vEPA
             United States
             Environmental Protection
             Agency
              Office of Solid Waste
              and Emergency Response
              Washington, DC 20460
EPA/530-SW-86-043
October 1986
             Solid Waste
Waste  Minimization
             Issues and  Options
             Volume  III

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Waste Minimization Issues and Options
 Volume 3:  Appendices C through K
           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

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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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                       LIST OF APPENDICES

C.  RECYCLING TECHNOLOGIES AND PRACTICES

    C.I   Solvent Recycling Technologies
    C.2   Halogenated Organics (Nonsolvent) Recycling Technologies
    C.3   Metal Recovery Technologies
    C.4   Recycling Technologies for Corrosive Wastes
    C.5   Cyanides and Other Reactives
    C.6   Summary Data on Offsite Recycling Practices
    C.7   References

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

E.  CONDUCTING A PROJECT PROFITABILITY ANALYSIS

F.  EPA'S DEFINITION OF SOLID WASTE

G.  CORRESPONDENCE FROM EPA ON WASTE MINIMIZATION ACTIVITIES

H.  COMPILATION OF INDUSTRIAL WASTE REDUCTION CASES

I.   EPA'S ENVIRONMENTAL AUDITING POLICY STATEMENT

J.  DESCRIPTIONS OF STATE PROGRAMS

    J.I    California
    J.2    Georgia
    J.3    Illinois
    J.4    Massachusetts
    J.5    Minnesota
    J.6    New Jersey
    J.7    New York
    J.8    North Carolina
    J.9    Pennsylvania
    J.10   Tennessee
    J.ll   Washington

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

    K.I    Sacramento  County
    K.2   Santa Cruz County

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       APPENDIX C


RECYCLING TECHNOLOGIES
     AND PRACTICES

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                 RECYCLING TECHNOLOGIES AND PRACTICES


C.I       Solvent Recycling Technologies


    Solvent wastes  are recycled by various unit treatment operations, which may be

performed singly or in sequence.   These operations are grouped  into  the  following

technology  categories:  distillation; solids  removal; liquid-liquid  phase separation;

emulsion/dispersion  breaking;  dissolved  and  emulsified  organics recovery;  and

organics  vapor recovery.  The  recyclable product  of  the operation  may  be the

solvent or the isolated contaminants, or both.  Applications and  limitations of use of

solvent recycling operations are presented in Table C-1  and  discussed below.


    Distillation


    Separation  techniques  that   rely  on  the  boiling  point   differences  of the

components of a  liquid  waste are  called distillations  and  include pot  distillation,
steam  distillation, fractional distillation, film evaporation, and  drying techniques.

Purification of organic solvents for recycling in process applications usually requires

at least one distillation step to remove wastes^of low volatility.   Distillation is the

dominant recycling technology for solvent wastes.
        Pot Distillation describes the process of heating  liquid indirectly to boiling
        in  a pot  and then  recovering  by condensation  of the vapors  that  are  in
        equilibrium with  the  remaining liquid.  Nonvolatile residues  removed from
        the pot also  are  reclaimed  (e.g., by dryers) for  use as fuel or for  disposal.
        Pot distillation can be performed in a batch or continuous mode of operation
        under vacuum or atmospheric pressure. Operation under vacuum enhances
        removal of organics from heavy residues.

        Pot distillation  is  effectively  used  to reclaim  halogenated   as  well  as
        nonhalogenated solvents from wastes.  For example, acetone  used as a paint
        cleaner is commonly recovered  from nonvolatile  oils,  resins,  pigment, etc.,
        by  pot distillation.   The technology  is  widely  used by (offsite) commercial
        solvent recovery operations.
                                       C-1

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   1208s
                                            Table C-l  Summary of  Recycling Technologies  for Solvent  Waste  Streams
   Type of process
    Description of technology
        Applications
       timitations of use
   Distillation

   Flash distillation
Distillation in which an appreciable
proportion of a liquid is quickly
converted to vapor in such a way that
the final vapor is in equilibrium with
the final liquid (Condensed Chemical
Dictionary 1985).  Nonvolatile residues
are removed for fuel reuse or disposal.
                                                                     Allows  for  solvent  recovery.   (Also  used  for
                                                                     desalination  of  sea water.)   Widely  used.
                                                Solvent must not be thermally
                                                unstable.
   Fractional
   di st111 ati on
o
i
ro
Distillation in which the product is
collected in a series of separate
components of similar boiling range.
Part of the vapor is condensed, and the
resulting liquid is contacted with
more vapor, usually in a column with
plates or packing (Condensed Chemical
Dictionary 1985).
Allows for recovery of reasonably pure
solvent.  Widely used.
Not applicable to azeotropic
mi xtures.
   Film evaporation
A set of rotating blades inside a
cylinder moves the waste material so
that the material is evaporated.
Same as above, except less frequently
used.
Same as above.  Capital costs are
higher than for other distillation
methods.
   Steam di sti1lation
Heating accomplished by steam injected
directly into the solvent.
                                                                    Distillation at lower  temperatures.
                                                Problems with product stability,
                                                corrosion,  foaming,  and condensate
                                                water di sposal.
   Dryers
Dryers achieve removal by distillation
of remaining solvents from heavy vis-
cous organic wastes.  Solvent vaporized
off of two horizontal cylindrical  drums
heated internally.  Solvent vapors are
condensed arid recovered;  solids scraped
otl drum and packaged for disposal.
Allows for dry product recovery; frequently
used.
Requires condensation equipment to
recover solvents.

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   1208s
                                                                    Table C-l  (continued)
   Type  of  process
    Description of technology
        Applications
       Limitations of use
   Soli ds  removal
   Sedinientati on
   Fi1tration
o
i
CO
  Centrifugation
The settling out by gravity of solid
particles suspended in a liquid
(Condensed Chemical Dictionary 1985).
Oversize and heavy solids drop out
readily on standing.

Separation of suspended solids from a
liquid (or gas) by forcing the mixture
through a porous barrier (Condensed
Chemical Dictionary 1985).
Solids larger than the pore openings
in the filter media are removed.

A separation technique based on the
application of centrifugal force  to a
mixture or suspension of materials of
closely similar densitites (Condensed
Chemical Dictionary 1985).
The settling force created by the cen-
trifuge enhances separation of small
particles and less dense solids.
   Liquid-liquid  phase  separation
  Decant  tank
  APf  separator
Liquid phases will separate in storage
so that one phase can be pulled off
the top and one off the bottom.

Rate of separation of liquid phases is
increased in an open basin with large
surface area.
Preliminary purification step; allows for
discharge of water contained in waste,
and for recovery of recyclable materials.
This is a widely used technology.
                                                                    Same as above.
Same as above, except the technology is
less frequently used.
Allows for recovery of spent solvents for
reprocessing.  This is a widely used,
inexpensive technology.

Allows for recovery of oily or petroleum-
based materials.  This is widely used in
the petroleum industry.
Finely divided solids or emulsified
materials sometimes difficult to
remove by sedimentation or
filtration.
                                                Because of the array of filtration
                                                equipment, costs vary widely.
Power requirements are high, and
operating supervision and maintenance
costs may be high.
Separated nonaqueous liquid will be
saturated with water and may require
further treatment before reuse.

Same as above; also, recovered
materials may contain some tar-like
substances.

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1208s
                                                                 Table C-l (continued)
Type of process
    Description of technology
        Applications
                                                                                                                         Limitations of use
Liquid-liquid phase separation (continued)
Ti1 ted plate
separator
The addition of tilted plates
to an open basin further increases
the rate of separation in proportion
to the projected horizontal surface
area.
Same as above.  This technology is less
frequently used than the above two
processes.
Separated nonaqueous liquid will
require further processing before
reuse.
Emu1 sion/dispersion breaking
Coalescence
The union of droplets of a liquid to form
a larger droplet, brought about when the
droplets approach one another closely
enough to overcome their individual
surface tensions (Condensed Chemical
Dictionary 1985).
Liquids are pumped through a fine mesh to
which entrained droplets tend to cling;
an oleophilic medium can be used to
enhance attraction of entrained drop-
lets.
Preliminary separation of aqueous-phase waste
to be treated by biological methods
before reuse.  This method is infrequently
used.
Some emulsions are difficult to
handle, particularly those containing
surfactants.
Centri f ugation
completely
Used to remove small amounts of water

as well as solids from recovered fuel.
Same as above; also used for recovery

of nonaqueous material.
Fine dispersants may not be

separated by this method.
Chemical
de-emulsi fyi ng
agents
Addition of chemical agents to raise
or lower pH or to change attractive
forces between particles causes some
solvents and oils to separate out of
water into a liquid organic phase.
Same as above; however, it is used only
with emulsions.
Some emulsions may require large
amounts of chemicals.   Chemical
emulsifying agents are more expensive
than the air flotation process.

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   1208s
                                                                    Table  C-l  (continued)
  Type of process
    Description of technology
        Appl ications
                                                                                                                           Limitations of use
  Emulsion/dispersion  breaking
  Air  f1otation
Fine organic droplets and/or
particles are removed from water by
introducing air bubbles which
attach themselves to the droplets
and are then carried to the surface
and skimmed.
Same as for centrifugation.
Recovered organics require
considerable processing before they
can be reused.
  Dissolved  and  emulsified  organics  recovery
   Steam  or  air
   st ri ppi ng
o
i
en
   Carbon  absorption
Waste is pumped to top of a packed
column.  Steam or air is fed through
the column from the bottom, picking
up volatile organics.  Organics are
recovered from the condensate.

Water with dissolved organics is
pumped through bed of activated
carbons which absorb the organics.
Bed regenerated with steam or
certain solvents to recover organics.
Discharge of treated wastewater; recovery
of stripped materials is also possible.
This is widely used to remove ammonia from
water.
Removes large variety of organics from
wastewater.  This is more costly than
steam stripping.  It is widely used
to remove trace organics from wastewater.
May cause air emissions problems if
stripped materials are vented to
atmosphere.  Limited to use with
volatile materials.
High cost of regenerating the carbon
or incinerating it.  Requires trained
operators and close monitoring
for efficient operation.  Not
effective on ethylene (Condensed
Chemical Dictionary 1985).
   Solvent  extraction      Water and  organic  contaminants  percolated  Allows  for  recovery  of  dissolved  organics
                          through a packed  column;  preselected
                          solvent,  pumped  in  counter-current,
                          dissolves the contaminant.   Spent
                          solvent is redistilled  leaving  organic
                          waste residue.
                                           from an aqueous solution.   Less frequently
                                           used than above two methods.
                                                Solvent losses to water
                                                Need for further processing
                                                to recover materials.

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   1208s
                                                                     Table C-l  (continued)
   Type of  process
    Description of technology
        Applications
     Limitations of use
  Dissolved  and  emulfisied  organics  recovery  (continued)
   Supercritical  fluid
   ext ract ion
  Mpmbrane  separation
i
en
Similar to above, except solvent is
at a temperature above its critical
point so acts as a fluid.  C02 is
being tested on this application;
selectively extracts organic solvents
from wastewater.
Highly efficient filtration system.   Mem-
brane pore openings are submicron size
(0.0025-0.010 u).  Molecules of water
and low molecular weight compounds
pass readily; larger organic molecules
and colloidal particles build up in  the
recirculation stream until it can be
used as fuel.
No commercial applications were identified
during this study.
Recovery of some dissolved organics.   Membranes
of cellophane, collodion, asbestos fiber,  etc.,
are used in waste liquor recovery, desalination,
and electrolysis.
Substantial energy savings over
distillation processes, but
high-pressure operating equipment
is higher in cost than conventional
processing equipment.  Requires
trained operators; must be well
designed to prevent explosions.

Membrane technology is higher in cost
than older technology.  Fairly costly
compared to other processes.
  Organic  vapor  recovery
  Condensation
Solvent vapors recovered by being
fed through a condenser cooler.
Recovery of solvent and reduction of
evaporative losses.
For some materials,  condensers
may require refrigeration,
which is expensive.

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1208s
                                                                 Table C-l  (continued)
Type of process
    Description of technology
        Applications
       Limitations of use
Organic vapor recovery (continued)
Carbon adsorption
Absorpt i on
Beds of activated carbon are used to
selectively adsorb organic vapors
from gas streams.  Spent carbon
regenerated with steam;  steam and
concentrated organics are recondensed
and separated.

Gas and liquid  streams flow counter-
current to each other; gaseous material
is transferred  to the liquid streams.
Removal of  organics from air emissions.
Recovery of gaseous organics not easily
confined, such as paint overspray.
Limited use.
Carbon regeneration or inciner-
ation is costly.   Process requires
close control  and well-trained
operators.
Most organics do not have high
solubility in water.  Most
applicable to high-temperature gas
streams.

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•   Steam  Distillation is similar to pot distillation except that heat is  supplied
    by direct steam injection which reduces the distillation temperature. Steam
    distillation  is applicable  to the recovery of solvents that are water insoluble
    (i.e.,  all  water-insoluble   nonhalogenated  solvents  and  water-insoluble
    halogenated solvents). However, product instability, corrosion, foaming, and
    condensate  water disposal may cause problems  with this process.

    One restriction on the use of steam distillation  is that the recovered solvent
    must have  a significant  vapor pressure at or below  the boiling point with
    water.  A second restriction is that the substance  to  be  recovered  must be
    stable  under distillation conditions.  Despite  these  two limitations, steam
    distillation  has been  used to recover semi-volatile organics from a variety
    of process waste streams in the organic  chemicals industry.

•   Fractional  Distillation is generally used  to  separate  individual components
    of waste solvent mixtures in  cases where the boiling points  of  individual
    constituents are fairly close to one another.  In this process, the feed stream
    enters a distillation column which contains plates on  packing  which provide
    a  high  surface area  of vapor-liquid  contact.  Vapors from the top of the
    column are  collected  and condensed, and a portion  of these is returned to
    the column.

    Boiling point differences among the various  constituents strongly affect the
    design (i.e., number of stages) of a fractional distillation column.  The closer
    the boiling  points of  the  compounds being  separated, the  greater the number
    of stages required to  achieve efficient separation.

    Individual applications of fractional distillation  to recovery  of solvents  from
    waste streams include:  recovery of acetone  from  wastewater generated
    from  printed  circuit  board   cleaning  operations;  onsite   recovery  of
    isopropanol   from wastewaters  generated by the organic chemical  industry;
    and  recovery  of  solvents  from  aqueous  and  nonaqueous  mixtures in  the
    specialty organics industry (Versar 1980).  A case in point  is the separation
    and recovery of acetic acid and benzene  separately  from  ternary  mixtures
    of these compounds with  water.

•   Azeotropes.   Solvents  forming   azeotropes  can   also  be  recovered  by
    fractional  distillation  with  some modifications (an  azeotrope is  a  liquid
    mixture with  a constant boiling  point;  azeotropes  exhibit a minimum or
    maximum boiling  point relative to the boiling points of surrounding  mixture
    compositions).  The  most common method to  break a binary azetrope  is to
    add  a  third  component (also  called  entrainer),  which  forms a  ternary
    azeotrope.  The ternary  azeotrope separates in  two layers, one of which is
    enriched in  one of the feed components.   This layer  is decanted  while the
    other  layer,  containing  most  of  the  entrainer, is  remtroduced  into the
    distillation  column (i.e., refluxed).  For  example,  water  can  be  removed
    from   a 95   percent  ethanol/5  percent  water mixture  using  azeotropic
    distillation with benzene.
                                   C-8

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        Another  method  of  breaking  azeotropes  is by  changing the  pressure  of
        distillation.  The  methyl ethyl ketone-water azeotrope, which  contains  35
        percent water  at atmospheric  pressure  and 50  percent water at 100 psi
        pressure, can  be broken  by  distilling  the mixture  first  at   atmospheric
        pressure and then at a higher pressure.

        Viscous wastes, including  solvents/resin mixtures, can be recovered using
        film  evaporation.   Wiped-  and  scraped-film  evaporators  have  a  set  of
        rotating  blades housed  in  a  steam-jacketed  cylinder.  As the  waste is
        heated, the  blades move the  material so that  heat transfer at the jacket
        surface is maintained. The  bottom residue must  flow to remove it from the
        equipment.  This technology  generally  is  more  expensive  to  install  than
        other distillation techniques and is not widely used.

    *   Dryers handle  distillation  residues and separate solvents from heavy viscous
        organic wastes.  The drum  consists  of  two horizontal,  internally  heated
        cylindrical  drums that rotate in contact  with each other.   Viscous solvent
        waste is fed into the  annulus between the drums;  the solvent is vaporized,
        and the resins  and  other  nonvolatiles are  pressed into  a  flat sheet as they
        pass  down  between  the drums.  The solvent  vapors  are   condensed  and
        recovered,  while the solids are scraped  off  the drum and packaged for
        disposal.   Drying technologies  have  potential  application  to  semi-solid,
        viscous,  nonpumpable,  or  barely   pumpable  sludges  that  currently  are
        landfilled.
    Solids Removal (Liquid-Solid Phase Separation)
     03

    Elimination  of   suspended  solids  is  a  necessary  pretreatment  for  certain

recycling  technologies (e.g., fractional distillation) to reduce  fouling.   Removal of

fine  stabilizing solids, which  cause oil/water emulsions, enhances  the  subsequent

separation of  liquid  phases.  Techniques  for  the  removal  of suspended solids from

liquid solvents include sedimentation, filtration,  and centrifugation.  Filtration or

centrifugation are required for removal of fine particles.
    •   Sedimentation is accomplished in tanks or holding ponds where heavy solids
        fall out of the suspension by gravity.

    •   Filtration  includes any method by which solids larger than the pore openings
        of  a filter medium are retained by  the  filter.  Specifications  and costs of
        filter equipment vary widely.

    •   Centrifugation  is commonly used to dewater sludges and to remove  oil  and
        dirt from metal parts. The settling  force  created by a centrifuge  enhances
        separation  of  small  and  low specific  gravity  solids.   Requirements  for
        energy, maintenance, and operating supervision may be high.
                                       C-9

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     Liquid-Liquid Phase Separation


     Water-insoluble  solvents can  be separated  from wastewater  in  one or  more

organic liquid phases, and then reclaimed or reused.  For example, nitrobenzene and

aniline are separated from the  wastewater  resulting from  aniline production.  The
aniline is recycled to the process.


     Types of equipment  available for liquid-liquid phase separation include decant

tanks, API separators, and tilted-plate separators.  API separators enhance the rate
of separation achievable  in a decant tank by using an open basin with a large surface

area. The addition of tilted plates to an open basin further increases the rate of
separation in proportion to the horizontal surface  area.


     Emulsion/Dispersion Breaking


     Dispersions of solvent or oil droplets in water or of water droplets in oil can be

separated by the use of a coalescer, centrifuge, or air flotation equipment, or by the
addition of chemical de-emulsifying agents.


     •   Coalescence.  When emulsions are pumped through  a  fine mesh, oil droplets
        will coalesce into  large drops  that separate  readily.  Attraction  of  the  oil
        droplets can be enhanced by the use of an  oleophilic  medium.

     •   Centrifugation can be used  to  remove small amounts  of  water (as  well as
        solids)  from  recovered  fuel.   This  technology  has  been applied  to  the
        shipboard  removal of oil from ballast water and,  by the electric  utilities
        industry,  to  separate  impurities  from spent  dielectric  fluids processed for
        reuse.

     •   Air Flotation.  Oil  droplets  (or particles) also may be removed from water
        by dissolved or diffused  air flotation.  Air for the process first is  dissolved
        under pressure in  a  recycle  stream, which then is released directly  or
        through a  fine diffuser into an air flotation  tank.   The  air bubbles become
        attached  to  the droplets or particles,  float to the surface, and  are skimmed.
        Chemical  agents  often  are  added to improve  flocculation.   In  petroleum
        refineries,  dissolved air flotation  is  commonly  used ro  remove  oil  from
        oil-in-water emulsions.   Recovered  oil is recycled to the refinery process
        (Jacobs Engineering 1975).

     •   Chemical  De-emulsifying Agents added  to liquid wastes  raise or lower the
        pH of the liquid  or  change  the attractive  forces between  the  particles.
        These processes separate solvents and oil from  the water phase into a liquid
        organic phase.

                                      C-10

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    Dissolved and Emulsified Organics Recovery


    Organics  separation  techniques  such  as  steam   or  air  stripping,   carbon

adsorption, and  solvent  extraction are generally considered  wastewater treatment

methods.  The  organics  that  are removed  are  concentrated and  amenable  to

recovery.
    •   Steam Stripping.  In steam stripping, steam (or air) fed to  the bottom of a
        packed column picks up volatile organics from wastes pumped onto the  top
        of  the column.  The organic vapors recovered at the top of the column  are
        condensed,  and the  organics  are  recovered  from the  condensate.  This
        process is used commonly  to  remove  chlorinated solvents  (e.g., methylene
        chloride) from wastewater.

    •   Carbon Adsorption.  Wastewaters with dissolved organic solvents  in  low
        concentrations (less than 1  percent)  can be pumped  through a packed bed of
        activated carbon,  which preferentially absorbs  the solvent.  When  the carbon
        becomes loaded with the solvent, the bed can be regenerated with steam or
        another solvent.   Although  carbon adsorption has been  used successfully to
        remove low  concentrations of  halogenated solvents (such as chloroethane,
        chloroform,  1,1-dichloroethane,   1,2-dichloroethane,   1,2-dichloropropane,
        1,1,1-trichloroethane,  1,1,2-trichloroethane,   and  phenol)   from  organic
        chemical  industry  wastewaters, the  solvents  evolved as gases  during  the
        regeneration of the carbon  are not recovered for reuse.  Instead, the evolved
        gases are  incinerated (USEPA - Effluent  Guidelines Development Document
        Organic Chemicals 1981).

    •   Solvent Extraction.  Separation  of  liquid waste constituents  is  achieved
        more commonly by solvent extraction.  The  wastewater is  mixed  with  a
        solvent that  extracts  certain  components of  the  waste  stream, but is
        immiscible with the remainder of the waste.   Then the  solvent is recovered
        and recycled to the process, leaving the residual organic  waste.

        The principal use  of  solvent extraction technology is in the organic  chemical
        industry (USEPA  -  Effluent Guidelines Development Document  -  Organic
        Chemicals 1981).   Phenol from wastewater  is commercially recovered  by
        extraction with isopropyl ether  followed  by  distillation.  The  recovered
        phenol is  recycled to the process or  sold as a  chemical. Solvent extraction
        (with water as  the solvent)  is used to recover water-soluble  organics from
        halogenated hydrocarbon solvents.

    •   Supercritical Fluid Extraction is  similar to solvent extraction, but uses an
        extracting solvent whose temperature has  been  raised above  its critical
        point (where it  no longer exists  as  a  solid, liquid,  or  gas,  but simply as a
        fluid).  Critical  Fluid Systems Inc, is  testing  supercritical  caroon dioxide
        (002), which exhibits unique solvent properties in this range.  Super critical
                                     C-ll

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        C02  selectively   extracts   organic   solvents   (e.g.,  isopropanoi)  from
        wastewater.  Then the C02/solvent  mixture is decompressea,  allowing  the
        C02 to vaporize, and leaving the extracted organic solvent residue.  Finally,
        the  vaporized C02  is recompressed above  its critical  point and recycled  to
        the  process.  No commercial applications of supercritical fluid extraction to
        recovery of hazardous masks were identified during this study.

    •   Membrane Separation is accomplished  by applying external pressure to one
        side of a  membrane so that solvent in a liquid wastestream will flow in  the
        opposite direction.  Molecules of water and low molecular weight compounds
        readily pass through the membrane,  while  the larger organic molecules build
        up in the recirculation stream, becoming  concentrated.

        Either ultrafiltration or reverse osmosis can be used  to achieve  membrane
        separation.  Ultrafiltration  units  have  membrane  openings ranging  from
        0.0025 to 0.010 micron and  operate at  about  50 psig.   Reverse osmosis units
        have  smaller  membrane   openings  (0.0005  to   0.0025  micron)  than  the
        ultrafiltration units, but operate at much higher  pressures  (several hundred
        pounds).  Ultrafiltration  is applied  in  both  onsite   and   offsite  recovery
        operations to concentrate waste organics.


    Recovery of Organic Vapor from Gaseous Waste Streams


    Solvent  vapors  are recovered  from gaseous  waste  streams   by condensation,
carbon adsorption, or absorption into a liquid stream.
    •   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 stream stripping. Solvent vapors are recovered
        through  a condenser cooled by recirculated  cooling water, chilled  water, or
        a refrigerant.  The choice of coolant  is one of economics and performance
        (i.e., adequate  volatile organic chemical removal).

    •   Carbon Adsorption, described previously  for  liquid-liquid phase separation,
        has been used to recover low concentrations of solvent  (e.g., acetone) vapors
        from gas streams.  General application  of carbon adsorption technology to
        recovery  of  solvents  for reuse  has  been  limited  for  safety  reasons.
        Activated   carbon   can  catalyze  the   decomposition  of  some  organics,
        resulting in hot spots  and possible bed  fires. (However, the technology  is
        widely used in  the organic chemical industry to limit  airborne  emissions of
        toxic vapors.)

    •   Liquid Phase Absorption is the transfer of a solvent from  the  gaseous stream
        into a liquid stream.  Continuous contact of  gas and liquid is required.  The
                                      C-12

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absorption apparatus may be a tower filled with solid packing material, an
empty tower  into which  the liquid is sprayed and through  which  the  gas
flows, or  a tower containing a number of plates for increased surface area.
The gas and liquid streams are  maintained in  countercurrent flow,  thereby
achieving  maximum  concentration  driving  force  and the  highest  possible
rate of absorption of gas by the liquid  phase.  A  new  absorption  process
recovers volatile  organic  chemical  emissions  from  paint spray booths using
an oil-in-water emulsion.  After absorption, the emulsion is separated into
clean water and  a solvent-oil rich phase.  The water is recycled to the paint
booth, and the solvent-oil rich phase is processed to recover the solvent  and
recycle oil to the absorption  loop.
                              C-13

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C.2       Haloqenated Orqanics (Nonsolvent) Recycling Technologies

     Halogenated  organic wastes  that  are  not  solvents  include  the chlorinated
hydrocarbon pesticides  and  intermediates (e.g.,  chlorinated  phenols,  halogenated
aliphatic  pesticides, aldrin,  and toxaphene); polychlorinated biphenyls (PCBs); and
other chlorinated  organic wastes such  as  epoxy strippers and  still  bottom residues
from recovery of halogenated solvents.

     Recycling  opportunities are  generally more restricted for this class of material
for  two  reasons:  (1)  some  of   these  wastes,  particulary  those  containing
polyhalogenated aromatics,  may  be contamined with dioxins,  and  (2)  markets for
some possible products, such  as carbon tetrachloride, have been declining  sharply in
recent years.

     Technologies  available for recycling nonsolvent halogenated  wastes,  either for
reuse or heat  recovery,  are  discussed below.  The uses and  limitations of  each
technology are  summarized in Table C-2.

     Pesticide Dusts

     Halogenated organic pesticides and pesticide intermediates usually are recycled
onsite.  Dusts and  particulates generated either from product drying  during pesticide
manufacture or from blending  operations during pesticide formulation  are collected
by baghouse filters and recycled to  the  process.

     Pesticide Wastewater

     Recycling of wastewater from pesticide  production also is  practiced commonly
in  conjunction  with solvent  extraction, steam stripping,  and distillation operations
(see  Table 4-2).
                                      C-14

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   1208s
                                       Table C-2  Summary  of  Recycling  Technologies  for  Halogenated  Organics Waste  Streams
   Type of process
Description of technology
        Applications
     Limitations of Use
   Fuel use
   Solvent extraction
Halogenated organic wastes are used as
fuel in cement kilns.  Energy is
recovered as well  as acid gas, which
reacts with free alkali  in the cement to
produce a low-alkali cement.
Dimethylformamide (DMF) solvent extracts
PCBs from waste oils; water washing
in second stage to separate out
solvent and leave a PCB concentrate.
                                                                     Recovers heat during thermal destruction of
                                                                     organics.  Method is widely used.
Process yields a decontaminated oil,  which
could be further processed to give a
recyclable product.
o
i
Limitation imposed by maximum halogen
loading per ton of cement.  At high
halogen loadings, salts formed by
reaction of acid gases and alkali in
the cement will begin to fuse into a
molten ring.  Interferes with
operation of the kiln.

Extraction efficiency depends on
relative solubilities of PCB in DMF
and other media; in some cases, may
not give a completely decontaminated
fluid.

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    Exhaustive Chiorination

    A commercial  process  that  involves high  temperature (600°  C) and exhaustive
chlorination converts chlorinated hydrocarbon  wastes to  a salable  product, carbon
tetrachloride.  This  process has  been  used  by  Dow Chemical Corporation at their
Freeport, Texas,  facility  (Versar  1975).   However,  portions  of  the  process  at
Freeport have been discontinued  (Chemical  Week 1985).  Exhaustive  chlorination can
be used to convert highly  chlorinated still  bottoms  generated  from distillation  of
crude  halogenated  solvents to carbon tetrachloride.  Such  reclamation operations
also have practiced by Ethyl Corporation and  Vulcan Materials (Versar  Inc.,  1975;
Versar Inc., 1980; personal communication with Mr. John Huguet, Ethyl Corporation,
February 1980).

    Reclamation of PCB-Contaminated Waste Oil

    Polychlorinated  biphenyls can be removed  from waste oil by  extraction  or the
waste  oil can  be dechlorinated.  Both  processes  are available  commercially for
offsite or onsite applications.
    •   Dechlorination.  State-of-the-art  dechlorination processes  reclaim  waste
        oils contaminated with PCBs at concentrations between 50 and 10,000  ppm
        so  that  the  oil can be reused.  These processes use sodium  compounds to
        dechlorinate  the  PCB molecules  and  produce  a  nonhalogenated  organic
        compound and a sodium  salt.  The  new processes  are  patented by PPM,
        Acurex, and Sunohio, and are improvements over the original dechlorination
        process investigated by Goodyear Tire and  Rubber Company.  Dechlorination
        process equipment is mounted on mobile equipment,  which  can be brought to
        the site of the generator's facility (usually  a transformer requiring service).
    •   Solvent  Extraction.  Another new  process, based on solvent  extraction, is
        suitable   for   removing   PCBs    from    waste    oil.    This   process,
        dimethylformamide  (DMF) extraction,  also  reduces  the  volume  of  PCB
        waste by a factor of  10.  The steps  of the process are:  extraction of PCBs
        with  DMF;  extraction with water of  the DMF from  the  DMF-PCB mixture;
        and recovery and purification of the DMF  by distillation. The ourified DMF
        is recycled  to the process, and  the decontaminated oil can be reused.   The
        concentrated PCB-containing residue requires disoosal as a  hazardous  waste.
                                      C-16

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     Heat Recovery from Halogenated Organic Wastes

     Halogenated organic  wastes can be incinerated for heat recovery during the
manufacture of  other  chlorinated  organics  or  in  cement  kilns.  A  new process
catalytically destroys  the chlorinated  hydrocarbon byproducts  of  vinyl  chloride
monomer production  and recovers heat and  chlorine value without  environmental
pollution  (Benson  1979).  In  cement  kilns,  the temperature and extended  residence
time  required for adequate  calcination  of cement ensure efficient destruction of
halogenated organic wastes.  In addition to recovering energy value from the waste
during its destruction, the  acid  gas generated reacts with free alkali in the cement
to produce  a low-alkali cement. This product  is desirable in a number  of market
applications.

     The primary limitation to the use of halogenated organic  waste in cement kilns
is the maximum halogen loading per ton  of cement.  Cement  kilns typically limit
chlorine content of the waste fuel to a maximum range of 5  to 10 percent, although
a kiln  equipped  to blend the  waste with other fuel prior to burning can  handle  higher
levels.  At high  halogen loadings (greater than 10 percent) salts formed by reaction
begin to fuse into a molten ring. The molten  salts interfere with proper operation of
the kiln and can cause shutdown if allowed to build up excessively.  Also, halogen
acid gases are corrosive to  any  metal parts of the  kiln system (Stoddard et al. 1981).

     Recovery of Hydrochloric Acid

     Hydrochloric acid is commercially produced  through destruction of chlorinated
byproducts or wastes by incineration and subsequent scrubbing of combustion gases
with  water.  For  example,  at  one  facility, chlorinated organic  compounds are
incinerated in a  high performance burner, and the resulting hydrochloric acid  gas  is
absorbed  in water to produce  a 21  percent hydrochloric  acid,  79 percent  water
azeotropic mixture.  A more  concentrated  acid (35 to 36 percent hydrocnloric acid)
is then  produced by extractive distillation (Fox 1972).  At two other facilities, over
                                     C-17

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90 percent of organic wastes are incinerated and the hydrochloric acid is recovered.
At one plant, the  acid is used to neutralize other wastes, and at another plant the
acid  is sold as a product.
                                       C-18

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C.3       Metal Recovery Technologies

    Metal  recovery  processes  can  be  divided  into  the  following  categories,
representing a variety of unit treatment operations:   metal concentration, metal
reduction,  metal  substitution, and  agglomeration.  Many  of  the  concentration,
reduction, and substitution processes are widely used.  Agglomeration  techniques,
however,  have not been widely employed. Although many metal recovery operations
are performed  onsite  (for  recycling  to a  manufacturing or  finishing  process),
commercial offsite  recycling  facilities  also are available (see  Offsite  Recycling,
Section 4.3 and Appendix C-6).

    Agglomeration

    Agglomeration is  a  term describing any process of gathering  of small particles
into larger  particles,  where the small particles  still can be identified. Mill scale,
sludges, and dusts generated by various  industries (e.g., iron and steel industry)  are
agglomerated  to be  used for their  metal  values  in  blast  or  induction  furances.
Agglomeration avoids  particulate carryover  from  furances.  The  agglomeration
techniques commonly used for waste recycling include low temperature bonding,  hot
briquetting, direct reduction, and green balling.
    •  Low Temperature Bonding. In this process, the waste steam is blended with
       a  binder and the  mixture is  formed into pellets by heat  and/or pressure.
       Low temperature bonding processes differ in the type  of  binder  used  (see
       Table C-3).
    •  Hot Briquetting.  Some  metal  wastes  can  be heated to a  temperature
       between 1,600°F and 1,800°F in  a  fluidized bed  and pressed into briquettes.
       These  briquettes  are  cooled by  heat  exchange  with  the feed  (Franklin
       Associates 1982a). This process is  not widely  used in the  U.S.
    •  Direct Reduction.  Wastes containing metal oxides can be mixed  with coke
       breeze  (coke  particles having a diameter smaller  than  0.5 inch)  from  iron
       and steel  mills and  formed into  pellets.   By  a  process  called  direct
       reduction,  these pellets  are  preheated on a  grate, then reduced (i.e., the
       metal oxides  in  the pellets  are  coverted to  metals) in  a rotary  kiln, at a
       temperature of about  1,100°C, using coke as the reducing agent.  The direct
       reduction process is used  commercially  only  in  Japan (Franklin Associates
       1982a).
                                      C-19

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                                       Table C-3  Summary of Recycling Technologies for Metals-Bearing Waste Streams
   Type of process
            Description
           Applications
         Limitations of Use
   Metal  concentration processes
   Hydrometallurgi cal
   processing  (leaching)
Metals can be leached out of solids
and sludges by extended contact with
specific acids.
Extraction of metals from
hazardous sludges, brine muds.
Concentration of desirable metals must
be reasonably high (over 5,000 ppm) to
make leaching attractive.  Moderate
cost of acids used is an economic
constraint imposing lower limits on
contents of waste to be handled.
   Solvent extraction
o
i
r-o
O
   Ion exchange
   Precipi tation
   Chemical  reduction
Selective solvents used to extract
and concentrate metal cations from
aqueous solutions such as leachate.
Ion exchange resins are produced
which will selectively remove certain
metal ions but permit others to pass
when wastewater is pumped through
the packed bed.
Metals dissolved in wastewater are
precipitated out of solution by re-
acting them to form insoluble com-
pounds.

Addition of reducing agents to waste
solution containing toxic metals
causes precipitation of elemental
silver and mercury, or the reduction
of Cr+b to Cr*3.
Economically feasible for recovery of
vanadium pentoxide.  Evaporation of the
amine solvent leads to recovery of
reasonably pure ammonium vanadate.

Same as above
Same as above; frequently used.
Recovery of silver or mercury
in useable form from wastes.   Converts
hazardous CR+" to nonhazardous Cr".
Solvent losses can be a problem with
some volatile solvents.  High cost is
not feasible for many metal-bearing
wastes.

Expected life of resins is a concern in
that frequent resin replacement will
make the process more costly.
Poisoning of resin with nonremovable
impurities is also a major concern.
For many applications the process is
costly.

