCLA, see Section 5.2 on liability and insurance.) This would be one possible way

of breaking  the "chain of liability," which  some industry sources feel severely limits

the  recycling  of  potentially recoverable  and reusable  materials  (see,  generally,

Section 5.3 on Attitudinal and Organization aspects).
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    Assuming it is possible  to develop certification standards that are (1) feasible  to

meet  and (2) adequately protective of health and the environment, how much impact

such a change would have would depend significantly on the scope of applicability  of
the exclusion.  Such a provision could either generally apply to any wastes sent for

recovery to a certified facility or could be narrowly restricted to  specific types  of

wastes  (e.g.,  those  with  significant  economic  value) or wastes  recovered  for
particular purposes or under specific contractual arrangements  (e.g., batch tolling).


    It  would  be  necessary  to  establish  a  separate  classification  of  recycling

facilities  that  would  be   specially certified  for  this purpose.  Minimally,  three

requirements would have to be met:
     1.   The facilities would  have to  be dedicated to  resource recovery.  The  State
         of California  has established a separate  category of  "resource recovery
         facility,"  which  refers  to  "an  offsite  hazardous  waste  facility  whose
         principal  method  of  hazardous  waste  management  is  the  handling,
         recycling, treatment, use or reuse of recyclable material."  To qualify,  a
         facility must recycle  at least  50  percent of  the  hazardous waste it
         receives.  It might be desirable to require  a  substantially  higher recycling
         rate  for the purpose under consideration in this option. (See discussion of
         California's  Resource  Recovery  Facility  Permits in   Section  7.4.1  and
         Appendix J-l.)

     2.   Such  a  facility  would  have  to  meet  exceptionally   high  standards  of
         performance  in  its  operations in order  to  obtain certification.  Beyond
         standard inspections, it  probably would be  desirable   to  require  regular
         environmental audits of both  the  facility  and its management system to
         determine continued adherence to whatever standards are required.

     3.   Since one of  the keys to transferring liability would be adequate assurance
         that  any resulting liability could still be  met,  it  would be  necessary  for
         such a facility to  pass  financial tests indicating a  more substantial degree
         of  financial   stability  and  insurance  protection,  both   long-term   and
         short-term, than  is  otherwise required  of TSD facilities  (under CFR 264,
         Subtitle H).
Observations:
        Breaking  the  chain  of  liability   for  generators  in  this fashion  should
        encourage generators  to recycle materials they might otherwise  dispose  of
        even  though the wastes might be recyclable.  This option  might have  the
        environmental benefit of preferentially directing recycling to facilities with
        especially sound operating and management practices.
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    •   While  possibly   facilitating  recycling,   this  approach  could  create   a
        disincentive for reduction of hazardous wastes at the source insofar as the
        driving motive for such source reduction is risk of future liability.

    •   The costs for a recycler of meeting any additional requirements  for  such
        certification could be  substantial.  Since these costs would then be passed
        along to  the generators using these facilities, it could  be  the case  that  the
        smaller generators,  who  might benefit  most from such  a  facility, would  be
        least able to afford it.

    •   Adequate technical  requirements for certification  could be   difficult  to
        determine,  and   the  procedure  for  certification   could be   burdensome
        administratively, even if the technical difficulties could be resolved.

    •   Sufficient financial standards would be difficult to ascertain  (just  as  it is
        difficult  for insurers to determine the risk involved in offering  coverage for
        long-term environmental liability), and could be prohibitive for  a facility  to
        meet.
8.7.9      Recycling Substances Act


    A  Recycled  Substances  Act  could  provide  legislative   encouragement  for
recycling a variety of  materials  deemed  to  have significant economic  value, which

would be similar to the incentive provided  for  recycling used  oil in  the Used  Oil

Recycling Act of 1980.


    Section  3014 (a) of RCRA  requires  EPA  to regulate  recycled oil.  It requires

EPA to  analyze the economic effect of the regulations on the oil recycling industry.

Of  particular  importance  is  the requirement  that any such   regulations "do  not

discourage the recovery or recycling of used  oil," provided that adequate  safeguards
are written to protect human health and the environment.


    This  section  of  RCRA  also makes  clear  that used  oil listed as  a hazardous

waste, is not subject to any manifest requirement or any associated recordkeeping
and reporting requirement with respect to such used oil, provided specific conditions
are met (Section  3014(b)(2)(B)).  These conditions are:
    •   Used oil  must be delivered to recycling facilities that have valid permits
        under Section 3005;

    •   Used oil recycled by the  generator must  be  at facilities permitted under
        Section 3005;

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    •   Used oil  must  be mixed by the generator  with  other  types of hazardous
        wastes; and
    •   The generator must keep records of agreements for the  delivery of used oil
        to recycling facilities.
    Presumably,  the rationale  is  that the  recycling  practices  of  used  oil  are
generally  well-known,  except for those  instances when it has  been mixed with
hazardous  wastes.   In  those  cases,  the  exemptions  would  not  apply.   Also,  the
"well-known"  aspect of used oil recycling includes a knowledge of general  methods
of recycling and recovery.  Apparently, the recycling methods  are  accepted enough
that delivery  to a  permitted facility ensures a sufficient degree  of  protection to
human health and the environment.

    A statute similar to RCRA's  regulation for recycled  oil also  may be  desirable
for certain other classes of recycled substances. The substances to which such a law
would  extend  could  include  those  materials  that,  like  used  oil, also  have  the
attribute of a "known quantity" about  them.  Such substances  may include  solvents
leased under arrangements with companies that  supply fresh  solvent and recycle the
spent solvent at permitted central facilities.  Other batch-tolling  arrangements for
a variety of substances may also apply.

