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
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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
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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.
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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.
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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.
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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
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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.
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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.
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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
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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.
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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)).
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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
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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.
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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.
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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
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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).
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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
-------
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
-------
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
-------
• 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
-------
• 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
-------
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
-------
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%
Recovery/
Reuse
—
Onsite
Wastewater
Treatment
—
Treatment of
Organics
O ~
,O
co Surface
QJ Impoundments
C
0)
E
0)
O)
CO
C Wastewater
«| Discharge
Land Disposal
i
If'
^ —
'''••••'.••
'•£?•
' >'•".'•
1
i:;:,:-X:::.
— "
•>v
;,.•!'!•
' ::':-:'
,
' :''.'£''" : '.
— —
''••'"'••
1
1
1
1
•<..:'•
1
?)':. .'''';'5'?'"'
< 0.01%
:%::l
?*5'"'':
•
i
''£'•/ ::'•!'.-•
|
''•'• .:'''''.' v
V'".. ••"''" (
t
1
•••';-.':x
.... '
1
"!':::;'•.•
.%•;
:•.-••'
,
1
,
1
i
1
i
1
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%
Recovery/
Reuse
Onsite
Wastewater
Treatment
—
O Treatment of
•— Organtes
O
2
Q. —
4-»
E Surface
9L Impoundments
(0
c
CO _
Wastewater
Discharge
—
Land Disposal
r+fv
pi;*!:!
I':*:
1
«
-;
I
'••"• •.
>
&t ••
•s ^
X
— —
\
^
1
.,•• '
•-. ••'<
•A "
.— —
•, ""
- %
|
\ ^
''-.••'• ••
,5 s -
~~~
•• s
1
1
^
•. f"*
J 0.18%
s *"<•••
1
1
1
-/
1
1
^ v
1
1
11 <.
1
1
-
i
1
'
i
|
i
1
i
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/
Reuse
Onsite
Wastewater
Treatment
Q Treatment of ,
»3 Drganics
O
2
0.
"c
O
£ Surface
SL Impoundments
CO
co
Wastewater
Discharge
Land Disposal
i
\-
i
»-—• •
i
0.93% |
i
i
i
i
i
•• ,"•<<• - ••- " ;'- : : > ss !
*^—
ri
0.0^
••
{% 1
•••1
v •. "i. X
1
1
'• '• ,. *
"" \ / / "* "
% '' f f < ""
1
i
i
i
1
1
i
t
"-
1
1
1
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
Onsite
Wastewater
Treatment
O Treatment of
•— Organics
O
CO
Surface
Impoundments
Wastewater
Discharge
Land Disposal
I
I
I
_L
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
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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%
Recovery/
Reuse
Onsite
Wastewater
Treatment
O Treatment of
~ Organics
O
2
Q. -
"c
di
E Surface
£> Impoundments
1
Wastewater
Discharge
Land Disposal
i
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1
1
1
1
1
1
1
1
1
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
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0 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Recovery/
Reuse
Onsite
Wastewater
Treatment
1 icauiiciu wi
•^ t3rganics
£ -
c
E Surface
SL Impoundments
(8
c
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Discharge
Land Disposal
i
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1
1
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
-------
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.
-------
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
-------
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
-------
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
-------
• 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
-------
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
-------
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
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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
-------
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
-------
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
-------
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
-------
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
-------
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
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o
c
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o
d>
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a>
45%
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-------
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Recovery/
Reuse
Onsite
Wastewater
Treatment
O
o
'•£ Treatment of
55 Organics
>_
Q.
+•• __
c
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O Impoundments
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s
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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%
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Reuse
Onsite
Wastewater
Treatment
_
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Organics
O
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O
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Q_ Surface
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0 ~
cn
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C Wastewater
^ Discharge
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i
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1
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1
1
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,
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1
,
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
•g Treatment of
to Drganics
V.
f*
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+••
C
o
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cn Impoundments
en
c
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Land Disposal
i
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1
1
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i
1
i
1
i
-
1
t
i
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
—
Treatment of
Organics
0
O
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05
Q_ Surface
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"c
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03
^ Wastewater
^ Discharge
Land Disposal
i
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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
•g Treatment ot
(5 Drganics
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*••
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0
jj Surface
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i
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1
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1
1
1
1
1
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
-------
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.
-------
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.
-------
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.
-------
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
-------
• 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
-------
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
-------
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
-------
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
4-50
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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).
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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
5-9
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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
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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.
-------
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.
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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.
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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).
-------
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.
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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
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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.
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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).
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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.
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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.
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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.
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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
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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).
5-55
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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
5-57
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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.
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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.
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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
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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.
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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
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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.
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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.
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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
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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
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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).
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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.
7-17
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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.
-------
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
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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
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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
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
1
•
•
•
•
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
-------
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
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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
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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.
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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
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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).
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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.
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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
-------
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
7-34
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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
7-35
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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
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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
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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
-------
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.
-------
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.
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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).
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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.
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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.
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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.
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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.)
8-9
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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
8-10
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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."
-------
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
8-12
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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).
8-14
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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.
8-16
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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).
8-17
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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
3-11
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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
8-19
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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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