Recovered sludges need further
processing to recover metal  values.
Useful only for wastes containing
easily reducible toxic constituents.

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                                                                   Table  C-3  (continued)
   Type  of  process
            Description
           Applications
         Limitations of Use
   Metal  concentration  processes  (continued)
   Crystal 1i zation
   Calci nati on
o
ro
   Evaporati on
   Membrane  separation
  Adsorption
Solid metal compounds removed from
solution by cooling it,  to lower
solubility of metal salts.

Consists of reacting metal-bearing
sludges at high temperatures to drive
off water and other volatiles,
incinerate residual organics,
and oxidize remaining inorganic
compounds including metals.

Concentration for recovery by evapor-
ation.  Widely used for chrome rinse
tanks.  Also used on rinse water from
other plating operations.

Solids larger than pore openings in
the filter media are removed.  The
openings must be smaller to achieve
metal separations than those used in
organi cs.
Similar to ion exchanges in select-
ively removing materials when  waste-
water is passed through a column  of
adsorptive media.   Various natural
materials including redwood bark  and
sphagnum moss are  in commercial use
for removal  of various metals.
Same as above.  Used only in limited
cases in which recovered material
is saleable.

Converts waste to oxide that is easily
handled as feedstock by a smelter.  Used
only in limited cases.
Allows for recovery of concentrated
solutions.
Allows for recovery of concentrated
solutions.  Rarely used because of
higher costs.
Removes metals from wastewaters.
Not frequently used due to higher
costs.
Practiced only for reasonably
concentrated solutions, (i.e., above
20 percent concentration).

Not applicable to wastes containing
arsenic or selenium, which form
volatile oxides.
Energy costs place lower limits on
concentrations to which technology is
applicable.  Used only in limited
cases.

Membrane materials must be selected
based on their ability to withstand
degradation by the waste; chromic acid
and high pH cyanide baths have been
particularly difficult streams to treat
with this operation.  Rarely used
because of higher costs.

Recovery of metals from adsorbents
such as high surface area clay or
silica is difficult.  Not frequently
used due to higher costs.

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   1420s
                                                                   Table C-3 (continued)
   Type of  process
            Description
           Appli cations
         Limitations of Use
   Foam f1otati on
Involves air flotation of foams after
addition of polyelectrolyte and ad-
justing pH.  Relatively new process -
no commerical installations to date.
   MeiaJ  reduction  and  recovery
Effectively removes copper, zinc,
chromium, and lead.  Rarely used due to
higher costs.
                                                                                                               Raw material to process must be
                                                                                                               ore-like.  Many waste types
                                                                                                               unacceptable as feeds.  Rarely used
                                                                                                               due to higher costs.
   Electrolyte recovery
o
i
ro
ro
   Sodium borohydride
   Reduction  in
   Iurnaces

   Other reducing
   processes
Current passed through electrodes
immersed in the metal solution.  Metal
ions migrate to the electrode where
they give up an electron and are
plated out.

Addition of sodium borohydride to
neutral or alkaline solutions of
metals will result in precipitation
of the metallic powders out of
solution.
Recovery of precious metals.
Sludge is mixed with coke or
other reducing agent and heated.

Copper can be removed from electroless
solutions in metallic form by addit-
ion of formaldehyde and raising the
pH.  Copper will  plate onto steel
in acidic copper baths.
Recovery of mercury from chloralkali
production.
Metal  refining
Recovery of material  in metallic form.
Process becomes inefficient when
handling dilute solutions
(concentrations below 100 mg/1.)
Process limited to recovering more
noble metals, i.e., precious metals,
nickel, cobalt, copper, and mercury.
Process limited to salts for which
metals are easily formed by reduction
and to neutral or alkaline solutions.
Used in limited cases due to higher
operating costs.

High cost limits this process
to metal refining.

Metal  salt must be easily reducible.
This limits process to precious
metals, nickel, cobalt, copper,
and mercury.   Value of there covered
material must justify cost of
using the process.  Used only in
limited cases due to higher costs.

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                                                                  Table  C-3  (continued)
  Type  of  process
            Description
           Applications
                                                                                                                       Limitations of Use
  Participate  and  vapor  recovery  from  gases

  Participate  recovery
  Selective  adsorbents
o
i
  Wet  scrubbers
  Retorting
  Metal	substi tution
Fine solid particles, entrained in
baghouses and electrostatic precipi-
tators (used in air pollution control)
are recycled as feed in steel mills,
or as source of trace metals to other
industries.

Adsorbent media are available commer-
cially which selectively tie up
specific metals.  Adsorbents can be
regenerated or destroyed to recover
the metals.  An example is the
recovery of gold from cyanide-
bearing solutions; gold is adsorbed
from solution onto a resin.
Incineration of the resin produces
gold in useful form.

Vapors and extremely fine particles
can be recovered by wet systems such
as packed scrubbing columns and
impingement plate scrubbers.

Process used to recovery mercury
from sludges; waste is heated in
an oxidizing environment.  Mercury
is recovered by condensation.

Closed loop recovery system involving
a replacement reaction between
calcium and salt, added to Na-sludge
in heated reaction vessel.
Reduction of air emissions.   Widely used,
chiefly for control  of air particulate
emissions from metallurgical  industries.
Reduction of air emissions.
                                                                    Reduction  of  air  emissions.
Recovery of mercury and minimization of
hazardous waste.  If retorting is done
properly, residue may be nonhazardous.
Recovery of sodium from waste sludge
in sodium manufacture.
Material recovered is dry; wet material
may be desired.  Requires reasonably
dry gas stream for suitable recovery.
Need to regenerate adsorbents or to
dispose of sludges generated by spent
adsorbent purification.  Not widely
used due to higher costs.
                                           Need to treat or handle wastewater
                                           generated.
Energy-intensive operation.  Value of
recovered mercury may be  insufficient
to cover costs unless wastes with high
mercury content are processed.

Only applicable to waste  sludges from
elemental sodium production.

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1420s
                                                                Table C-3 (continued)
Type of process
            Description
           Appli cations
                                                                                                                      Limitations  of  Use
Agglomeration
Low temperature
bonding
Hot briquetting
Di rect reduction
Waste stream mixed with a binder;
briquettes or pellets pressed out,
which are then used as feedstock in
metals operations (steelmaking, iron).
Feed material heated between 1600°F
and 1800°F in fluidized bed, then
pressed into briquettes.
The process mixes, pelletizes,  and pre-
heats the waste stream on a grate and
reduces the pellets on a rotary kiln
by making use of the carbon in  the
pellets as the reductant.
Allows for reuse of collected particulate
materials.
Same as above.
                                                                  Some  oxide/hydroxide  wastes  from  plating
                                                                  operations,  if  kept segregated  by metals
                                                                  could be  a useful  feedstock  for a
                                                                  smelter using such a  process  to convert
                                                                  ore to metal.
Briquettes prepared by this method may
not have desired integrity at elevated
temperatures.  Use of waste by metals
procedure is probably preferable to any
onsite use of such a process.

Applicable only to solids with low
vapor pressure at briquetting
temperature.  Process is not widely
used.

Useful only with easily reducible
substances (i.e., some metal oxides).
Recovered metal  must justify cost.
Process is used as part of smelting
industry to reduce ores to metals.
Shipment of waste to smelter in lieu of
onsite processing is probably preferred.

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       Green Balling.  The  green  balling process, another agglomeration technique,
       recycles baghouse  and electrostatic precipitator dust (air pollution control
       devices) from  electric  and open  hearth furnaces  of  the iron  and  steel
       industry.  The collected dust is wetted and formed into balls, which then are
       fed back into the furnace as a material feedstock.
    Particulate and Vapor Recovery from Gases


    Metals  and  metal compounds are recovered from air or gas streams usually as
fine particles; however, more volatile metals (such as mercury, lead, cadmium, and
zinc), which tend to vaporize in high-temperature processes, are recovered from the
vapor phase.
        Particulate  Recovery.   Baghouses,  electrostatic  precipitators,  and  wet
        scrubbers are used in  many industries to capture fine solid particles.  These
        particles  may  be recycled to feed streams as  in steel  mills or  may be  a
        source of trace metals to other industries such as smelters in the nonferrous
        metals  industries.   Cadmium  dust  generated from  cadmium  batteries or
        pigment plants can be  recycled (Versar  1980).

        Vapor  Recovery.   Metal vapors  can  be  recovered  by adsorbents that
        selectively tie up metals from  gas streams.  These  commercially  available
        adsorbents  are  regenerated  or destroyed  to  recover the  metals.   Metal
        vapors  also  can  be recovered  by wet systems  such  as  packed scrubbing
        columns or impingement plate scrubbers.

        The metals  recovered by adsorption generally are disposed  of rather than
        reused (personal  communication with Dr. M.  Caprini, Modux Corp.,  1985).
        For example, in  the production of  phenol  mercuric acetate, the process tail
        gases are  passed through a  carbon adsorption column  for the  removal of
        mercury,  and the spent  carbon (containing  the mercury)  is sent offsite to
        hazardous waste  landfills or offsite reclaims.

        Retorting.  This  process is used in the chloralkali  industry (SIC  2812) to
        recover mercury from mercury-bearing sludges  and solid wastes.  The waste
        is heated  in  an  oxidizing environment.   As elemental  mercury forms,  it
        distills  from the  waste and is collected by condensation.  The residues from
        the   retorting   are   shipped  offsite  as   hazardous  wastes.   (Personal
        communication with Mr. Paul Tobia,  Plant Manager, and Mr.  George Gissell,
        Plant Environmental Coordinator, Vulcan Materials Inc., July 16, 1985).
                                     C-25

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    Metal Concentration Processes


    There are diverse methods available  to  concentrate  metal compounds  from a
bulk solid or liquid  into a  sludge  or  solution.  Unit  operations for concentrating
metals  include  hydrometallurgical  processing  (leaching), solvent  extraction,  ion
exchange, chemical  precipitation, calcination, evaporation, membrane separation,
adsorption, and  foam flotation.  These processes  have been  developed either to
recycle the  metals or to treat the bulk stream to render it nonhazardous.  The metal
concentrates formed must be treated  further to  recover the  metals  in a  usable
(salable) form.
    •   HydrometaUurqicai  Processing.    The  primary   application  of   hydro-
        metallurgical processing (leaching) is  for  metals  recovery  from  ores, but
        leaching technology also has been applied  to the extraction of metals from
        hazardous  sludges. Metals are  leached from solids and sludges by extended
        contact  with inorganic solvents.  Then the  dissolved metals are recovered by
        unit  operations  such  as  electrolysis,  chemical  reduction,  or  chemical
        precipitation followed by  filtration, electrolysis, and ion exchange.  Solvents
        used  in hydrometallurgical leaching include sulfuric acid, hydrochloric acid,
        nitric acid,  ammonia,  ammonium carbonate,  ferric  chloride,  and sulfur
        dioxide (Mehta 1981).

        Although the leaching of metals  from hazardous sludges  is  not  practiced
        widely,  one  such  application   is  in the   removal  of  mercury  from
        contaminated brine muds generated from  mercury cell  chloralkali plants.
        Vulcan  Materials  Inc.  (one facility  at Port  Edwards, Wisconsin)  leaches
        contaminated muds with sulfuric  acid  to convert the solids to nonhazardous
        gypsum  and to recover  the  mercury.   Subsequent treatment of the leaching
        solution generates a much reduced volume  of mercury-bearing wastes which
        is retorted  to recover mercury (Personal communication with Mr. P. Tobiz,
        Vulcan Materials, 1985).

    •   Solvent  Extraction. Organic solvents can  be  used  similarly to extract and
        concentrate  metal cations  from  aqueous or  nonaqueous solutions  (e.g.,
        leachates).   Commercial  application   of  organic  solvent  extraction   to
        recovery of metals is not common because of  the  high cost.  One exception
        is the recovery of vanadium  pentoxide  from spent  sulfuric acid catalysts (at
        two  plants).  The  vanadium  is  leached from the catalysts, then  selectively
        extracted   from   aqueous  solution with a high  molecular  weight amine.
        Evaporation  of  the  amine solvent leads  to  recovery  of reasonably pure
        ammonium   vanadate   ^personal   communication   with   Dr.   T.   Hurst,
        Kerr-McGee Corp. 1980).
                                      C-26

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•  Ion Exchange.  Ion exchange columns are used extensively in  large  plating
   shops  to  remove  metals  such  as cadmium,  nickel, silver, and  gold  from
   wastewaters (Ploos Van Anstel and  Frampton 1977).   When  metal-bearing
   wastewater is pumped through the column, the resins  in the column remove
   certain metal ions but permit  others  to  pass.  The treated wastewater  is
   recycled to the  process as rinse water. The resin is regenerated with strong
   acid, which, in  turn, is treated to  recover  the   metals  before reuse.  By
   removing dissolved metals  from an electroplating  bath,  the  ion exchange
   column extends  the service life of the bath.

•  Precipitation. Toxic metals dissolved in wastewaters can  be precipitated by
   addition of  chemicals,  usually  lime  or caustic soda.  This conventional
   technology  (hydroxide precipitation) has been  improved upon  by  processes
   such as sulfide precipitation, which reduce the concentrtion of toxic metals
   in the  treated wastewater.

   One commercial  precipitation  process removes  metals  from  wastewaters
   through  addition   of  a  ferrous  salt  followed  by  neutralization  and  air
   oxidation.  The  ferrites formed  from  this treatment  are  insoluble  over a
   wide  pH range  and easy  to separate because  of their magnetic  properties
   and  the size of  the  precipitate  crystals.   Information  on  commercial
   applications of this process was not available during this study.

   Nickel-plating solutions and spent-nickel catalyst are commonly recycled by
   the   electroplating  and   inorganics   chemical  (SIC   2819)   industries.
   Nickel-plating  solutions  are  reacted  with soda  ash  to  precipitate nickel
   carbonate,  which  then  is collected  and  reacted  with   sulfuric  acid  to
   generate an  impure nickel-sulfate solution.  This solution is purified  from
   iron salts by addition  of  small  quantities of sodium sulfide (iron salts are
   precipitated  as   iron  sulfide).  The  solution  is  next  separated  from  iron
   sulfide  by  filtration  and evaporated  to  recover  pure  nickel  sulfate.
   Spent-nickel catalysts, after being dissolved with a mineral acid  to form a
   nickel salt  solution,  are treated  the  same  way  as  the  nickel-plating
   solutions.  This   recovery technology  is  currently  used  by  at  least  two
   manufacturers  of  plating chemicals,  Harshaw-Filtrol  (personal  communi-
   cation with Mr.  David Wilson,  Manager of  Environmental Affairs  and Mr.
   Fred  Kaplan,  Business Manager  of  Industrial  Chemical Products  Division,
   Harshaw-Filtrol,  Inc.,  Cleveland,  Ohio, July  16, 1985) and C-P  Chemical
   (personal   communication  with  Mr.   Vincent   Krajewski,   Director  of
   Environmental Affairs, C-P Chemical Co.,  Sewaren,  New Jersey,  July  16,
   1985).

   Another  precipitation process  uses  cross-linked starch  xanthate   as the
   •chemical additive. This  process  has a fast reaction rate  and  high  removal
   rates of metals from waste solutions. It  reacts rapidly  to  tie up the metals
   and leaves very low  levels of most  metals in the solution.  The floe that
   settles rapidly can be dewatered to much  lower levels than can be obtained
                                 C-27

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   with metal hydroxides.  Subsequent treatment  of  the  precipitate with  acid
   releases the metals readily. This process is effective over a pH range from
   3 to 11.  The U.S.  Department of Agriculture holds some patents,  but  others
   are also developing patented or proprietary improvements over this process.

   Another application of  chemical precipitation is  for  the recovery  of spent
   hydrofluoric acid  etching solutions at the Conservation Chemical Company,
   St. Louis,  Missouri, facility.  The spent etching solution is neutralized  with
   potassium  hydroxide, converting the  heavy metal  fluorides  present  into the
   corresponding  insoluble  hydroxides,  which precipitate  from the  solution.
   The resulting  potassium  fluoride   sludges  are  filtered  to remove  the
   hydroxide sludge which is disposed of (landfilled) as a  hazardous waste.  The
   remaining solution is evaporated to  yield technical grade potassium fluoride
   for resale.  Approximately  2,000 tons per year of  this product are produced
   by  this  process  (personal communication  with  H.  Kaiser,  Conservation
   Chemical Company, July 16, 1985).

•  Chemical  Reduction.  In certain instances, chemical  reduction  is  required
   prior to precipitation  of metals.  For example,   to  precipitate  silver  or
   mercury as metal, a reducing agent is added to the waste solution  containing
   these metal ions.  Hexavalent chromium is reduced to  a  trivalent  state  with
   a  reducing agent such  as sodium  bisulfide or sodium  metabisulfide.  The
   trivalent chromium  can  then be  precipitated in the form of a hydroxide.  It
   has been  proposed that the hydroxide sludge can be  treated with sulfuric
   acid to recover chromium sulfate, which  can then be  used in the leather
   tanning industry.  Precipitation  processes  are  widely  used  in the inorganic
   chemical, electroplating, and metal-finishing industries.

•  Crystallization. Crystallization  of metal  ions from a  waste solution  occurs
   as  the temperature of the solution  is lowered.  This transformation takes
   place   because   metal   compounds   have   lower  solubility   at   colder
   temperatures.  Crystallization commonly  is used  to recover ferrous sulfate
   from  waste  pickle liquors  or from sulfate  process titanium dioxide  waste
   acid solutions.  The acid is pumped to a  crystallizer where the temperature
   is maintained  at  approximately  35°  to 40°F  to crystallize ferrous sulfate
   heptahydrate (FeSO^TH^O)  from the  solution.  Crystallization also is used  to
   regenerate  copper  etching baths  for  reuse.   The  baths  (with  hydrogen
   peroxide and sulfuric acid) are regenerated by refrigeration and freezing  of
   the copper sulfate crystals out of the solution.

•  Calcination.   Calcination  drives  off  water   and  other  volatiles  from
   metal-bearing  sludges by exposure to high (incineration) temperatures.  The
   residual organics  in the  sludge  are  combusted during  the  process,  and any
   remaining  inorganic compounds (including metals)  are oxidized.  Leaded  tank
   bottoms are treated by calcination  to recover lead oxide (Stoddard et al.
   1981).
                                  C-28

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•  Evaporation.  Evaporation is used to concentrate  rinse water  from plating
   operations (nickel,  cadmium,  copper,  chromium, silver, gold, and  zinc),
   yielding distilled water  and  a  metal concentrate  that  are  recycled  to  the
   rinse tanks and plating  tanks, respectively (Warnke et  al. 1977, Bhatiz  and
   Jump  1977, Elickerr and Lacy  1978,  and Caprio  et  al.  1977).  Additional
   metal  recovery  steps  may  be  necessary.   For  example,  solutions  from
   chromium rinse  tanks that are  first concentrated by evaporation are  passed
   through ion exchange columns to recover the chromium that is recycled to
   the plating baths.

•  Membrane Separation.  Membrane  separation  processes  include  reverse
   osmosis,  ultrafiltration,  and electrodialysis.  The membranes serve as  a
   medium for separating  metals  and other dissolved species  from water  and
   small  molecular species.  In reverse osmosis and  ultrafiltration separation
   processes, the waste solution is forced through the membrane  by pumping.
   In electrodialysis, an electrical  potential is  applied across  the  membrane,
   causing the transport of either cations or anions through  the membrane.

   Reverse  osmosis  membranes have  smaller  pore  openings  and operate  at
   higher pressures.  Membrane  materials must be selected  based  on their
   ability to  withstand  degradation by (corrosive) wastes.   Pretreatment of  the
   waste  is needed to  reduce plugging and  fouling of the  membrane.  Reverse
   osmosis is frequently applied to the recovery of metals from  copper and zinc
   plating solutions,  silver-bearing  photoprocessing solutions (Daignault  1977),
   and  mixed plating wastes. Ultrafiltration membranes used for  organics  can
   remove suspended,  colloidal,  and  large molecular dissolved  solids.  This
   separation technique can, therefore, serve as a pretreatment for metals.

•  Adsorption is  similar to ion exchange in selectively removing  materials when
   wastewater is passed through  a  column of adsorptive media; however,  this
   process involves a looser bond between  the  surface of the  media and  the
   metal  being  removed.  (In ion exchange resins, there is an  actual chemical
   group replacement in the  complex molecular structure of the resin.)

   Various natural  materials, including redwood  bark and  sphagnum  moss,  are
   used  commercially   for  adsorbing  metals   from  solution,  and synthetic
   adsorbents, first commercialized  in Japan, are also used  in the U.S.

   Synthetic   adsorbents  are regenerated  by  passing an  acid  through  the
   column.   Alternatively,  the adsorbent  may  be  incinerated,  leaving  an
   ash-metal oxide concentrate.

   Foam flotation is a new process,  which involves air flotation of foams after
   addition of polyelectrolyte and pH adjustment. Foam  flotation  effectively
   removes copper,  zinc, chromium,  and  lead   from waste solutions  (WPCF
   1983).  Although the economics of this process are claimed to  be favorable
   (WPCF 1983), no commercial installations were identified during this report.
                                 C-29

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    Metals Reduction and Metals Recovery


    Metals  reduction  and  recovery  operations  include  electrolytic  recovery,

chemical  recovery with sodium  borohydride, and  reduction in metal furnaces and

through other  processes.  Wastes  must  be  concentrated  by  one  of the  methods
described  above prior to application of reduction and recovery operations.
    •   Electrolytic  Recovery   is   the   most  conventional  commercial  metals
        reduction process, where current is passed through  electrodes immersed  in
        the  metal solution. Metal ions migrate to the cathode (negative terminal)  to
        be reduced  to their elemental form (by giving up an electron) and  are plated
        out.  The reaction at the  anode (positive  terminal) generates  oxygen  to
        complete the  oxidation-reduction reaction.  The  deposited  metal can be
        peeled  off  the  cathode  and  sent to  a refiner or,  if the cathode is made  of
        stainless  steel, it can  be  directly  used  as an  anode  in  a  plating   tank.
        Battelle Columbus Laboratories and  Rolla Metallurgy Center have developed
        an electrolytic process that  removes copper  from  a mixed-metals leachate.
        After removal of  copper,  the  chromium  and zinc  which remain in the
        leachate  are  recovered  by roasting.  Silver  has also been  electrolytically
        recovered from spent photographic development  solutions (Daignault 1977).

    •   Chemical recovery with Sodium Borohydride. A recently developed process
        involves addition  of sodium  borohydrate  to  neutral  or  alkaline solutions  of
        metals,  and precipitation of metals by reduction  in their elemental form.
        No additional treatment is required except for filtration of the precipitated
        metals from the solution. The metals after filtration can be sold  directly  to
        scrap metal dealers.

        Chemical recovery with the sodium  borohydride  process  is acquiring wide
        acceptance for treatment and recycling of metals in various industries.  This
        process  has been  used  to recover  mercury  from  chlor-alkali  production
        wastes,  and  precious  metals  from  spent  photographic  fixer and  plating
        solutions (Business Week 1974, Medding and Lander 1981).

        This process has  a very low capital  requirement,  but is  relatively high  in
        operating costs because of the cost  of sodium borohydride.  The  use of this
        process   is  limited  to   neutral  or   alkaline  solutions,   because  sodium
        borohydride may   cause an  explosive reaction in  acidic solutions (Business
        Week 1974).

    •   Reduction in Furnaces.  Metal refiners recover metals directly from certain
        sludges in reduction furnaces.  This operation is very similar to the recovery
        of metals from ores in furnaces.
                                      C-30

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        The sludge is mixed  with  a reducing agent (usually coke) and charged into
        the furnace.  The metallic compound is reduced to the metal,  while the coke
        is  oxidized  to  carbon  monoxide  and  carbon  dioxide.   The  high  capital
        investment limits application of this technology to metal refiners.

        Other   Reduction  Processes.    Other  reduction   processes  are   also
        commercially  available in limited applications.  For  example, copper can be
        removed from alkalone electroless solutions in metallic form by addition of
        formaldehyde.  Copper can  also be  removed as  metal from  acidic copper
        baths  if steel  sheets are placed into  the solution. In  this application, iron
        cations replace copper in the solution.
     Metal Substitution and Recovery


     A byproduct sludge containing sodium, calcium, and  their oxides,  results from

the  manufacture of sodium  metal.  The sodium  metal is recovered from the sludge

using a closed  loop recovery system  and  returned to the sodium  process  as usable
finished product (DuPont 1985).


     The recovery  process involves  a replacement reaction between  calcium and

salt, which is added to the  sludge in a heated reaction vessel.  The reaction converts

the calcium into calcium chloride and yields recoverable sodium metal.


     The sodium recovery  process at DuPont results in approximately 1,100  tons  of

usable sodium being recovered per year.  Additionally, approximately 1,200  tons  of

RCRA  hazardous  wastes  are  eliminated  per  year.   The  process  results  in the

generation of  800  tons per year of nonhazardous waste,  which is  disposed of  in  an
approved sanitary landfill.


     A somewhat different,  proprietary process  is used at the RMI sodium facility.
There, also, waste sodium-bearing sludge is reprocessed to recover the metal.


     Process Substitution


     In a few cases, it is possible to substitute the use of a new process to entirely

avoid generation of hazardous waste.  The  premier case of this situation exists  in
                                      C-31

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the  chloralkali  industry.  Up  until  1980, all  high-purity  sodium  hydroxide was
produced  by the  mercury-cell  process,  which generates  mercury-bearing  solid
wastes.  A new  process, the membrane cell, has been  developed by DuPont. The
process  also  produces  high-grade  caustic  soda   at  lower  cost  than  the  old
mercury-cell process.  In the membrane cell, chlorine  is formed at the anode and
sodium ions migrate through a membrane  to  undergo further  electrolytic  reaction
with  water  in  the cathode  compartment,  thus  forming  sodium  hydroxide and
hydrogen. Five membrane cell  plants have been built since 1980  in the  U.S.  All  of
them are fairly  small  and use either  evaporated salt  or  salt recovered for onsite
diaphragm  cell  operations  as  feedstock.   In  April  1985,  DuPont   announced
construction of a new  1,000 ton-per-day membrane cell plant at Niagara Falls, New
York,  to  open  in  mid-1987.  According  to data  supplied  by  DuPont  (personal
communication  and  material  submitted   by  Dr.  John  Cooper,  Petrochemicals
Department, E. I. duPont de Nemours, Inc., Delaware,  October 2, 1985). The plant
design calls for the  following features:

     •     Zero production of hazardous waste;
     •     Total  recycling of spent brines  to  the brine wells for  solution mining  of
          raw salt material;
     •     Production  of  hydrochloric  acid from chlorine present  in  process tail
          gases; and
     •     Total sale of the spent sulfuric acid  used in chlorine drying.

     The  effect of the construction  of  this new plant  on  the  industry  has  already
manifested itself.   Recently, Olin Corporation (Wall Street  Journal, September  27,
1985) announced the closure  of  their mercury cell  plant located in Niagara  Falls,
New York, because  they do not feel  their plant  can be competitive with the new
DuPont  facility  under  construction.    Should  the  new  facility   meet  industry
expectations, a further expansion of membrane cell  capacity is to be expected. This
may be  accompanied  by a further decline  in the amounts  of  mercury-bearing
hazardous wastes generated.
                                     C-32

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    The  number of cases in which new process developments have the  potential to
eliminate hazardous  waste has been  small.  In cases in which they do occur, such as
for the membrane cell, their effect  on future hazardous  waste generation may be
substantial.
                                     C-33

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C.4       Recycling Technologies for Corrosive Wastes


    Corrosive  wastes  that  are recycled  include spent  acids  and  alkalis  from

chemical  manufacture  and petroleum refining  processes,  and also the acid from

spent  pickle  liquor.  Technologies  commonly  used  to  recycle  corrosive  wastes
include thermal  decomposition,  evaporation,  crystallization,  ion exchange, and

oxidation.  The limitations and uses of each of these  technologies  are  presented  in

Table C-4 and discussed below.


    Thermal Decomposition


    Thermal decomposition is used in the recovery of sulfuric acid from spent acid

sludges to recover ferric  chloride  from acidic titanium dioxide  waste  and  for the

recovery  of hydrochloric acid  from  spent  pickle  liquor  or halogenated  organic

residues.
    •   Recovery  of  Sulfuric Acid.  Thermal  decomposition  is  widely  used  in
        petroleum  refineries  to  recover  concentrated sulfuric  acid  from  spent
        alkylating  acid  sludges  contaminated  with  hydrocarbons  and  containing
        water.   The  acid  sludges  are  recyucled  by  spent  acid   processors  in
        evaporators at temperatures ranging  from 2,000° to 2,300°F.  Mixed sulfur
        dioxide  and water  vapors produced from decomposition of  the  sludge  are
        passed  through  a  dust collection  chamber  for  particulate collection,  a
        waste-heat  boiler for heat  recovery, and a heat  exchanger  to lower  the
        temperature  to  700°F.  The  water  vapor  is  removed from the  gas  by
        93 percent  acid  and the sulfur  dioxide  is oxidized  to sulfur trioxide in  the
        presence of vanadium  catalyst.  Finally, the sulfur trioxide  gas is scrubbed
        with strong acid in  an absorption  tower to yeild  98 to 99 percent  sulfuric
        acid (Versar 1980).

    •   Recovery  of Hydrochloric Acid from  Pickle  Liquor. Iron  and  steel mills
        (SICs 331  and 332) generate  a  spent  pickle liquor (RCRA Code  K062^ that
        contains approximately   20  percent   ferrous  chloride   and   5   percent
        hydrochloric   acid.   Recovery   of  the  hydrochloric   acid  by   thermal
        decomposition could be practiced by many of these facilities.

        The first step in  the recovery process  is the preheating and concentration of
        the spent   pickle  liquor  in  evaporators.   This concentrated  solution  is
        introduced   into  a   hydrolysis  reactor.    The   reactor,   operating   at
        approximately 1470°F to  1830QF, creates an oxidizing  environment for the
        reaction between  ferrous  chloride  and water.   Ferric  oxide  solids  are
        produced and precipitate out of the solution.
                                      C-34

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                                        Table C-4  Summary of Recycling Technologies for Corrosive Waste Streams
 Type of process
           Descri ption
            Applications
         Limitations of Use
 Thermal decomposition
 Recovery of HC1
Hydrochloric acid containing dissolved
ferrous chloride from pickling is  re-
acted with water in the presence of
heat to yield hydrochloric acid and
ferric oxide.
Recovery of HC1 for reuse.
Hydrolysis of FeCl£ requires
a considerable input of energy; iron
oxide becomes a waste, needing disposal.
Use of FeCl2 to produce ferrous/
ferric chlorides for sale, where
viable, is preferred.  (Not widely used
due to higher cost.)
 Recovery of
CO
en
 Evaporation
Concentrated sulfuric acids contamin-
ated by water and hydrocarbons  are
burned at high temperatures.  Gases
are passed through dust collection
chamber, dried by 93% acid, and
the S(>2 present is oxidized to  SOj
in the presence of a vanadium catalyst.
The SOj is scrubbed with acid to
yield 98 to 99% H2S04.

Involves removal  of water from  the
waste by evaporation leaving a
concentrated solution behind.
Allows for Recovery of sulfuric acid.
Widely used to recover spent sulfuric
acid from refineries.
Recovery of alumina from bauxite;
recovery of sulfuric acid in nitrobenzene
production; concentration of phosphoric
acid (fertilizers) and chromic acid
(plating baths).
Transportation may be a constraint.
The facility regenerating the acid
needs to be nearby to minimize shipping
cost.  Process is costly to operate
with small volumes, but economical with
large volumes.
Only applicable to concentration of low-
volatility acids.  Will not remove
nonvolatile contaminants.  Used only
in selective cases where acids are of
higher value.

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   1420s
                                                                       Table C-4 (continued)
   Type of process
           Description
                                                                                Incentives
                                                                                                                                       Constraints
   Crystal 1i zation (continued)
   Recovery of ferric
   sul I ate or f erri c
   chloride from
   pickle 1iquor
   Caustic soda from
   aluminum etch
o
i
CO
CTi
   Ion  exchange
   Oxi dati on
Solution cooled  to  induce crystalliza-
tion.  Crystals  separated from the
acid by centrifugation for disposal
or marketing.  Acid  returned to the
pickli ng tank.

Caustic soda  is  recovered by contin-
uously pumping the etchant to a
crystallizing  tower, where precipita-
tion occurs in a controlled manner.

Process employs a resin that select-
ively adsorbs acids  and rejects
metallic contaminants.  The bed is
then flushed with water to displace
the absorbed acid for reuse.

KEL CHLOR® process reacts
HC1 with 02 at 170°  to 400°C,
nitric acid catalyst in reaction
system with 2 liquid-gas contactors
with a homogeneous gas-phase reactor
between them.   Chlorine purified
by absorption and drying with  sulfuric
acid.
Recovery of ferric sulfate or
ferric chloride allows for recovery
of iron salts.
Process removes alumina from the caustic
to then be reconcentrated for reuse.
Regeneration of electroplating,
metal finishing, and fertilizer
manufacturing wastes.
                                                                    Recovery of chlorine from
                                                                    hydrochloric acid.
Limited market  for recovered  iron
sulfate that must compete for markets
with iron sulfate derived as a
byproduct from  titanium dioxide
production.  Acid not recovered.

Impurities other than aluminum will
not be removed.  Not widely used
in the U.S.
Oxidizing agents (acids) may degrade
the ion exchange resins, leading to a
product acid contaminated with
organics.  Process is costly and not
widely used.

Application only to waste HC1 that
is gaseous.

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   Any particulates present in the hydrochloric acid  gas from the reactor are
   removed in a cyclone.  The hydrochloric acid is  next  cooled and absorbed
   with  water to  form  a  20 percent  acid  solution.  Ferric oxide  particles
   collected from  the  reactor and  cyclones  are  recycled at the iron  and  steel
   mills.

   Although recovery  of  hydrochloric  acid  from  pickle  liquor is a  capital-
   intensive operation, the value of the recovered acid could be substantial.  At
   present, however,  industry  practice  is  geared  toward recovery  of  iron
   chlorides from  this waste (K062).  This is  achieved  by reacting  the waste
   with iron, converting the pickle  liquor to an  iron chloride  solution free of
   unreacted   HCL.   The   iron  chloride  is  then  marketed.   Conservation
   Chemical in Gary,  Indiana, uses such  a  process,  as do  some of the larger
   steel   companies   (personal   communication   with   Mr. Howard Kaiser,
   Conservation Chemical, July 16,  1985).

•  Recovery of Haloqenated Acids  from Halogenated Orqanics.  This  recovery
   operation was  discussed  previously under recycling of halogenated  organics
   (Section C.2).  It  involves incineration of halogenated  organics and water
   scrubbing of the combustion  gases to recover  halogenated acids.  Because
   the  intent  of  the  operation  is  the  disposal  of  halogenated  organics  by
   incineration, any recovered halogenated acid  is a  byproduct of  the process,
   with low capital costs  and no raw materials costs.

•  Recovery of Ferric Chloride from Acidic  Titanium Dioxide  Wastes. DuPont
   recovers about  100,000 tons per year of saleable ferric chloride  from the
   wastes  generated  by   their chloride  process  titanium dioxide  plant  in
   Edgemoore, Delaware.  The technology used includes partial evaporation of
   a highly acidic  wastewater stream.  Ferric  chloride crystallizes from the
   concentrated liquor, is recovered, dried, and sold as a solid product.

   Use of  this technology has provided DuPont with  an additional  product line
   and  has saved  DuPont the cost  of having to  neutralize large volumes of
   aqueous ferric  chloride  solutions  (personal  communication with  Mr.  John
   Cooper, E. I. DuPont du Nemours, Inc., October 2, 1985).

   According to DuPont, the technology is constrained in its further application
   by  limited  markets for ferric chloride.  The Edgemoore facility  presently
   produces about 40 percent of the U.S. ferric chloride. This  process, in  fact,
   is  not  used at  other  DuPont  titanium  dioxide  plants  because of  market
   lilmitations for ferric  chloride.   Furthermore,  ferric   chloride  recovered
   from titanium dioxide  process  wastes currently competes with the material
   recovered from  waste pickle liquor from the steel industry.
                                  C-37

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    Evaporation


    Evaporation  involves vaporization of water  from  a liquid  waste  that  leaves

behind a concentrated solution.  Both atmospheric and vacuum evaporators are used

to concentrate  corrosive  wastes.   Atmospheric  evaporation can  be  achieved by

boiling the waste solution or by  heating the waste solution  (to a temperature below

its boiling point) to enhance the transfer of water from  the waste solution  into  a

sweeping  air  stream.  Evaporation under vacuum  is also commonly  performed  to

remove  water  at  reduced  temperatures.    Evaporation  is  applicable  only  to

concentrated corrosive acids or bases with low volatilities.   Examples of corrosives

concentrated  by  evaporation  are sodium hydroxide, phosphoric  acid,  and  chromic

acid.  Evaporation is  not applicable for  volatile corrosives such as hydrochloric acid

and ammonia. Use of evaporation to recover sodium hydroxide for reuse  is found in

the aluminum industry (Versar Inc.  1980; USEPA 1979).