Observations:
    •   Such legislation  would encourage an  approach  to  recyclable  materials
        recognizing their economic value, and recognizing the value of substituting
        recycled wastes for the production of virgin toxic materials.
    •   This  option  would encourage  a  regulatory  approach   focused  more  on
        recycling,  and  would promote the  identification and favorable treatment of
        other  commodities that  are  economically  beneficial.   It  is  difficult  to
        predict, however,  how substantial the  economic  impact  would be  for a
        generic requirement that  does not specify particular  substances.  This  is
        because the variety of substances and their uses covers a wide range and a
        general formula for economic effects is not possible to derive.
    •   This  option  would result  in  the  relaxation of  some   of  the regulatory
        requirements  for hazardous wastes and generally could create an increased
        risk of sham operations and illegal  dumping.

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     •   The requirements of Section 241 of the  1984 HSWA  amendments that EPA
        look more carefully at the risks posed by used oil indicate increased  concern
        about   loopholes  in   the  regulatory process  under  which  any  classes  of
        substances or operators would escape examination.
8.7.10    Expedited Consideration of Delisting Petitions

     Wastes that are  residuals from reclamation processes could be granted priority
in review and action  on delisting petitions.  Since  this would  involve  only  internal
setting   of   priorities,  it  would  not   require  the  drafting  of  regulations  for
implementation (see  Section 5.5.7 for a discussion  of the delisting process).  If  the
approach of  setting  specific  toxicity limits for  hazardous wastes and constituents
(see Section  8.5.1  for  a  discussion of that  option) were  adopted, such  expedited
evaluation of delisting petitions  from reclamation processes would presumably  not
be necessary.

Observations:
     •   Expedited consideration of delisting petitions could create an incentive for
        reclamation,  and would not require  the massive  analytical effort needed for
        setting automatic toxicity limits for  delisting  petitions.  Generators  with
        petitions for other wastes might object to such a priority, however.
     •   While providing  for more rapid  consideration  of those  petitions  that are
        submitted for reclamation residuals, this would not provide as  clear a set of
        guidelines to reclaimers as to what level  of treatment  is necessary for a
        residual to be delisted as would predetermined toxicity limits.
8.7.11     Enforcement Bounties

    According to a GAO report  on the difficulty of detecting or deterring illegal
disposal  of  hazardous waste  (GAO 1985),  one  of  the mechanisms  through which
States have  been most successful in obtaining  information on illegal disposal  has
been through informants.  Not infrequently, these informants have been  employees
who  were  either  generally  dissatisfied  with  their  employer  or  were specifically
unhappy  over the illegal handling of  hazardous wastes.  GAO recommends that  a
bounty program might be a fruitful expenditure of enforcement dollars.
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Observations:

    •  While there is precedent at the Federal level for a bounty program under the
       Rivers and Harbors Act of 1899, what is  being recommended here is simply
       that EPA encourage States and localities to undertake such an approach, and
       keep a public record on the results.

    •  This would  be an extremely low-cost effort for EPA, and might encourage
       activity  that  would  lead  to  identification  of noncompliance  by  smaller
       generators  who, in   some cases,  may  not  even  have  been  identified as
       hazardous waste generators by the State.

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                           9.  ANALYSIS OF FINDINGS

    This  report  has  identified  trends  and patterns  in  the  practice  of  waste
minimization  by U.S.  industries.  It has  explored  the relationships between  the
causes of hazardous  waste generation and  the  volumes generated, as well as  the
extent to which source reduction and recycling are  practiced.  Waste minimization
practices have  been  characterized  both  by  major  industrial  processes  (source
reduction) and by major waste stream categories (recycling).

    Economics, regulatory  requirements, liability issues, technology limitations,  and
attitude/organizational issues  all contribute to a  generator's  decisions regarding
waste  minimization practices.  This study  has  identified  aspects  of  these  factors
that promote or inhibit the adoption of waste minimization practices.

    Some of the conflicts that affect the  decision  to employ  waste minimization
practices may  be  resolved  through  the  efforts   of  various  State and  Federal
regulatory and nonregulatory  programs.   The nature of these conflicts, along with
the potential  of the  programs  to resolve  them, was used  to develop  options to
promote  waste minimization.  These  options have been described and analyzed with
respect to the possible effects of their implementation. EPA will develop and refine
the stated options  in  preparation  for the  mandated Report to Congress  on waste
minimization.

9.1        Trends in Waste Minimization

    Until recently, waste  minimization  was undertaken primarily for purposes other
than for reducing wastes.  Waste minimization was an incidental result of efforts to
decrease  manufacturing   costs  through   improvement   of   yields and  operating
efficiency.  With the  requirements  of  RCRA  and  the  recent  passage of  HSWA,
however, companies have  begun to consider such  practices as  a means to reduce
wastes, liabilities, and the costs associated with regulation.

    Neither source reduction nor recycling is a major component of industrial waste
management  practice  in the  United  States. The total volume  of  hazardous waste
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recycled in  1981  was 4 percent of the volume  generated,  based on the population
surveyed (RIA Mail Survey for Generators). Although the overall rate of recycling is
low, the survey data indicate certain waste stream-specific patterns.  For  example,
suitability of a waste for recycling  depends on  market demand for and the purity of
the  material.  Another observation  is  that  the  higher  the  weighted   average
concentration of known constituents in a waste stream,  the more  likely  is the
selection of recycling as a waste management  option.

     The ratio of waste recycled  to waste generated  for  the ten  highest  volume
generators suggests that the waste streams most likely to be recycled are those with
high-volume,  heavy-industry  applications.   This  pattern   is  suggested   by  the
economies of scale.  Generally, it is more cost-effective to recycle large volumes of
materials than small volumes because of  the payback period involved.

     Although economics favors recycling of any large  volume of  waste generated,
the profile drawn from the  RIA Mail Survey data implies that characteristics of the
waste  stream  are  more important than  volume  generated  in  determining  the
technical and economic  feasibility of recycling. Automobile manufacturers (SIC 37)
recycled 39 percent of  900 M gal of  waste  generated in   1981,  compared  to the
1.2 percent  of 28,000 M gal of generated waste recycled by chemical manufacturers
(SIC 28). The limiting factor for recycling within  these industries  is not the  volume
of waste generated, but the type of process and  nature of the wastes generated.