    •   Caustic  Soda  Concentration by  Evaporation. For the recovery  of alumina
        from bauxite, hot caustic soda (sodium  hydroxide) is used to dissolve alumina
        as   sodium   aluminate.  After  removal   of  insolubles  by  filtration and
        precipitation   of  aluminum,  the  caustic  solution  is   concentrated  by
        evaporation and the concentrate is reused  in the  process (USEPA 1979).

    •   Nitration Acid Recovery by Evaporation.  Spent acid containing  70 percent
        sulfuric  acid   is generated  from production  of  nitrobenzene  by  reacting
        benzene with nitric acid in the  presence  of sulfuric  acid. After  removal of
        organic   impurities  by  stripping,  the   spent   acid  is  concentrated by
        evaporation for reuse in the nitration  process (personal communication with
        Dr.  John  Cooper,  Petrochemicals  Department,  E. I. duPont  de  Nemours,
        Inc., Wilmington, Delaware, October 2, 1985).

        To avoid the  concentration of impurities in the recycle loop, about 5 percent
        of the spent acid (after stripping) is  purged.  This purged acid is  sold  to the
        fertilizer industry  as  a commodity.  An additional 5 percent  of  the acid
        (after stripping) is  used  to  neutralize  acidic  streams from  the plant.  Ten
        percent  fresh  acid  is added to the recycle stream to replace that which was
        purged and used to neutralize the acid.

        The economic incentives for reconcentration and reuse are  commodity costs
        for  once-through sulfuric  acid, transportation  and handling costs,  selling
        expense  for spent acid, and working capital  invested  in inventories.  If the
        once-through  spent  acid   were  not  marketable,  the  additional cost  of
        neutralization would increase the incentive to reconcentration and reuse.
                                      C-38

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        The  obstacles  to reconcentration  and reuse  of spent  acid  are basically
        economic.  Large investments in equipment and environmental  controls  are
        required, and  high  maintenance  and employee protection (safety) costs  are
        inherent in  the sulfuric acid concentration  process.

    •   Phosphoric   Acid  Concentration  by  Evaporation.   Phosphoric  acid   is
        concentrated to standard acid strength by evaporation under vacuum. This
        is normally  practiced in the production of wet-process  phosphoric  acid in
        the  fertilizer industry (Versar 1980).

    •   Chromic  Acid  Concentration  by  Evaporation.  Evaporation   is  used   to
        concentrate chromic acid from  plating-rinse tanks from the metal  plating
        industry.  The concentrated solution is then reused  in plating baths. This
        technology  has  been  proposed  for  use in its electroplating  industry.  Its
        current degree of use is not known.
    Crystallization


    Corrosive wastes that are recycled by crystallization  include pickle liquors (for
recovery of ferrous  sulfate and ferric chloride) and aluminum etch (for recovery of
caustic  soda).  Acid solutions containing copper also may be  regenerated  by  this
method.
    •   Recovery  of  ferrous  sulfate from pickle liquors.  Iron  salts (mainly ferrous
        sulfate) are crystallized from  pickle  solutions to recycle  sulfuric acid  to
        pickling baths in metal  finishing processes.  Crystallization of iron salts in
        pickle liquor can  be induced by direct cooling of  the solution or by indirect
        cooling  through  the  application  of  a  vacuum and the evaporation  of water
        from the solution. Commercial processes use  either direct  cooling, indirect
        cooling, or combinations of these  two  techniques in  batch or continuous
        modes of operation.

        For direct cooling,  the solution temperature  is slowly reduced  by 35°  to
        50°F to crystallize ferrous sulfate heptahydrate (FeSO^  • VH^O) over a period
        of  8 to  16 hours. The slurry is then passed to a  collection  chamber, which
        retains  the  crystals  but  allows  the pickle liquor  to  pass  through an  acid
        recovery tank. The crystals are washed with water  to remove  free  acid and
        then  dried by drawing air from the crystal  bed.   The crystals are either
        disposed of or sold, and the pickle  liquor  is  either reused in  the  pickling
        tanks or neutralized and discharged.
                                      C-39

-------
   For  indirect cooling,  the  pressure  in the  crystallizer  is  reduced to  allow
   evaporation  of  water,  which   in  turn  cools  the  liquid  and  enhances
   crystallization  of FeSO^  •  Th^O.   Separation  of  crystals  from  the  pickle
   liquor can be achieved by centrifugation.

   Recovery of ferrous sulfate  by  crystallization is used  in large steel  mills,
   where the capital cost for a package unit is justified by  the large volume  of
   pickle  liquor recovered and reused.  The ferrous sulfate separated from this
   process is of adequate quality for use as a  flocculating agent in wastewater
   treatment  plants. Besides the size of the recovery plant, process economics
   are  highly  dependent  on the  value  of  ferrous sulfate  recovered, disposal
   costs, and availability  of a market for ferrous sulfate.

•  Recovery  of  Ferric   Chloride  from   Spent   HC1  Pickling  Solutions.   A
   somewhat similar process exists  and is used to recover  ferric chloride from
   spent hydrochloric  acid pickling  solutions.  There, the spent pickle liquor is
   reacted with iron to yield a ferric chloride solution free  of hydrochloric acid
   for sale (Versar 1980).

   This process has a  limited economic appeal for the metal finishing industry,
   which consists  of a large number of manufacturers  each generating  small
   amounts   of   spent   pickle   liquor.    For   such   small  manufacturers,
   neutralization and land disposal of wastes  appear to be  more attractive.  In
   either  case, the process  is  generally  limited to recovery of  iron  salts.
   Reconcentration of the residual acid is energy-intensive  and not practiced.

•  Recovery of Caustic  Soda from Aluminum Etching  Solutions.  A  process
   developed  by Fuji Sash Industries of Japan for the  recovery of caustic soda
   (NaOH) from aluminum etching solutions has been commercially available in
   the  U.S. since about  1980.  During aluminum  etching,  caustic  soda  reacts
   with aluminum to form sodium aluminate (NaAlO.2), which normally tends to
   hydrolize,  yielding  NaOH  and  AKOH)},  (hydrated  alumina   or  aluminum
   hydroxide). To prevent precipitation of A1(OH)3  on the  heating coils and
   walls of the etching  tank, chelating agents, such as sodium gluconate,  are
   added into  the  solution.

   Caustic  soda  is recovered  by  continuously   pumping  the  etchant  to  a
   crystallization  tower, where  AKOHDj is precipitated  in a controlled manner.
   The recovered  caustic  soda  is  then returned to  the  etching  tank.  The
   A1(OH)3  crystals  withdrawn  from the  bottom   of  the crystallizer  are
   dewatered  by means of a centrifuge, and the centrifugate  is returned to  the
   etching tank for  reuse.

   This recovery  operation  can  reduce caustic soda purchases  by 80 percent.
   The hydrated alumina  crystals produced are equivalent  to  commercial  grade
   and  can  be a  source  of income  provided a market is found. However, this
   operation is not widely used in the U.S.
                                  C-4C

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        Recovery   of  Sulfuric  Acid/Hydrogen  Peroxide  from  Copper-Cleaning
        Solutions.  Regeneration of an acid solution  for copper cleaning is commonly
        accomplished  by  crystallization  of  copper sulfate and  removal of  the
        crystals. This process is  used by printed circuit manufacturers and  metal
        finishers.   The  value  of  the recovered copper  salts justifies use of  the
        process.
     Ion Exchange

     Ion exchange resins can remove heavy metals and  cyanides from acid and base
solutions.  The purified solutions can then be reused  in the  manufacturing process.
The  ion  exchange technology  has  found  application in  regenerating  waste solutions
from the electroplating, metal finishing, and fertilizer manufacturing  industries.

     In this process, the ion exchanger is contacted with the solution containing the
heavy  metal or cyanide ion to be  removed.  When the ion exchanger is exhausted
(i.e., the active sites are partially or completely used up by the ion to  be removed),
it  is regenerated  with a concentrated solution of the ion originally present  in the
exchanger.  Although  this process regenerates a spent acid  or  base  solution,  the
undesirable ions present in  the original solution are transferred into another solution
(in a more  concentrated form)  that requires further treatment or disposal.

     A  recent  ion exchange  process  developed  by  Eco-Tech  Ltd.   of  Canada
(Pickering,  Ontario)  purifies  acid solutions  by ion  exchange without  producing  a
waste  regenerant  stream.  This process  uses a  resin that  selectively  removes acids
and  rejects metallic contaminants.  Metallic salts pass through the resin bed and are
collected.  The bed is flushed with water to displace the acid for reuse.  This process
has been used in numerous installations since the mid 1970s.

     Oxidation

     Byproduct  hydrogen  chloride  can  be  oxidized  to  produce chlorine  via  the
Kel-Chlor® Process jointly developed by M.  W. Kellogg and DuPont  (DuPont,  1985).
The chlorine  is then used to produce chlorinated hydrocarbons.
                                      C-41

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In the  Kel-Chior® Process, the  hydrogen chloride is reacted with oxygen at
170°C  to  400°C  and  15 atm (210 psig) in  the presence  of a  nitric  acid
catalyst.  The oxidation reaction is:

                            HN03
             2 HC1 + 1/2 02 	»  C12 + H20
The  reaction  system  utilizes  a  unique   combination  of  two  liquid-gas
contactors with a homogenous gas-phase reactor integrated between  them.
Recirculating sulfuric acid removes the heat of reaction and water from the
contactors.  The  recirculating acid is also  used to trap the catalyst, oxides
of nitrogen, between the  two contactors.  Reducing  the pressure on  the
sulfuric  acid  before  recycling  flashes  off the  water  and  removes  the
reaction  heat.

Chlorine  from  the  second contactor  is  then purified.   The  purification
system   involves   absorption  and  drying  by  sulfuric  acid,  followed  by
condensation to produce  dry chlorine. Waste hydrochloric acid and chlorine
from  vents  are recovered by absorption  with carbon tetrachloride.  The
Kel-Chlor®  Process  has  a 97 percent conversion  of hydrochloric  acid  and
99.7  percent yield.  DuPont operates the  process at  their Corpus Christi,
Texas, facility.

Dow Chemical  at Freeport,  Texas, reacts byproduct  HC1 with  magnesium
oxide produced  onsite to generate  magnesium chloride.  This  magnesium
chloride  is then electrolyzed in the molten state  to yield magnesium  metal
and  chlorine gas.   The   magnesium  metal  is  sold as  a  product, and  the
chlorine  is reused  onsite  to produce chlorinated organic  compounds (Versar
1979).

The  DuPont,  Mobay,  and  Dow facilities  all  generate  large volumes  of
unsalable byproduct hydrochloric  acid. The large  volumes of acid generated
justify the  costs  of  installing conversion-to-chlorine technologies (Versar
1989).  These technologies probably are  unsuited,   however,  for  plants
generating relatively  small  volumes of  waste  HC1.  Current  production
capacities for the three plants are as  follows (SRI  1985):

  DuPont (Kel-Chior®)           216,000 metric tons/year chlorine
  Moby (Electroelytic)           82,000 metric tons/year chlorine
  Dow (Magnesium)              343,000 metric tons/year chlorine
                              C-42

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C.5       Cyanides and Other Reactives


    Cyanides


    Cyanide  wastewaters   generated  from  precious  metal  (e.g.,  gold,  silver)

beneficiation are commonly recycled.


    •   Gold Beneficiation.  In gold beneficiation, the crushed ore is  contacted with
        a  cyanide solution  to  dissolve gold.  The slurry  is next filtered to separate
        the  insolubles  from  the  cyanide  solution.   Gold  from  the  solution  is
        recovered by precipitation with  zinc  dust  or  by adsorption  onto activated
        charcoal.  Most of  the  resulting gold-free solution,  which  contains  free
        cyanide  and  cyanide complexes of various metals (e.g., copper,  iron, nickel,
        zinc, arsenic, antimony,  silica), is recycled as a  filter  cake  wastewater  to
        displace  and recover additional  gold.   The  remainder  of   the  gold-free
        solution  is discharged after treatment.

    •   Limitations of Recycling  Cyanide Solutions.  Cyanide  solutions from other
        industries are not  commercially  recycled.  For example,  a study  by the
        California Department of  Health  reports  that no commercial recycling  of
        cyanide  is practiced  in California.  The  common management  practice for
        contaminated cyanide rinse waters (with concentrations less  than  100 mg/1)
        from metal finishing operations is destruction  by chemical oxidation before
        discharge to  municipal treatment  plants.  The major reason for this practice
        is the low cost of  fresh  cyanide.  Land  disposal of  cyanide wastes is  no
        longer possible as an option because it was banned by EPA several years  ago.

    •   Potential Recovery  Techniques. Techniques that  potentially  can be used for
        recovering and recycling cyanide solutions from metal plating (e.g.,  zinc,
        cadmium, brass,  and  silver  plating)  operations  include   refrigeration/
        crystallization,   evaporation,   ion  exchange,   and  membrane  separation
        (reverse  osmosis or  electrodialysis).  Among these techniques, refrigeration/
        crystallization  was proposed  and patented by the  Department of Defense
        (U.S. Patent  No. 4,365,481) to recover  and recycle  cyanide from  plating
        solutions that contain excessive amounts  of sodium carbonate (carbonate to
        cyanide  weight ratios greater than 6:1). The process involves  cooling of the
        cyanide  plating bath liquid via heat  exchange with a cold surface (e.g., a tin
        box  filled with dry ice and acetone inserted into  the liquid) to form  sodium
        carbonate crystals  on  the cold  surface.  With the removal  of  the  cold
        surface from the solution, cyanide is freed  from sodium  carbonate  and made
        ready  for reuse  in  subsequent plating operations. Although  some  members
        of the  electroplating  industry  have  found this  patented  process  to  be
        promising, they  believe  that  its  widespread use is limited because  of the
        formalities  involved  in   obtaining  the   necessary  permission  from  the
        Department  of  Defense.  The  limitation  for the  other above-mentioned
        recovery techniques is mainly economic.
                                     C-43

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    Reactives


    The primary barrier to the recycling of  most water-reactive wastes (e.g., most

alkali  metals)  is  technical.   In  specialized  applications of alkali  metals,  such  as

lithium, where  high  purity  is  critical  (metal  hydrides,  lithium  batteries,  etc.),

recycling  of purified  wastes  is impractical because contamination with oxides, dirt,

oil, etc.,  affects  product  quality  and plugs pumping equipment used  for molten

materials.   The  most   common  disposal  method  for  water-reactive  wastes  is

incineration; however, it is expensive (over $25 per pound plus transportation) and is

conducted  by  only  a small  number  of  permitted  disposal companies.   Available

technologies for recycling reactive wastes are discussed below.


    •  Ammonium Perchlorate Separation by Filtration - Evaporation. Research is
       underway  at  DOD facilities to investigate the feasibility of recovering and
       recycling  reactive wastes.   For  example,  at Indian  Head  Naval  Ordance
       Station  (NOS),  recovery and recycling  of  reactives from  a  demilitarization
       facility  is being evaluated.  This facility  houses equipment that  uses high
       pressure  water  to remove propellent  (containing  ammonium perchlorate,
       aluminum,    RDX     (cyclotrimethylene    base    trinitramine),    HMX
       (cyclotetrametaylene  tetranitroamine),   and   HBNQ   (high   bulk  nitro
       guanidine) from rocket  cases,  which are  then  reused.  A  screen in  the
       case-reclamation tank  is  used  to remove large propellant  particles.  The
       effluent from the case-reclamation  tank is  introduced  into  a baffled  tank
       where  small  particles are  settled.   The  overflow from  the baffled  tank,
       containing  approximately  0.3  percent  AP  (ammonium  perchlorate),  is
       currently  discharged through a filter located at the end of  the  discharge
       pipe.  Plans  are underway  to   eliminate  this  discharge.   The   proposed
       operation  involves concentration of  the ammonium  perchlorate solution to
        12 percent,   evaporation  of  this  concentrated  solution,  and  sale of  the
       recovered AP (with 10 to 20 percent  moisture content) to a contractor.

    •  Separation  of  Propellants  Constituents  by  Soiubilites.  Research is also
       underway  at  Indian   Head  NOS   to   recover  RDX  and  HMX  from
       demilitarization operations.  The  technique  for  separating  these propellant
       ingredients is based on differences in solubility:  ammonium  perchlorate  and
       inorganics are soluble  in hot water;  RDX is insoluble in  water, but soluble in
       acetone; HMX  is insoluble  in water and acetone, but  soluble in  dimethyl
       sulfoxide (DMSO) and dimethyl formamide (DMF).  Recovery of HMX from
       acetone is possible  by  evaporation  of  acetone.  Removal of  HMX from  a
       DMSO  or DMF  solution can  be achieved  by crystallization followed  by
       liquid-solid separation.  In addition,  research programs  are being conducted
       at the  Army Armaments R&D  Center (Dover, New Jersey) and  National
       Research Laboratory (Oak Ridge, Tennessee).
                                       C-44

-------
•  Sodium.  Waste sodium  is  recovered from  wastes  from the  Downs Cell
   Process for sodium manufacture.  The technology used was discussed earlier
   under  metal recovery (Section  C.3).  Ventron, a  manufacturer  of  sodium
   borohydride, accepts  sodium  waste  for  reprocessing  by this process to
   recover sodium.  About 600 tons/year of impure sodium waste are returned
   for reprocessing.

•  Ignitable Wastes.   Recycling  of ignitable materials for these  materials  is
   very limited. One case where recycling is documentable is in  the production
   of  elemental  phosphorus  where phossy  wastes are  generally  retorted to
   recover additional phosphorus. The  use of retorting technology is common
   practice in the  phosphorus industry.

•  Magnesium.  A second case of documented  recycling  of reactive wastes  is
   the production  of magnesium chemicals from  wastes containing low levels of
   magnesium   at  the   Mineral  Research  and  Development   Corporation,
   Harrisburg, North Carolina (personal  communication with Mr.  J. T. Rose,
   Mineral Research and Development  Corportion, December  17,  1985).  The
   company formerly shipped these wastes for disposal but now reuses them to
   recover the  magnesium  values.  The recovery process involves digestion of
   magnesium  in dilute mineral acid to  generate solutions of magnesium salts
   for agricultural applications.
                                 C-45

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C.6       Summary Data on Offsite Recycling Practices

     This  appendix presents detailed information to  supplement  the  overview  of
offsite recycling practices provided in Section 4.3 of the report.  Table C-5 lists the
number of recycling, recycling-and-treatment, and treatment-only  facilities in each
State.  These  data support  the  observation  made  in Section  4  that  recycling
facilities  are clustered in  the  more  industrialized States.   Table C-6  presents  the
distribution of  recycling and  treatment facilities available to  or located  in each
State according  to  the type  of  treatment process,   including  solvent  recovery,
resource  recovery,  mobile  treatment,  PCB  services,  and  thermal  treatment
facilities.  With the exception  of Alaska, which  is not  served by mobile treatment
facilities, all States are served by at least one facility in each category.

     Supplementary  information  on  wastes  recycled  through waste exchanges is
presented in Tables  C-7  and  C-8.  Table  C-7 lists  solvent,  metal, corrosive,
halogenated  organic,  and  cyanide/reactive  wastes by  waste  exchanges.  The wide
range of requested halogenated and nonhalogenated solvents,  metals, and  corrosive
wastes  suggests  a  market for offsite recycling.  The  absence of  cyanide/reactive
wastes  from the  lists is  consistent  with  the  dominance  of  onsite recycling  of
wastewater  treatment  sludges  from  electroplatng   operations (F006),  the  only
cyanide/reactive waste category that is recycled in high volume.  Similarly,  reuses
for halogenated organic wastes  (e.g., pesticides,  PCB-contaminated dielectric and
hydraulic  fluids) are  confined  to  onsite  applications;  such wastes  are  therefore
unlikely to be recycled through waste exchanges.

     Table  C-8  is  a  summary  of materials recycled   through  three major waste
exchanges and  the  associated  time period,  quantity of waste, value, and  distance
each  waste was transported  for recycling.  Although  the total volume  of waste
recycled is small relative to the  total volumes  of hazardous waste  generated and
recycled  during   this  period,  this profile  of  wastes  recycled  represents   the
establishment of a mechanism for continued  recycling of similar  types of wastes by
the users of the exchange.
                                      C-45

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1125s
     Table C-5  Number  of  Recycling and Treatment Facilities by State
Number of facilities
Recycl
Alabama
Alaska
Arizona
Arkansas
Cal ifornia
Colorado
Connecticut
Delaware
Florida
Georgia
Hawai i
Idaho
m inois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carol ina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
ing only
4
0
1
3
25
4
10
3
1
5 •
1
4
20
20
3
4
4
5
1
6
12
7
10
4
18
0
1
1
2
9
0
12
8
0
23
2
3
21
Recycling and
treatment
3
0
3
3
31
1
6
3
3
6
0
1
19
10
0
3
8
6
1
6
8
10
1
1
3
0
2
0
1
12
1
16
4
0
18
3
5
13
Treatment only
1
0
0
0
6
0
5
0
2
2
0
0
6
2
1
0
1
1
0
0
2
7
0
0
2
0
0
0
0
6
0
2
4
0
11
2
0
5
Total
8
0
4
6
62
5
21
6
6
13
1
5
45
32
4
7
13
12
2
12
22
24
11
5
23
0
3
1
3
27
1
30
16
0
52
7
8
39
                                     C-47

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1125s
                          Table C-5 (continued)
                                  Number of facilities
Recycling only
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
Puerto Rico
6
4
0
10
15
2
2
4
8
1
5
0
3
Recycling and
treatment
3
6
0
8
21
1
0
3
7
0
4
0
1
Treatment only
0
0
0
2
11
0
0
2
1
0
2
0
0
Total
9
10
0
20
47
3
2
9
16
1
11
0
4
Source:   EPA/530-SW-85-019.  Aug.  1985  (Draft).
                                     C-48

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                                                  Table C-6  Scope of Recycling and Treatment Facilities by State
o
States
Alabama
Al aska
Arizona
Arkansas
Cal i forni a
Colorado
Connecti cut
Delaware
D.C.
Florida
Georgia
Idaho
11 1 i noi s
Indiana
Iowa
Kansas
Kentucky
Loui siana
Mai ne
Maryl and
Massachusetts
Mi chigan
Solvent
Faci 1 i ties
serving
each State
20
-
10
8
17
5
18
9
3
10
14
7
18
12
9
9
12
13
18
13
12
12
recovery
Faci 1 i ties
located
in each State
3
-
3
3
20
4
2
1
-
4
3
-
15
2
1
1
1
-
-
1
3
8
Resource
Facilities
serving
each State
10
-
7
8
7
6
12
13
7
13
14
6
9
13
9
7
14
8
12
14
7
9
recovery
Facil ities
located
in each State
1
-
-
-
9
-
1
1
-
1
2
-
5
1
-
4
1
-
-
-
-
2
Mobile treatment
Facilities Facilities
serving located
each State in each State
13
-
12
12 1
12 6
12
12
12
10
14 3
13 2
12 1
12 1
12
12
12 2
12
12 1
12
12
12
12
PCB
Facil ities
serving
each State
26
1
16
24
16
18
26
26
22
24
25
18
23
23
20
21
27
25
25
25
25
25
services
Faci 1 i ties
located
in each State
1
-
2
1
12
2
1
1
1
1
2
2
3
4
-
4
2
-
-
2
2
4
Thermal
Faci 1 ities
servi ng
each State
5
-
4
4
6
4
11
11
3
9
10
4
5
11
5
5
12
5
9
11
6
5
treatment
Facil ities
located
in each State
1
-
1
-
4
-
0
-
-
1
1
1
4
1
-
1
2
1
-
1
2
1

-------
1127s
                                                                   Table C-6 (continued)
States
Mi nnesota
Mi ssi ssi ppi
Mi ssouri
Montana
Nebraska
Nevada
New Hampshi re
<-rl New Jersey
o
New Mexico
New York
North Carol ina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
llf =h
Solvent
Faci 1 i ties
serving
each State
8
10
14
6
7
6
8
17
2
20
19
2
22
8
4
18
10
13
3
13
12
•3
recovery
Facil i ties
located
in each State
2
1
6
-
2
-
-
7
-
6
3
-
13
2
2
4
1
3
-
2
6

Resource
Facil i ties
serving
each State
10
7
10
8
6
7
12
15
6
15
14
6
15
6
6
15
12
13
7
12
6
f.
recovery
Facil ities
located
in each State
1
-
4
-
-
-
-
5
-
3
4
-
7
-
-
3
-
3
-
1
7

Mobile treatment
Facilities Facilities
serving located
each State in each State
12
13
13 2
12
12
12
12
12 1
12
12
13 1
12
12 5
12
12
12 4
12
13
12
12 2
12 4
n
PCB
Facil ities
serving
each State
26
24
27
16
16
14
25
26
18
31
25
17
24
19
16
26
25
25
18
26
18
1 C-
services
Facilities
located
in each State
3
-
8
-
1
1
1
4
-
5
3
-
12
-
1
4
-
-
-
4
6

Thermal
Facil ities
serving
each State
5
4
5
4
4
4
10
11
4
12
12
4
11
4
4
12
10
11
4
12
4
A
treatment
Faci 1 i ties
located
in each State
2
-
2
-
-
-
-
4
-
1
2
-
2
-
-
1
-
3
-
1
3


-------
                                                                   Table  C-6 (continued)

States
Vermont
Vi rgi nia
Washington
West Vi rginia
Wi sconsi n
Wyomi ng
0
en
Solvent
Facil i ties
servi ng
each State
9
16
7
10
6
3

recovery
Facil i ties
located
in each State
_
1
6
-
6


Resource recoverv
Facilities Facilities
serving located
each State in each State
12
15 5
12 1
13
7
7

Mobile treatment
Facilities Facilities
serving located
each State in each State
12
12 2
12
12
12
12

PCB services
Facilities Facilities
serving located
each State in each State
24
27 4
16 5
25
19 4
15

Thermal
Facilities
serving
each State
10
11
3
11
5
4

treatment
Facil ities
located
in each State
-
6
-
-
1


Source:   Environmental  Information Ltd.  1984.

-------
1132s
              Table C-7  Types of Wastes Listed by Waste Exchanges
    Wastes available
 Wastes wanted
99% Methyl ethyl ketone, 1% laquer
Aromatic 140 solvent
30-35% acetone, 65-70% water
45% solvent, 45% resin and pigment
  10% wax
Orthodichlorobenzene
94% trichlorethylene,
  2% methanol,  2% acetone
Toluene diisocyanate residue
Spent halogenated and  non-
  halogenated solvents
Solvents

 Chlorinated and fluonnated hydrocarbons
 Ketones
 Esters
 Alcohols
 Aliphatics
 Freon
 Aromatics
 Various solvents,  no more than 40%
   solids
 Pigments
 Halogenated solvents
 Flammable solvents,  chlorinated
   solvents, and fluorinated solvents
    Zinc hydroxide filter cake
    Chrome drag-out solution
    Metal-plating sludge
    Electrodeless nickel bath
    Copper filter cake
    Magnesium sludge
    Aluminum oxide slag
    60-70% Fe; 6% Cr;  3% Ni;
      1% Si
    Zinc cyanide
    Zinc-containing dust from
      baghouses and scrubbers
 Metals

 Alumina,  aluminum,  and aluminum sludge
 Nickel
 Tungsten  carbide
 Copper solutions
 Tin residue
 Precious  metals
 Zirconia  and zirconium compounds
 Residues,  grinding,  spent catalysts,
   sludges,  and waste byproducts
   containing nonferrous and precious
   metals
                                   Corrosives
    Sodium hydroxide
    Calcium
    Sodium nitrite
    Acetylene sludge
    Hydrochloric acid
    Pickle liquors
      (FeCl2, or FeS04)
    Chromic acid
 Sodium hydroxide
 Aluminum chloride solution
 Sulfuric acid
 Alkali  equal  to 25,000 Ibs/mo NaOH
 Spent  acids
 Spent  alkalis
                                    C-52

-------
1132s
                             Table C-7 (continued)
    Wastes  available                 Wastes wanted
                              Halogenated  Organics

    Unrinsed  pesticide  containers     No  listings  found


                               Cyanides/Reactives

    Sodium cyanide  solution           No  listings  found
    Cyanides;  sodium, potassium,
      or metal  cyanide
    Cyanide solution  from  cyanide
      recovery  process
    Zinc cyanide
                                   C-53

-------
                    1131s
                                  Table C-8  Summary of Materials Recycled via Three Major Waste  Exchanges
o
 i
en

Type of
wastes

Waste
exchange

Time
period

Quanti ty
(tonsj(f)
Distance
transported
(miles)

Estimated
value ($)
                   Acids                       IMEa
Acids
 Hydrochlori c
 Phosphori c
 Polyphosphoric
 Sul furic
 Spent sulfuric acid
 Isophthalic acid 220
 Acetic anhydride
 Polyphosphori c
 Cupric chloride
 Ferric chloride
 Various acids

Alkalis
 Liquid caustic soda
 Sodium nitrite solution
 20% sodium sulfide
 Sodium sulfide
                   Other inorganic chemicals   IME

                   Inorganic chemicals         NEIWE
                    Chloroform                 NEIWE

                   Other inorganic chemicals   NEIWE
                    Copper sulfate crystals
                    Potassium cyanide (e)
                    Liquid bleach
                                          1985
                                                                                  9.6
                                          1985

                                          1983
                                          1983

                                          6/81 -  12/81
28.8
 1.6
                                                                .11
                                                          2,167
20
             300
             125
              25
                                                                                           200  (d)
NEIWEb
NEIWE
NEIWE
NEIWE
NEIWE
NEIWE
NEIWE
NEIWE
NEIWE
NEIWE
NEIWE
IME
NEIWE
NEIWE
NEIWE
NEIWE
1983
1983
1983
1983
6/81 -
6/81 -
6/81 -
2/82 -
2/82 -
2/82 -
2/82 -
1985
1983
1983
2/82 -
2/82 -




12/81
12/81
12/81
2/83
2/83
2/83
2/83



2/83
2/83
18
208
18
750
27
11
31
50
33
675
.3
.0
.3
.0






Unknown
25
2
100
480
24
.2
.1
.0


25
100
850
15
50
-
-
600
600
125
Unknown
_
25
975
275
Unknown
23


40
1

3
15
3
18
15
12

2
35
12
,790
645
80
,000
,647
990
,230
,000
,600
.000
,000
,782
50
,000
,000
,000
(d)
(d)









(d)




                          11,515 (d)
                           3,000
               840
               150
            52,000

-------
                                                            Table C-8  (continued)
o
i
on
en
Type of Waste
wastes exchange
Solvents
Organ ics/sol vents
Carbon tetrachloride
Ethanol
Lacquer solvent
Mixed solvents
Paint & ink wash solvents
Paint solvents
Phenol
Pol yd i methyl si loxane
Tri chloroethane
Trichloroethylene
Acetone (e)
Solvents (e)
Trichloroethylene (e)
Trichloroethane (e)
Solvents
Ethylene glycol
Solvents
Mixed ethylene glycols
Tri chloroethane
Paint thinner
Trichloroethane
Al cohols
Solvents
Chemicals

I ME
NEIWE
NEIWE
NEIWE
NEIWE
NEIWE
NEIWE
NEIWE
NEIWE
NEIWE
NEIWE
NEIWE
NEIWE
NEIWE
NEIWE
NEIWE
NEIWE
NEIWE
NEIWE
NEIWE
NEIWE
NEIWE
NEIWE
NEIWE
NEIWE
PWE

Time
period
1985
1983
1983
1983
1983
1983
1983
1983
1983
1983
1983
1983
6/81 -
6/81 -
6/81 -
6/81 -
6/81 -
6/81 -
6/81 -
6/81 -
6/81 -
2/82 -
2/82 -
2/82 -
2/82 -
1983 -

Quanti ty
(tonsMf)




639.

.
3.
3

9
8
Unknown







12/81
12/81
12/81
12/81
12/81
12/81
12/81
12/81
12/81
2/83
2/83
2/83
2/83
1984

75.
8.
27.

2.
3.
4.

10
3
3
55
5
142
16
3
42
2
0
3
5
3
7
4
2
6










Unknown
210
2476




Oi stance
transported Estimated
(miles) value ($)
-

400
450
200
200
50
175
5
175
375
60
75
125
75
25
250
75
150
Unknown
Unknown
175
75
Unknown
Unknown
_

937,960
15,077

396
400
875
16,000
2,000
20,000
250
3,000
1.500
2,000
208
2,040
None
1,100
10,000
3,000
39,000
Unknown
2,992
14,000
385
Unknown
110,000
482,200
583,489
(d)

(d)






















(9)
(h)

-------
                   1131s
                                                            Table  C-8  (continued)
o
i
Type of Waste
wastes exchange
Other organic chemicals
Metals and metal sludges

Metals

Metal/metal solutions
Copper oxide
Copper oxide
Copper sul fate
Nickel sludge
Metal/metal sludges
Copper sul fate solution (e)
Metal /metal sludges
Copper sulfate solution
IME
I ME

PWEC

NEIWE
NEIWE
NEIWE
NEIWE
NEIWE

NEIWE

NEIWE
Distance
Time Quantity hauled
period (tons)(f) (miles)
1985 .9
1985 56.9

1983 - 1984 6.9

1983
1983 10.0 1,025
1983 5.0 25
1983 41.7 50
1983 80.0 200

6/81 - 12/81 7 400

2/82 - 2/83 Unknown 150
Estimated
value ($)
1,290 (d)
24,000
1,000 (d)
15,000 (g)
18,602 (h)

5,000
2,400
37,905 (d)
5,000

1,000

400
                   a IME =  Industrial Material Exchange.
                   h NEIWE  = Nbrtheast  Industrial Waste Exchange.
                   c PWE -  Piedmont Waste Exchange.
                   d Unit cost estimate obtained from Chemical Marketing Reporter, May 28, 1984 issue.
                   e One-time only transaction.
                   f Formula used was 250 gal/ton.
                   9 Savings/earnings.
                     Average Replacement Value (Aggregate).

-------
C.7       References
Benson, J.  1979.  Hydrocarbon Processing 59(10): 107-108.

Bhatia, S. and Jump R.  1977.  Recovery makes good sense!  Environmental Science
and Technology.  11(8):752-755.

Business  Week.   1974.  Cleanup agent that recovers precious  metal.  Reprint from
November 2, 1974.  New York:  McGraw-Hill, Inc.

Caprio, C.M., Beasley,  D., LaHinger, L.   1977.  Reverse  osmosis provides reusable
water  from  electronics waste.  Industrial  Water Engineering.  October 1977. pp.
24-30.

Chemical Week.  March 1985.

DuPont.    1985.   Descriptive   information   on  processes   transmitted   by  Dr.
John R. Cooper, Manager Environmental Affairs and Occupational Health,  duPont,
Wilmington, DE  September 25, 1985.

Elicker, L.N. and  Lacy,  R.W.  1978. Evaporation recovery  of  chromium  plating rinse
water. Finishing  Industries.  2(10:28-32,2(12):  13-15.

Franklin  Associates.   1982a.   Industrial   resource  recovery  practices:   metals
smelting  and refining.  Contract No. 68-01-6000,  draft  final  report  for  the U.S.
Environmental Protection Agency, Office of Solid Waste, Washington, DC.

Jacobs Engineering.  1975.   Assessment of  hazardous  waste  practices, petroleum
industry  for  U.S.  Environmental   Protection  Agency,   Office of  Solid   Waste
Management Practices.

Medding, G.L., and Lander, J.A.  1981.  Applications for  sodium borohydride in
precious  metal recovery and  recycling.  Ventron Division  of Thiokol.   150 Andover
Street, Danvers, MA 01923.

Ploos Van  Anstel,  J.J.A. and  Frampton,  J.L..  1977.  Converting wastes  to raw
materials.  Environmental Science and Technology.  1 l(10):956-963.

Stoddard, S.K., David, G.A., Freeman, H.M.  1981.  Alternatives to the land disposal
of  hazardous  waste:   an  assessment  for  California.   Governor's  Office  of
Appropriate Technology. Sacramento, California.

USEPA.  1975. Development  Document  for Effluent Limitations  Guidelines, New
Source Performance Standards and  Pretreatment Standards  for  the Fabricated and
Reclaimed   Segment   of   the   Rubber   Processing  Point    Source   Category.
Environmental  Protection  Agency,  Effluent  Guidelines  Division, Washington, DC,
April  1974.
                                     C-57

-------
USEPA.  1979.  Development  Document for Effluent Limitations Guidelines, New
Source  Performance  Standards  and  Pretreatment  Standards  for  the  Petroleum
Refining  Point  Source  Category.  Environmental  Protection  Agency,  Effluent
Guidelines Division, Washington, DC.

USEPA.   1981.    Development  Document   for   Proposed  Effluent   Limitations
Guidelines, New  Source Performance Standards and Pretreatment Standards for the
Organic  Chemicals  Manufacturing Point Source  Category.   U.S.  Environemtnal
Protection Agency, Effluent Guidelines Division, Washington, DC.

Versar  Inc.   1975.  Assessment of Industrial  Hazardous  Waste Practices of the
Inorganic  Chemicals  Industry.   Final   Report.    Contract  68-01-2246.   U.S.
Environmental Protection Agency, Office of Solid Waste, Washington, DC.

Versar  Inc.    1980.   Multimedia  assessment/inorganic  chemicals  industry.   Final
Report  Contract No.  68-03-2604 for U.S. EPA, Office of Solid Waste  Management
Programs, U.S. Environmental Protection Agency, Washington, DC.

Wall Street Journal.  September 27, 1985.

Warnke, J.E.,  Thomas, K.G., Creason, S.C.  1977.  Waste water reclamation system
ups productivity, cuts water use. Chemical Engineering.  84(7):75.

Water Pollution Control Federation. 55(9):  1144, September 1983.
                                     C-58

-------
              APPENDIX D

NORTHEAST INDUSTRIAL WASTE EXCHANGE'S
       ON-LINE COMPUTER SYSTEM

-------
                NORTHEAST INDUSTRIAL WASTE EXCHANGE'S
                         ON-LINE COMPUTER SYSTEM
    The  Northeast  Industrial  Waste  Exchange  (NIWE)  functions as  a passive
information clearinghouse.  Established in  1981  by  the Manufacturers Association of
Central New York in cooperation with the Central New York Regional Planning and
Development Board,  the nonprofit exchange is co-sponsored and partially funded by
the  New   York  State  Environmental  Facilities   Corporation  and by  the  Ohio
Environmental  Protection Agency.  The information  is  widely circulated  but  used
primarily in New York, New Jersey, New England, Pennsylvania, Ohio, and Maryland.

    Information is distributed in two  ways; a Listings Catalog is published quarterly,
and a  computerized  waste  materials listings service is available.  Each February,
May, August, and November, a list  of "Materials Available" and "Materials Wanted"
is printed  and distributed  as widely as possible, with  current  circulation numbering
8,500.  A company wishing to have  information  included in a  list  may do so for $25
for three  issues.  The  information  is  also  made  available   on  the computerized
listings for  the same period  of time (Northeast Industrial Waste Exchange, Listings
Catalog, Issue No. 18., November 1985.,  p. 5).

    The computerized service is provided free  of  charge and  is available to  anyone
having  access to  a microcomputer and modem;  the Exchange  provides the necessary
password.    The  service  is  designed  to  allow   immediate access   to  current
information. Figure  D-l provides an  example of a search.  In  this  case, the searcher
is looking  for a company in  New Jersey or  New  York  (EPA  Region 2)  that  wants
recyclable  solvents.   The  inquirer  would  then  notify  the exchange of  interest in
either  of the matches found.  The  companies listed would  then  be notified so that
the two parties could negotiate an  exchange (personal communication  with  Lewis
Cutler, NIW, December  18, 1985).
                                       D-l

-------
USER INDICATES  —
TYPE OF LISTING,
IN THIS CASE. USER
IS INTERESTED IN
WASTES WANTED
USER INDICATES	
DESIRE TO SPECIFY
 DESIRE TO SPECIFY
 LISTING BY EPA REGION
        386 RECORDS  	
1. Type of Listing
2. Listing Category
3. Listing Code         :
4. Material Type
5. State
6. EPA Region
7. Surplus Material      :
Display
Up one level
Main level
Exit
Enter selection: 1

Enter Available or Wanted: WANTED
                107 RECORDS
                                                                            INDICATES TOTAL NUMBER
                                                                            OF LISTINGS CURRENTLY ON
                                                                            THE SYSTEM
                                      1. Type of Listing
                                      2. Listing Category
                                      3. Listing Code
                                      4. Material Type
                                      5. State
                                      6. EPA Region
                                      7. Surplus Material
                                      Display
                                      Up one level
                                      Main level
                                      Exit
                                      Enter selection: 2
                                                         : Wanted
                                       THERE ARE 107
                                       LISTINGS OF
                                       WASTES WANTED
THE LISTING CATEGORY

OPPORTUNITY TO
SPECIFY WASTE
CATEGORY AND
SELECTS 04, WHICH
IS SOLVENTS
01 • Acids
02 - Alkalis
03 • Other inorganic chemical!
04 • Solvents
06 • Oils and Waxes
07 • Plastics, and Rubber
08 • Textile* and Leather
09 • Wood and Paper
10 - Metals and Metal Sludges
11 • Miscellaneous
14 RECORDS
1. Type of Listing Wanted
2. Listing Category Solvent!
3. Listing Code
4. Material Type
6. State
6. EPA Region
7. Surplus Material
Display
Up one tovel
Main level
Exit
                                                                            THERE ARE 14 LISTINGS
                                                                            OF SOLVENTS WANTED
                                      • USER THEN REQUESTS
                                       EPA REGION 2

                                      • THERE ARE 2 LISTINGS OF
                                       SOLVENTS WANTED IN
                                       REGION 2
 USER REQUESTS 	
 THAT THESE LISTINGS
 BE DISPLAYED
 LISTINGS ARE
 THEN PRINTED,
 SHOWING LOCATION
 AND TYPE OF SOLVENT.
 IF USER IS INTERESTED IN
 CONTACTING THE PERSON MAKING
 THE LISTING, HE OR SHE MUST
 CONTACT NIWE WITH THE
 LISTING NUMBERS
                                      Enter two digit EPA Region Code: 02
                                                       2 RECORDS
                                      1. Type of Listing        Wanted
                                      2. Luting Category       Solvents
                                      3. Lining Codes
                                      4. Materiel Type
                                      5. State
                                      6. EPA Region          02
                                      7. Surplus Materiel
                                      Display
                                      Up one level
                                      Main level
                                      Exit
                                      Enter selection: D
SOLVENTS                      NE: W04-0022
LOCATION: NJ                  USEPA Region: 02
ALL TYPES FROM UPSTATE NY ONLY.  CATERING TO LESS THAN
TDUCKLOAD GENERATORS. BULK/DRUMS

SOLVENTS                      NE:W04-0023
LOCATION: NJ                  USEPA Region: 02
WILL PURCHASE SPENT CHLORINATED SOLVENTS FOR RECYCLE AND
RESALE ALSO FLUORINATED SOLVENTS, KEYSTONES. ESTERS,
AND MIXTURES. TRAILER OR TANK TRUCK LOADS NEEDED. BULK.
EAST COAST.
                  Figure  D-1   Sample Output from NIWE Computer Search
                                                     D-2

-------
                  APPENDIX E






CONDUCTING A PROJECT PROFITABILITY ANALYSIS

-------
             CONDUCTING A PROJECT PROFITABILITY ANALYSIS

     This appendix provides information  on  how a profitability analysis is conducted
to evaluate investments in waste minimization technology and methods.  The crucial
question in making an investment in waste  minimization is "How much  will it return
to the firm?" To answer this question,  a method for evaluating the profitability of
the investment and  comparing it to other investment opportunities is required.

     The simplest method to use  is  the  payback period.  The  payback period is
defined as the  minimum length  of time  required to recover the modification cost in
the firm of cash  flows to the project, based on total income minus all costs except
depreciation.  The formula for quickly estimating the  payback period (PBP) is:

          PBP    =   	depreciable capital investment	
                    avg. annual profit + avg. annual  depreciation

     For a waste  reduction project, the  denominator  in the formula would consist of
average annual cost savings plus average  annual depreciation. For example,  suppose
a waste generator installs a  piece  of equipment  that generates $100,000 per year in
cost savings and depreciation. If the total cost of the equipment was $300,000,  then
the payback  period  is three years.  This formula  is reliable only for  projects that
return consistent amounts from year to  year.  For projects  with a high variation in
annual  returns,  it  is necessary  to calculate the cumulative total each year,  and
check it against the depreciable  capital investment. Payback periods in the range of
three to four years are considered acceptable for low risk  investments.

    The payback period  is a measure  of an investment's liquidity (i.e., how  fast the
cost is recovered).  A  short payback period  is thus a desirable  characteristic.
Selecting  a  waste reduction project over another investment solely on the  basis of
its short payback  period  may not be wise because another alternative with a longer
payback period may  offer a higher return on investment  over its  assumed economic
                                       E-l

-------
life.  The payback period does not measure  the profitability of the investment, nor
does it account for the  time value of money or for inflation.  For  these  reasons,
many  corporations use discounted cash flow methods that take  these factors into
account.

    The discounted cash  flow (DCF) method has two main  variants.   One of these
variants is the net present value (NPV) method,  which recognizes  the time  value of
money by discounting  projected net cash flows to the present.  The NPV  method is
shown  by the formula:

          NPV  =    §     (PTCF)i
                    i=o    (1+r)1
where
          PTCF =   the post tax cash flow
          r      =   the average cost of the capital
          n      =   the assumed  life of the  project

    If  the net present  value of a project is higher than zero,  then the investment is
earning  more than  the  cost of capital  and the  firm  can increase  its  wealth  by
undertaking the project.   The other variant of the  DCF  method is  the internal rate
of return (IRR)  method,  in which  a discount rate is found such  that the sum of the
present values of future net cash flows, including the initial  cost of the investment,
is  equal  to zero.  If this rate, called the internal rate of return, is higher than the
firm's  average cost of capital (which is  the  minimum required rate of return)  then
the project  is  profitable.   Typically, the  initial  cost  of  implementing a waste
reduction program outweighs the short-term savings in the total cost  of  hazardous
waste  generation.   However, by   using  the DCF  method,  one  can  compare  the
cumulative effect  of the program on the facility's cash flow to the  total cost of the
investment.   For investments with a low  level of risk, a post tax internal rate  of
return  in the  12  to 15 percent range is frequently acceptable.

    The  first step  in evaluating  a  waste  reduction project is to estimate the future
cash flows the investment will generate.  Investments in  waste  reduction  can differ
from other investments in at least  two important respects.  First, waste reduction is
                                      E-2

-------
often  an  investment  not to generate  revenue but  to  reduce  future  costs  (e.g.,
cleanup, liability insurance,  and disposal costs). These cost savings will be reflected
in the  project's cash  flows.  Second,  a  waste reduction  project  may offer  the
possibility of  using an accelerated depreciation schedule, in which case a tax savings
will be realized, which in turn will increase the project's net cash flow.

    The main difficulty in estimating project  cash  flows  is that these cash  flows
occur  in   the  future,  and  thus  forecasting  of  future production  volumes,  tax
requirements, and other related factors becomes necessary.  Once the  estimates  are
made,  they should be organized for  the  analysis.  Summary  forms can be  used to
classify the estimates by category and year.  An investment summary  form  contains
information  on   fixed  and  working  capital requirements.  A  sample  investment
summary  form appears  in Figure E-l.  A depreciation  summary  form should  show
depreciation amounts  relating  to each piece or category of equipment (especially if
they are  depreciated at  different rates) and yearly depreciation amounts.   Tax
credits for  equipment purchases and  writeoffs should also be included.  This makes
annual tax savings in the form  of depreciation, tax  credits, and write-offs readily
available.

    A   summary   form  can  also  be  constructed   for  gross  savings  from   the
investment.  A  sample gross savings  summary form  appears  in Figure E-2.  Cost
impacts should be investigated  for the cost categories outlined  in Section 5.1.3.  Not
all of  the  costs  listed  are  easily estimated.  For example, future cleanup costs (see
Section 5.2.2) are  uncertain,  as  are the  costs  of pollution  liability  insurance,
emergency preparedness, and State fees and  taxes.  Estimation of many cost  savings
will involve making assumptions about future  regulatory requirements.  The trend
has been for these requirements to  become more stringent and  for waste generation
costs to rise.  A  conservative estimate of cost savings from the project is obtained
if it is assumed  that  the firm would incur the present waste generation costs  over
the period of time that corresponds to  the life of the investment.
                                      E-3

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1333s
OUTLAYS
Land
Bui Idings
Equipment
(1) Total capital
Project supplies
Spare parts
Other
(2) Total expenses
Cash
Accounts receivable
Inventories
(3) Subtotal current assets
Accounts payable
Income taxes payable
(4) Subtotal current liabilities
(5) Working capital [(3) - (4)]
TOTAL OUTLAYS [(1) + (2) + (5)]
ANNUAL PERIOD
1

















2

















3

















4

















5

















                            Figure E-l   Investment Summary
                                         E-4

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           1357s
AVOIDED COSTS
Disposal fees
Generator fees/taxes
Transport
Storage and handling
Compliance equipment and
pre-disposal treatment
Permit costs
Reporting costs
Manifesting costs
Emergency preparation
and cleanup
Pollution liability
i nsurance
Raw material purchases
GROSS SAVINGS
ANNUAL PERIOD
1












2












3












4












5












6












7












8












9












10.. .n












I
CTI
                                                            Figure E-2  Gross Savings Calculation Form

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     Finally, it is not unusual to vary the financial performance  requirements (e.g.,
internal  rate  of  return)  of  an  investment  with respect  to  an  identified  but
unquantified level of risk.  In this manner,  it may be appropriate to decrease  the
financial performance requirements imposed on  investments in waste minimization.
Such adjustments would reflect  the potential benefits associated with  investments in
waste  minimization, in terms of avoided future  costs (e.g., cleanup waste transport
and disposal, and pollution liability insurance) which were not quantified  and did  not
enter  the  analysis directly.  For example,  the  acceptable payback  period  may be
increased to five years instead of the  more  conventional  three  to  four years to
account  for  the  non-inclusion  of   the  hard-to-estimate  avoided  future costs.
Alternatively, the acceptable internal rate of return may be lowered for  the same
reason (i.e., unquantified future  cost savings).

    Once  the  depreciation and  cost savings have been  calculated, a  cash flow
summary  can  be  prepared.   A  sample  cash   flow  summary  form  appears in
Figure E-3.  From gross  savings, additional operation costs attributable  to  the
project, such as extra manhour and energy requirements, are subtracted as  are other
cash  expenses.    These  other   cash expenses   include   project  start-up  costs,
construction start-up, and  the  cost of off-spec product turned  out  during  project
operation.  Annual  depreciation  and tax credits from the depreciation  summary form
are then subtracted to give  net profit before taxes.

    Cash  flow estimates used   in investment  profitability  analysis  are  generally
presented after taxes. Applying the appropriate  tax  rate to  net  profit  gives  net
profit  after  taxes.  Adding back  depreciation  and tax credits  gives  the  annual
post-tax  cash flow.  These cash flows  are used to calculate  payback  period,  net
present value, and internal rate  of return for the  investment.

    A  discounted cash flow calculation form appears in Figure E-4. Here, time "0"
is  the start of  the  construction  period.  Discounted cash  flow  methods  require
choosing a reference point in time at which the value of the return generated by  the
                                      E-6

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1357s
CASH FLOW SUMMARY
Annual production quantity
Net receipts or gross savings
Less: cash operating costs
Less: other cash expenses
Less: depreciation, tax credits
and write-offs
Net profit before taxes
Less: income taxes at %

Net profit after taxes
Add back: depreciation, tax
credits, etc.
POST-TAX CASH FLOW
ANNUAL PERIOD
1










2










3










4










5










6










7










8










9










10. ..n










                                                       Figure E-3  Cash Flow Summary

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       1359s
i
cc

CASH
FLOWS
TRIAL
1
discount
rate
TRIAL
2
di scount
rate

Investment summary
Cash flow summary
Net of all cash flows
Discount factor
Present value
Discount factor
Present value

ANNUAL PERIOD
1








2








3








4








5








6








7








8








9








10. ..n









TRIAL
1
di scount
rate
Discount factor
Present value




















                                                            Figure E-4  Discounted Cash Flow Summary

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investment  will be  measured.  The  important  thing  to  remember is that  cash
amounts spent  or received before time "0" must be  escalated (or compounded), and
cash amounts spent  or received after time "0" must be discounted to  reflect  their
proper value at that  point in time.

     Using  the  amounts from  the investment  and cash flow summaries,  net  cash
flows (post-tax cash flow minus  investment)  can be  entered for each  year. To
calculate the net  present  value  of the project, the net cash flows are reduced by
discount factors corresponding to the  firm's average cost of capital.  The sum of the
discounted cash flows is the  net present value of the project.  As stated above,  a
positive  net present  value  means  that  the  project will  increase the wealth of the
firm.

     Calculating the  internal rate of  return (IRR) is  more difficult. The unknown to
be solved for is the  discount rate that makes  the  sum  of  the  discounted  net  cash
flows,  including the  initial cost  of the investment,  equal to zero. Finding the proper
discount rate is an iterative process.  If a  rate produces a sum higher than zero,  then
a  higher rate  must be  tried.  A number  of financial  analysis software programs
contain algorithms that greatly simplify this calculation.

     Investment projects analyzed  using discounted cash  flow methods  can be
compared only  if  the  reference  point  — time "0" — is the same  for  all  projects.
For  ranking  projects,  the internal  rate  of return  method  is preferred by  some
companies  because it  provides comparable indices,  whereas the net present value
method  gives  cash  amounts  resulting  from  different  investment commitments.
However,  the  net  present   value   method can  be  modified slightly  to  give  a
benefit-to-cost ratio (i.e., the dollar return per dollar  invested).   Calculating this
ratio for all  investment  opportunities also yields a set of indices by which projects
can be ranked.  In addition, the  NPV method allows  returns to  be  summed over  a
group of investments because returns  are given in current  dollar amounts. This is
amenable to the capital budgeting  process, where the  firm is trying to maximize the
profits obtainable from a fixed pool of funds.
                                      E-9

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    Other  measures can be employed to assess the impacts of investment projects
on firms.   For  example, contribution analysis can be used to rapidly determine the
effects  of  changes in manufacturing costs on profitability.  These methods  are not
substitutes for DCF  methods.  The  objective is always to maximize the  present
value  of the cash flow that can be generated by the available pool of capital.
                                    E-10

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          APPENDIX F




EPA'S DEFINITION OF SOLID WASTE

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                      ERA'S DEFINITION OF SOLID WASTE

    EPA  published  a  revised  version  of the  definition  of  solid  waste  in  the
January 4, 1985, Federal  Register.  The  revised  definition  introduces  new tests by
which  a substance  may  be  deemed  a  solid  waste  and legitimately recycled.  In
essence, this revision defines  RCRA jurisdiction  over materials being recycled to be
determined  by what the material is and how it  is being recycled.

    The definition  itself is  complicated;  as an  aid  to  understanding it, the  flow
chart (Figure F-l) provides an overview  of the  entire definition, with appropriate
references  to the position of  the regulation.  The central concept in this definition
of solid waste is that of  throwing something away. If a material  is thrown away, it
is a solid waste;  if  it  is not thrown away, it  is not a solid waste.  The definition
expands the concept of throwing away to include (1)  storing or treating the material
if the  storing or treating occurs prior to its being thrown away, or (2) certain types
of recycling activities.  In the former  case,  storing or treating the material prior  to
recycling may  meet  the specified  specifications for solid waste,  while in the latter
case, qualification as a solid  waste is dependent upon what  the material is and  how
it is  to be  recycled.  Thus,  certain  types of recycling  activities may  be deemed
throwing away.

     Another important  aspect of the definition  is that although  a material  may
qualify as a solid  waste, any activity associated with it is not automatically  subject
to  RCRA regulation. A solid waste material  would  be regulated only if  (1) 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  various  wastes  recycled  onsite  may  qualify  as   solid  wastes  under the
definition, the actual recycling activity is not regulated  under RCRA. 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
RCRA  regulations would apply to  the storage of such  waste.  In  such  instances, the
recycling activity would still not be regulated.  For wastes that  are  recycled by
shipping  offsite,   and   which  qualify  as solid  wastes  under  the  definition,  the
manifesting  requirements of  the RCRA regulations  would  apply.   Similarly, if the
                                       F-!

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recycling facility  stores  the  wastes  as  described  above,  the  appropriate RCRA
regulations  would  apply.   There  are,  however,  no  current  waste  management
standards that apply to the recycling practices themselves (40 CFR 261.6 and 266
Subpart C).

    Below are brief descriptions of the four major activity  areas  delineated in the
definition of solid wastes, followed by a discussion of the  incentives and constraints
to recycling that the new definition may pose.

    I.      Major Activity Areas Included in the Definition

    The definition  states  that  four types  of recycling activities  are  within EPA's
jurisdiction:

    1.   Use constituting disposal;
    2.   Burning waste or  waste  fuels  for  energy  recovery  or using  wastes to
         produce a  fuel;
    3.   Reclamation; and
    4.   Speculative accumulation.

    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 of Volume  1 provides a summary of which materials are defined as
solid wastes when handled  in the respective activity areas.

    A.    Use Constituting Disposal

    With the exception of commercial chemical products for which land  application
is  the normal, intended use, all waste materials that are hazardous  are  defined as
solid wastes when  placed  on or in the land.  An  example of a land-applied waste
material  that  would  not  be defined as  a solid waste is rinsate  from  pesticide
containers.  The rinsate is essentially the  same  product, and is  being applied to the
land in the manner intended for the original product.

                                      F-2

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Figure F-1. Flow Chart of EPA's Definition of Solid Waste
                         F-3

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    REPRINTED WITH
    PERMISSION OF THE
ENVIRONMENTAL LAW INSTITUTE
   WASHINGTON. DC 2Wt»
                                                                      Figure F-1.  Flow Chart of EPA's Definition of Solid Waste (Concluded)
                                                                                                         F-5

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    As another example, assume that a waste stream is mixed with oil  and  placed
on the land.  If the waste  material  is a listed or characteristic hazardous waste, it
qualifies as a solid  waste under  the  definition.  Because of this  classification, the
placement  of this material on the  land would now be subject  to RCRA regulation.

    Not all hazardous  waste-derived  products are subject  to  regulation, however;
their  classification as solid wastes  does not imply that they are fully regulated.  If
the waste is used to make commercial fertilizer, the application of the fertilizer to
the land is not presently regulated. There are important issues associated with this
example, however, and  they are discussed below in  further detail.

    B.    Burning for Energy  Recovery

    With the  exception of waste  materials that are commercial chemical products
intended for burning or using as an  ingredient in a fuel, hazardous wastes burned for
energy recovery are solid  wastes.  Although  they are considered solid wastes,  the
actual burning of the materials is not yet regulated.  Eventually there will be limits
imposed on the contaminants for  the  materials burned  in boilers  and other energy
recovery devices; a  rule  to  this effect  was published in  the November 29, 1985,
Federal Register.

    Another distinction made by EPA  is between burning for material recovery and
burning for energy recovery.  If a material is burned  as  part of a  material recovery
process, it  would not be considered to be burned as a fuel, provided that the burning
is an  integral  part of the normal recovery process.  If burning is not a normal part of
the operation, EPA  will consider the materials  to  be  burned  as a fuel and  will
regulate such  burning  accordingly.  Also,  when  both  materials and energy  are
recovered from burning waste materials, EPA will consider it to be burned  as a fuel.

    C.    Reclamation

    The reclamation of a waste  refers to  the  processing  or  regeneration of  that
waste  to enable  the  recovery of a  usable product.  Materials  defined as hazardous
wastes that are  reclaimed prior  to being recycled  are solid  wastes,  except  for
                                      F-7

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byproducts  and  sludges that  are  hazardous  by  characteristic, and commercial
chemical  products.   The definition  allows for  variances  to  be made  for  those
situations in which a minimal amount of processing is needed to complete recovery.

     D.    Speculative Accumulation

     As  discussed earlier, storage  of  a material prior to  recycling  may be under
RCRA jurisdiction, depending on what  the material is and how it is to be recycled.
For those instances  in which the material being recycled is otherwise  excluded from
the definition of solid waste, it  may  still  qualify if  less than  75 percent  of the
material  is  recycled or  transferred  to another  facility  within one year.  (This
condition  does not apply  to waste materials that are chemical products.)

     A variance from this provision of the definition  is allowed if the  petitioner can
demonstrate  that economic  and/or other conditions  prevented  his or her company
from recycling the required 75 percent.

    II.     Materials That Are Not Solid Wastes When Recycled

     Wastes that are recycled by direct  use are usually  not defined as solid wastes if
reclamation of the material does not occur prior to, or as  a condition of, its being
used. Three situations are specified in  the definition  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; or
    •   The material  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
the material's  use.  Also, if  a waste material  fails  to  be excluded from  the  solid
waste definition for one of the three criteria, it could  still be excluded if it  qualifies
under  the other  two.   For example,  the third condition specifies  that  a waste
                                      F-E

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material must be returned as a substitute for raw material feedstocks to the process
from which it originated.  A waste solvent used for degreasing, returned to the same
degreasing operation, would  not qualify  under  the  third  situation, since  it is  not
being returned to a  production  process.  It would,  however, qualify  for  exclusion
under the second situation, because it  is being used  as  an  effective substitute for a
commercial product and it is not being reclaimed prior to being reused.  If it were
spent solvent that must be distilled prior to being reused,  it would not be excluded,
since the distillation qualifies as reclamation prior to its reuse.  In this  case, since it
is  not  excluded, generators  would be  required  to  manifest the waste  if  it were
shipped offsite.  If  the material were to be stored onsite for more than 90 days,  a
TSDF permit would be required.

     The end use of  the product in  which the  waste is incorporated is of extreme
importance in considering  whether a material is excluded.  For example,  use of  a
waste material to make  fertilizer would define the  material as a solid waste (unless
the  waste material  were  a  commercial  chemical  product  for  which  fertilizer
manufacture  is an intended use). Since it is incorporated in  a product  that would be
applied  to the land, this would be considered use constituting disposal and would be  a
solid  waste.   Although  waste-derived  commercial  fertilizers  are  not  as   yet
regulated, this is still an important consideration  for reasons to be discussed below.

     III.    Incentives and Constraints of the Definition

     The definition presents some problems  for companies that may wish to recycle.
Some of the p.roblems lie in  the companies'  misinterpretation  of the regulation, in
increased requirements resulting from the definition, and in confusing issues that
may result in disputes with EPA.

     A.    Effect on Generators

     Waste that is defined to  be  a "solid waste"  under  the  definition  is both  a
hazardous and solid waste  and thus subject to RCRA management standards.  As  a
result,  generators  will  have  to report  the quantities of  such  waste  under  the
reporting  requirements of Section 3310  of RCRA, even if  the  waste is  recycled
                                      F-9

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onsite and is not stored  for  more  than  90 days.  The notification must  state  the
location,  general description  of  such  activities,  and  the  identified  or listed
hazardous waste that the generator handles.

    In addition, the definition will result in generators now having 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) is defined
as a solid  waste if  it  is  both a  hazardous waste and is reclaimed prior  to being
recycled.  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.  Future liability  is of concern to most  generators since, under the strict,
joint, and several liability  provisions of  the  Superfund law (CERCLA) they may  be
liable for the costs of cleanups  of leaks or spills  that  involve their wastes.  To
generators who  previously  did  not  have to  manifest  wastes when  shipping  to
reclaimers, this is a  constraint to recycling, since it is not clear to what extent they
may be  liable for any future accident or leak.

    One advantage  of this situation, however, is that  the generator has an  increased
need to know 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  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.

    In addition  to these  concerns,  the issues of final product end  use and  what
constitutes reclaiming  also may play a role  in  affecting  a  company's decision on
whether or  not to  recycle.  These  issues have  particular relevance  for specific
applications,  as discussed below.
                                      F-10

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     1.    Hazardous  waste-derived  fertilizers.  A  material  that  is  a  hazardous
waste and  is used as  an ingredient in making  fertilizers is a solid waste (unless the
waste is a  commercial chemical product for which the normal intended use  is land
application).  Because  the  final  product  is   applied  to  the land, the  hazardous
materials incorporated in it  are  defined as  solid wastes.  Even  though  they  are
defined  as  solid  wastes, however,   hazardous waste-derived fertilizers are  not
currently regulated provided the fertilizer is used commercially.

     "Commercially"  (as  it is  discussed in  the  preamble  of  the  January 4, 1985,
Federal Register) has a specific meaning and  refers to materials that are sold to the
general public.  If the generator uses the  material himself,  it  is not  considered
commercial  use   and a  RCRA  permit would be  required  for  application  of  the
material on the land.  Discussions with EPA personnel (personal communication with
Matt Straus, U.S. EPA,  July 26, 1985) indicate that the reason for this distinction is
the utility  of its  implementation.  Eventually, EPA will be examining  the degree to
which all fertilizers should be regulated.  At this time, however, EPA feels that it is
not feasible to require that all applicators of fertilizers obtain RCRA permits. The
result   of  this  EPA  policy   is  that  only  the  noncommercial use  of  hazardous
waste-derived fertilizers will be regulated.

     This aspect of the definition and its interpretation has the  potential to result in
a constraint to companies with the ability  to  recycle material for use as ingredients
in fertilizer.  How this works as  a  constraint is  shown  in  the  following example
provided by EPA (personal  communication  with Matt Straus, U.S. EPA, July 26,
1985).  A company generates K061 dust which it sells to  a fertilizer manufacturing
company.  The company  adds lime,  briquettes it, and sells it  to the public.   Under
the  new definition,  this  is commercial  use  and  is therefore not  regulated. The
company shipping the wastes, however, must  manifest them since they are defined
as solid wastes.  The  company then decides it  wants to perform the same operation
in-house  that  the fertilizer  company  had   performed,  namely, adding lime and
briquetting.  The  company requests  that  EPA clarify  whether application  of  the
resulting fertilizer product would be regulated.
                                      F-l

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    In this  case,  EPA  decided that for the generators to perform the same step
in-house and  sell the  processed material  to an  intermediary does not qualify as
commercial use.  Presumably, distributing  directly  to the  consumer,  rather  than
through a manufacturer or wholesaler, legitimates its commerciality.  Consequently,
a permit  would  be  required  for application of  the  material to  the  land if  the
material were manufactured in-house and not sold  directly to the public.

    In the above instance, the company initially decided it would be to its benefit to
process the  waste material in-house since, under the  new definition, shipping offsite
would require manifesting the material now defined as a solid waste.  The  company
in the example may have seen the possibility of  not having to  manifest  the  waste by
processing it onsite, as well as of achieving a return on its investment by marketing
the material itself.  EPA's decision  in the matter  now leaves the company  with the
alternative  of  continuing to  ship offsite  and manifesting  it, or finding a less risky
means of disposal with respect  to  future  liability.  Onsite  incineration may be  a
possibility  if (1) the company  has a permitted incinerator and (2) the incinerator has
the capacity  to handle  this  waste.  As  discussed  in the section  on  permitting,
obtaining an incinerator  permit is  time consuming  and would  not  be  an attractive
option.

    Another aspect  of  the  waste-derived  fertilizer situation  is shown  by  the
following example (personal  communication with  Matt  Straus, U.S. EPA,  July 26,
1985):  A sludge  is reclaimed at a recycling  facility to recover zinc.  The  recycler
ships  the  zinc  to a fertilizer company for use in the manufacture of  fertilizer. Since
the fertilizer is applied to the land, the use of zinc as  an ingredient  in  the  fertilizer
renders the zinc a solid waste. The zinc must therefore be manifested when shipped
to  the  fertilizer  company.   If  the  zinc  were  shipped  to a  paint manufacturing
company,  however, it  would  not be  a solid  waste,  since  paints  are  usually not
products applied to the  land.

    The example illustrates how the same material (zinc) may be deemed a waste  in
one instance  and a product  in another.  Similarly,  in the  first example,  the same
product may be regulated in one instance and not in another. From the standpoint
of regulators,  a decline in the amount of waste-derived products applied to the land
                                      F-12

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can be seen as beneficial.  However, the definition and regulatory scheme  presently
do not take  into account the equivalency of the waste-derived product to the one
derived from so-called virgin feedstocks.  Companies may, therefore, view this  as a
disincentive  to  consider using their waste  products for such  purposes,  and  may
instead consider alternatives that  could present  a potential   for  environmental
damage, including the option of illegal disposal.

    2.    Materials  used  as  ingredients  in  industrial  processes.  The  definition
makes a distinction between materials  that are used  directly in  a process without
reclamation  beforehand and  materials  that  must be reclaimed prior to being used.
In addition,  if  the use of a  material  as an  ingredient  in a  process results in  the
reclamation  of  that  material, it is defined  as a solid waste. Similarly, a material
returned to the generating process that is "raw material based" is  excluded  from the
definition, provided it is not  reclaimed beforehand.

    For  materials  that  are  recycled onsite, these provisions do  not constrain such
operations, even if reclamation  is conducted prior  to  use.  This  is because  the
recycling process itself  is not currently regulated.  Materials  shipped offsite, if solid
wastes, are subject to manifesting  requirements.  Thus, this  provision of  the  solid
waste  definition may serve  as an  incentive  to use the waste materials directly in
processes onsite or offsite  without prior reclamation.  EPA's concern for  "sham"
operations dictates in large  part  the condition that  materials not be reclaimed prior
to or during the industrial  process to  which they are  introduced.   The  difficulty
arises in determining what constitutes reclamation.

    An  example of  a material  used as an ingredient in  an  industrial process but
considered to be "reclaimed" was presented by EPA (personal communication  with
Matt Straus, U.S.  EPA,  July 26, 1985):  A  company  ships spent pickle liquor offsite;
it is mixed with iron and chlorine and  evaporated to obtain salable  ferric  chloride.
Although  the  pickle liquor  is  mixed  with  other  materials,  and  hence  is  an
"ingredient,"  the   mixing   and   subsequent   evaporation  would   be  considered
reclamation, since pickle  liquor normally  contains ferric  chloride that can be  used
directly.  The purpose of  the reclamation process is to remove  the acidity.   The
mixing and evaporation  is a reclamation step and  not  solely an ingredient mixing
process.  Thus, the  company shipping the pickle liquor would have  to manifest it.
                                      F-13

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    From  the  standpoint of  the  regulators,  the reclamation  provision  of  the
definition is necessary in order to prevent companies from  labeling processes as
"ingredient" steps in  order to  avoid  regulation (i.e., shipping wastes unmanifested
offsite for use  as an  ingredient in another process).  There may be an incentive also
in  that companies may  be encouraged to perform  such  operations onsite whenever
possible.  For companies  that  cannot accommodate  such an onsite  operation,  this
aspect of the regulation may present a constraint.

    The  condition  that  a  material  be returned  to  the  originating  process  as
feedstock also  creates  some confusion.  Materials that  are used as feedstocks are
essentially being  reclaimed.  Because  they are in  somewhat "raw" form, their state
is  considered to  be  more virgin-like  than waste-like;  thus, the reclamation of the
originating process  is viewed  as a production process.  If  a material is  used  as a
feedstock or ingredient  in  a  nonoriginating or  secondary process, however,  it is
viewed as a reclamation step.  EPA's decision in this matter is again dictated by the
concern for "sham" operations.  No consideration  is given for the equivalency of the
waste material used in  the secondary process to the other "virgin" materials used.
Thus, an  emission  control  dust (baghouse  dust)  that  may be  obtained from  one
smelter operation used in  the same  originating operation would not be considered to
be a  solid waste. A baghouse  dust from another  facility,  shipped to a smelter for
use in the smelting process, would be deemed to  be reclamation and would thus  need
to be manifested.

     B.    Effect  on Recyclers

     Because many  of the wastes shipped to recyclers  can now be defined as  solid
wastes, the company accepting  the  wastes  for recycling  would  now be  accepting
manifested  wastes.  Thus, the recycling company's name appears on the  manifest. It
is  not clear at  this time  to  what extent the recycling  company  bears  liability for
future damages  resulting from the waste materials associated  with the recycling
operation.  For  example, a  reclaiming operation accepting  spent  solvent would
generate  still  bottoms  that   it may  ship  offsite  for  landfilling.   Although  the
generator shares in the fear that it  may  have to pay if the recycler  goes out of
business,  the recycler may fear the same thing: what happens if  the generator goes
                                      F-14

-------
out of  business?   Under  the "strict,  joint,  and  several"  liability  provision  of
Superfund, the recycler  may be liable as well.  There may be some reclaimers who
have not had to worry about this  situation, because the wastes they accepted were
previously  exempted  from  the  manifesting  requirements.  They  are now in  the
position  of having  to  accept  a  manifested hazardous  waste  that  bears their
company's name on  it. The fear of future liability may be viewed by these recyclers
as a constraining  factor, and they may  decide  not to  accept the  now  manifested
wastes that before  the  revised definition they  had processed.  If  such  behavior  is
common,  the  consequence of this reaction will affect generators who  may still
choose to  ship wastes offsite for recycling,  but may be severely  limited in their
choices as  to where to send it.