     The uniformity and constituent concentrations of a waste stream  are important
in determining the technical feasibility of reclaiming the  waste  at  a  reasonable
cost. Segregated wastes (e.g., wastes from a continuous process)  are more likely to
be recycled than wastes that are mixed.  This is  evidenced by the fact  that, in  1981,
dilute inorganic and cyanide/reactive waste streams from continuous processes were
recycled in the highest volumes  of all  hazardous  wastes.   Pickling  liquor,  metal
finishing solutions, and spent acids and  alkalies were the  wastes reported to  be
recycled in the largest volumes  (RIA Mail  Survey  for  Generators).  In  contrast,
mixed solvent wastes from equipment cleaning  and degreasing operations (e.g., from
the trucking and warehousing industries, SIC 42) are not easily separated  into  their
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constituents; therefore, although solvent wastes were generated  in  high  volumes,
recycling rates for solvent wastes were lower in 1981  than for some inorganic waste
streams.

     Recycling  by  high-volume  generators  tends to  be  performed  onsite  as  the
volume of waste increases,  whereas  most  small  quantity  generators (SQGs) ship
wastes offsite for recycling.  Economies of scale may  contribute to this pattern, as
well as the lack of expertise and eguipment among  many SQGs to  perform onsite
treatment operations.

     The  trend   toward  future  reduction  of   waste   generation  appears  to   be
significant.  Estimates  range  from 15 to  30  percent  reduction of unit waste per unit
product  based on the  current level  of waste generation.  These reductions would
result  from  the  extension  of existing source  control techniques and the application,
to their fullest potential, of new  technologies identified in Appendix B.

     Although   Good  Operating   Practice  (GOP)   is  generally  well   accepted.
understood,  and  the most frequently applied  source  control  technique,  there is
substantial potential  for  improvement.  A common  business  practice  is to  select
source  control  procedures that  are  obvious, easy, and  relatively inexpensive  to
implement.  Nevertheless, management initiatives  to  promote  waste  minimization
activities are still needed as incentives to companies  to adopt them.

     Of  all  source  reduction   techniques,  product substitution  is  the  most
controversial.   Product  substitution  involves  an evaluation  of  the  substitute's
feasibility with respect to (1) its adequacy as a replacement for the original product,
(2)  its  environmental  benefit  compared with  the original  product,  and  (3) its
compatibility  with a  free  market  economy.   With  respect  to item  3,  industry
generally views  the inclusion of product substitution as an  inappropriate  waste
minimization technique.  It is held  that  such categorization hints of  governmental
intrusion into the free marketplace.

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9.2       Nontechnical Factors That Promote and Inhibit Waste Minimization

    Economic Issues

    Investment in innovative waste  minimization technologies  is influenced by the
profit  and risk  associated with the innovation, as well as cost; capital availability;
the adaptability  of  the  technology;  market  and regulatory  factors; and  internal
production factors.  If a  firm lacks the ability to raise funds for a project,  the firm
will not undertake it.  Companies that are able  to obtain sufficient capital at an
acceptable  cost  are  in   a  better position  to  implement  new  waste minimization
technology.  A firm  may  be motivated to raise  funds, however, if  the  investment
may result in a potential for increased profit and if the payback period is reasonably
short.   Market  factors  play  a significant  role  in  investment  in  recycling
technologies.  If  there is  a  limited market for the material reclaimed from  a waste,
then there may be  little  or no return on the initial investment for  the  reclamation
technology.

    Product  quality  is   a  critical  consideration  for  all   waste  minimization
investments, however.   If  the innovation  will  cause lower   production  costs or
improve product quality,  the  firm has an  incentive to invest.  On the other hand, if
product quality is sacrificed as a result of  the waste minimization effort,  the firm  is
highly  unlikely to make  such an investment, since the  product  may no longer be as
desirable.  For example,  manufacturers of  electronic equipment  (e.g., printed circuit
boards) require  a high degree of purity in their solvents.   Many choose to use virgin
solvent rather  than  recycled material. Although the costs for recycled materials
(particularly when recycled onsite) may sometimes be less than for virgin materials,
the risk of  inferior  product  quality  represents a  potential  loss in profits.   The
company  would thus consider risk of  losses to outweigh  the cost savings resulting
from use of recycled materials.

    A major incentive to invest in waste minimization technologies is the  increasing
cost and/or banning of  land  disposal  of hazardous wastes.  HSWA impose restrictions
on the land disposal of certain hazardous  wastes.  In the case  of liquid  hazardous
wastes,  there  is  an  absolute   ban   on  landfilling.   In  addition,   the  increased
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technological  requirements  imposed  on  new  landfills  may  cause  costs of  land
disposal to increase substantially.  Finally, there may be a decrease in the number of
permitted  landfills  because of the  inability  of  the owners to  comply  with  the
requirements.  The  restrictions thus force generators to consider alternative forms
of waste management, among them source reduction  and recycling. The decrease in
demand  for  landfills,  coupled with  a decrease  in  their  supply, would result in
increasing  costs.   Thus,  technologies  and  methods that  were  once  marginally
economical may now be economically attractive.

    Liability Issues

    The risk of  future  liability  resulting  from  damages caused  by subsequent
handling of  hazardous waste  may inhibit shipping   wastes offsite  for recycling.
Conversely, it may  promote onsite recycling as well as source  reduction practices.
Some companies may  lack  the in-house expertise  for such activity,  however,  and
may also  feel  that  it is  a  departure  from their normal production activity.  Under
Section 107(a) of the CERCLA statute, generators potentially can be subject  to  pay
for  damages caused  by   the  future  handling of  their   hazardous   waste;  thus,
generators could be  made to pay for damages caused  by recyclers. Where recycling
companies  are   inadequately   insured,  therefore,  the   potential  future  risk  to
companies sending their wastes to recyclers increases.