    As mentioned above, a  TSDF permit is not  necessary for  the  reclamation
activity itself. Such a permit is required, however, if the recyclers store any of the
hazardous  materials  they  receive  for any  amount  of time prior to  processing  it.
Although  many reclaiming operations would  process the materials directly, there
may still  be  instances  in which substances must be  stored  prior to  processing,
depending  on the size of the  facility and the  volumes it receives.  Discussions with
EPA (personal  communication with Matt Straus, U.S.  EPA,  July  26,  1985) indicate
that there  may  be increased incidents  of "disguised"  storage, in  which  recyclers
state  that the material  contained in  a tank  is  undergoing reclamation.  With  the
prospect for such  claims being made,  additional  regulations or criteria may then be
necessary  to determine  what is legitimate reclamation  or processing as  opposed to
storage.  An example  of an ambiguous situation  is one in which material in a tank  is
settled  and  decanted.  The  question remains  as  to   whether  settling  will  be
considered  a  legitimate recovery operation,  or whether  it  will  be  judged to  be
storage, and hence regulated  if placed  in the tank prior to processing.

    C.    Effect on  Waste  Exchanges

    Because the end use and  recycling method of the waste material must  be known
in order  to determine whether or not  the recycling of such material qualifies it as a
solid waste, the  use of  material  exchanges  may  diminish  considerably.   Material
exchanges  take physical possession of the  waste  and broker it to companies that
                                      F-15

-------
could use it. The  generator  transferring  the material to such an exchange would not
know  whether  the   material  would  qualify   as  a  solid  waste  (thus  requiring
manifesting), unless  it were  known how the waste  is to be recycled and what would
be the end use of the  recovered materials.

     In the case of  information exchanges, there is more likelihood  that  the ultimate
disposition of the  waste could  be  learned  in  advance, depending on  whether the
exchange is  passive or active. In  a passive exchange, the generator bears the burden
for contacting the interested party, so that there  would be communication between
the parties exchanging the waste.  Some  active exchanges arrange for  the  transfer
of the waste, with the identities of the buyer and seller kept confidential. This type
of arm's-length transaction is likely to become less attractive.

     IV.    Summary and Conclusions

     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.  Also, the  complexity of  the  definition  lends  itself to
misinterpretation.  This misinterpretation leads to perceptions of constraints  that do
not really exist. Section 5.3 of  Volume  1 (Organizational  and  Attitudinal Aspects)
discusses these perceptions and their implication for industry actions in more detail.

     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 possibly inherent in the RCRA statute itself.  For
example, RCRA requires that 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 (Section 3014(a)  of  RCRA). As  a consequence of
this  language, proposed regulations relating to the burning and blending of hazardous
wastes  as fuels do not require "full" compliance with  the  manifesting requirements
of RCRA (November 29, 1985 at 50 FR  49231).  No such privileges are granted at
this  time toward other substances that are recycled.  Thus, there  appears to  be an
inequity in that  products and raw materials (as opposed to waste products and spent
materials) that  may be  every  bit  as   hazardous, if  not more  hazardous,  than
                                      F-16

-------
comparable  waste streams,  are  not  required  to  obtain  the  same  degree  of
permitting, tracking,  review, and  regulation  as  the waste  streams.  A  tank car
transporting  virgin trichloroethane, for  example, for  use  in a process is not subject
to the same  degree of  manifesting  requirements as is a tank car  transporting spent
trichloroethane being 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,
therefore,  center  around what is  considered to be reclamation.  Also, the ultimate
end use of the product  in which the waste material is  introduced determines whether
it falls under the solid  waste  definition.  As a result, the regulated  community may
be more concerned with escaping regulation,  even  when the opportunity exists to
recycle.

     The new definition of hazardous and  solid wastes,  however, may provide  an
additional  incentive  to onsite recycling,  even where it might  not otherwise  be
economically  justified,  or where the scale  of operation involved may not  allow the
fullest  reduction  in  the  volume of the  waste  that must be  disposed  of  after
recovery.  Unlike  the April 1983  proposal,  the  final rule classifies wastes in such  a
way  that,  for example, waste solvents  sent to recyclers for batch  tolling must  be
manifested—even when the recovered solvent  is being returned  to  the originating
company.  Some recyclers have  noted  to  Versar  in  interviews that  their business
base involves receiving the majority of  their gross income (i.e., 80 percent) from  a
relatively  small number  of large companies (comprising about 20 percent of total
customers).  For  these  customers,  the  fact  that   wastes  recycled  offsite   face
regulatory  requirements that  wastes recycled onsite do not face shifts the economic
balance. This shift occurs even where the ability  to  recycle process residues may
not be as great  as that of a larger  recycler. Even smaller companies are beginning
to look  at the  possibility of installing  small distilling  units,  which  will  leave
relatively  large proportions of the  waste stream unrecovered.  Unfortunately, such
companies  are probably  considering  the  short-term  costs  and  liabilities of the
manifesting requirements,  and ignoring the likely long-term increasing  costs for
disposing of the larger  proportion of wastes from the  onsite process.  (Recyclers in
                                      F-17

-------
California,  while  agreeing on  this  impact  generally, note  that the  new  Federal
requirement makes no difference there, since  manifesting  was already required by
the State.)

    The definition, in summary,  contains both  constraints  and incentives.   It  is
perceived mostly  as a constraining mechanism, which, in  tandem with other aspects
such as liability, siting, and permitting, may contribute to  a  general  attitude against
consideration of certain recycling practices.
                                       F-l

-------
             APPENDIX G

CORRESPONDENCE FROM EPA ON WASTE
       MINIMIZATION ACTIVITIES

-------
                                                                IBCC4.16
   \        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
    I                    WASHINGTON. O.C. 20460
   '/


                           MAR i  '1985
                                                        OFFICE OF
                                                SOLID WASTE AND EMERGENCY RESPONSE
Mr. Willi am Stough
01 rector
Great Lakes Regional Waste Exchange
3250 Townsend. N.E.
Grand Rapids. Michigan  49505

Dear Mr. Stough             .?

     It was a pleasure to hear from you and-learn of your
interest in using waste^exchange programs to support the
waste minimization concept of the Resource Conservation and
Recovery Act  (RCRA) Reauthorization.

     Where participation in a waste exchange program affects
a generator's efforts to reduce the volume or toxicity of
hazardous waste, such participation may be used to satisfy
Section 3002(b)(l) of RCRA.  Participation in a waste exchange
program could also be used as evidence of compliance with
§3002(b)(2), wnich .requires that the  generator select the
method of treatment, storage or disposal  which minimizes the
threat to human health and the environment.

     It is our hope that each year greater volumes of hazardous
waste will  be recycled,  reclaimed and reused through waste
exchange programs.  Achievement of this goal will go a long
way toward meeting the intent of Congress regarding the disposal
of hazardous waste in or on the land.

     We appreciate hearing from you.   If  you have further
questions,  please let me knew.
                                S i nee rely vours
                                John H.  Skinner
                                D i rector
                                Office of Solid Waste (WH-562)

-------
          UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                      WASHINGTON. D.C. 20460


                            JUL I I 1985


                                                      OFFICE OF
                                              SOLID WASTE AND EME^GEr.C* >=>*S
Mr. R. R. Saulsman, Manager
Energy & Environmental Affairs
The Boeing Company
P. O. Box 3707
Seattle, Washington 98124-2207

Dear Mr. Saulsman:

     Thank you  for your letter of June 5, 1985, concerning the
waste minimization statement which generators will be required
to sign on the  Uniform Hazardous Waste Manifest  (UHWM) effective
September 1, 1985.

     As you indicated when you originally spoke to Carolyn Barley
in May, your concern was that Boeing Company  employees would be
reluctant to sign this statement because as individuals they do
not have a waste minimization program in place as required by
the statement.  Our suggestion in response to your concern was
for the employee signing the statement to include under the
signature line  in Item 16 the phrase,  "on behalf of The Boeing
Company."  You  indicated in your letter that this solution is
satisfactory provided that this phrase can be preprinted on
the form.  Of course, the individual signing the statement is
responsible for the veracity of the statement, as is the company.

     We recognize that preprinting this phrase on the form would
be a more efficient and less time consuming procedure than re-
quiring Boeing  employees to write it in by hand.  Additionally,
the Agency's March 20, 1985, regulations on the UHWM do not
specifically preclude you from preprinting this phrase on the
form.  Therefore, I have no objections to your proposal.

     If you have other questions about the waste minimization
statement or the UHWM system, I suggest that you again contact
Carolyn Barley  (202-382-2217).
                                Sincerely yours,
                                John H.  Skinner
                                   Director
                              Office of Solid Waste

-------
                           -          ...      .      _ .
                                                                         H-I
     -  -          -  '         -                           .                 3 5
                                                                         p „
                                                                         kirf **
 Mr. Peter Ashbrook                                                       ~ ;
 Head, Hazardous Waste Management                         ~              ^.^
 University of Illinois    ..      -  •  --•'-.--    _                  * «
 317 McKinley Hospital .          '                     .
 1109 South Lincoln  Avenue                                       X
 Urbana, Illinois  61801   	                                        >£
                                                                         CD y.
                                                                         vi r
 Dear Mr. Ashbrook:     "    "~"    -.-.-_   ...     _..  .....          c
                                                   :    _ —                w
                                                                          9
      Thank you for  your letter of August 26, 1985, to Lee Thomas         »-»
 concerning the availability of guidance on implementation of waste       5
 minimization practices at the University of Illinois.  I am sympa-       *g
 thetic to the challenge you face in managing a large variety of          K>
 relatively small quantity wastes that,  in total, represent a             i
 significant quantity.                                                    J£
                           ' '                                              -"j
      The Hazardous  and Solid Waste Amendments (HSWA) of 1984,            £
,establish as national policy the minimization of hazardous waste.        E
 The legislation requires waste minimization considerations to be         to
 addressed in the Resource Conservation and Recovery Act (RCRA)           £?
 transport manifests*  generator reports, and permits.                     £"
                                  ' "      •                                 to
      The Agency has not developed  guidance on waste minimization        ^
 activities that may be practiced by generators and, at  this time,       "*£•
 does not intend to.  Instead,  it is  hoped  that activities such as       u\
 source reduction and  recycling will be  explored by individual           £,
 generators to reduce  the volume or quantity and toxicity of the         *
hazardous waste generated.          .   -                                en
                                                                         -2
      Senate Report  No. 284,  98th Congress, 1st Session  66 (1983),       £
 articulates Congress*  intent with  regard to the waste minimiza-         *>
 tion requirements in  the HSWA.   As  this legislative history states,      £j
both minimization requirements for the  manifest and biennial report      £
prefer to a certification by the generator  that a program is in          **
place to reduce the volume or  quantity  and toxicity of  hazardous        H-
waste to the degree determined by  the generator to be economically       ~
practicable.   While the  requirement  to  make this certification is       ft
mandatory,  the determination of what waste minimization practices       3
are  economically practicable are to  be  made solely by the generator.     £,
                                                                         en

-------
The legislative history makes clear that Congress1 objective in
enacting the requirement for waste minimization certification is
to encourage generators of hazardous waste to voluntarily reduce
the quantity and toxicity of waste generated.

     As the legislative history suggests and as the Environmental
Protection Agency (EPA) has stated, generators that recycle wastes
on-site, send their wastes off—site to be recycled or participate
in a waste exchange program are exercising a form'of waste minimi-
zation that may be used to satisfy the waste minimization certifi-
cation requirement, and may certify as such.

     In addition to the requirements for waste minimization
certification imposed by the HSWA, the Amendments also require
that a "Report to Congress" be submitted by the EPA by October 1,
1986, assessing the feasibility of establishing waste minimiza-
tion regulations.                ".       .    .   '      .r

     The Office of Solid Waste (OSW) is undertaking extensive
technical studies on waste minimization practices including
source reduction and recycling in support of the "Report to
Congress.  These studies will identify and assess current waste
minimization practices for generators of hazardous waste.  These
activities include: good housekeeping practices,  source reduction
strategies and recycling opportunities for generators.  They will
also identify generic and specific problems associated with the
implementation of waste minimization strategies.   In addition, the
studies will assess the potential for further applications of the
identified waste minimization strategies and will evaluate what
steps can be taken to mitigate problems and promote the increased
use of waste minimization.  This information, as  well as recommenda-
tions for legislative changes or new regulatory intiatives will be
presented in Report to Congress due October 1, 1986.  In the
interim, OSW will distribute information regarding specific waste
minimization practices identified through our technical support
studies and technology transfer seminars.

     The Agency appreciates your concern with the waste minimization
certification requirement.  If you should have any further questions,
please contact James Berlow, Manager of the Treatment, Recycling,
and Reduction Program at (202) 382-7917.

                              Sincerely,
                              J. Winston Porter
                              Assistant Administrator

-------
Mr. williasi  Stough
Director
Great  Lalie«..aeVio*al  Waste Exchange
3250
Grand>*l>T$|^t>l£chfgan  49505
      '* %•***»-. *i*>'A.** T  ,V**_ i » _ BF
     *iA
Dear tfir»

     It was  a pleasure to hear frost you and learn of your
interest  in  using waste exchange  programs to support the
waste  minimization  concept of the Resource Conservation and
Recovery  Act  (RCRA) Reauthorization.

     where participation in a waste exchange program affects
a generator's efforts to reduce the volume or toxicity of
hazardous waste, such participation may be used to satisfy
Section 3002(b)(l)  of RCRA.  Participation in a waste exchange
program could also  be used as evidence of compliance with
$3002(b)(2), which  requires that  the  generator select the
method of treatment,  storage or disposal which minimizes the
threat to human health and the environment.

     It is our hope that each year greater volumes of hazardous
waste will be recycled,  reclaimed and reused through waste
exchange  orograns.  Achievement of this goal will go a long
way toward meeting  the intent of  Congress regarding the disposal
of hazardous waste  in or on the land.

     We appreciate  hearing fron you.   If you have further
questions, please let me know.

                                 Sincerely yours,
                                John H. Skinner
                                Director
                                Office of  Solid  waste (WH-562)

WH-563iJThompsoniccz2-8-85t382-4697iCC*s disk4.doc!4
Control ftOSto-015
bee »,lTTy»iJl t«jf ^ir/incom ing
                     Management Division Directors,  Regions  I-X
                   OWPE
REVISED by Steve Levysees2-11-85
Revised by Clem Rastattertcct2-13-85
Required Concurrences:OGCi Mike Cook:elwt2/28/85

-------
          UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                      WASHINGTON. D.C. 20460
                            JUL I I 1985
                                                      OFFICE Of
                                             SOLIDWASTE AND EMERGE^C" ^eS
Mr. R. R. Saulsraan, Manager
Energy & Environmental Affairs
The Boeing Company
P. O. Box 3707
Seattle, Washington 98124-2207

Dear Mr. Saulsman:

     Thank you for your letter of June 5, 1985, concerning the
waste minimization statement which generators will be required
to sign on the Uniform Hazardous Waste Manifest (UHWM) effective
September 1, 1985.

     As you indicated when you originally spoke to Carolyn Barley
in May, your concern was that Boeing Company employees would be
reluctant to sign this statement because as individuals they do
not have a waste minimization program in place as required by
the statement.  Our suggestion in response to your concern was
for the employee signing the statement to include under the
signature line in Item 16 the phrase, "on behalf of The Boeing
Company."  You indicated in your letter that this solution is
satisfactory provided that this phrase can be preprinted on
the form.  Of course, the individual signing the statement is
responsible for the veracity of the statement, as is the company.

     We recognize that preprinting this phrase on the form would
be a more efficient and less time consuming procedure than re-
quiring Boeing employees to write it in by hand.  Additionally,
the Agency's March 20, 1985, regulations on the UHWM do not
specifically preclude you from preprinting this phrase on the
form.  Therefore, I have no objections to your proposal.

     If you have other questions about the waste minimization
statement or the UHWM system,  I suggest that you again contact
Carolyn Barley (202-382-2217).
                                Sincerely yours,
                                John H.  Skinner
                                                **£
                                   Director
                              Office of Solid Waste

-------
                  UNITED
   TES ENVIRONMENTAL PROTECTION
                                                      NCY
                                           5 1985
    Ms. Faitb Gavin Kuhn
    Executive Director/Editor
    National Association of Solvent  Pecyclers
    1333 New Hampshire Avenue, N.W.
    Suite 1100
    Washington, D.C.  20036
                                                     EC '
                                                     I  t
                                                     Ul •
                                                     \ t
                                                     o t
                                                     en
    Tear Ms. Kuhn:

         Thank you for your letter of July  19,  1985,  requesting
    clarification on the types of activities  that  may be used to
    satisfy the waste minimization certification as required by the
    Hazardous and Solid ttaste Amendments  (HSWA) of 1984.  In addi-
    tion, thank you for the copy of the National Association of
    Solvent Recyclers1 (NASR) latest industry brochure and member-
    ship list.

         The FSftA establish as national policy  the minimization of
    hazardous waste.  The legislation requires  waste  minimization
    considerations to be addressed in the Resource Conservation and
    Recovery Act (PCKA) transport manifests,  generator reports, and
    permits .

         Senate Report No. 284, 98th Congress,  1st Session 66
    (1983), articulates Congress' intent with regard  to the waste
    minimization requirements in the HSViA.  As  this legislative
    history states, both minimization requirements for the manifest
    and biennial report refer to a certification by the generator
    that a program is in place to reduce the  volume or quantity and
    toxicity of hazardous waste to the degree determined by the
    generator to be economically practicable.   While  the requirement
    to make this certification is mandatory,  the determination  of
    what waste minimization practices are economically practicable
    are to be made by the generator.  The legislative history makes
    clear that Congress1  objective in enacting  the requirement  for
    waste minimization certification is to encourage  generators of
    hazardous waste to voluntarily reduce the quantity and toxicity
    of waste generated.
                                                   \
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                                                                             \=
                                 CONCURRENCES
MBOU
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                                       OFFICIAL FILE COPY

-------
     As we previously discussed, and as the legislative history
suggests, generators that either recycle wastes on-site or send
their wastes off-site to be recycled are exercising a form of
waste minimization that may be used to satisfy the waste mini-
mization certification requirement, and may certify as such on
the uniforn hazardous waste manifest.

     The Agency appreciates FASP's concern with the waste mini-
mization certification requirement.  If you have any further
questions, please let TT.P know.

                              Sincerely,
                              John h. Skinner
                              rirector
                              Office of Solid Waste (V:H-562)

-------
                    APPENDIX H




COMPILATION OF INDUSTRIAL WASTE REDUCTION CASES

-------
                                                                                    APPENDIX H - Compilation of Industrial Haste Reduction Cases.
Case
No
1





2


3


4


5


6


	 <
Ref
1





1


1


1


1


1



7 1



8 1

9 1

10 1



	
Company and
Location
Climax Molybdenum
Co., Leadville,
Colo



United Globe
Corp , Lexington,
N C.
West Point
Pepperell,
Lumberton, N.C.
Rexham Corp. ,
Greensboro, N.C.

Exxon Chemical
America, Linden,
	 4
SIC
Code
	
1061





251


266


275


2869

N.J.
Allied Chemical | 2819
Corp. .Metropolis, |
111.
I
Borden Chemical 2869
Co , Fremont,
Calif.

America Euka Co., 2824
Euka, N.C.
Rike11 Laboratory, 2834
Northridge, Calif.
USS Chemicals, 2869
Haverhill, Ohio


Product
Raw molybdenum,
copper, zinc,
iron, manganese



Furniture


Textile dye and
finishing

Specialized
product labels

Solvents, chemical
additives

Chemicals, nuclear
fuel


Urea, phenolic
resins


Nyton yarn

Pharmaceuticals

Phenol, aniline,
Waste Minimization Method Description
Waste Reduction
Percent | Quantity
Installation of interceptor canals to pass runoff |93.2 (Cu)|
water through ion exchange unit. Other separation of |99.9 (Fe)|
heavy metals through coagulative electrolytic |99.9 (Mn)|
processing. |93.4 (Zn)|
|90.3 (Mb) |
|96 4 (Cn)
Incineration of process water waste solids and solvent|95.0l by
wastes to produce steam for use in plant. volume

Establishment of Toxic Chemicals Review Committee.


Substitution of water-borne ink for alcohol/acetone
ink. Distillation to recover n-propyl alcohol from
waste inks for reuse in the process.
Equipment redesign to retain solvents.
Employee stewardship program, where organics are
monitored at different stations.
Recycling of waste calcium fluoride into anhydrous
hydrofluoric acid production at another facility.


Filter rinse and reuse of phenolic resins.
Implementation of 2-stage tank rinsing.
Employee education in waste reduction.

Recycling of solvents using in-house distillation.

Substitution of water-based solvent for organic-based
solvent in tablet coatings.
Control of organic vapors through addition of adsorp-














95.0







80.0
related products | tion unit, scrap condenser, and floating roofs on |(air

1.5
MM Ib/yr




13,000
gal/yr
(solvent)
1.5
MM Ib/yr
(total)
1,000
cu yd/mo
recycled





10,000
gal/yr
24
ton/yr


storage tanks. |em1ssion)|
I
Classification
Treatment





Treatment


Good operating
practice

Process modif.
(recovery/reuse)

Process modif.
Good operating
practice
Recycling



Process modif.
Process modif.
Good operating
practice
Process modif.

Process modif.


Process modif.


Number of
Employees









22,000





150,000


















Year
(*)






1982


1975


a1976


1975


a1976







1983







Objective
(*»)
YM





WM


WM


HM.Tech.


WM


WM



WM



YM

WM
Capital
Investment
($ 1,000)






1,500


No change


16


5 - 13


4.300







7.5


I
I
WM
I

Annual Cost
Savings
(J 1,000)






905





15


150


1,000







90

15


175/100


Payback |
Period






<3 yrs





<1 yr


<1 yr


4.5 yrs







1 month

<1 yr


1 month/
18 days

(*) a-after;b:before / (**) WM-waste minimizat1on;Tech-technical improvement;YM:yield  maximization

-------
                                                                                                         APPENDIX H (continued).
t














~T~
1
ro


















Case
No
11



12


13


U


15



16


17


18


19


20


21


	 4
Ret
1



1


1


1


1



1


1


t


1


1


1


	 4
Company and
Location
Industrial and
Agricultural
Chemicals, Inc..
Red Springs, N.C.
ICI Americas, Inc.
Goldsboro, N.C.

Daly-Herring Co. ,
Kinston, N.C.

lexasgulf ,
Saltvllle, Va.

Florida Steel
Corp., Charlotte,
N.C.

Haupaca Foundry,
Haupaca, His.

Stanadyne, Inc.,
Sanford, N.C.

Elkhart Products
D1v., Inc ,
Elkhart, Ind.
Pioneer Metal
Finishing, Inc.,
Frankllnville.N.J
Dec he and Co.,
Mollne, HI.

Hamilton Beach
01v.,Scov1ll,Inc.
Clinton, N.C.
SIC
Code
281



2879


2879


2879


3312



3321


3132


3471


3«71


3520
3530

36


Product
Trace elements
sold to ferti-
lizer Industry

Agricultural RiO


Pesticides


Defluorlnated
phosphate

Steel



Grey & compacted
graphite Iron
casting
Flushing products


Pipe fitting
fabrication

Electroplating
job shop

Farm & construc-
tion equipment

Small appliances


Haste Minimization Method Description
Use of Inorganic chemical wastes fro* other Industries
to process out trace elenents — reduction 1n raw
materials costs.

Etablishment of Environmental Compliance Committee.
Haste stream segregation to prevent cross-contamina-
tion and to allow off-site distillation.
Separation of waste dust streams to allow reuse of
dust.

Closed-loop recycling systen Installed to remove
inorganic fluorides fro* process water discharge
stream.
Resale of collected high-zinc furnace dust instead of
land filling.


Separation of wastewater to reduce amount requiring
treatment to 251.

Combination of equipment installations and revised
operating procedures to reduce sludge volume and
cyanide concentrations from plating operations.
Process redesign for waste reduction in combination
with electrolytic recovery of copper.

Replacement of single-pass continuous treatment system
with closed-loop batch treatment systems.

Formation of a hazardous waste task force.
Comprehensive treatment facility to reclal* and
detoxify selected wastes.
Off-site solvent recycling, plus substitution of
water-based for solvent-based cleaners.

Haste Reduction
Percent Quantity




70.0















46.0





50.0
(sludge)










7700
gal/yr

45,000
Ib/vr
waste dust
280,000
gal/day











182,000
gal/yr

40,000
gal/yr
(sludge)
330.000
«al/yr

38,000
Ib/yr
|(subst'n)
1
Classification
Process nodif.



Good operating
practice

Good operating
practice
(recovery/reuse)
Process nodif.


Recycling/reuse



Good operating
practice

Process nodif.
Good operating
practice
Process modlf.
(recovery/reuse)

Process nod If .
Treatment

Good operating
practice
Treatment
Recycling
Process oodif.

Number of
Employees



































Year
(*)




1984


1983









1980


1982


1979





1980





Objective
(**)
YM



HM


HM


MM


HM



HM, Tech.


HM


HM


HM


HM


HM


Capital
Investment
(» 1.000)
No change



Minimal


9.6





No change









60


210


1,900


3.250


Annual Cost
Savings
($ 1,000)




37


11.638


2,000


129.6



20.995





120


52.460


155.750


20.260


	 *
Payback
Period




Immediate


10 months


1 yr


Immediate



3.5 yrs





0.5 yr


3 yrs


2.5 yrs


5 months


(«) a:after;b:before / (**) HMrwaste i»inim1zation;Tech:technical  1mprovei»ent;YM:y1eld maximization.

-------
                                                                                                         APPENDIX  H  (continued).

















in
i
CJ


















Case
No
22








23


24



25

26

27


28




29


30




Ret
\








1


1



1

1

1


1




1


1




Company and
Location
Emerson Electric
Co., Special
Products 01 v.,
Murphy, N.C.





GTE Sylvania,
Chicago, 111.

Data General
Corp., Clayton,
N.C.

3M Corp.,
Columbia. Mo.
Digital Equipment
Corp., Tempe, Ariz.
Modine Manufac-
turing, Trenton,
Mo.
Rexham Corp.,
Hat thews, N.C.



Carolina Power S
Light Co., New
Hill, N.C.
Duke Power Co.




SIC
Code
35
36







3661


3573
3679


367

3679

3711


3861




4911


4911




Product
Metal finishing
Stationery manu-
facture






Electronic tele-
phone switching
equipment
Printed circuit
boards


Microelectronics

Printed wiring
boards
Metal radiators


Laminated and
coated paper,
fi In, foil product


Electric power


Electric power




Waste Minimization Method Description
Equipment installation for waste reduction/elimination
plus a chemical waste management program and an
Incentive progra* for cost reduction or product Ideas






Installation of closed-loop treatment system and elec-
trolytic copper recovery system.

Sale of untreated wastes, process changes to obtain
marketable copper sludge.


Use of alternative cleaning equipment which uses
furnice Instead of hazardous solutions.
Electrolytic recovery of Cu in treatment system, use
of waste from other Industries.
Ion exchange and electrolytic equipment for recovery
of copper.

Solvent segregation, solvent vapor collection and sale,
off-site distillation of solvent for reuse, Incinera-
tion, comprehensive chemical waste management program.


Sale of fly ash and bottom ash for reuse.


Sale of fly ash and bottom ash, PCB Incineration,
waste stream segregation, revised equipment operation.
establlshient of an ongoing waste minimization pro-
gram, reduction of radioactive waste.

Haste Reduction
Percent | Quantity
100.0
solvent
waste oil
ZnCr03








100.0
(process
waste-
water)




100.0


60.0-65.0
(methyl
ethyl
ketone
recovery)
30.0
(max)

95.0
(liquid
rad.
waste)
60.0
68 Ib/dy
(paint
solids)
90 Ib/dy
(plating
add. oil.
caustic)
720 Ib/mo
(solvent)
55 gal/wk
(CuOH
sludge)
400 ton/yr
(landfill
waste)

40,000
Ib/yr





4515
ton/yr
(air
emission)




345,000
ton/yr
(ash)


Classification
>
Process modif .
Good operating
practice






Treatment
Process modif.
(recovery/reuse)
Process modlf.
Recycling


Process modlf.

Process modif.
(Int. recycling)
Process modlf.
(Int. recycling)

Good operating
practice
Recycling/reuse


Recovery/reuse


Good operating
practice
Recycling/reuse
Treatment

Number of
Employees




































rear
(*)









a1976


1981





a1976




1979




1979


1979




Objective
('*)
YN. m








MM


HM



HM

YM

HM


NM




YM. HM


YM, HM




Capital
Investment
0 1.000)
874











50



59



27










1.365




Annual Cost
Savings
($ 1.000)
1,800








6


180



15



22










6.184




Payback
Period
1.1-5 yrs











1.5 month



3 yrs



14 months











-------
                                                                                                       APPENDIX H (continued).
+ 	 H
Case
Nn
no



31


32




33


3(








35




36










Ref




1


1




1


2








2




2










Company and
Location



3M Corp.,
Columbia, Mo.

PCA International
Inc, . Matthews,
N.C


American Fotokenl
Inc., Elk Grove,
111.
Allied Corp.,
Chemical Sector
(North America)






Amoco Chemicals
Corp., Chicago,
111.


AT&T Technologies
Union, N.J.









SIC
CnAa
uouo



7371


7395




7399


2824
2619
2865
2669





222*
26
3079


366)










Product




Film developing
unit of electro-
nic products div.
Mass portrait
photography



Silver recovered
from films and
fixer solution
Chenkals








Industrial
organic and other
chemicals
Oil and lubricant
additives
Telecommunication










Haste Minimization Method Description




Decanter system for gravity separation of solvent
from water for reuse.

Silver recovery through electrolysis and developer
regeneration through ion exchange.



Centralization of silver recovery processing, improve-
ment In treatment to extract nearly 1001 of silver
from solutions.
Sale of waste hydrochloric add.
Spent catalyst recovery for reuse.
Combination fo hydrofluoric add and calcium fluoride
/lime Into salable product.
Incineration of creosole, waste sludge for heat.
Use of byproduct sulfurlc add as process raw material
Recovery of spent 1,1,1-trichloroethane.


Manufacturing process modification.
Reuse through sale.
Internal recycling.
Incineration of organic waste as supplemental fuel.
Reduction of waste sludge generation.
Distillation of 1,1,1-trichloroethane.
Use of carbon adsorbers to capture solvent emnisslons
for reuse.
Treatment of plating rinse water.
Substitution of two polymers at 70 ppsi Into sludge for
ferric chloride fed at 250-300 ppn at a waste treat-
ment plant.
Refinement of sludge for copper extraction.
Substitution of tin sulfamate for stannous fluoro-
borate for tin plating of copper wire.
Change In testing operation eliminated cable-end
Haste
Percent
(tritium
and boron
release)











70.0
100.0
100.0


10.0
too.o


60.0-70.0
60.0-70.0
90.0-100
70.0-80.0
20.0-30.0
95.0
80.0-95.0

99. Of



100 0
100.0

50.0-75.0
Reduction
Quantity






115.000
troy ounce
silver
2919
gal/dy







5000 NT/yr




















Classification
'



Process «od1f.
(Int. recycling)

Process aodif.
Treatment



Treatment
Process modif.
(recovery/reuse)
Recovery/reuse
Process modif.
Recovery/reuse

Treatment
Process «od1f .
Process modlf./
Good operating
practice
Process nod If.
Recovery/reuse
Process nodif.
Treatment

Process modif.
Process modif.

Treatment
Treatment


Process modif.
Process modif.

Process modif.
Number of
Employees














14,000








15,600




365.000










Year
/ 1 \
( l











a1976


b1967








1980




1973










Objective
/**\
(")



VM, HM


MM




YM


YM








YM




HM










Capital
Investment
($ 1.000)



4







No change



























Annual Cost
Savings
($ 1,000)



12







6



























^ 	 *
Payback
Period



0.25 yr


1 yr




Immediate



























(')  a:atter;b:before /  (") WM:waste minimization;Tech:techn1cal  improvement;YM:yield maximization.

-------
                                                                                                         APPENDIX H (continued).



















o:
i
en






















Case
No


37



















38




39



40










Ref


2



















2




2



2










Company and
Locs t ion


Chevron Chemical
Co., San Francis-
co, Calif.

















DON Chemical USA,
Midland, Mich.



Eastman Chemicals
Div., Eastman
Kodak Co..
Kingsport, Tenn.
E.I du Pont de
Nemours & Co..Inc
Wilmington, Del.








SIC
Pnrlo
LOUc

2843
2869
2873
2874
2879















28
3079
3339


28



28
13
29








Product


Agri. chemicals
Fertilizers
Hone I garden
consumer products
Oil/fuel additive















Organic, Inorganic
chemicals
Plastic resins
Non-ferrous metal
Pesticides
Chemicals
Fibers
Plastics

Fibers
Industrial and
consumer products
Polymer products
Agricultural and
Industrial
chemicals
Biomedical
products
Coal
Petroleum product
^ 	 . 	
Naste Minimization Method Description

cleaning step using t,1,1-tr1chloroethane.
Reformulation/repackaging of damaged containers and
floor sweepings of pesticides.
Reuse of product samples taken during production runs.
Use of fertilizer tank bottom sludges as raw material
for fertilizer.
Recovery of oils.
Triple-rinsing of pesticide drums and return to manu-
facturer.
Solvent production process change.
Wastewater and solvent segregation.
Source control of wastewater.

Rinse solutions fro* equipment cleaning used to make
water-based products.
On-site distillation of solvents.
Reduce frequency of tank cleaning (sludge).
Biologlfcal treatment of phenolic waste to reduce
toxidty.
Substitute returnable pesticide bulk tote bins for
non-returnable drums.
Full range of activities.




Use of liquid waste as feedstock.
Solvent distillation.
Neutralization of liquid waste.

Process change in AON manufacture.

Marketing of landf tiled waste, recycling of off-spec
product.
Filtration of paint sludge, Incineration of liquid.
Pretreatment of waste aluminium oxide for sale to
recycler.
Process change to reduce Incinerator ash.
Sale of waste ferric chloride Instead of ocean dumping
Conversion of waste HC1 into chlorine.
Process modification to reduce load to treatment plant
Naste
Percent

"50.0




64.0
50.0

60.0
13.0,52.0
16. 0

100.0


20.0









99.6
99.0
100.0

50.0
(water)



100.0

90.0


20.0
Deduction
Quantity







































300Kton/yr

t 	
Classification
'

Process modlf.
(int. recycling)
Process modif.
Reuse

Process modif.
Recycling/good
oper. practice
Process todif .
Good oper. prac
Process modif./
good oper. prac
Reclamation

Process modif.
Good oper. prac
Treatment

Good oper. prac
product subst'n





Reuse
Process modif.
Treatment

Process modif.

Reclamation/
process modif.
Treatment
Recycling/
treatment
Process modif.
Recovery/reuse
Reuse
Process modif.
» 	
Number of
Employees

3,200



















30,000




17,000



146.000










> 	
Year
ft\
(*)

1982



















1972




61983



1980










i 	
Objective
(** \
)

MM



















HM




MM



YM










t 	
Capital
Investment
($ 1,000)









































t 	
Annual Cost
Savings
(t 1.000)









































	 4
Payback
Per i od









































(*) a:after;b:before / (»*) HM:waste m1nimizat1on;Tech:techn1cal  improvement;YM:y1eld maximization.

-------
                                                                                                         APPENDIX H (continued).
Case
No





41









42







43




44











	
Kef





2









2







2




2











	 1 	 ^
Company and SIC
Location Code





Exxon Chemical
Americas, Houston
Tex.







ICI Americas, Inc
Wilmington. Del.






3H Corp. .St. Paul
Minn.



Occidental
Chemical, Niagara
Falls. N.Y.














28
2221
2298
3079






28












28
29










Product





Olefins, aroma-
tics, polyolefins.
elastomers, sol-
vents, special-
ties, oil/fuel
additives




Agri. chemicals
Pharmaceuticals
Petrochemicals
Fibers & textile
chemicals
Security devices
Aerospace compo-
nents
Various




Industrial and
spec'lty chemical
Ourez resins and
molding materials
PVC resins and
fabricated
products
Agricultural
products



Haste Minimization Method Description
Return of distillation residue to process as raw
material.
Neutralization of spent caustics for treatment.
Storage of radioactive waste and reduce hazardous
amount to one half.
Aluminium hydroxide removal from sludge for reclama-
tion.
More selective polymerization technology to reduce
generation of plastic byproduct.
Reformulation of end product to reduce hydrocarbon
waste.
Reduction of carbon/water slurry by dewatering.
Reduction of waste oil by operational optimizations.


Input of waste back into process.
t 	
Waste Reduction
Percent | Quantity
|4 MMlb/yr


50.0

60.0

65.0

100.0

30.0
40.0


14.0,86.0


312Kgal/yr












|40. 0,75.0)
Sale of waste as feedstok to other process. |14.0,41.0|
New manufacturing processes and techniques.

New procedures


Development of the Pollution Prevention Pays (3P)
program.


*.
Segregation of liquid rafflnsts fron phenol waste.

Incineration of liquid halogenated organlcs.
Sale of co-product waste stream dilutent.
Eliminate use of plastlcizer. Install water separation
equipment to reduce volume and cross-contamination.
Detoxification of solids and contaninated water
through hydrolysis, catalytic oxidation.
Detoxification of sludge from manufacture of
inorganics to reduce chloride content.
Recovery and reuse of solvent.
Improved filtration stage, product recovery from
70.0

52.0







"33.0

"18.0
"7.0
"2.5

"1.8

'1.0

"0.$























f. 	
Classification
t
Reuse/process
modification
Treatment
Good operating
practice
Process modif.

Process modif.

Process modif./
product subst'n
Treatment
Good operating
practice/pro-
cess modif.
Reuse

Recovery/reuse
Process modif./
good oper. prac
Good operating
practice

Process modif.
(12)
Product reform/
subst'n (9)
Recovery/reuse
Good operating
practice
Treatment
Recovery/reuse
Good operating
practice
Treatment

Treatment

Recovery/reuse
Process modif.
> 	
Number of
Employees





8,000









8,000







50,000




9,600











Year
(*)





1982









b!984







1975




1919











Objective
(*')





m

















HM




KM











t 	
Capital
Investment
(1 1.000)





































Annual Cost
Savings
($ 1,000)








































Payback
Period








































(*) a:after;b:before / (*') HM:waste minimization;Tech:technical 1mprovement;YM:y
-------
                                                                                                         APPENDIX N (continued).
+ 	
Case
No

45








46







47






48









49




Ref

2








2







2






2









2




r 	
Company and
Location

Olin Corp.,
Stanford, Conn.







Rohm and Haas,
Philadelphia, Pa.






Shell Oil Co..
Houston, Tex.





Union Carbide
Corp., Danbury,
Conn.







Velsicol Chemical
Corp., Chicago,
111.


SIC
Code

26
28
34






28







12
13
28
29
646


10
28
30
36






28




Product

Chemicals
Brass & stainless
strip and mill
products





Acrylic emulsions
Surfactants
Bloc ides
Ion exchange
resins
Electro. & agrl.
chemicals
(etc.)
Fuels i petro-
chemical feed-
stocks, aromatics
Plastic, resins
Agrichemicals
(etc.)

Carbons
Commodity and
specialty chemi-
cals & plastics
Electronics
Hone and auto
products
Industrial gases
Processed metal
ores
Pesticides
Specialty
chemicals


f 	
Waste Minimization Method Description
sodium chlorate sludge.
Replacement of cyanides, solvent-based paints, raw
material substitutions.
Haste solvents in electronics used for paints manufac-
ture, refinery caustic used tn wood pulping, paint
sludge used as sealant.
(etc.)



Incineration of waste oils, spent solvents, still
bottoms, polymers, and disposable process equipment.
On-site neutralization or pH adjustment, then off-site
biotreatment.
Minimize maintenance using Inorganic add.



Recovery of oil from tanks during cleaning.
Belt pressing and Incineration of blosludge.

Installation of Incinerators In process units.
Use of spent adds as feed for fresh add.
Use of spent caustic for pH control.
Regeneration of catalysts.
Change in operating configuration of biotreatment unit
to reduce sludge generation.
Material substitution to eliminate flammable liquid
gas.
Catalyst Improvement to reduce production of by-
products.




Refrigeration system on process vents to recover
toluene.
I. 	
Haste Reduction
Percent | Quantity



















SO
MM ton/yr
















Installation of equipment to recover and recycle spent) 43.0
hypochlorite.
Classification
t







































Conservation and recycle improvements for water. |83. 0,97.0)
Process modif.

Reuse


Process modif./
good operating
practice/treat-
ment/recycling
Treatment

Treatment

Good operating
practice/pro-
cess modif.

Recovery/reuse
Treatment

Treatment
Recovery/reuse
Recovery/reuse
Process modif.
Good operating
practice
Process modif.

Process modif.





Recovery/reuse/
process modif.
Process modif.

Process modif.
h 	
Number of
Employees

17,800








11,911







34,700






51,300









1.600




h 	
Year
(*)

1983








1983







61976






1981









1978




h 	
Objective
(**)

m








m







YM






HM









HM




Capital
Investment
($ 1.000)








































Annual Cost
Savings
($ 1,000)








































t 	 *
Payback
Period








































(*) a.after;b:before / (**} HM:waste minimization;Tech:technical  1*provement;YM:yield  maximization.

-------
                                                                                                           APPENDIX H (continued).
t 	 »
Case
No
f 	 1










50

51


52


53


54

55

56



57



58

Ref











3

3


3


3


3

3

3



3



3

	 i
Company and
Location











Model Blue Ribbon
Cleaners
California Elec-
troplating, Los
Angeles, Calif.
Allied Metal
Finishing,
Baltimore, Md.
General Plating,
Detroit, Mich.

Ford Motor Co.,
Sabine, Mich.
Ford Motor Co.,
Sabine, Mich.
Advance Plating
Co., Cleveland,
Ohio

Reliable Plating
Horks, Milwaukee,
His.

Caterpillar
Tractor Co.,
	
SIC
Code











7216

3471


3471


3471


3471

3471

3471



3471





Product











Dry-cleaning
services
Plating


Plating of parts


Metal plating


Metal plating

Automotive parts
plating
Automotive parts
plating


Plating of nap-
kins, paper towels
and toilet tissue
dispensers
Paint application
Haste Minimization Method Description
Installation of still bottoms reboller and Improved
column Internals
Solvent recovery (distillation) out of liquid waste.
which is Incinerated.
Process change to reduce solvent and water usage.
Reaction of still bottoms to form saleable product.
Collection and separation of equipment cleaning waste.

Use of vent scrubber to recycle HCl, water to process.
Replacement of bearing and seal systems to arrest
leaks from bearing.
Addition of refrigerated solvent recovery system.

Installation of 4 counterflow rinses after each
plating stage, plus spray nozzles to wash drag-out
back into tanks.
Installation of N.S.A reactor.


Installation of tising fill evaporator unit.


Installation of evaporator recovery units.

Installation of 3 evaporator recovery units.

Attachment of Innova Chrome Napper Ion transfer system
to allow closed-loop recovery of chromium.


Attachment of Innova Chrome Napper Ion transfer system
to automatic hoist line.


| Use of water-borne coatings.
(engine)
	
Waste Reduction
Percent | Quantity
44.0

53.0

100.0




100.0


























Cd<1.22ppm


350 Ib/dy
(chromic





80.0-90.0
(Cr)
99.0
(water)
80.0-90.0
(Cr)
99.0
(water)


add








39.4 kg/wk
(H2Cr04)
92 KVdy



Classification
Process modif.

Process modif./
treatment
Process modif.
Recovery/reuse
Good operating
practice
Reuse
Good operating
practice
Recovery/recy-
cling
Process modif.


Process modif.
(recovery/reuse)

Process modif.
(recovery/reuse)

Process modif.
(recovery/reuse)
Process modif.

Process modif.



Process modif.



Process modif.

Number of
Employees




































rear
(*)





'






























Objective
(**)




































^ 	
Capital
Investment
($ 1,000)




































Annual Cost
Savings
($ 1.000)
















43.620


MOO
















Payback
Period
















1.5 yrs



















00
     (')  a:after;b:before / (") HN:waste m1n1m1zat1on;Tech:techn1cal  1mprovement;YM:y
-------
                                                                                                        APPENDIX H (continued).
f 	
Case
No

59


60


61

62



63

64

65



66




67



68

69

	 4
Ref


3


3


3

3



3

3

3



3




3



3

3

	
Company and
Location
Mossville, 111.
Flexsteel
Industries,
Dubuque, Iowa
Oshkosh Truck
Corp., Oshkosh,
His.
Fisher 8ody (GM).
Lansing, Mich.
USI Agribusiness,
Atlanta, Ga.


3M Corp.,St Paul,
Minn.
Colorcraft,
Rockford, 111.
Deluxe Motion
Picture Labora-
tories, Hollywood
Calif.
PCA International
Matthews, N.C.



Sweetheart Plas-
tics, Conyers.Ga.


Eastman Chemicals
Kingsport, Tenn.
Goodyear Tire and
Rubber Co.,
	 1
SIC
Code




3713


3711

2646
3523
3811



7395

7819



7395




3079







Product


Paint application
(furniture)

Assembly of heavy
specialty trucks

Automobile bodies

Poultry-feeding,
egg collection.
environmental
control equipment
Various

Photo finishing

Film processing



Photo finishing




Thermoforned
packaging






Maste Minimization Method Description


Change from conventional air spray to electrostatic
finishing system.

Purification of paint-laden air using water Venturis,
with water then electrostatically treated to remove
floating overspray by skinning.
Shift fron solvent-borne-coating system to electro-
coating, which uses water-bornes .
Shift to powder coating line.



Redesign of spray booth to reduce resin overspray and
recycle overspray back into to process.
Installation of production prototype developer
recycling unit (electrodialysls).
Introduction of ion exchange technology to purify
waste washwater for reuse and recover silver.


Recycle bleaches.
Recover silver from washwater.
Recover heavy metals fron wastewater.
Recycle pre-bath, final bath, paper color developer.
Total water recycle with 3-stage evaporation.
Switch to 2-stage granulator design.



Production of thermoset polyester resins fron used
polyethylene containers.
Recycle of polyethylene bottles economically into
fabric, auto parts, carpeting, home Insulation, etc.
Maste (
Percent

40.0
overspray












80. 0

62.0
(water)
90.0
(Ag)
"100.0
(Ag)
"100.0
(water)

80.0
(scrap
regrind-
Ing)




eduction
Quantity













500 Klb/yr
resin



















Classification


Process modif.


Treatment/
process modif.

Process modif.

Process nodlf.



Process modif./
recycling
Process todif.
(int. recycling)
Process nodlf.
(int. recycling)


Process modif.
(int. recycling/
reuse)


Process nodlf.



Reuse

Reuse

Number of
tflip loyees


































Year



































Objective
r»*\
I /


































Capital
(t 1.000)


































Annual Cost
(» 1,000)

15











125

50










46







Payback
Period


<2 yrs
































(*) a:after;b:before / (»') HM:waste minimization;Tech:technical  1nprovement;¥M:yield maximization.

-------
                                                                                                             APPENDIX H (continued).
+ 	
Case
No

70
71
72
73
H
75
76
77
78
79
80
81
Ref


3
3
3
3
3
3
3
3
3
3
3
3
^ 	
Company and
Location
Akron, Ohio
Graphic Arts
Technical founda-
tion, Pittsburgh,
Pa.
St. Petersburg
Times, St. Peter-
sburg, Fla.
The Oregonian,
Portland, Oreg.
Milwaukee Journal
and Sentinel,
Milwaukee, His.
Charleston News-
paper, Charleston
H. Va.
Minneapolis Star
and Tribune,
Minneapolis, Minn.
Union Carbide
IBM
Shuford Mills,
Hickory, N.C.
Pierce Industries
Inc.,Nalden, N.Y.
Sealed Power Carp
Muskegon, Mich.
Halstead
Industries,
SIC
rt*rtn
Code

27
27
27
27
27
27


36
2514
3592
3143
Product


Printing
Printed natter
Printed natter
Printed latter
Printed natter
Printed latter
Various
Various
Tape
Metal furniture
Piston rings
Heat-transfer
equipment
Haste Mininizatlon Method Description


Technical plant audits.
In-house waste reduction program.
Introductin of anllox (flexography) Inking device to
reduce newsprint waste.
In-house Ink recycling.
In-house Ink recycling.
Installation of fountain cleaner.
Mandated computer-assisted plant evaluation systens
(to calculate taterial balances).
Use of computer to nonltor continuous solvent Intake
for polishing, lachining, and cleaning operations.
Installation of two carbon adsorption units for
recovery of toluene.
Installation of Detrex free board extension unit and a
powered degreaser cover.
Installation of Detrex free board chillers.
Installation of carbon adsorption systei on contlnous-
use degreaser.
Waste
Percent


2.0
newsprint
25.0


80.0
(Ink)


95.0
efficient



Reduction
Quantity




54,000
gal/yr





3300
gal/dy
45 pp«
under OSHA
Unit of
100
75 pp*
under OSHA
t 	
Classification
>

Good operating
practice
Good operating
practice
Process lodif.

Process «od1f .
Process lodlf.
Good operating
practice
Good operating
practice
Process nodif.
Process nodlf.
Process nodif.
Process nodif.
t 	
Nuiber of
Enployees













Year
(* \
*)













Objective
(**)













Capital
Investment
(t 1.000)













(. 	
Annual Cost
Savings
(> 1,000)






350
2 per day




>25
t 	 »
Payback
Period









4 yrs



 I
I—•
o
     (*) a:after;b:before / (**) HN:waste mininizat1on;Tech:technical  1nprovenent;YM:y1eld iux1i1zat1on.

-------
                                                                                                       APPENDIX H (continued).
Case
Nn
nu


82



83


84




85

86


67


88




89





90


Ref



3



3


3




3

3


3


3




3





3


j. 	
Company and
Locat ion

Scottsboro, Ala

Foremost Screen
Print Plant of
Fieldcrest Mills,
Stokesdale, N.C
Hollytex Carpet
Mills. Inc.,
Southampton, Pa.
J.P. Stevens Co.,
Clemson, S.C.



Spring Mills,
S.C.
Riegel Textile
Co., La France,
S.C.
Lumberton Dyeing
and Finishing Co.
Lumberton, N.C.
Gaston County,
Stanley, N.C.,
Spinners
Processing Co.,
Splndale, N.C.
Adams-Mi 11 is
Hosiery Co., High
Point, N.C.



La France
Industries,
La France, S.C.
SIC
Pnffa
UOue


2261
2262


227


22




22

22


22


226




22





22


Product



Screen printing
of consumer cloth
goods

Carpet


Textiles




Textiles

Textiles


Textiles


Textile dyeing




Textiles





Textiles


Haste Minimization Method Description



Recycling of water after treatment.
.


Recycling of wastewater using carbon adsorption unit,
with incineration of carbon.

Recovery and re-use of PVA size (sizing chemical)
using ultra-filtration technology developed jointly
by Clemson University, J.P. Stevens Co., Gaston
County Dyeing Machine Co. and Union Carbide Corp.,
oil recovery/reuse fro* exhaust.
Installation of Afacor System to recover PVA sizing
chemical.
Installation of ultraflltration plant for complete
recycle of textile wastewater and for heat recovery
(co-funded with USEPA).
Installation of counterflow heat recovery system to
heat process Hater with exhaust and to precipitate
out hydrocarbon pollutants.
Use of low-liquor dyeing technology, which increases
dye efficiency, reduces water consumption, and emits
less polluting wastestream.


Reconstitute and reuse of dye baths an average of 15
times before discharge.




Ultrafiltration technology to achieve closed-cycle
dyeing, ultraflltration concentrates the dye solution
and recycles waste water for reuse.
t 	
Haste
Percent






80.0







96.0












19.0
(dye)
35.0
chemical
43.0
(water)



ieduction
Quantity
Unit of
100
175,000
gal/dy





1.000
ton/yr

























y 	
Classification
•


Process modif.



Process modif.


Process modif.
(int. recycling)



Process modif.

Process modif.


Process nodif.


Process modif.




Process modif.
(Int. recycling)




Process modif.


^ 	
Number of
Employees




































	
Year
/*\
(*)




































	
Objective
(** \
)




































	
Capital
Investment
($ 1.000)




































	
Annual Cost
Savings
(1 1.000)






















3.6 per week










560


	 +
Payback
Period



















5 months
















(•)  a:after;b:before / (") NM:waste minimization;Tech:techn1cal  improvement;YM:y1eld maximization.

-------
                                                                                                              APPENDIX H (continued).
f 	 *
Case
No
91




92


93


94

95




96


91







98






	 4
Kef
3




4


4


4

4




5


5







5






Company and | SIC
Location Code
Cone Mills,
Greensboro, N.C.
Dan River Textile
Co., Greenville,
S.C.
General Motors
Corp., Narren,
Mich.
Phelps Dodge
Corp., Hidalgo,
N. Mex.
Kennecott,
Garfield, Utah
Ubia. Inc.,
Crankton , R.I.



Ou Pont,
Petrochemicals'
Victoria, lex.
Ou Pont,
Petrochemicals'
Sabine, Tex.





Ou Pont's Cape
fear Plant,
Hilmington. N.C.




22




37


33


33

3411




28


28







28






	 1
Product
Textiles




Automobiles


Copper


Copper

Electroplating
job shop



Petrochemicals


Petrochemicals







Chemicals






Haste Minimization Method Description
Undergo recycling through redesign of rinse boxes to
counter-current rinse system, dropping amount of
rinsewater and producing concentrated feed for
ultrafHtratlon.

Side-stream separator technology for control of coal-
fired boiler participate emissions.

Replacement of copper smelting using a reverberatory
furnace by the Outokumpu flash smelting process to
facilitate sulfur recovery and energy saving.
Use of the Noranda continous process for copper
smelting to facilitate sulfur and energy saving.
Replacement of counter-current flow rinsing by the
Providence method, which removes the majority of
contaminating dragout In small volume before using a
flowing rinse to reduce wastewater volume and to alow
for recovery of plating solution.
Use of a new process to produce adlponitrile (ADN)
which eliminates one Intermediate to reduce
wastewater.
Recovery and sale of alumina Instead of off-side
disposal.
Distillation of waste materials to recover feed
materials for other processes, burning of distilla-
tion residues for energy.
Reduction in sludge volume using a belt-filter press.


Substitution .of safer solvents and disposal of solvent
on-slte by incineration
Incineration of acid waste, recovery of cobalt for
reformulation as catalyst in dimethyl terephthalate
(DMT) manufacturing process.
Recovery of raw materials from byproduct stream in DMT
manufacture, burning of off-gtses to generate heat.
Haste Reduction
Percent | Quantity





38.0-62.0







94.0
(waste-
water)


50.0
(waste-
water)


80.0


55.6
35.0-40.0
(overall)

























400
gal/min
















h 	 1
Classification
h
Process modlf .




Treatment


Process modlf.


Process modif.

Process nodif.




Process modlf.


Recovery/reuse

Recovery


Treatment


Process modif.

Recovery/reuse


Recovery

Number of
Employees




































Year
(')




































Objective
('«)




































Capital
Investment
($ 1,000)




































Annual Cost
Savings
(t 1,000)




































e 	 1
Payback
Period




































 I
I—>
ro
     (*) a:after;b:before / ('») HM:naste m1niin1zation;Tech:technical 1mprovement;YM:y1eld maximization.

-------
                                                                                                             APPENDIX H (continued).
# — - —
Casa
ftirt
no
9)

100

101







102

103


101

105




ioe


10T


108

109

t 	
Ref

6

t

(







1

(


7

I




7


7


1

1

t 	
Conpany and
II rvjit Irvt
LOCfll (On
Monsanto, Baxlty,
6a.
Monsanto,
Anntston, Ala.
Sadlscht Corp.







Allied Corp.

Htrcultt, Inc.


3M, St. Paul.
N1nn.
3M, Magnetic
Materials Re-
sources Olv.,
Cottage Grove,
Minn.
3N, Decorative
Products Olv.,
Nevada, Mo.
3M, Hiker
Laboratories,
Northrldge, Calif.
Rexhan Corp.,
Suiter, S.C.
Southern Coating,
Suiter. S.C.
, 	
SIC
fft/tm
IvuV
21

217}

21







21














21


27

2ISI

Product

Paper cheetcals

Pesticides

Cheilcels







Cheelcals




Various









Pheriaceutlcels


Printing

Paints, coatings

Matte Nin1«1iat1on Method Description

Sale of sodtui hydroxide as a neutral lier Instead of
disposal.
Recovery of sulfur Mste to be used In parclthlon
Insecticide eanufacture.
Recovery of Hterlali froe Haste, burning of Mste as
boiler fuel.
Sale of by-products Instead of disposal.



Sale of Haste street (sodiw-organic-acid salt streai)
instead of disposal.
Recovery of sulfurlc acid fro* spent scrubbing Mdiue
generated froe other fires.
Recovery of spent solvent* by distillation.
Reeoval of organic! froe) MStevater wing biological
treatient lysttes.
Burning solvent-laden air (SLA) in boilers to recover
energy and reduce Mission level.
Recovery of aMontu* sulfete fnxa vasteMter vhlch is
subsequently processed end sold as ferti liter.



Redesigning pan to reduce the aanunt of coating solu-
tion required and to decrease the pan clean-up tie*.

Replacing solvent-based by e Hater-based Mdlclne
tablet coating to reduce air pollution and shorten
clean-up tie*.
Recovery and sale of solvent vapors for reuse.

Recovery of solvent by distillation nhich Is sub-
sequently used for cleanup.
Haste
Percent






112
•Illton
Ibs sold
in 1911




"100.0
(solvent)


















Reduction
Quantity


5. 000.000
Ib/yr






























( 	
Classification
'
Reuse

Recovery/reuse

Recovery

Reuse



Reuse

Recovery

Recovery
Treatment

Reuse/tr*ata*nt

Recovery/reuse







Product subst'n


Recovery/reuse

Recovery/re-
claMtion
i 	
Nucber of
Employees


































> 	
Year
(ti
•J




'





























i 	
Objective
(Ml
/


































	
Capital
InvastMflt
(t 1.000)


































	 <
Annual Cost
Savings
(t 1.000)
100









1.000






1SS






11









	 «
Payback
«_., j_j
Par loo


































 I
I—'
CJ
     (•) a:efter;b:before / (•') NM:vaste •In1iizat1on;lech:techn1cal  Improvement;YM:y1«ld Mxtiliation.

-------
                                                                                                         APPENDIX  H  (continued).
Case
No

110
111
112
113
114
115
Ref

8
8
8
8
8
8
Company and
Location

Bowling Co., Mt.
Olive, N.C.
Lenoir Minor, Co.,
Lenoir. N.C.
Thiele-Engdahl,
Hinston-Salem,
N.C.
Hestinghouse
Electric Meter
Plant, Raleigh,
N.C.
Celanese Fiber
Operations,
Charlotte, N.C.
Burlington Furni-
ture Co.,
Lexington, N.C.
SIC
Code

2521
27
2893
3825
2823
2824
2521
Product

Hood office fur-
niture
Printing
Solvent-based Ink
Electric meters
Polyester resins
and fibers,
cellulosies.
Hood furniture
Haste Minimization Method Description

Recovery and reuse of spent acetone as thinner.
Burning of spent lacquer for heat recovery.
Recovery of xylene contaminated with paint by pot
distillation.
Rcovery of spent isopropyl acetate by pot distilla-
tion. The solvent Is resued for equipment cleanup.
Recovery of perchloroethylene and Freon IMS degreaser
by distillation.
Recovery of Freon THC and Dowthem solvents by
distillation.
Burning of concentrated MeO-acetone mixture In cement
kilns for heat recovery.
Burning of spent solvents for heat recovery.
Haste
Percent






Reduction
Quantity






Classification
1

Recovery/reuse
Recovery/treat-
ment
Recovery
Recovery/reuse
Recovery
Recovery
Recovery/treat-
ment
ment
Number of
Employees






Year
(ft \
*)






Objective
(** \
**)






Capital
Investment
($ 1.000)






Annual Cost
Savings
(1 1,000)






t 	 4
Payback
Period






(») a:after;b:before / (**) HM:waste »inii>ization;Tech:techn1cal improvement;YM:yield max1»izat1on.

-------
                 APPENDIX I




ENVIRONMENTAL AUDITING POLICY STATEMENT

-------
Wednesday
July 9, 1986
Part IV

Environmental
Protection Agency
Environmental Auditing Policy Statement;
Notice

-------
25004
Federal Register  /  Vol.  51, No. 131 / Wednesday, July 9, 1986 / Notices
ENVIRONMENTAL PROTECTION
AGENCY

[OPPE-FRL-3046-6]

Environmental Auditing Policy
Statement

AGENCY: Environmental Protection
Agency (EPA).
ACTION: Final policy statement.	

SUMMARY: It is EPA policy to encourage
the use of environmental auditing by
regulated entities to help achieve and
maintain compliance with
environmental laws and regulations, as
well as to help identify and correct
unregulated environmental hazards.
EPA first published this policy as
interim guidance on November 8,1985
(50 FR 46504). Based on comments
received regarding the interim guidance.
the Agency is issuing today's final
policy statement with only minor
changes.
  This final policy statement       •
specifically:
  • Encourages regulated entities to
develop, implement and upgrade
environmental auditing programs;
  • Discusses when the Agency may or
may not request audit reports:
  • Explains how EPA's inspection and
enforcement activities may respond to
regulated entities' efforts to assure
compliance through auditing;
  • Endorses environmental auditing at
federal facilities:
  • Encourages state and local
environmental auditing initiatives: and
  • Outlines elements of effective audit
programs*
  Environmental auditing includes a
variety of compliance assessment
techniques which go beyond those
legally required and are used to identify
actual and potential environmental
problems. Effective environmental
auditing can lead to higher levels of
overall compliance and reduced risk to
human health and the environment. EPA
endorses the practice of environmental
auditing and supports its accelerated
use by regulated entities to help meet
the goals of federal, state and local
environmental requirements. However.
the existence of an auditing program
does not create any defense to. or
otherwise limit, the responsibility of any
regulated entity to comply with
 applicable regulatory requirements.
   States are encouraged to adopt these
or similar and equally effective policies
 in order to advance the use of
 environmental auditing on a consistent,
nationwide basis.
 DATES: This final policy statement is
 effectiv-R July 9.1986.
                   FOR FURTHER INFORMATION CONTACT:
                   Leonard Fleckenstein, Office of Policy.
                     Planning and Evaluation, (202) 382-
                     2726;
                         or
                   Cheryl Wasserman, Office of
                     Enforcement and Compliance
                     Monitoring, (202) 382-7550.
                   SUPPLEMENTARY INFORMATION:
                   ENVIRONMENTAL AUDITING
                   POLICY STATEMENT
                   I. Preamble
                     On November 8. 1985 EPA published
                   an Environmental Auditing Policy
                   Statement effective as interim guidance,
                   and solicited written  comments until
                   January 7,1986.
                     Thirteen commenters submitted
                   written comments. Eight were from
                   private industry. Two commenters
                   represented industry  trade associations.
                   One federal agency, one consulting firm
                   and one law firm also submitted
                   comments.
                     Twelve commenters addressed EPA
                   requests for audit reports. Three
                   comments per subject were received
                   regarding inspections, enforcement
                   response and elements of effective
                   environmental auditing. One coznmenter
                   addressed audit provisions as remedies
                   in enforcement actions, one addressed
                   environmental auditing at federal
                   facilities, and one addressed the
                   relationship of the policy statement to
                   state or local regulatory agencies.
                   Comments generally  supported both the
                   concept of a policy statement and the
                   interim guidance, but raised specific
                    concerns with respect to particular
                    language and policy issues in sections of
                    the guidance.
                    General Comments 	
                      Three commenters found the interim
                    guidance to be constructive, balanced
                    and effective at encouraging more and
                    better environmental auditing.
                      Another commenter, while
                    considering the policy on the whole to
                    be constructive, felt that new and
                    identifiable auditing "incentives" should
                    be offered by EPA. Based on earlier
                    comments received from industry, EPA
                    believes most companies would not
                    support or participate in an "incentives-
                    based" environmental auditing program
                    with EPA. Moreover, general promises
                    to forgo inspections or reduce
                    enforcement responses in exchange for
                    companies' adoption of environmental
                    auditing programs—the "incentives"
                    most frequently mentioned in this
                    context—are fraught with legal and
                    policy obstacles.
                      Several commenters expressed
                    concern that states or localities might  -
use the interim guidance to require
auditing. The Agency disagrees that the
policy statement opens the way for
states and localities to require auditing.
No EPA policy can grant states or
localities any more (or less) authority
than, they already possess. EPA believes
that the interim guidance effectively
encourages voluntary auditing. In fact
Section II.B. of the policy states:
."because audit quality depends to a
large degree on genuine management
commitment to the program and its
objectives, auditing should remain a
voluntary program."
   Another commenter suggested that
EPA should not expect an audit to
identify all potential problem areas or
conclude that a problem identified in an
audit reflects normal operations and
procedures. EPA agrees that an audit
report should clearly reflect these
realities and should be written to point
out the audit's limitations. However,
since EPA will not routinely request
audit reports, the Agency does not
believe these concerns raise issues
which need to be addressed in the
policy statement
   A second concern expressed by the
same commenter was that EPA should
acknowledge that environmental audits
are  only part of a successful
 environmental management program
 and thus should not be expected to
 cover every environmental issue or
solve ail problems. EPA agrees and
 accordingly has amended the statement
 of purpose which appears at the end of
 this preamble.
   Yet another commenter thought EPA
 should focus on environmental
 performance results (compliance or non-
 compliance), not on tile processes or
 vehicles used to achieve those results. In
 general, EPA agrees with this statement
 and will continue to focus on
 environmental results. However, EPA
 also believes that such results can be
 improved through Agency efforts to
 identify and encourage effective
 environmental management practices,
 and will continue to encourage such
 practices in non-regulatory ways.
   A final general comment
 recommended that EPA should sponsor
 seminars for small businesses on how to
 start auditing programs. EPA agrees that
 such seminars would be useful.
 However, since audit seminars already
 are available from several private sector
 organizations. EPA does not believe it
 should intervene in that market, with the
 possible exception of seminars for
 government agencies, especially federal
 agencies, for which EPA has a broad
 mandate under Executive Order 12088 to

-------
                   Federal Register / Vol. 51. No. 131  /  Wednesday. July  9. 1986  /  Notices
                                                                    23003
provide technical assistance for
environmental compliance.
Requests for Reports
  EPA received 12 comments regarding
Agency requests for environmental audit
reports, far more than on any other topic
in the policy statement. One commenter
felt that EPA struck an appropriate
balance between respecting the need for
self-evaluation with some  measure of
pr.vacy, and allowing the Agency
enough flexibility of inquiry to
accomplish future statutory missions.
However, most comraenters expressed
concern that the interim guidance did
not go far enough to assuage corporate
fears that EPA will use audit reports for
environmental compliance "witch
hunts." Several commenters suggested
additional specific assurances regarding
the circumstances under which EPA will
request such reports.
   One commenter recommended that
EPA request audit reports only "when
the Agency can show the information it
needs to perform its statutory mission
cannot be obtained from the monitoring,
compliance or other data that is
otherwise reportable and/or accessible
to EPA. or where the Government deems
an audit report material to a criminal
investigation." EPA accepts this
recommendation in part. The Agency
believes it would not be in the best
 interest of human health and the
 environment to commit to making a
 "showing" of a compelling information
 need before ever requesting an audit
 report. While EPA may normally be
 willing to do so, the Agency cannot rule
 out in advance all circumstances in
 which such a showing may not be
 possible. However, it would be helpful
 to further clarify that a request for an
 audit report or a portion of a report
 normally will be made when needed
 information is not available by
 alternative means. Therefore. EPA has
 revised Section m.A., paragraph two
 and added the phrase: "and usually
 made where the information needed
 cannot be obtained from  monitoring,
 reporting or other data otherwise
 available to the Agency."
   Another commenter suggested that
 (except in the case of criminal
 investigations) EPA should limit
 requests for audit documents to specific
 questions. By including the phrase "or
 relevant  portions of a report" in Section
 IILA., EPA meant to emphasize it would
 not request an entire audit document
 when only a relevant portion would
 suffice. Likewise, EPA fully intends not
 to request even a portion of a report if
 needed information or data can be
 otherwise obtained. To further clarify
  this point EPA has added the phrase,
"most likely focused on particular
information needs rather than the entire
report," to the second sentence of
paragraph two, Section m.A.
incorporating the two comments above,
the first two sentences in paragraoh two
of final Section IILA. now read: "EPA's
authority to request an audit report, or
relevant portions thereof, will be
exercised on a case-by-case basis where
the Agency determines it is needed to
accomplish a statutory mission or the
Government deems it to be material to a
criminal investigation. EPA expects such
requests to be limited, most likely
focused on particular information needs
rather than the entire report, and usually
made where the information needed
cannot be obtained from monitoring,
reporting or other data otherwise
available to the Agency."
   Other commenters recommended that
EPA not request audit reports under any
circumstances, that requests be
"restricted totmlythose legally
required," that requests be limited to
criminal investigations, or that requests
be made only when EPA has reason to
believe "that the audit programs or
reports are being used to conceal
evidence of environmental non-
compliance or otherwise being used in
bad faith." EPA appreciates concerns
underlying all of these comments and
has considered each carefully. However,
the Agency believes that these
recommendations  do not strike the
 appropriate balance between retaining
 the flexibility to accomplish EPA's
 statutory missions in future, unforeseen
 circumstances, and acknowledging
 regulated entities'  need to self-evaluate
 environmental performance with some
 measure of privacy. Indeed, based on
 prime informal comments, the small
 number of formal comments received,
 and the even smaller number of adverse
 comments, EPA believes the final policy
 statement should remain largely
 unchanged from the interim version.
 Elements of Effective Environmental
 Auditing
   Three commenters expressed
 concerns regarding the seven general
 elements EPA outlined in the Appendix
 to the interim guidance.
   One commenter noted that were EPA
 to further expand or more fully detail
 such elements, programs not specifically
 fulfilling each element would then be
 judged inadequate. EPA agrees that
 presenting highly  specific and
 prescriptive auditing elements could be
 counter-productive by not taking into
 account numerous factors which vary
 extensively from one organization to
 another, but which may still result in
 effective auditing programs.
Accordingly. EPA does not plan to
expand or more fully detail these
auditing elements.
  Another commenter asserted tha!
states and localities should be cautioned
not to consider EPA's auditing elements
as mandatory steps. The Agency is ruliy
axvare of this concern and in the interim
guidance noted its strong opinion that
"regulatory agencies should not attempt
to prescribe the precise form and
structure of regulated entities'
environmental management or auditing
programs." While EPA cannot require
state or Iocs! regulators to adopt this or
similar policies, the Agency does
strongly encourage them to do so. both
in the interim and final policies.
   A final commenter thought the
Appendix too specifically prescribed
what should and what should not be
included in an auditing program. Other
commenters. on the other hand, viewed
the elements described as very general
in nature. EPA agrees with these other
commenters. The elements are in no
way binding. Moreover. EPA believes
that most mature, effective
environmental auditing programs do
 incorporate each of these general
 elements in some form, and considers
 them useful yardsticks for those
 considering adopting or upgrading audit
 programs. For these reasons EPA has
 not revised the Appendix in today's
 final policy statement.