    Some  companies that send their wastes offsite are aware of this  problem  and
attempt to  prequalify  the offsite  waste  management  or  recycling  firm.   This
involves an audit  of the recycler. In  addition,  companies may find that source
reduction  is  a  viable alternative  in  light of  future liability  costs.  Although  the
incentive  exists for companies that can afford  to  make such investments, this  may
not be possible  for smaller  companies.  Many simply cannot afford to conduct audits
of their recyclers, yet they  lack the resources and in-house expertise to enlist onsite
recycling or source reduction.

    The cost of some recycled materials may be higher than that of virgin materials
because  of the  high  transportation  costs  associated  with  liability.  Under  the
CERCLA  legislation,  transporters (as  well as generators) may be held liable  for
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future damages  associated  with  hazardous wastes.  This  liability  provision  for
transporters applies to hazardous wastes, but not hazardous virgin  materials.  Thus,
transporters may charge more for  shipping hazardous wastes in order to ensure that
they are capable of paying  for future environmental  damages  for which  they  may be
held  liable.  (The  definition  of  solid  waste,   as  revised,  would  not subject  to
regulation wastes that are directly used or reused,  provided they are not reclaimed
prior  to or during  their use.  Materials so exempted from regulation would not need
to  be manifested  and  would  enjoy  the  same regulatory  treatment  as  virgin
materials.)  Since  virgin materials may be  cheaper than hazardous wastes needing
reclamation, this  would inhibit such  practices,  notwithstanding issues of product
quality.

    Regulatory Issues

    HSWA  will  increase  awareness  of  waste minimization  as an alternative, and
may also result in such practices being viewed as economically attractive relative  to
other waste  management  techniques.  As mentioned previously, the provisions for
land disposal restrictions and increased requirements for landfills found in  HSWA are
likely  to  cause  generators  to  give  more serious consideration  to  other waste
management alternatives,  among them source reduction  and  recycling.  Because  of
these recent legislative and regulatory developments, some companies,  who might
never have done so, may now  consider  waste  minimization.   Other companies,  for
whom waste minimization was actually  a  result of changes  designed to  increase
product yield, may now give primary consideration to these practices in  light of land
disposal restrictions and limited waste management  alternatives.

     RCRA and other regulations may serve to  inhibit waste  minimization activities
that require permits.   Waste  minimization activities that require the installation  of
new equipment onsite may be  considered  to be  treatment facilities under the RCRA
regulations.  Although  at present  reclamation  activities   are   not  subject   to
regulation,  other  activities   that  do  not qualify as  reclamation   may  require
permitting.  Since permitting  can  be  a slow, unpredictable, and  costly process, it
may  serve to inhibit waste minimization  activities  for which permits are required.
Similarly, permits  are  required for hazardous  wastes  stored onsite for  more than
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90 days.  In order  for recycling to prove  economical, sufficient volumes must be
recycled. Smaller  companies may not generate enough wastes in a  90-day period to
warrant  shipping them offsite, yet to  accumulate  the waste onsite would  require
permitting;  such smaller  companies  may  find  other  means  of  waste management
more economical.  With restrictions on land disposal  in the future, this situation has
the potential to lead to increases in illegal disposal.

     In addition to  RCRA permits, permits  for air and wastewater  emissions  also
may be required before new equipment is installed.  Air permits  may  be  difficult to
obtain  in areas of  the country in  which  one or more of the national ambient air
quality standards  are violated,  since offsetting   emission  reductions  would  be
required  to satisfy  the permitting  requirements.

     Increased  requirements and  misinterpretations of EPA's revised definition of
solid waste  may  inhibit both onsite and offsite recycling.  EPA's new definition of
solid waste  requires that some  wastes that previously did not need to be manifested
when shipped  offsite  for recycling  now  must  be  manifested  if  reclamation is
involved.  Because of the fear  of future liability  for  damages under  CERCLA,
manifesting wastes is seen to  inhibit such offsite  recycling.  The  definition  also
contains  confusing  language, which has been  misinterpreted  by both industry  and
some State  agencies.  Although reclamation  activities currently are  not  regulated,
some people feel that the installation of equipment to perform onsite recycling  will
require a permit.  The difficulty  of  misinterpretation is  compounded  when State
agencies believe this  to  be  correct and incorporate such an  interpretation in their
version of the regulations.

     The  problems associated with  siting waste treatment facilities  are obstacles to
expanding resource recovery capacity.  An increase  in offsite  recycling may create
a need for additional  facilities; however, recyclers face difficulties in  finding  new
sites and obtaining timely approval of permits. Siting of such facilities often results
in the  "not in my backyard" reaction.  Such reactions  are due  to past practices  and
increased publicity (and fear) of hazardous waste problems.  They also may be due to
the failure of State or local governments to  educate communities on the costs  and
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benefits  of  such  sites and  their  relation to  the  local  job  base.  In some cases,
prospective  operators are unwilling to enter  into  dialogues with the  community
about the prospective facility and its design and operations.

    Attitude/Organizational Issues

    The  effect of  current  practice   on  industrial design  may  serve  to  inhibit
development  of  waste  minimization  practices  within  companies.   There  is  a
tendency  to preserve  designs and  practices that  may  generate large volumes of
waste  because they  have worked well and provide ready  solutions  to production
problems.  Familiarity with production techniques  also results  in  lower time  and
personnel requirements.   As  a result,  company managements may be satisfied with
status  quo  production operations, in  spite  of their tendencies to produce  large
volumes of waste.

    Opposition to possible waste minimization  measures may  arise out  of fear of
reduced product quality.  This  is only  one factor,  however.  Process modifications
may also  involve production downtime  that impedes fulfillment  of production goals
or contractual  obligations. Thus, process modifications are viewed as  a relatively
expensive endeavor.

    Corporate policies can  influence  waste  minimization  practices.   To increase
awareness and  motivation, companies may provide  waste minimization newsletters,
cash   awards,   certificates,   seminars,   and   workshops.    Without   effective
communication, engineers responsible  for production operations may  not be  fully
cognizant of the problems associated with hazardous waste handling and disposal and
the potential  environmental  liabilities associated   with  generated waste streams.
Effective communication  of  the  corporate   waste  minimization  policy  to  all
operational  levels  contributes  to  the  implementation  of  a  successful  waste
minimization   program.   Upper  management  support,   however,  is   especially
necessary. In  particular,  the program  requires a "champion," a  person at an  upper
level who is committed  to  waste  minimization. Such a person  can overcome  both
developmental   problems  and  the   general   inertia   that   protects  existing
waste-producing practices.
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9.3        Governmental Efforts to Promote Waste Minimization

    State Programs

    Some State agencies provide  information to increase awareness and to educate
the regulated  community on  waste minimization.  Many States have information
programs,  which disseminate waste  minimization  information through publications
and conferences.  Technical Assistance Programs are another form of information
program, providing generators with specific technical advice  on how their  processes
could be altered to reduce waste  generation. Such programs are particularly helpful
to smaller companies  that lack the  resources or in-house expertise to make such
evaluations.  The  programs  include advice on regulatory matters,  which could  also
aid smaller  companies unfamiliar  with  Federal and   State  requirements.   Such
programs may effectively complement corporate efforts in waste minimization.

    Financial incentives in the form of loans, grants, and fee and  tax systems  also
promote waste  minimization.  Some  States have instituted loan and grant  programs
for projects involving  installation of equipment associated with source  reduction or
recycling.  Other programs are structured in the  form of awards,  which are sums of
money  awarded to firms in recognition  of  their efforts to  reduce pollution.  Such
grant,  loan,  and  award programs promote waste  minimization  by  "seeding"  the
investment process within a firm,  and in so doing, share some  of the  risk.

    Taxes and fees are also forms of financial incentive.  The fee and tax systems
of various  States are structured to serve as incentives to minimize waste.  In some
States they are assessed on the basis of amounts of wastes disposed.  This tax, called
a "waste-end" tax, is levied primarily to generate revenue and to  make land disposal
the  least  preferred  alternative,  thus attempting  to encourage waste  reduction.
These two goals — revenue  generation and  waste reduction  — potentially conflict
with  one another, however,  because  States may  lose  a significant source of revenue
if land disposal is severely discouraged.
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    Federal Programs

    Federal waste minimization programs  include research  and development and
technology transfer.  Research  and  development  on  waste minimization are  being
conducted by various Federal agencies including  EPA, the Department of Energy,
and the Bureau of Mines.  The  Tennessee Valley  Authority receives $1.5 million  in
Federal appropriations  per year to  implement  its  waste  management  program.
Research  is also being  conducted by  Congressional agencies such as the Office  of
Technology Assessment  and the  Congressional Budget  Office.  OTA is conducting a
study on  source reduction,  which  will  examine  State  and Federal activities and
provide policy options on the types of programs that  the  Federal  Government can
implement to enhance source reduction.  CBO has completed a study examining the
different types  of waste-end  tax systems as ways of encouraging waste reduction.

    The Department of  Defense  waste minimization program  may serve as  a  model
for some  industries,  and  thus is  a  significant  information source  on  waste
minimization and its implementation.  As a generator  of  hazardous waste,  DOD  is
involved in  waste  minimization at  both the research and  implementation levels.
Since 1980, DOD has made it a  policy to limit the generation  of  hazardous  waste
through  alternative  procurement   policies  and  operational  procedures.   Waste
minimization  activities  are  implemented  through   the  Defense  Environmental
Leadership Project, the  Defense Logistics Agency, and the efforts  of  the individual
bases or installations themselves. Recently, the  Joint  Logistics Chiefs (JLC) of the
services developed a waste minimization strategy  and  proposed it for adoption on a
DOD-wide basis. The program would  include a review  of procedures and equipment
for  application,  increased  research   and  development,  and  an  inter-service
information exchange/technology transfer.

    Some of the  activities  underway at  various bases  include  the  use  of  bead
blasting for paint removal and the use of water-borne paints  rather than those that
are solvent based. The  Air Force  System  Command  (AFSC)  recently completed  a
study of the  Air Force's contract suppliers to evaluate  the extent to which  waste
minimization is practiced in their operations.  Because of the large market influence
exerted by  the  military,  projects  that affect   the  production  practices of the
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military's suppliers, as well as those within  military bases themselves, may have
far-reaching effects on nonmilitary industries.

9.4        Options to Further Promote Waste Minimization

    Options to  further  promote  waste minimization  were developed  as possible
means to  meet the national policy objective of waste minimization added to Section
1003 of RCRA by HSWA.  The factors that promote  and  inhibit waste  minimization,
as well as government regulatory  and  nonregulatory programs to encourage waste
minimization,  were instrumental  in developing options  for  the promotion of waste
minimization.  In some cases, the options identified were based on programs that  are
actually  in  place;  in other cases, they were based on  those that  are  proposed.
Performance  standards,   management  practices, and a  broad array of  economic
incentives represent  the  types of options developed.   Options  took the  form  of
regulatory programs under  RCRA and  other  environmental laws,  nonregulatory
programs, and  legislative changes.

    The options were designed  in  part  to  alleviate some of  the  problems  and
conflicts  identified  in  current  regulatory  programs.  In  particular,  one  option
examines  changes  that  could be made  to  EPA's  definition of  solid  waste   to
potentially alleviate some of the disincentives to recycling.  Another option reviews
the various  forms of waste-end taxes and  suggests that the  money from  such taxes
be used to fund  grant programs dedicated to companies who invest in new equipment
that reduces waste.  Also considered was the option of "no change," in which  HSWA
remain  as  written.  As  discussed  above, HSWA requirements  will  force many
companies to consider, perhaps for the first time, waste  management alternatives  to
land disposal.