 Other Comments
   Other significant comments addressed
 EPA inspection priorities for, and
 enforcement responses to, organizations
 with environmental auditing programs.
   ©ne commenter, stressing that audit
 programs are internal management
 tools, took exception to the phrase in the
 second paragraph of section IILB.l. of
 the interim guidance which states that
 environmental audits  can 'complement'
 regulatory oversight. By using the word
 'complement' in this context, EPA does
 not intend to imply that audit reports
 must be obtained by the Agency in order
 to supplement regulatory inspections.
 'Complement' is used in a broad sense
 of being in addition to inspections and
 providing something (i.e., self-
 assessment) which otherwise would be
 lacking. To clarify this point EPA has
 added the phrase "by providing self-
 assessment to assure compliance"  after
 "environmental audits may complement
 inspections" in this paragraph.
   The same commenter also expressed
 concern that, as EPA sets inspection
 priorities, a company having an audit
 program could appear to be a 'poor
 performer' due to complete and accurate
 reporting when measured against a

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25006	Federal Register /  Vol.  51.  No. 131  /  Wednesday. }uly 9. 1986  /  Notices
company which reports something less
than required by law. EPA agrees that it
is important to communicate this- fact to
Agency and state personnel, and will do
so. However, the Agency does not
believe a change in the policy statement
is necessary.
  A further comment suggested EPA
should commit to take auditing
programs into account when assessing
all enforcement actions. However, in
order to maintain enforcement flexibility
under varied circumstances, the Agency
cannot promise reduced enforcement
responses to violations at all audited
facilities when other factors may be
overriding. Therefore the policy
statement continues to state that EPA
may exercise its decretion to consider
auditing programs as evidence of honest
and genuine efforts to assure
compliance, which would then be taken
into account in fashioning enforcement
responses to violations.
   A final commenter suggested the
phrase "expeditiously correct        •
environmental problems" not be used in
 the enforcement context since it implied
 EPA would use an entity's record of
 correcting nonregulated matters when
 evaluating regulatory violations. EPA
 did  not intend for such an inference to
 be made. EPA intended the term
 "environmental problems" to refer to the
 underlying circumstances which
 eventually lead up to the violations. To
 clarify this point, EPA is revising the
 first two sentences of the paragraph to
 which this comment refers by changing
 "environmental problems" to "violations
 and underlying environmental
 problems" in the first sentence and to
 "underlying environmental problems" in
 the second sentence.
   In a separate development EPA is
 preparing an update of its January 1984
 Federal Facilities Compliance Strategy.
 which is referenced in section 111. C. of
 the auditing policy. The Strategy should
 be completed and available on request
 from EPA's Office of Federal Activities
  later this year.
   EPA thanks all commenters for
  responding to the .November 8,1985
 publication. Today's notice is being
  issued to inform regulated entities and
  the public of EPA's final policy toward
  environmental auditing. This policy was
  developed to help (a) encourage
  reculated entities to institutionalize
  effective audit practices as one means of
  improving compliance and  sound
  environmental management and (b)
  guide internal EPA actions directly
  related to regulated entities'
  environmental auditing programs.
    EPA will evaluate implementation of
  this final policy to ensure it meets the
  aoove goals and continues to encourage
better environmental management
while strengthening the Agency's own
efforts to monitor and enforce
compliance with environmental
requirements.

II. General EPA Policy on
Environmental Auditing
A. Introduction
  Environmental auditing is a
systematic, documented, periodic and
objective review by regulated entities '
of facility operations and practices
related to meeting environmental
requirements.  Audits can be designed to
accomplish any or all of the following:
verify  compliance with environmental
requirements:  evaluate the effectiveness
of environmental management systems
already in place; or assess risks from
regulated and unregulated materials and
practices.
   Auditing serves as a quality assurance
check to help  improve the effectiveness
of basic environmental management by
verifying that  management practices are
in place, functioning and adequate.
Environmental audits evaluate, and are
not a substitute  for, direct compliance
activities such as obtaining permits,
installing controls, monitoring
compliance, reporting violations, and
keeping records. Environmental auditing
may verify but does not include
activities required by law, regulation or
 permit (e.g.. continuous emissions
monitoring, composite correction plans
 at wagtewater treatment plants, etc.).
 Audits do not in any way replace
 regulatory agency inspections. However,
 environmental audits can improve
 compliance by complementing
 conventional  federal. Ifate and local
 oversight.
   The appendix to this policy statement
 outlines some basic elements of
 environmental auditing (e.g., auditor
 independence and top management
 support) for use by those considering
 implementation of effective auditing
 programs to help achieve and maintain
 compliance. Additional information on
 environmental auditing practices can be
 found in vanous published materials.2
   1 "Regulated entities" include pnvate firms and
  public agencies with facilities subtect to
  environmental regulation. Public agencies can
  include federal, state or local agencies as well as
  special-purpose organizations such as regional
  sewage commissions.
   * See. e.g.. "Current Practices in Environmental
  Auditing." EPA Report No. EPA-ZMW»-«3-006.
  February 1984. "Annotated Bibliograpny on
  Environmental Auditing," Fifth Edition. September
  1985. both available from- Resuiatorv Reform Slaff.
  PM-223. EPA. 401 M Street SW. Washington. DC
  20460.
  Environmental auditing has developed
for sound business reasons, particularly
as a means of helping regulated entities
manage pollution control affirmatively
over time instead of reacting to crises.
Auditing can result in improved facility
environmental performance, help
communicate effective solutions to
common environmental problems, focus
facility managers' attention on current
and upcoming regulatory requirements.
and generate protocols and checklists
which help facilities better manage
themselves. Auditing also can result in
better-integrated management of
environmental hazards, since auditors
frequently identify environmental
liabilities which go beyond regulatory
compliance. Companies, public entities
and federal facilities have employed a
variety of environmental  auditing
practices in recent years. Several
hundred major firms in diverse
industries now have environmental
auditing programs, although they often
are known by other names such as
assessment survey, surveillance, review
or appraisal
   While auditing has demonstrated its
usefulness to those with audit programs,
many others still do not audit
Clarification of EPA's position regarding
auditing may help encourage regulated
entities to establish audit programs or
upgrade systems already in place.
B. EPA Encourages the Use of
Environmental Auditing
   EPA encourages regulated entities to
 adopt sound environmental
 management practices to improve
 environmental performance. In
 particular. EPA encourages regulated
 entities subject to environmental
 regulations to institute environmental
 auditing programs to help ensure the
 adequacy of internal systems to achieve,
 maintain and monitor compliance.
 Implementation of environmental
 auditing programs can result in better
 identification, resolution and avoidance
 of environmental problems, as well as
 improvements to management practices.
 Audits can be conducted effectively by
 independent internal or  third party
 auditors. Larger organizations generally
 have greater resources to devote to an
 internal  audit team, while smaller
 entities might be more likely to use
 outside auditors.
   Regulated entities are responsible for
 taking all necessary steps to ensure
 compliance with environmental
 requirements, whether or not they adopt
 audit programs. Although environmental
 laws do not require a regulated facility
  to have an auditing program, ultimate
  responsibility for the environmental

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                    Federal  Register / Vol. 51. No. 131 / Wednesday. July 9. 1986  / Notices
                                                                       25007
performance of the facility lies with top
management, which therefore has a
strong incentive to use reasonable
means, such as environmental auditing,
to secure reliable information of facility
compliance status.
  EPA does not intend to dictate.or
interfere with the environmental
management practices of private or
public organizations. Nor does EPA
intend to mandate auditing (though in
certain instances EPA may seek to
include provisions for environmental
auditing as part of settlement
agreements, as noted  below). 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.
III. EPA Policy on Specific
Environmental Auditing Issues

A. Agency Requests for Audit Reports'
  EPA has broad statutory authority to
request relevant information on the
environmental compliance status of
regulated entities. However, EPA
believes routine Agency requests for
audit reports 3 could inhibit auditing in
the long run. decreasing both the
quantity and quality of audits
conducted. Therefore, as a matter of
policy. EPA will not routinely request
environmental audit'reports.
  EPA's authority to request an audit
report or relevant portions thereof, will
be exercised on a case-by-case basis
where the Agency determines it is
needed to accomplish a statutory
mission, or where the  Government
deems it to be material to a criminal
investigation. EPA expects such
requests to be limited, most likely
focused on particular information needs
rather than the entire report, and usually
made where the information needed
cannot be obtained from monitoring,
reporting or other data otherwise
available to the Agency. Examples
would likely include situations where:
audits are conducted under consent
decrees or other settlement agreements:
a company has placed its management
practices at issue by raising them as a
defense: or state of mind or intent are a
relevant element of inquiry, such as
during a criminal investigation. This list
  1 An "onviroaimnial audit report" u a written
report wnich candidly and thoroughly presents
findings from a review, conducted as part of an
environmental audit as dncnbed in aecnon II-A.. of
facility environmental periormam and practice!.
An aucil report is not a substitute for compliance
momionne reports or other reports or records which
mav be required by EPA or other regulatory
agencies
is illustrative rather than exhaustive.
since there doubtless will be other
situations, not subject to prediction, in
which audit reports rather than
information may be required.
   EPA acknowledges regulated entities'
need to self-evaluate environmental
performance with some measure of
privacy and encourages such activity.
However, audit reports may not shield
monitoring, compliance, or other
information, that would otherwise be
reportable and/or accessible to EPA.
even if there is no explicit 'requirement'
to generate that data.4 Thus, this policy
does not alter regulated entities' existing
or future obligations to monitoB record
or report information required under
environmental statutes, regulations or
permits, or to allow EPA access to that
information. Nor does this policy alter
EPA's authority to request and receive
any relevant information—including that
contained in audit reports-Hinder
various environmental statutes (e.g..
Clean Water Act section 308, Clean Air
Act sections 114 and 208) or in other
administrative or judicial proceedings.
   Regulated entities also should be
aware that certain audit findings may by
law have to be reported to government
agencies. However, in addition to any
such requirements. EPA encourages
regulated entities to notify appropriate
State or Federal officials of findings
which suggest significant environmental
or public health risks, even when not
specifically required to do so.

B. EPA Response to Environmental
Auditing

1. General Policy

  EPA will not promiseta forgo
inspections, reduce enforcement
responses, or offer other such incentives
in exchange for implementation of
environmental auditing or other sound
environmental management practices.
Indeed, a credible enforcement program
provides a strong incentive for regulated
entities to audit.
  Regulatory agencies have an
obligation to assess source compliance
status independently and cannot
eliminate inspections for particular firms
or classes of firms. Although
environmental audits may complement
inspections by providing self-
assessment to assure compliance., they
are in no way a substitute for regulatory
oversight. Moreover, certain statutes
(e.g. RCRA) and Agency policies
establish minimum facility inspection
frequencies to which EPA will adhere.
  However. EPA will continue to
address environmental problems on a
priority basis and will consequently
inspect facilities with poor
environmental records and practices
more frequently. Since effective
environmental auditing helps
management identify and promptly
correct actual or potential problems.
audited facilities' environmental
performance should improve. Thus,
while EPA inspections of self-audited
facilities will continue, to the extent that
compliance performance is considered
in setting inspection priorities, facilities
with a good compliance history may be
subject to fewer inspections.
  In fashioning enforcement responses
to violations, EPA policy is to take into
account, on a case-by-case basis, the
honest and genuine efforts of regulated
entities to avoid and promptly correct
violations and underlying environmental
problems. When regulated entities take
reasonable precautions to avoid
noncompliance, expeditiously correct
underlying environmental problems
discovered through audits or other
means, and implement measures to
prevent their recurrence, EPA may
exercise its discretion to consider such
actions as honest and genuine efforts to
assure compliance. Such consideration
applies particularly when a regulated
entity promptly reports violations or
compliance data which otherwise were
not required to be recorded or reported
to EPA.

2. Audit Provisions as Remedies in
Enforcement Actions

  EPA may propose environmental
auditing provisions in consent decrees
and in other settlement negotiations
where auditing  could provide a remedy
for  identified problems and reduce the
likelihood of similar problems recurring
in the future.9 Environmental auditing
provisions are most likely to be
proposed in settlement negotiations
where:
  • A pattern of violations can be
attributed, at least in part, to the
absence or poor functioning of an
environmental management system: or
  • The type  or nature of violations
indicates a likelihood that similar
noncompliance problems may exist or
occur elsewhere in the facility or at
other facilities operated by the regulated
entitv.
  4 See. for example. "Duiie> to Report or Disclose
Information on the Environmental Aspects of
Business Activities." Environmental Law Institute
report lo EPA. final report. September 1985.
  s r_-A is developing guidance for use by Agency
negotiators in structuring appropriate environment**
audit urovisioas for consent decrees and older
settietaent negotiations.

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25008
Federal  Register / Vol. 51. No. 131  / Wednesday.  July 9. 1986  /  Notices
  Through this consent decree approach
and other means. EPA may consider
how to encourage effective auditing by
publicly owned sewage treatment works
(POTWs), POTWs often have
compliance problems related to
operation and maintenance procedures
which can be addressed effectively
through the use of environmental
auditing. Under its National Municipal
Policy EPA already is requiring many
POTWs to develop composite correction
plans to identify and correct compliance
problems.

C. Environmental Auditing at Federal
Facilities
  EPA encourages all federal agencies
subject to environmental laws and
regulations to institute environmental
auditing systems to help ensure the
adequacy of internal systems to achieve,
maintain and monitor compliance.
Environmental auditing at federal
facilities can be an effective supplement
to EPA and state inspections. Such
federal facility environmental audit"
programs should be structured to
promptly identify environmental
problems and expenditiously develop
schedules for remedial action.
  To the extent feasible. EPA will
provide technical assistance to help
federal agencies design and initiate
audit programs. Where appropriate. EPA
will enter into agreements with other
agencies to clarify the respective roles,
responsibilities and commitments of
each agency in conducting and
responding to federal facility
environmental audits.
  With respect to inspections of self-
audited facilities (see section Ul.B.l
above) and requests for audit reports
(see section III.A above), EPA generally
will respond to environmental audits by
federal facilities in the same manner as
it does for other regulated entities, in
keeping with the spirit and intent of
Executive Order 12088 and the EPA
Federal Facilities Compliance Strategy
(January 1984. update forthcoming in
late 1986). Federal agencies should.
however, be  aware that the Freedom of
Information Act will govern any
disclosure of audit reports or audit-
generated information requested from
federal agencies by the public.
  When federal agencies discover
significant violations through an
environmental audit, EPA encourages
them to submit the related audit findings
and remedial action plans expeditiously
to the applicable EPA regional office
(and responsible state agencies, where
appropriate) even when not specifically
required to do so. EPA will review the
 audit findings and action plans and
 either provide written  approval or
                    negotiate a Federal Facilities
                    Compliance Agreement. EPA will utilize
                    the escalation procedures provided in
                    Executive Order 12088 and the EPA
                    Federal Facilities Compliance Strategy
                    only when agreement between agencies
                    cannot be reached. In any event federal
                    agencies are expected to report pollution
                    abatement projects involving costs
                    (necessary to correct problems
                    discovered through the audit) to EPA in
                    accordance with OMB Circular A-106.
                    Upon request and in appropriate
                    circumstances, EPA will assist affected
                    federal agencies through coordination of
                    any public release of audit findings with
                    approved action plans once agreement
                    has been reached.
                    IV. Relationship to State or Local
                    Regulatory Agencies
                      State and local regulatory agencies
                    have independent jurisdiction over
                    regulated entities. EPA encourages them
                    to adopt these or similar policies, in
                    order to advance the use of effective
                    environmental auditing in a consistent
                    manner.
                      EPA recognizes that some states have
                    already undertaken environmental
                    auditing initiatives which differ
                    somewhat from this  policy. Other states
                    also may want to develop auditing
                    policies which accommodate their
                    particular needs or circumstances.
                    Nothing in this policy statement is
                    intended to preempt or preclude states
                    from developing other approaches to
                    environmental auditing. EPA encourages
                    state and local authorities to consider
                    the basic principles which guided the
                    Agency in developing this policy:
                       • Regulated entities must continue to
                    report or record compliance information
                    required  under existing statutes or
                    regulations, regardless of whether such
                    information is generated by an
                    environmental audit or contained in an
                    audit report. Required information
                    cannot be withheld merely because it is
                    generated by an audit rather than by
                    some other means.
                       • Regulatory agencies cannot make
                    promises to forgo or limit enforcement
                    action against a particular facility or
                    class of facilities in  exchange for the use
                    of environmental auditing systems.
                    However, such agencies may use their
                    discretion to adjust  enforcement actions
                    on a case-by-case basis in response to
                    honest and genuine  efforts by regulated
                    entities to assure environmental
                    compliance.
                       • When setting inspection priorities
                    regulatory agencies  should focus to the
                    extent possible on compliance
                    performance and environmental results.
                       • Regulatory agencies must continue
                    to meet minimum program requirements
(e.g.. minimum inspection requirements,
etc.).
  •  Regulatory agencies should not
attempt to prescribe the precise form
and structure of regulated entities*
environmental management or auditing
programs.
  An effective state/federal partnership
is needed to accomplish the mutual goal
of achieving and maintaining high levels
of compliance with environmental laws
and regulations. The greater the
consistency between state or local
policies and this federal response to
environmental auditing, the greater the
degree to which sound auditing
practices might be adopted and
compliance levels improve.
  Dated: June 28.1986.
Lee M. Thomas.
Administrator.

Appendix—Elements of Effective
Environmental Auditing Program*

  Introduction: Environmental auditing
is a systematic, documented, periodic
and objective review by a regulated
entity of facility operations and
practices related to meeting
, environmental requirements.
   Private sector environmental audits of
facilities have been conducted for
several years and have taken a variety
of forms, in part to accommodate unique
organizational structures and
circumstances. Nevertheless, effective
environmental audits appear to have
certain discernible elements in common
 with other kinds of audits. Standards for
 internal audits have been documented
 extensively. The elements outlined
 below draw heavily on two of these
 documents: "Compendium of Audit
 Standards" (*>1983. Walter Willborn.
 American Society for Quality Control)
 and "Standards for the Professional
 Practice of Internal Auditing" (°1981,
 The Institute of Internal Auditors. Inc.).
 They also reflect Agency analyses
 conducted over the last several years.
   Performance-oriented auditing
 elements are outlined here to help
 accomplish several objectives. A general
 description of features of effective.
 mature audit programs can help  those
 starting audit programs, especially
 federal agencies and smaller businesses.
 These elements also indicate the
 attributes of auditing EPA generally
 considers important to ensure program
 effectiveness. Regulatory agencies may
 use these elements in negotiating
 environmental auditing provisions for
 consent decrees. Finally, these elements
 can help guide states and localities
 considering auditing initiatives.

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                    Federal Register  /  Vol. 51, No.  131 / Wednesday. July 9, 1986 / Notices
                                                                        25009
  An effective environmental auditing
system will likely include the following
general elements:
  L Explicit top management support for
environmental auditing and
commitment to follow-up on audit
findings. Management support may be
demonstrated by a written policy
articulating upper management support
for the auditing program, and for
compliance with all pertinent
requirements, including corporate
policies and permit requirements as well
as federal, state and local statutes and
regulations.
  Management support for the auditing
program also should be demonstrated
by an explicit written commitment to
follow-up on audit findings to correct
identified problems and prevent their
recurrence.
  E. An environmental auditing function
independent of audited activities. The
status or organizational locus of
environmental auditors should be
sufficient to ensure objective and
unobstructed inquiry, observation and
testing. Auditor objectivity should not
be impaired by personal relationships,
financial or other conflicts of interest,
interference with free inquiry or
judgment, or fear of potential
retribution.
  HL Adequate team staffing and
auditor training. Environmental auditors
should possess or have ready access to
the knowledge, skills, and disciplines
needed to accomplish audit objectives.
Each individual auditor should comply
with the company's professional
standards of conduct Auditors, whether
full-time or part-time, should maintain
their technical and analytical
competence through continuing
education and training.
  IV. Explicit audit program objectives,
scope, resources and frequency. At a
minimum, audit objectives should
include assessing compliance with
applicable environmental laws and
evaluating the adequacy  of internal
compliance policies, procedures and
personnel training programs to ensure
continued compliance.
  Audits should be based on a process
which provides auditors: all corporate
policies, permits, and federal, state, and
local regulations pertinent to the facility;
and checklists or protocols addressing
specific features that should be
evaluated by auditors.
  Explicit written audit procedures
generally should be used for planning
audits, establishing audit scope,
examining and evaluating audit findings,
communicating audit results, and
following-up.
  V. A process which collects, analyzes.
interprets and documents information
sufficient to achieve audit objectives.
Information should be collected before
and during an onsite visit regarding
environmental compliance) 7).
environmental management
effectiveness!,?), and other matters {3}
related to audit objectives and scope.
This information should be sufficient.
reliable, relevant and useful to provide a
sound basis for audit findings and
recommendations.
  a. Sufficient information is factual.
adequate and convincing so that a
prudent, informed person would be
likely to reach the same conclusions as
the auditor.
  b. Reliable information is the best
attainable through use of appropriate
audit techniques.
  c. Relevant information supports audit
findings and recommendations and is
consistent with the objectives for the
audit.
  d.  Useful information helps the
organization meet its goals.
  The audit process should include a
periodic review of the reliability and
integrity of this information and the
means used to identify, measure,
classify and report it. Audit procedures,
including the testing and sampling
techniques employed, should be selected
in advance, to the extent practical, and
expanded or altered if circumstances
warrant. The process of collecting,
analyzing, interpreting, and
documenting information should provide
reasonable assurance that audit
objectivity is maintained and audit goals
are met
  VI. A process which includes specific
procedures to promptly prepare candid,
clear and appropriate written reports on
audit findings, corrective actions, and
schedules for implementation.
Procedures should be in place to ensure
that such information is communicated
to managers, including facility and
corporate management, who can
evaluate the information and ensure
correction of identified problems.
Procedures also should be in place for
determining what internal findings are
reportable to state or federal agencies.
  VII. A process which includes quality
assurance procedures to assure the
accuracy and thoroughness of
environmental audits. Quality assurance
may be accomplished through
supervision, independent internal
reviews, external reviews, or a
combination of these approaches.

Footnote* to Appendix
  (7) A comprehensive assessment of
compliance with federal environmental
regulations requires an analysis of facility
performance against numerous
environmental statutes and implementing
regulations. These statutes include:
Resource Conservation and Recovery Act
Federal Water Pollution Control Act
Clean Air Act
Hazardous Materials Transportation Act
Toxic Substances Control Act
Comprehensive Environmental Response.
  Compensation and Liability Act
Safe Drinking Water Act
Federal Insecticide. Fungicide and
  Rodenticide Act
Marine Protection. Research and Sanctuaries
  Act
Uranium Mill Tailings Radiation Control Act
  In addition, state and local government are
likely to have their own environmental laws.
Many states have been delegated authority to
administer federal programs. Many local
governments' building, fire, safety and health
codes also have environmental requirements
relevant to an audit evaluation.
  (2) An environmental audit could go well
beyond the type of compliance assessment
normally conducted during regulatory
inspections, for example, by evaluating
policies and practices, regardless of whether
they are part of the environmental system or
the operating and maintenance procedures.
Specifically, audits can evaluate the extent to
which systems or procedures:
  1. Develop organizational environmental
policies which: a. implement regulatory
requirements: b. provide management
guidance for environmental hazards not
specifically addressed in regulations:
  2. Train and motivate facility personnel to
work in an environmentally-acceptable
manner and to understand and comply with
government regulations and the entitv 's
environmental policy;
  3. Communicate relevant environmental
developments expeditious)}' to facility and
other personnel;
  4. Communicate effectively with
government and the public regarding serious
environmental incidents;
  5. Require third parties working for. with or
on behalf of the organization to follow its
environmental procedures;

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25010	Federal Register  /  Vol.  51.  No. 131  / Wednesday. July 9. 1986 / Notices
  6. Make proficient personnel available at
all times lo carry out environmental
(especially emergency) procedures:
  7. incorporate environmental protection
into written operating procedures:
  8. Apply best management practices and
operating procedures, including "good
housekeeping" techniques:
  9. Institute preventive and corrective
mair'pnance systems to minimize actual and
poii, ..ui environmental harm:
  10. Utilize best available process and
control technologies:
  11. Use most-effective sampling and
monitoring techniques, test methods,
rrcordkeeping systems or reporting protocols
(beyond minimum legal requirements);
  12. Evaluate causes behind any serious
environmental incidents and establish
procedures to avoid recurrence:
  13. Exploit source reduction, recycle and
reuse potential wherever practical: and
  14. Substitute materials or processes to
allow use  of the least-hazardous substances
feasible.
  (J) Auditors could also assess
environmental risks and uncertainties.
|FR Doc. 86-15423 Filed 7-8-86 8:45 am| *
MLLWOCOOE (SSO-SO-M

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          APPENDIX J






DESCRIPTIONS OF STATE PROGRAMS

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APPENDIX J.I
CALIFORNIA

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J.I        California

    I.       Legislative Background

    California has  been relatively  active in efforts to  promote  hazardous waste
minimization.   State   programs  include  land   disposal  restrictions,   regulatory
requirements  for  recycling  some  waste  materials,  different  requirements  for
hazardous waste  facilities,  depending on the  type of  waste processed,  and fee and
tax assessments on generators and some disposal facilities. Financial assistance for
the purchase  of  pollution  control  equipment  and for research, development, and
demonstrations of  minimization technologies is  also available in the  forms of loans
and grants.  California is  sponsoring  a study  for the  establishment  of  a  waste
reduction program  and already operates a waste exchange.  Numerous publications
are also available through the California Department of Health Services.

    In California,  the  volume of proposed legislation relating  to  hazardous waste
has increased  dramatically  in recent years.  For  the   1985  legislative session,
approximately  300 bills were introduced  that  dealt  in  some  way  with  toxic or
hazardous contamination.

    Significant  pieces  of  hazardous waste legislation include the Hazardous Waste
Control Act of  1977  and   the Hazardous  Substances Account  Act  of  1981.  The
former  prescribed  the  regulation of hazardous  waste by the State  Department of
Health  Services,  set  hazardous  waste  transport and   land  disposal  rules,  and
mandated that  all recyclable materials be recycled where  economically  feasible.
The Hazardous Substances Account Act established a State  fund for site  cleanups
and specified  a formula for taxes per ton of  waste generated.  Both  acts have been
significantly amended  since they were passed.  For example, sections of the State
Health and  Safety  Code established by the California Hazardous Waste Control Act
of 1977 have been  altered by recent legislation  that  ties  fees on  hazardous waste
generators to a  variable base rate.  Previously,  the numerical amounts of these  fees
had been specified.

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    Phase-out  of the land disposal of specified hazardous waste was not legislated,
but rather was  enacted  by the  Executive Order of former Governor Jerry Brown on
the  basis  of  a  1981   Department   of  Health  Services  study  of  land disposal
alternatives.

    II.      Regulatory Programs

            A.  Land Disposal Restrictions

    Title 22, Article  15,  of Chapter 30, Division  4,  of  the  State of  California's
hazardous  and  solid  waste regulations specifies that the  land disposal of  certain
specified wastes is to be banned.  The article sets  forth the following schedule:

    June 1, 1983           Banning of wastes containing free cyanides.
    January 1, 1984       Banning  of  toxic  metal   wastes   and  polychlorinated
                          biphenyls (PCBs).
    January 1, 1985       Banning of liquid  wastes containing  halogenated  organic
                          compounds.
    July 1, 1985           Banning of organic sludges,  solids containing  halogenated
                          organic compounds,  and lab packs containing any of the
                          restricted wastes.

    The above schedule  is contingent upon  a determination by the Department of
Health  Services (DHS) that sufficient  recycling  and treatment  capacity  for the
wastes  listed above will be permitted and fully  operational by the day the  landfill
restrictions take effect. In making its determination, the Department must consider:
     •   The technical feasibility of recycling or treatment  to  process  substantially
        all wastes subject to the land disposal restriction;
     •   The  proximity  of   adequate  recycling  and  treatment  facilities  to the
        generators of the hazardous wastes; and
     •   The technical feasibility of  reducing, recycling, or treating the hazardous
        wastes at  the point  of generation.
                                      Jl-2

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    Revisions in the schedule  to  postpone the effective dates of the restrictions
must  be  followed  by written  notification to registered treatment,  storage,  and
disposal facilities within  15  days.  At the time of this writing (December 1985), the
effective  date of the land disposal restrictions on organic sludges, solids  containing
halogenated  organic  compounds, and  lab  packs  containing  any of the  restricted
hazardous wastes, has been changed from July 1, 1985, to  July 8,  1987.

    Exemptions from the land  disposal restrictions include (1) drilling fluids spent
during  exploration,  development,  and/or  production of  oil  and  gas,  (2) mining
overburden, and  (3) contaminated  soils from the  cleanup of toxic disposal sites,
unless it is determined that  such soils can be recycled or treated. Variances for land
disposal of the restricted wastes may be granted by the DHS after consideration of
the following:

    •  The acute or chronic toxicity to humans,  domestic livestock, and wildlife if
        the restricted waste  is ingested, inhaled, or absorbed through the skin;
    •  The immobility of the restricted waste in the  land disposal environment;
    •  The persistence of this restricted waste in the  land disposal environment;
    •  The  ability  of constituents  of the  restricted waste to bioaccumulate in
        plants or animals; and
    •  The ability of the restricted waste to be isolated by land disposal.

    In addition, in reviewing  variance  petitions,  the DHS must consider the  good
faith  efforts  of  the petitioner plus any economic  hardship caused by the use of
existing recycling or treatment facilities.

            B.  Formation of the Department of Waste Management

    The formation of a  new  Department  of Waste   Management,  as proposed  by
current   Governor   George   Deukmejian,   is   an   endeavor   to   steamline   the
administrative functions,  reduce the costs, and increase the efficiency of the State's
waste management  program.  Justification for  the reorganization  is  based on the
observation of current administrative inefficiencies, some of  which are:
                                      Jl-3

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        The  existence  of  12 State  agencies  having  duplicative  and overlapping
        functions;
        The distribution of EPA  funds to three State agencies, each  of which pays
        administrative overhead;
        The duplication of inspections, permits, and cleanup orders; and
        An  inadequate  recognition of public health and  environmental issues and
        slow  progress  in  developing and  implementing  new  hazardous   waste
        technologies.
     At the  time of this writing  (January  1986), the latest reorganization  plan  had
been  rejected by  the  State senate as incomplete; several political  aspects are still
being debated, most notably, the composition and authority of the administrative
board of the toxics program.

            C.  Regulatory Promotion of  Recycling

     In  California,  generators  of  wastes deemed recyclable  must recycle  those
wastes or must, by request of the Department of  Health Services,  provide  written
justification  for not recycling them. Title 22, Article 12, of the State's hazardous
and  solid waste  regulations  contains  a list  of  wastes  that  the  State  considers
recyclable.  The  list comprises  mainly  organic  wastes,  alkalis, and unrinsed empty
containers used for hazardous chemicals.

     In addition, the Department of  Health Services has  modified its  regulatory
requirements  relating  to  hazardous  waste  facilities  in  an  effort  to  promote
recycling. These modifications, which went into effect in late August 1985, include:

     •   Changing  the  title   of  facilities  that  recycle  hazardous   waste  from
        "hazardous waste facility" to "resource recovery facility," provided certain
        specifications are met;
    •   Simplifying  permit requirements  for  facilities  that  recycle  non-RCRA
        hazardous  wastes;
    •   Reducing  permit  requirements  for facilities  that  handle large-volume,
        low-hazard materials or that  use recyclable  materials as substitutes for raw
        materials or commercial  products;  and
                                      Jl-4

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    •  Establishing  certain requirements  for the  management of recyclable spent
       lead-acid storage batteries and waste elemental mercury.

    Three  series of resource recovery  facilities are now defined:   Series "A" for
Federal RCRA hazardous wastes, Series "B" for California, non-RCRA wastes, and
Series "C" for directly recyclable or large-volume, low-hazard wastes.  A Series "A"
permit is very similar to the  Federal RCRA  permit, and most  resource  recovery
facilities of  that type already  have Federal RCRA  permits.  Series "B" and  "C"
permit regulations lessen some  of the permit application and processing stipulations
consistent with the degree of hazard posed by the waste handled. This is intended to
cut permit  processing time and lessen the paperwork load for facility  operators.

    The  designation  "resource  recovery  facility"  is intended to  reduce the stigma
imposed  by the title "hazardous waste facility" by differentiating  those  facilities
that recycle wastes  from those that ultimately  dispose  of  hazardous waste.  The
objective is to make  the siting of recycling facilities less of a  problem.

            D.  Local Government Regulatory Requirements

    In California, regulation of hazardous waste is also found  at the  county level.
In at least  two counties,  Santa  Cruz and Sacramento, generators may be required to
employ special consultants or inspectors to conduct environmental audits if deemed
necessary by  the county.  In Santa Cruz County, the consultants must demonstrate
expertise to the satisfaction of the  county.  Their report  must include an evaluation
of the  facility  and recommendations to the  generator on how to comply with county
regulations.  Within  30 days of issuing the report,  the generator must  file  with the
county a plan for implementation of the recommendations or an explanation of  why
the recommendations will not be implemented.

    III.      Fee and Tax Incentives

    Under  the Hazardous Waste Control Act, California imposes fees on hazardous
waste disposal  according  to the type of waste  being handled.  Prior  to July 1, 1985,
                                      Jl-5

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specified charges were  levied on each ton of hazardous waste. These charges varied
according to whether  the  waste was  hazardous, extremely  hazardous, restricted,
etc., under the State's  classification.  Legislation passed during the 1985 session has
replaced these specified charges  with  a fee schedule  anchored  to  a base  rate
formula.  Using  the formula,  the fees  will depend upon  the  amount of waste
produced in  the State.  The formula is designed such that fees  per  ton generated  will
increase as  total tons  generated  fall.  Revenues from the fees are collected in an
amount sufficient to cover the costs of administering  the fee  program plus  a  5
percent operating margin.

    Recent  legislation  has also shifted the burden  of payment of these fees from
disposal facilities to hazardous waste generators.  Disposal  facilities are responsible
for paying  fees  only   on  their   disposal  of waste received  from  out-of-State
generators.

    In addition to the  hazardous waste control fees,  generators are required to  pay
taxes under the Hazardous Substances Account Act.   The revenues  from these taxes
revert to  the Hazardous Substances Account, which  is a site cleanup  fund. These
"Superfund" taxes are  based  upon  a formula much  like  the  one for the generator
fees.  The base rate  for the tax is inversely related to the estimated number of tons
produced in  the State.

    IV.     Loan and Bond Assistance

            A.  Pollution Control Financing

    Assistance with pollution control  financing is available  through the California
Pollution  Control  Financing  Authority.  The  assistance  is  provided  in  the  form of
tax-exempt bond  financing for the purchase of pollution equipment.  The program
features:

    •   No limit on the amount of  tax-exempt bond financing available; and
    •   Exemption  from the  State  interest  rate  ceiling  on industrial  development
        bonds.
                                      Jl-6

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    According to  the  Authority, annual interest rates on these bonds are 2 percent
to 5 percent lower than rates on funds from conventional sources, so that the cost of
borrowing capital to pay  for pollution  equipment  is lower.  The payback  period is
also longer.  Interest earned by the bond purchaser  is exempt from taxation. A  key
point   of  project  eligibility  for  a  bond  issue  is  the  Internal Revenue  Service
requirement  that pollution  abatement  facilities  produce  no  material  profit  or
productivity  increase  for  the operator,  and  that  resource  recovery facilities yield
useful  forms  of material or energy as a means of waste disposal alone.

            B.  The Hazardous Waste Reduction Incentives Account

    The Hazardous Waste Reduction  Incentives  Account  is  currently  funded  at
$5,200,000 of  which  $2,600,000  is allotted  to  the California Pollution  Control
Financing Authority.  With this money,  the Authority is permitted to contract with
financial  institutions  in  support  of  the  granting  of credit  to  medium and  small
generators for the purchase  of  waste-reducing  equipment.  The  impetus  for  the
legislation establishing the account  originated with the  observation that medium  and
small generators have had difficulty obtaining  such  financing because o.f their poor
credit  and/or the  high costs  associated  with  obtaining  loans.  The Authority  can
lower these costs by using the account to support interest rates  and/or directly  pay
loan  costs.  It may also use the account to cover its own costs from the issuance of
revenue bonds.

    V.      Grant Programs

    The State of California provides  funds for research and development by private
consultants   and   hazardous  waste   generators.  A   current  example  of  work   by
consultants is a study  of the  economic  incentives to reduce  hazardous  waste (ICF
1985).   Recent legislation has set aside funds to support research and development
by  the  public,   private, and   academic  sectors,  and  to   enable  technology
demonstrations by cities, counties, and private firms.
                                      Jl-7

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    With the Hazardous Waste Reduction,  Recycling, and Treatment Research and
Demonstration  Act of  1985  (Assembly Bill 685), a  grant program  was established
within the Department of Health  Services  to  disburse funds  for the  research,
development, and  commercial demonstration  of reduction, recycling, and treatment
technologies.  The  Act established  two separate fund accounts, one for  providing
research  and  development  support to  universities,  governmental  agencies,  and
private  organizations,  and the other  to  facilitate  technology demonstrations by
cities, counties, and private  firms.  For the demonstration project grants, one of the
following criteria must  be met:

    •  The project must  have onsite  as well as offsite potential  for  reduction,
        recycling, or treatment of hazardous wastes;
    •  The  project  must  have  the  potential  to  benefit, or be  used by, small
        businesses; or
    •  The project must be potentially applicable to  a range of industries.

Examples of reports put out or sponsored by State offices follow in Section VIII.