    The  degree to  which  HSWA by  themselves  effect  an increase  in  waste
minimization  will  be  significant  in  determining whether  additional performance
standards or management practices are desirable.  Such information probably will
not be evident  for several  years.   Other  options  suggested may be effective  in
encouraging waste  minimization  independent  of  the effect of  HSWA. Such  options
may provide an immediate opportunity for innovative Federal and State  approaches
to the problem.
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                               10.  REFERENCES

Adamson, V.  1984.  Breaking the barriers, a study of legislative and economic
barriers to industrial waste reduction and recycling.  Toronto, Canada:  Pollution
Probe Foundation and the Canadian Environmental Law Research Foundation.

Alabama, State of.  1985.  The governor's award for outstanding achievement in
waste management.  Project descriptions of winning waste reduction and recycling
projects presented at the first annual Symposium on Pollution Prevention Pays, 30
October  1985, at the University of Alabama, Birmingham, Alabama.

Banning, W.   1984. An assessment of the effectiveness of the Northeast Industrial
Waste Exchange in 1984. Northeast Industrial Waste Exchange, 90 Presidential
Plaza, Suite 122, Syracuse, N.Y.  13202.

Banning, W., and Hoefer, S.  1983.  An assessment of the effectiveness of the
Northeast Industrial Waste  Exchange in 1983.  Northeast Industrial Waste Exchange,
90 Presidential Plaza, Suite 122,  Syracuse, N.Y.  13202.

Berkowitz, Joan B., et ai.  1977.  Arthur D. Little, Inc.,  The physical, chemical and
biological treatment techniques for industrial wastes.

Boubel,  R.W.  1985.  Recovery, reuse, and recycle of solvents.  Defense
Environmental Leadership Project. Washington, D.C.: Department of Defense.

Branson, W.H.  1972. Macroeconomic theory and policy.  New York: Harper  &  Row.

Bulanowski, G.A., et al.  1981. A survey and analysis of state policy options to
encourage alternatives to land disposal  of hazardous waste.  National Conference of
State Legislatures, July  1981, Denver, Colorado.

CBO. 1985.  Congressional Budget Office.  Hazardous waste management:   recent
changes and policy alternatives.  Prepared for Senate Committee on Environmental
and Public Works.

Campbell, M., and Glenn, M.  1982.  Profit from pollution prevention. Toronto,
Canada:  Pollution Pr6be Foundation.

Chemical Week. 1985a.  Surplus  gas: is the "bubble" big enough?  Vol. 1 37,  No.  12,
p. 10. September 18, 1985.

Chemical Week. 1985b.  Gas-price decontrol is a "nonevent". Vol.  136, No. 4, p.
44. January 23, 1985.

Chemical Week. 1985c.  For U.S. copper, a far-from-rosy future.  Vol.  137, No. 9,
p. 6. August 28, 1985.
                                      [0-1

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Chemical Week.  1985d.  More ground lost in Louisiana. Vol. 136 No. 26  p  14
June 26, 1985.

Christensen, E. and Delwiche, J.  1982.  Removal of heavy metals from
electroplating rinsewaters by precipitation,  flocculation and ultrafiltration. Water
Research.  16:729-737.

DOE.  1983a.  Department of Energy, Office of Industrial  Programs. DOE industrial
energy conservation program. Washington, D.C.: U.S. Government Printing Office.

DOE.  1983b.  Concentration of electroplating waste rinse water: process uses
energy efficient low-temperature evaporation. Washington, D.C.

DOE.  1983c.  Energy recovery from industrial solid waste: boilers with  multifuel
burners can use refuse derived fuel.  Washington, D.C.

DOE.  1983d.  Department of Energy, Office of Industrial  Programs. Energy
recovery from waste plastic: converting atactic polypropylene to fuel oil. Project
description sheet compiled by Argonne National Laboratory.  Washington, D.C.:
U.S. Department of Energy.

Daignault,  L.G.  1977.  Pollution control in the photoprocessing industry through
regeneration and reuse. Journal of Applied Photograph Engineering 3(2):93-96.

Dasgupta, P., and Stiglitz, J. June 1980. Industrial structure and the nature of
innovative  activity.  The Economic Journal 90:  266-293.

Engineering-Science.  1984.  Supplemental report on the technical assessment  of
treatment alternatives for waste solvents. Final report for Office of Solid Waste.
Contract No. 68-03-3149,  Washington, D.C.: U.S. Environmental Protection
Agency.

Environmental Information Ltd.  1985.  Industrial and  hazardous waste management
firms 1985.  Minneapolis, Minnesota.

Ferguson, C.E.  1972. Microeconomic theory, Homewood,  111.:  Richard D. Irwin, Inc.

Finlayson, R.A.  1985a. EIL  market crumbles as  Shand, Morabaw pulls out. Business
insurance.  January 28, 1985. p.  2.

Finlayson, R.A.  1985b. EIL  market crunch forces search for options.  Business
insurance.  December 30, 1985.  p. 22.

GAO.  1984.  U.S. General Accounting Office. State experience with taxes on
generators  or disposers of hazardous waste.  Pub.  no. GAO/RCED-84-146. May 4,
1984. Washington, D.C.:  U.S. General Accounting Office.
                                     10-2

-------
GAO.  1985.  U.S. General Accounting Office. Illegal disposal of hazardous waste;
difficult to detect or deter.  Pub. No. GAO/RCED-85-2. February 22, 1985.
Washington, D.C.:  U.S. General Accounting Office.

GCA.  1984.  Technical assessment of treatment alternatives for wastes containing
halogenated organics.  Contract no. 68-01-6871, final report  for Office of Solid
Waste.  Washington,  D.C.: U.S. Environmental Protection Agency.

Garrison, L.S.  1985. duPont News, 14(9): 1.

Haas, Charles N. 1984. Incentives for the treatment and disposal of hazardous
wastes by alternative means. Paper prepared under a grant from the National
Association for the Advancement of Science, for EPA's  Office of Solid Waste.
August  10, 1984.

Higgins, I.E.  1985.  Industrial processes to reduce generation of hazardous waste at
POD facilities.  CH2M Hill.  Contract No. DAC A87-84-C-0076.  Report for  DOD
Environmental Leadership Project Office and U.S.  Army Corps of Engineers.
Washington D.C.: Department of Defense.

Higgins, I.E., and Termath,  S.  1982. Treatment of plating wastewaters by ferrous
reduction, sulfide precipitation, coagulation and upflow  filtration. In Proceedings of
the 36th Industrial Waste Conference May 12, 13, and 14, 1981. Ann Arbor Science,
Ann Arbor, ML  pp. 462-471.

Hirshleifer, J.  1971. The private and social value  of information and the reward to
inventive activity. American Economic Review 61: 661-574.

Huisingh, D., Martin, L., Hilger, H., Seldman, N.  July 1985.  Proven profit from
pollution prevention. Washington, D.C.:  Institute for Local Self-Reliance.

Humpstone, C.  1984. Liabilities, insurance, and  waste reduction in Massachusetts
Hazardous Waste Source Reduction Conference Proceedings.  Massachusetts.
Department of Environmental Management, Bureau of Solid Waste Disposal.

Industrial Material Exchange.  1985.  Assessment report. Illinois Environmental
Protection  Agency, 2200 Churchill Rd.,  Springfield, IL  62706.

Inform.   1985. Cutting chemical wastes. New York: Inform.

J.J. Keller and Associates Inc. 1984. Hazardous waste services directory. Neenah,
Wisconsin.  December 1984.

Jacobs Engineering.  1975. Assessment of hazardous waste practices, petroleum
industry  in U.S.  Washington, D.C.: U.S. Environmental Protection Agency, Office
of Solid Waste Management Practices.
                                     10-3

-------
Kerr, R.L.  1985a.  Summary of issues and discussions at the conference on
procurement and environmental quality.  December 6-7, 1984, in Edison, N.J.
Contract no. 68-01-7002.  Draft report for Office of Policy, Planning, and
Evaluation. Washington, D.C.:  U.S Environmental Protection Agency.

Kerr, R.L.  1985b.  Summary of issues and discussions at the second workshop for
state waste reduction programs. (October 31-November 1, 1985). Submitted to U.S.
Environmental Protection  Agency, Office of Policy, Planning, and Evaluation,
Regulatory Reform Staff.  Washington, D.C. December 1985.

Kohl, J., Moses, P., and  Triplett, B. 1984. Managing and recycling solvents;  North
Carolina practices, facilities and regulations. Raleigh,  N.C.: Industrial Extension
Service, North Carolina  State University.

League of Women Voters of Massachusetts.  1985. Waste reduction: the untold
story.  Conference held  June 19-21, 1985, at National Academy  of Sciences
Conference Center, Woods Hole, Massachusetts.

Mansfield, E.  1982.  Microeconomics: theory and applications, New York:  W.W.
Norton and Company.

Massachusetts Department of Environmental Management.  1983. Hazardous waste
management in Massachusetts; statewide environmental impact  report. Bureau of
Solid Waste Disposal.

Mehta, Anil.  1981. Routes to  metals  recovery from metal finishing sludges.  In
Third Conference on Advanced Pollution Control for the Metal Finishing Industry.
Industrial Environmental Research Laboratory.  Cincinnati, Ohio:  U.S.
Environmental Protection  Agency.

Moellendorf, G.V.  1985. Progress report: priority waste management study  for
Washington State hazardous waste.  Olympia, Washington:  Washington State
Department of Ecology.

National Research Council.  1985.  Reducing hazardous waste generation; an
evaluation and a call for action.  Washington, D.C.:  National Academy Press.

New Jersey Department of Environmental Protection.   September 1984.  Cross
reference New Jersey - federal (RCRA) hazardous waste regulations. Division of
Waste Management.

New Jersey Hazardous Waste Facilities.  Siting Commission and  Source Reduction
and Recycling Task Force. 1985.

New York State Environmental Facilities Corporation.  1985.  Industrial materials
recycling act program, fourth annual report. July 31, 1985.
                                      10-4

-------
OMB.  1972.  U.S. Office of Management and Budget.  Standard industrial
classification manual.  Washington, D.C.:  U.S. Government Printing Office.

OTA.  1983.  U.S. Office of Technology Assessment.  Technologies and management
strategies for hazardous waste control.  Pub. no. OTA-M-196.  March 1983.
Washington, D.C.:  U.S. Government Printing Office.

Pace.  1983.  Solvent recovery in the United States, 1980-1990. Houston:  Pace
Company Consultants and Engineers, Inc.

Perry, R. and Green, D.  1984.  Perry's chemical engineer's handbook. 6th ed. New
York:  McGraw-Hill Co.

Pesticide and Toxic Chemical News. 1985.  Real opportunities appearing for mobile
incineration, operator notes, p. 21. December 11, 1985.

Peterson, J.J., Burbank, N.C., and  Amy, G.L. 1982. Liquid ion exchange
pretreatment for removal of heavy metals from plating rinsewater.  In Proceedings
of the 36th Industrial Waste Conference May 12, 13, and 14, 1981. Ann  Arbor
Science, Ann Arbor, ML  pp. 472-485.

Piedmont Waste Exchange.  1984.  Annual report. Charlotte, N. C.:  Urban  Institute.

Pope-Reid.  1986.  Alternative waste management technology cost estimate  for
California List land disposal restrictions.  Report to the U.S. Environmental
Protection Agency, Office  of Policy and Planning Information.  Economic Analysis
Staff, Washington, D.C. September 1986.

Powell, T.  1985.  A review of recent developments in project evaluation. Chemical
Engineering  (November  11): 187-194.

Radimsky, J. and Marx,  R.E.  1983. Recycling and/or treatment capacity for liquid
hazardous wastes containing polychlorinated biphenyls.  Alternative Technology and
Policy Development Section. California: Department of Health Services.

Radimsky, J., Piacentini, R., and Diebler, P.  1983. Recycling and/or treatment
capacity for hazardous waste containing cyanides.  Hazardous Waste Management
Branch Staff report.  California: Department of Health Services.

Rosenburg, N. 1982. Inside the black box:  technology and economics.  New York:
Cambridge University Press.

Rozck, Douglas R.  1985. Interim report on sample populations design and
questionnaire distribution.  Prepared for Massachusetts Department of
Environmental Management. February  1985.
                                     10-5

-------
Rozelle, T., Kopp Jr., C.V., and Cobian, K.E.  1973.  New membranes for reverse
osmosis treatment of metal finishing effluents.  Report to the Minnesota Pollution
Control Agency and the U.S. Environmental Protection Agency. EPA-660/2-73-003;
NTI5 PB-240-722.

Ruder, E., Wells R., Battaglia M., and Anderson, R.  1985. National small quantity
hazardous waste generator survey. Final Report to the Environmental Protection
Agency, Office of Solid Waste.  Contract No. 68-0 1-6892. Cambridge,
Massachusetts: Abt Associates Inc.

SRI. 1985.  Directory of chemical producers. Menlo Park, Calif.:  Stanford
Research Institute.

Sabrina, F.  1985.  Chemical Marketing Reporter,  November  17, 1985 issue, p. 38.

Savant Associates, Inc.  1984.  Experiences of hazardous waste generators with
EPA's Phase I RCRA C Program.  Prepared for Office of Policy Analysis.
Princeton,  New Jersey: U.S. Environmental Protection Agency.

Sloan, W.M.  1985. Economic exchange of chemical and industrial waste.
Conservation and Recycling.  Vol. 8,  No. 3/4, p. 335-341.

Stoddard, S.K., et al.  1981.  Alternatives to  the land disposal of hazardous wastes:
an assessment for California. Toxic Waste Assessment Group.  California:
Governor's Office of Appropriate Technology, Sacramento, California.

Telego, D.J. 1985.  Pollution liability insurance market, EIL  insurance's current
events in the marketplace: future trends and impact on Government action.
Proceedings from National Conference, Hazardous Materials Control Research
Institute.  May 19-21,  1985.

Telego, D.J. 1986.  Corporate risk management strategy against pollution  liability.
Hazardous  Substances.  Vol.  1, No. 4.  February 1986.

3 M Corporation. 1985. Pollution prevention pays, St. Paul, Minn.: Environmental
Engineering and Pollution  Control Dept.

U.S. Census of Manufacturers.  1977.  Industry Series Survey.  Obtained from data
base maintained by Development Planning and Research Associates, Inc.
Washington, D.C.  October 10, 1985.

U.S. EPA.  1975.  Development document for effluent  limitations guidelines and new
sourc performance standards for the  petroleum refining point source category.
April 1974. Environmental Protection Agency, Effluent Guidelines Division.
Washington, D.C.

U.S. EPA.  1979.  Assessment of solid waste  management problems and practices in
the inorganic chemicals industry. Report SW180C. Office of Water and Waste
Management, U.S. Environmental Protection Agency.  Washington, D.C.

                                      10-6

-------
U.S. EPA.  1983.  Development document for effluent limitations guidelines and
standards for the organic chemicals and plastics and synthetic  fibers industries.
EPA 44Q/l-83/009-b. U.E. Environmental Protection Agency,  Effluent Guidelines
Division.  Washington, D.C.  Feburary.

U.S. EPA.  1984.  Survey of states' experiences with waste-end taxes. Prepared by
Office of Policy, Planning, and Evaluation, Office of Policy Analysis.  September
1984.

U.S. Patent 4,443,251.   1984.  Method of operating a  blast furnace.  April 17,  1984.

United Nations, n.d.  U.N. compendium on low and non-waste technology 1981-1985.
Vols. I and II.  Geneva, Switzerland:  Economic Commission for Europe.

Versar Inc. 1975.  Assessment of industrial hazardous waste practices - inorganic
chemicals industry.  Final Report, Contract No. 68-01-2246 for U.S. EPA, Office of
Solid Waste Management Programs.  U.S. Environmental Protection  Agency,
Washington, D.C.

V/ersar Inc. 1979.  A survey of potential chlorine production processes. Final
Report.  Contract No. 31-109-38-4211  for Argonne National Laboratories, Argonne,
111.  Argonne Report  No. ANL/OEP 7-79-1.

Versar Inc. 1980.  Multimedia assessment/inorganic chemicals  industry.  Final
Report, Contract No. 68-03-2604 for U.S. EPA, Office of Research  and
Development.  U.S. Environmental Protection Agency, Cincinnati, Ohio. Volume 3,
Chapter  11, Salt Derivatives.

Versar, Inc. 1984. Technical assessment of treatment alternatives for wastes
containing metals and/or cyanides.  Contract  no. 68-03-3149, final report for  Office
of Solid Waste. Washington, D.C..:  U.S. Environmental Protection Agency.

Westat, Inc. 1984.  National survey of hazardous waste generators and treatment.
storage and disposal  facilities regulated under RCRA in 1981.  Contract  No.
68-01-6861. Final report  for Office of Solid Waste.  Washington, D.C.:  U.S.
Environmental Protection Agency.

Wisconsin DNR.   1983.  Alternatives to hazardous waste land disposal. Madison,
Wisconsin: Bureau of Solid Waste Management.

Wisconsin DNR.  n.d. Hazardous waste recycling guide to the Chapter NR  181
Recycling Prosisions.

Wise,  R.T. and Amman,  P. Remedial cost estimation system for Superfund sites.
Management of Uncontrolled Hazardous Waste Sites,  5th National Conference,
Washington, D.C. 1984.
                                     10-7

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World Information Systems.  Hazardous materials intelligence report,  p. 5.  May 24,
1985. Cambridge, Massachusetts:  World Information Systems.

Wright, B.  1983.  The economics of invention incentives:  patents prizes, and
research  contracts.  American Economic Review 73:691-707.

Zimmerman, L., and Hart, G.  1982. Value engineering - A practical approach for
owners, designers, and contractors.  New York:   Von Nostrand Reinhold Company.
                                     10-8

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