    VI.      Information Programs

            A.  The Waste Reduction Program

    The Alternative Technology and Policy Department  Section of  the DHS's Toxic
Substance  Control Division  has outlined a  program  for the  promotion  of waste
reduction.   The program,  a responsibility of the Waste Reduction Unit,  features
several  approaches to  the  problem  including  technical  assistance,  information
transfer, regulatory measures, and economic incentives.  Technical assistance would
include  joint studies with  industry associations of waste  reduction  possibilities for
large generators,  studies of specific waste streams, and waste reduction audits for
small businesses.  The  plans for information  transfer include  the  development of
regulatory fact sheets, of  appropriate technology, and of financial incentives as well
as the use of seminars,  biennial alternative  technology reports,  the California Waste
Exchange  newsletter,  and a technical reference  center.  The regulatory  program
includes the California  land disposal ban (which can be suspended for certain  wastes
if capacities for  alternative  means  of  disposal do not exist), in  addition  to the
                                      Jl-8

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economic incentives, both  in place and  planned,  are  grants  and appropriations as
positive incentives for waste  reduction activity, and generator  fees  and Superfund
taxes as disincentives to  waste generation.

            B.  The California  Waste Exchange

    The  California Waste Exchange is operated by the Resource Recovery Unit of
the Department of Health Services' Alternative Technology and Policy Development
Section.  The  program has been operating for approximately five years and currently
has three staff members.

    To facilitate the exchange  of wastes among generators, a newsletter is  issued
quarterly  containing listings on available or desired  wastes.  The  listings are  coded
and include information on waste type, concentrations,  quantity, and the geographic
location of available or desired  wastes.  In  addition,  there are reports on changes in
State and Federal hazardous waste laws, regulations, and procedures.

    The  program also  puts  out  a Directory of Industry Recylcers, which gives the
names and  locations  of recycling  companies  and  the  types   of  materials they
recycle.  The  listings are  compiled  from information  obtained  by questionnaires,
field  reports,  and telephone  contacts.  Only those  facilities  with a  California
hazardous waste facility  permit or  with interim status  documentation  are  listed.
The Directory is updated as appropriate.

    VII.     Award Programs

    California currently  has award programs to encourage  minimization.

    VIII.     Publications and References
    Alternative Technology  and Policy  Development Section.   1985.  Directory of
    industrial recyclers. Sacramento, Calif.:  Department of Health Services.
    Alternative   Technology    and   Policy    Development    Section.     1985.
    Newsletter/Catalog.  Sacramento, Calif.:  Department of Health Services.
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California Air Resources Board. 1983. Air pollution impact of hazardous waste
incineration: a California perspective.

	.  1980.  Disposal of polychlorinated biphenyls in California.
	.  1982. Suggested control measures to reduce organic compound emissions
associated with volatile organic waste disposal.

	.  1982. Technologies for the treatment and destruction of organic waste
as alternatives to land disposal.

California   State  Water  Resources Control  Board.   1983.   Polychlorinated
biphenyls (PCBs).

ICF.  1985.  Economic incentives  for the reduction of hazardous wastes.  Final
report prepared for  Alternative Technology  and Policy  Development Section.
Sacramento, Calif.: Department of Health Services.

Radimsky,  J., and Marx, R.E.  1983. Recycling and/or treatment  capacity for
liquid  hazardous  wastes  containing  polychlorinated  biphenyls.   Alternative
Technology  and Policy Development Section staff report.  Sacramento, Calif.:
Department of Health Services.

Radimsky,  J., Piacentini, R., and Diebler, P.  1983.  Recycling and/or treatment
capacity  for  hazardous   waste   containing   cyanides.   Hazardous   Waste
Management Branch  staff report. Sacramento,  Calif.:   Department  of  Health
Services.

Radimsky,  J., et al.  1983.  Recycling and/or  treatment capacity for hazardous
wastes  containing  dissolved  metals and strong acids.  Alternative Technology
and Policy  Development Section staff report.  Sacramento, Calif.:   Department
of Health Services.

Radimsky,  J., et al.  1984.  Recycling and/or treatment capacity for hazardous
wastes containing  halogenated organic compounds. Alternative Technology and
Policy Development  Section draft report.  Sacramento, Calif.:  Department of
Health Services.

Radimsky,  J., et  al.  1984.  Recycling and/or  treatment capacity for hazardous
wastes containing polychlorinated biphenyls.  Alternative Technology and Policy
Development Section draft report. Sacramento,  Calif.:   Department  of  Health
Services.

Stoddard,  S.K.  et  al.  1981.  Alternatives to  the  land disposal  of hazardous
wastes;  an assessment  for  California.  Toxic  Waste  Assessment   Group.
Sacramento: Governor's Office  of Appropriate Technology, State of California.
                                 Jl-10

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APPENDIX J.2






  GEORGIA

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J.2        Georgia

    Georgia's major effort to promote waste minimization is the Hazardous Waste
Onsite  Consultation  Program,   a  nonregulatory  technical  assistance  program.
Proceeds from revenue  bonds may also serve as incentives for recycling and source
reduction.

    I.       Legislative  Background

    The Georgia Hazardous  Waste Management  Act, adopted in 1979, established
the administration  and  enforcement  procedures  applying to the  State's hazardous
waste regulatory effort.  It authorized the Environmental Protection  Division (EPD)
of the Georgia  Department  of  Natural  Resources as the lead agency  in hazardous
waste regulation and set  penalty fees  for  noncompliance at a maximum $25,000 per
day.

    In  1981, the Georgia  Hazardous Waste  Management Authority  Act created a
State Authority  with the power  to  plan,  construct,  and operate/manage hazardous
waste  facilities.  The Authority  was  also empowered to charge fees for the use of
facilities under its operation.

    II.      Regulatory  Programs

    Hazardous waste rules in Georgia are  the same as the Federal rules.  The State
rules   appear under  Title  391,  Natural  Resources,  Article  3,  Environmental
Protection,   Chapter   11,   Hazardous  Waste  Management,  where  the   Federal
regulations are directly cited.

    III.     Fee and Tax Incentives

    Georgia  currently uses no fee or tax incentive to encourage waste minimization.

    IV.     Loan and Bond Assistance

    Proceeds from Georgia's general  obligation revenue bonds may be used to pay
for  project costs related to hazardous waste recycling and source reduction.
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    V.      Grant Programs

    Grants  are  available  to  cities  and counties  for  solid  waste management
endeavors, which  may include  resource  recovery  from  hazardous waste  (personal
communication  with  John Taylor, Georgia  DNR, February  13,  1986).  Thus  far.
Georgia  has  not awarded grant  monies  to  hazardous waste  generators  or other
organizations  for research, development, or demonstrations of waste minimization
technologies.

    VI.     Information Programs

            A.  Hazardous Waste Education/Information Program

    In June  1984,  the EPD began a hazardous waste education program  to increase
the public's awareness of  existing  sources and  management options for hazardous
waste.  The program promotes the concept  of management  of  hazardous  waste
alternatives to  land  disposal, e.g.,  hazardous waste reduction, treatment,  and
recycling.

    The  program has three major components:  (1) public meetings  and  workshops,
(2) media  information  coverage,  and  (3) school  support.  The  most  intensive
component is comprised of  public meetings, speeches, and workshops.  Workshops for
citizens  and  breakfast  meetings for opinion leaders have been  held  in  18  cities
throughout  Georgia.   Concurrent  with  the   workshops,  the   EPD   has   made
presentations  to  civic  and  professional groups, and  numerous  radio  and  TV
appearances.   A major goal of the program  is  to  inform the  public on  hazardous
waste  issues  and  solutions and to encourage them to take an active  role  in  the
decision-making process.

           B.   The Hazardous Waste Onsite Consultation Program

    The  Hazardous Waste  Onsite  Consultation Program (OSCP) is a pilot program
conducted by  the  Georgia Tech Research  Institute's Environmental  Health  and
Safety Division.  It  is jointly  funded  by  the  Georgia  Environmental  Protection
Division  (EPD) and the U.S. EPA, and was  established in  mid-1983 to determine
                                     J2-2

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whether  such  a  program  could  significantly  aid  the  expanding  community  of
regulated  waste  generators  in  voluntarily  complying  with   hazardous  waste
regulations.  Georgia's  small- and medium-size businesses are expected  to  derive
the greatest benefit  from the  program.

    The  actual onsite  evaluation  involves  several  steps.  05CP  is supplied  with
preliminary information, and  a visit to the facility is scheduled. The OSCP auditor
and a  company representative  then  go over  regulations and  company  processes
before touring  the facility site.  The auditor and representative  discuss the auditor's
observations,  and  the  auditor  preliminarily  assesses  the  facility's  regulatory
compliance status.  After the first visit, the auditor submits a confidential  report
containing  his identification  and  characterization  of the  waste  streams, results  of
any laboratory  analysis, his final assessment of the facility's regulatory compliance,
and his recommendations to  correct or improve any problems.   A  follow-up visit  is
scheduled for sometime during the next year.

    Assistance  is also  provided to  firms  in  meeting  reporting  and  pretransport
requirements and  in  preparing  manifests.   Additionally, program  personnel  can
review  treatment,  storage,  and disposal  alternatives  and can  provide guidance
concerning  the financial  requirements  of  complying  with  the  regulations.   No
engineering or  analytical services are supported,  and  assistance  is expected to be
short-term. The program is publicized in the media and through  the regional offices
of  Georgia Tech.   As  part  of  its  educational  function,  the  program conducts
seminars, workshops, and short courses.

    VII.     Award Programs

    Both  the  Business  Council of  Georgia  and  the   Georgia  Department  of
Community Affairs  sponsor  award programs that  may encourage hazardous  waste
recycling and source reduction.   Each year, the Georgia  Environmental Protection
Division  nominates  companies that  have shown  outstanding improvement in  the
areas  of  air quality, water  quality,  and/or  hazardous  waste  management  to  the
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Business  Council.  The  annual  award  given  by  the   Georgia   Department   of

Community   Affairs   is   for  achievement   in   resource   recovery  (personal

communication with John Taylor, Georgia EPD, February 13,  1986).


    VIII.     Publications and References
    Georgia  Institute  of  Technology  Research  Institute.   n.d.    Fact  sheet:
    Hazardous  Waste Onsite Consultation  Program.  Atlanta:  Georgia Institute  of
    Technology.

    Nemeth,  J.C.,  and  Kamperman,  K.L.   1985.   Small   quantity  generator
    compliance  manual.  Hazardous  and Industrial Waste  Management  Program.
    Atlanta: Georgia Institute of Technology.
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APPENDIX J.3






  ILLINOIS

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J.3        Illinois

    Illinois  has attempted to  minimize  hazardous waste  generation  through  the
regulatory strategies,  fee incentives,  loan  and  bond  assistance, research   and
information programs,  as well as  a waste  exchange.  The  Illinois Environmental
Protection Agency,  the  Development  Finance  Authority,  the  Hazardous  Waste
Research  and  Information Center,  and the Industrial Materials Exchange Service are
just some  of the organizations involved with waste minimization in Illinois.

    I.       Legislative Background

    Waste control  in Illinois began  in 1970 with  the Environmental Protection  Act,
which  created the  Illinois Environmental Protection  Agency (IEPA)  and statutes
addressing the pollution problem. In the mid-1970s,  the  Act  was amended to include
provisions on  hazardous waste  as the IEPA turned  towards the regulation  of waste
from industrial sources.  Restrictions on  the  location  of hazardous waste disposal
sites were added in  1979, as were provisions  for  long-term  care  of sites, for the
financial responsibility  of  owners, and  for the  establishment  of  a hazardous waste
fund financed  through fees on hazardous waste disposal.

    In  1981,  the Environmental Protection  Act was  again amended,  this time  to
authorize  a State regulatory program paralleling the Federal program.  Also in  1981,
the General  Assembly  passed  a bill banning land  disposal of all liquid hazardous
wastes beginning January  1, 1987.  In 1983, this schedule was accelerated to prohibit
landfill disposal  of  all  liquid  hazardous  wastes  after  July 1,  1984,  unless  no
technically and economically feasible alternative existed.

    Further revisions to   the Environmental  Protection  Act in  1983  included  an
increase in disposal and treatment  fees and the requirement for an annual hazardous
waste report by regulated facilities.  The  Act was amended  again in  1984 to  list
certain dioxins as hazardous waste, to establish fees on  waste handling, and  to direct
the Department of  Energy and Natural Resources  to study the  underground  injection
of hazardous waste.
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     The State of Illinois has also launched the Chemical Safety Research  Initiative,
which  calls  for  toxicity testing of common chemicals and  for  State  government
assistance to  industries,  communities,  and local  governments  in  coping  with
hazardous waste problems.

     An Illinois State Law, effective January 1,  1987, will require that recycling be
considered as a waste management practice prior to land disposal (Ferguson 1985).

     II.      Regulatory Programs

            A.  Land Disposal Ban

     The Illinois Administrative  Code (Title  35-Environmental  Protection,  Subtitle
G-Waste  Disposal, Subchapter C:  Hazardous Waste  Operating Requirements, Part
729) stipulates that landfilling  of  certain wastes  is  prohibited.  At this  time, the
code prohibits the landfilling of  all liquid hazardous wastes, of  halogenated organic
solvents in nonaqueous  liquid phase, and of  solids  containing halogenated organics
which,  when combined  with water, would  form a liquid  having  concentrations in
excess of the specified  minimum.  To  determine whether a waste is a  liquid, the
State  of  Illinois  uses  not  only the Federal  paint  filter test,  but also  its own
penetrometer test.

     The land disposal ban on halogenated  organics and liquid hazardous wastes  went
into effect in July 1, 1984.  Sludges and still  bottoms  resulting from the recycling of
halogenated organic  solvents are  excluded from the ban.

            B.   Special Generic  Permits

     Illinois   has  three   classes   of    permits:   (1) individual    waste    stream,
(2) development  and/or construction,  and   (3) operating.   Operators  are  usually
required to  obtain permits for  each waste  stream in  addition to  their  operating
permit. The  Illinois EPA has developed a generic permit for operators, which allows
operators to receive more than one waste  stream under a single permit.  The  generic
permit was created to expedite the facility permitting process.
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    III.     Fee and Tax Incentives

    The  State of Illinois  levies  waste-end  fees  on hazardous  waste  which vary
according to the method of waste  management employed. The  fee  structure is  as
follows (Illinois Environmental Protection Act Sec.  22.2):

    Waste going to treatment         $0.01/gal or $2.02/cu. yd. ($10,000/yr. max.)
    Land disposal                    $0.03/gal. or $6.06/cu. yd. ($10,000/yr. max.)
    Underground injection            $2,000/yr. for  less than 10 million gals./yr.
                                     $5,000/yr.  for between  10  and  50 million
                                     gals./yr.
                                     $9,000/yr. for  more than 50 million gals./yr.

    IV.     Loan and Bond Assistance

    The  Illinois Development Finance Authority (IDFA) conducts  an environmental
control financing program  for small businesses as defined by the  Small  Business
Administration.  According  to  that definition, a business  is small if, together with
all affiliates, it has:

    a.   A  maximum  net  worth  of $6,000,000  and an average  net  income  of
         $2,000,000  in the preceding two years, or
    b.   A maximum of 250 employees, though  this number is the general maximum
         with many specific industries (by SIC code) having larger limits.

    The  IDFA  provides financing through issuance  of environmental  control revenue
bonds.  The  interest  on these  bonds  is  exempt  from  Federal  income taxation.
Proceeds from bond  sales are loaned to successful applicants for construction  and/or
acquisition of environmental control facilities.
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     The State of Illinois does not guarantee repayment of bond obligations, but acts
solely to secure  the  tax exemption on  the  interest.   Repayment terms, interest
rates, and other  particulars  of the financing  are  negotiated among the IDFAs,  the
small business applicant, and the bond purchaser.

     V.      Grant Programs

     Illinois awards research  grants  through  the  Hazardous  Waste  Research  and
Information Center (see discussion under VI.A).

     VI.     Information Programs

            A.   The Hazardous Waste Research and Information Center

     The Illinois Hazardous Waste  Research and Information Center was created by
the Chemical  Safety Research Initiative  of 1983, which  arose  out of public concern
over  hazardous  waste disposal.  The center  has  three  programs:   (1) research,
(2) technical information  and information/data management, and (3)  industrial  and
technical assistance.  Initial funds and  activities  have thus  far  focused  on  the
research program,  which is  staffed by a program coordinator, a research scientist,
and a collaborating scientist in each of  three surveys (Natural History,  Geological,
Water,  and State Museum)  within  the  Illinois Department  of Energy and Natural
Resources.  This group is investigating several alternative technologies to hazardous
waste disposal.

    The Center  began operation  in  June 1984 but  was not fully  staffed until  the
summer of 1985.  The  Center has  a director and is  supported by an  administrative
staff  consisting of an  executive secretary and a financial affairs officer.  Additional
administrative support is received from Water Survey Office personnel.

    For  fiscal year  1985, the  Center received $800,000 outright from  the Illinois
legislature,  another   $200,000  from  utility  tax  revenues,  and   $300,000  from
hazardous and solid  waste disposal  fees, for  a total funding of  $1.3  million.  The
level of funding has remained approximately the same for fiscal year 1986.
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    In  fiscal  year  1985, research  grants administered  by  the  Center  totalled
approximately $500,000.  Research  is promoted in four areas:  (1) characterization
and  assessment   of  hazardous  waste;  (2) environmental   processes;  (3) source
reduction; and (A) treatment and remediation.  Most of  the initial research work has
been  on  characterizing  waste streams  and   assessing  the  quantity  of  waste
generated.  Research projects  for fiscal year 1986 contain further work in this  area
and also include  several studies of  environmental processes  and  a study  on waste
cleanup.  The  results  of  these studies will  have  some  bearing  on  future grant
programs.

    A hazardous materials laboratory is  planned  for  the  near  future. It is expected
to be a state-of-the-art  facility for research  and pilot studies of hazardous wastes.
The lab is projected to cost approximately $8,000,000 to 10,000,000, and $200,000
has already  been  committed to the effort.

    The research budget  for fiscal  year  1987 is anticipated  to  contain $100,000 for
matching grants  to  aid  firms in  studying  the   feasibility  of  waste  reduction
measures.   To  fund its future research projects, the  Center  hopes eventually  to
obtain funding from sources outside the State government.

            B.    The Industrial Materials Exchange Service

    The Industrial Materials  Exchange  Service (IMES)  completed  four  years  of
operation  as  a  passive  waste exchange  in  April  1985.   This  waste exchange,
sponsored by the  Illinois EPA and the Illinois State Chamber  of Commerce, is being
cooperatively distributed  through  eight State and private sector agencies, including
the Illinois EPA (IMES  1985).   Funding is by State  government appropriations and is
currently at a level of approximately $300,000 per year.

    In  addition  to its passive waste exchange  operation, IMES  conducted a  pilot
study to actively identify  possible  waste  exchanges.  Thirty leads of potentially
recyclable waste streams  were identified. Of  those leads,  one firm was  already
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applying  for a permit to transfer the waste stream identified to the same company
that had  been identified by the IMES staff; seven firms had waste streams that were
not  reuseable, had  insufficient  quantities or concentrations,  or  were no  longer
available. The remaining 22  firms  were interested in  following  up on the potential
exchange (IMES 1985).

     Over four  years of  operation, IMES reports  that  it has helped  industry realize
costs benefits of $2.57  million while reusing and recycling approximately 12 million
gallons of waste.  For the 1984 calendar year,  industry profited over  $1.21 million by
transferring over 900,000 gallons of waste through the IMES.  A successful exchange
rate of  20 percent was estimated for 1984, the IMES believes that  the actual rate
was higher (IMES 1985).

     VII.     Award Programs

    Illinois presently has no award program that directly promotes hazardous waste
minimization.

    VIII.    Publications and References
    Division  of  Land Pollution Control.  1984.  Annual report on hazardous waste:
    generation,  treatment,  storage and  disposal.   Springfield, 111.:   Environmental
    Protection Agency.
    Ferguson, M.   1985.   Waste  exchange  in  North  America:   a  coordinated
    approach.   IMES  presentation  at   Haz  Pro   '85,  16  May  1985,  Baltimore
    Convention  Center, Baltimore, Md.
    HWRIC.  1985a. Hazardous Waste Research and Information Center. Industrial
    and  technical  assistance  program:  status  report   (April-September  1985).
    Savoy, 111.:  Department of Energy and Nautral  Resources.
    	.   1985b.  Meeting  the  challenge  of  hazardous  waste management in
    Illinois.  Champaign, 111.: Department of Energy and Natural Resources.
           1985c.  FY '85 progress report (May 1985).  SWS/HWRIG Report 003. 111.
    Department of Energy and Natural Resources.
    	.   1985d.  Program  plan  for  FY '86 (September  1985).  HWRIC  005.  111.
    Department of Energy and Natural Resources.
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     .   1984a.  Plan for FY '85  (July 10, 1984).  SWS/HWRIC Report 001.  111.
Department of Energy and Natural Resources.

	.   1984b.  Hazardous  materials  laboratory  feasibility  study  (September
1984).   SWS/HWRIC   Report  002.   111.  Department of  Energy  and  Natural
Resources.

IMES.   1985.  Industrial  Material  Exchange  Service  assessment report:  April
1985. Springfield, 111.: Environmental  Protection Agency.

	.   1984.  Industrial  Material  Exchange  Service  directory:   August  -
September 1984.  Springfield, 111.:  Environmental Protection Agency.
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  APPENDIX J.4






MASSACHUSETTS

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J.4        Massachusetts

    Massachusetts  has recognized  the  importance of minimizing hazardous  waste
and is taking  steps to develop a comprehensive source reduction  program  in  the
Commonwealth. After lengthy analysis of the  topic,  the  State has determined that
an effective  program must be integrated with  other  State  programs  influencing
hazardous substance management.  The  State  points to industry case  studies that
show how far reaching source reduction efforts  can  minimize the  use  and release of
hazardous  substances.  Source  reduction  program  development  in  Massachusetts
focuses  on  input  substitution and  plant-wide  process  improvements.  Program
components  may  include  coordination  of  regulatory  programs  in  air,  water,
hazardous waste, and right-to-know;  improvements  in  reporting requirements to
enable better planning  of  source  reduction efforts;  and education and outreach
programs, which include technical and economic assistance.

    I.       Legislative Background

    Massachusetts  legislation that  involves  hazardous  substance  management
consists  of  (l)the  Massachusetts  Hazardous Waste  Management Act of  1979
(Chapter  21C),  which establishes the  authority for development of a  hazardous
waste  management program; (2) the Massachusetts Hazardous Waste  Facility  Siting
Act of  1980  (Chapter 21D), which  prescribes  a process  for siting  new  hazardous
waste management facilities;  (3) the regulations pursuant to  the  Clean Air Act (310
Code  of  Massachusetts Regulations (CMR Section 6-8); (4) the  regulations pursuant
to the Clean  Water Act  (314 CMR 1-9); (5) the Right-to-Know law (Chapter 11F;
105 CMR  670,  310  CMR  33, 441 CMR 21);  and (6) the  Massachusetts Oil  and
Hazardous Materials  Release  Prevention and Response Act of 1983 (Chapter 2 IE),
which establishes a $75 million fund for State cleanup  of uncontrolled  waste disposal
sites to be paid for by a transporter fee.

    Implementation  of  these  laws is  carried out  by  two  State  agencies:  the
Department of Environmental Quality  Engineering  (DEQE) and  the  Department of
Environmental Management (DEM), as  well as  by the Hazardous Waste Facility Site
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Safety  Council  (HWFSSC).  Overseeing  DEM and DEQE is the Executive Office of
Environmental Affairs  (EOEA).  The  Secretary of Environmental Affairs  is  in  a
position analogous to  that  of  the  U.S. Secretary of the Interior.  He  has indicated
that the foundation of a hazardous waste  management  plan  should include, among
other things:

     •   Development  and   enforcement  of  strict  hazardous  waste  management
        regulations;
     •   Reduction of the quantity of hazardous waste generated;
     •   Establishment  of safe  and  well-managed treatment, storage,  and  disposal
        facilities; and
     •   Establishment  of  public participation  and education  programs  regarding
        hazardous waste issues  (Mass. DEM, p. 1-1).

     The Massachusetts Hazardous  Waste  Management  Act  of  1979 (Chapter 210),
implemented  by DEQE, is the act  by which  Massachusetts  has taken  primary
responsibility  for  administration of RCRA.  DEQE has undertaken its responsibility
for the  hazardous waste program in  two phases.  Phase I  regulations, effective as of
July 1982,  cover the  management and administration  of notification, manifests,
recordkeeping, and reporting for generators.  The Phase  II  components, promulgated
in October 1983, essentially parallel RCRA Part B requirements.

     In  the  FY  86 statutory  budget,  the  Bureau  of  Solid Waste Disposal  and its
Source  Reduction  Program were relocated from the Department of Environmental
Management  (DEM)  to the   Department  of  Environmental Quality  Engineering
(DEQE). In the  fall of 1985,  the  Secretary  of Environmental  Affairs designated
DEQE   as  the  lead agency to develop  programs, plans, and  policy for  source
reduction.   The   Bureau of  Solid  Waste  Disposal has  continued  to  carry   out
substantial  research  and  planning activities  to  develop  a  comprehensive  source
reduction program  for  Massachusetts,  and  will integrate  these  activities  with
DEQE's regulatory programs in air, water, hazardous  waste,  and right-to-know, as
well as  other agencies where appropriate.  The  Secretary of Environmental  Affairs
has  stated  that  source reduction  activities, for the purpose  of  hazardous waste
generation and facilities needs  data, as they relate  to siting responsibilities, should
remain  at DEM, operating  in consultation with  DEQE  (personal communication  with
Richard Bird, Massachusetts DEQE,  February 13, 1986).

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    The  attention of  the Department  of  Environmental Management (DEM)  is
focused on a variety  of  hazardous waste issues,  including public  participation and
the siting of T5D  facilities, household hazardous  waste, an autobody  shop recycling
program, and a coalitions program, which offers small  grants to regional groups for
a  variety  of  efforts.  The   Hazardous  Waste  Facility  Site Safety  Council  is
responsible for implementation of the Siting Act with DEM (personal communication
with Pat  Lebau, Massachusetts HWFSSC, February 13, 1986).

    II.      Regulatory Programs

    The  Massachusetts source reduction program does  not consider recycling as part
of its  program  unless the recycling  is an  integral part  of a  manufacturing  unit.
Nevertheless, the  State has put substantial effort into creating a  fair and effective
recycling regulatory program.

    As of  1983,  DEQE  developed guidelines to  encourage recycling.  Hazardous
wastes that  were  reused,  reclaimed,  or  burned as fuel  were  not  subject to  State
regulations regarding  transportation and TSD facility licensing. Before  a  company
was eligible  for regulatory relief, an  application  had to be filed with and  approved
by  DEQE.   Compliance   with  terms  and  conditions stipulating  operation   was
necessary for approval of a request.  The recycling permit was viewed by firms as
very restrictive, however,  since  only  12 permits  were  issued between 1983 and
January  1,  1986.

    DEQE   must   now   develop  regulations  consistent  with   those  that  EPA
promulgated   January 4, 1985, i.e.,  the  revised  definition of   solid waste  (see
Appendix F  for further  details on these  regulations).  The new  RCRA  regulations
now include some  wastes as hazardous and  solid wastes even if recycled.  Although
the actual  act of  recycling is  not regulated under Federal  regulations, shipping  these
wastes offsite to be recycled  requires manifesting.  Those  wastes  that are excluded
from  the definition of solid  waste under RCRA are exempt  from the manifesting
requirement  at  the Federal level.  Under  Massachusetts  laws, the  actual  act  of
recycling is  regulated.  The exemptions  from the Federal manifesting requirement
for wastes that are excluded  from the definition  of solid  waste are  also exempted
from Massachusetts' manifesting requirements.

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     The  new  DEQE  recycling  regulations,   based   on   those   promulgated
January 4, 1985 by EPA and  now in draft form in Massachusetts, are expected to
encourage recycling  upon their implementation.  There are, however,  no source
reduction regulatory  requirements now in place other than the RCRA II mandated
certification   requirements   (personal    communication   with   Karl   Eklund.
Massachusetts DEQE, February 13, 1986).

     Under the new recycling regulations, DEQE is  proposing that  there be  a  new
category  for hazardous  waste  to  be  known  as regulated  recyclable  material.
Operators who  wish  to  function under  the new  regulations  must do so  under
recycling  permits  that are less restrictive than either the recycling  permit or the
T5D permit now required.  Failure to  comply with the conditions of the new permit
will, however,  result in  a company's  being required  to  go  through the full  TSDF
permit process.

     There  will be  three  classes  of permits, each with  increasingly stringent
requirements for compliance.  The  categories of permit are  based on substance and
process.

     The   Class A  permit is  the least  restrictive  and covers substances  that EPA
categorically  exempts  from  TSD requirements.  The   application   for  a   permit
basically  will inform  the State that recycling is taking place. Requirements will be
few and conditions broad.

     Class B permits will apply to wastes  delineated  as less  hazardous in the EPA
recycling  regulations.  Categories of waste included are:
        Use constitutes disposal;
        Burning for energy recovery;
        Used oil recycled in  any way;
        Wastes that contain  precious metals; and
        Spent lead acid storage batteries.
    Class C is the third and most restrictive regulatory category.  Wastes requiring
Class C  permits  are also designated  in the EPA recycling regulations.  Though this
group is  subject to regulations that resemble  those of  a  TSD  facility  more closely

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than either A or B, recycling will still be encouraged.  The  generator  will be able to
recycle onsite,  where previously  the  only viable  choice  was to have  the  material
hauled offsite for disposal.

    The Massachusetts recycling  regulations will be presented  for public comment
in  February   1986,  and  DEQE  expects   promulgation  on  or  before  July  1, 1986.
Implementation of these regulations  will allow businesses to  tailor  management
standards  to   encourage recycling  (personal  communication  with  Karl  Eklund,
Massachusetts  DEQE, February  13, 1986).  RCRA regulations require hazardous
waste  transporters  to  be licensed just  as T5D  facilities must be  licensed  under
RCRA, and limit the landfilling of hazardous wastes.  They also prohibit landfilling
over  "actual,  planned  or   potential"  underground  drinking   water sources,  and
landfilling  is only acceptable  when a  waste cannot  be further treated, recycled,
destroyed,  or disposed  of by other means.  Massachusetts  regulations, however, do
not  yet speak  to  these  issues  (personal  communication, Massachusetts   DEQE,
February 13, 1986).

    In  addition  to licensing  regulations,  DEM  land  the  HWFSSC  implement
regulations that establish siting procedures for  hazardous  waste  facilities. The goal
of this  procedure  is to  ensure  that all concerned parties understand their function in
the process.  The HWFSSC plays the following roles:

    •   Oversees the operation of the siting process;
    •   Ensures fairness for communities and developers;
    •   Makes  the majority  of major substantive decisions  in the  siting process;
    •   Reviews notices of intent  to determine  feasibility; and
    •   Awards technical assistance grant money  to communities participating in
        the siting process.

    This system has been  used in  the State's attempts  to attract  private  sector
developers for  hazardous waste  treatment facilities.  So  far,  five  proposals  have
been received,  but  none has been accepted.   Public resistance has been  a  major
factor, as has  the fact  that the objectives of  the  developer have  in  most cases not
matched those  of the  State  (personal communication with  Pat  Lebau,  HWFSSC,
December  19, 1985).
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     Finally, regulatory  activities  considered  more  specific and  important  to  the
development of the Massachusetts source reduction program  include  the effort to
coordinate those existing regulations  that  influence the  management  of hazardous
substances at the  industry level.  The State's  objective is to integrate  the activities
of these programs so that source  reduction is  encouraged wherever possible, and to
develop new regulatory  systems, especially in  the area of reporting requirements, to
more   directly   facilitate   source   reduction  efforts   in   industry   (personal
communication with Richard Bird, Massachusetts DEQE, February 13, 1986).

     III.     Fee and Tax Incentives

     Massachusetts  has  carried  out  preliminary  reviews  of  revenue  generation
systems and has considered their  potential to  serve as direct  incentives for waste
minimization.   The  State  will   investigate   revenue  generation  systems  more
extensively  in  the  near  future  and considers  them  a necessary  component of  an
effective  source reduction program.  A stable revenue generation system would be
used primarily to fund  targeted and substantial incentive  programs to assist industry
with source  reduction efforts.

     The State  has  concluded  that  in some  situations taxes or fees will  serve only as
indirect incentives for source reduction,  since the costs of  waste management  and
liability insurance are  fluctuating so rapidly.  These fluctuations will, in most cases,
offset  the effect of such taxes  or fees, which would be  minor in  comparison.  The
State  believes  waste-end fees  or  taxes may  serve  in  certain  instances   as
disincentives to the RCRA waste  generation reporting requirements, which are still
in the  early stages of development and  reliability.  As an alternative, the State is
investigating a tax or  fee  system  on hazardous inputs and intermediates, believing
that such a  system may  serve as a more reliable means of raising revenue for source
reduction.   A tax  or fee on  inputs may  simultaneously  encourage  some firms  to
consider source  reduction input   substitution  and  process  changes to  avoid  the
increased costs of both hazardous inputs and the release of these constituents to  the
environment at large  (personal  communication with  Richard Bird, Massachusetts
DEQE, February 13, 1986).

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    One  fee  structure   under  consideration   may  have  some  effect  on  waste
management.  Under Chapter 21E (this is the State version of Superfund), DEQE is
in  the  process of implementing  a  transporter fee designed  to help recover some of
the costs  associated with State  cleanups. This  fee will  be, in effect,  a waste-end
tax.  Onsite waste  management appears to  be  increasing in part in  anticipation of
this  fee,   according  to   discussions  with   DEQE  and   DEM  personnel  (personal
communication with Richard  Bird and Lee Dane, February 13, 1986).

    IV.     Loan and Bond Assistance

    Massachusetts  legislators have filed several bills calling for loans  and bonds to
facilitate  waste minimization practices.  Although the concept  of source  reduction
has earned  strong  support  among lawmakers,  the consensus  has been that more
analysis is needed  before such  economic incentives are established.  The analysis
necessary for development  of  an effective source reduction  program is  nearing
completion, and a renewed emphasis on  legislation for loan and bond  assistance  may
be included at that time (personal communication with Lee  Dane, Massachusetts
DEM, December 20, 1985).

    The Massachusetts Industrial  Finance Authority (MIFA) has been considered a
possible source of  revenue  to enable small  generators  to  install source  reduction
equipment.  No credit assistance program for source reduction has been initiated  by
MIFA to date, but one is under  review at the present time (personal  communication
with Lee Dane, Massachusetts DEM, and Pat Lebau, HWFSSC, February  13, 1986).

    V.      Grant Programs

    In  1983,  DEM  made  the  first  grant   under their Safe  Waste  Management
Participation Program.   This program  is composed of  local  advocacy groups  who
view  hazardous  waste issues from a  variety  of  perspectives.  The  program   has
funded  studies and  projects  on subjects ranging from  underground  storage tank
management to technical assistance workshops  for specific industry  segments, and
will be expanded  further in FY  1987  (personal communication with Anita  Flanagan,
Massachusetts DEM, February 13,  1986).

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     VI.     Information Programs

            A.  Information Transfer and Technical Assistance

     Distribution  of  information  concerning  waste reduction  is initiated  in  two
general ways:  (1) the Commonwealth offers activities designed to inform  concerned
parties or  (2) inquiries  are made to the  State  by generators.  Conferences  and
seminars have been successful promotional  tools in the past,  and  the information
programs  have  stimulated enough   interest  to continue  the  conference/seminar
format.

     In October 1983, the Bureau of Solid Waste, then  part  of  DEM, held the first
Source Reduction Conference and Exhibition with the help of the Source  Reduction
Advisory  Committee.   The  one-day  gathering  in   Boxborough,   Massachusetts,
featured 40  exhibitors,  27 speakers, and  approximately 350  attendees.  Sessions
focused on  a variety of  waste  reduction  issues  including  solvent  recycling  and
substitution, waste  exchanges and recycling, policy  issues, technical assistance, and
plant management.  The second conference, held in October  1984,  grew  to nearly
twice the size of the first. According to DEM personnel, the proceedings resulting
from these  conferences  have  been two  of  the most effective technology transfer
tools to date.

     A third general conference is planned for  October 1986, in addition to others of
a smaller scope.   One  of the smaller  conferences  will  be  geared  toward  the
corporate office  and  will  stress  management  strategies for source reduction.  In
addition, industry-specific  regional  workshops are planned  and other substantial
outreach projects  are  under  development  as part of  the  comprehensive  source
reduction  programs  (personal  communication with Lee  Dane, Massachusetts  DEM,
December 20,  1985).

     Increased awareness  of source reduction/recycling  has  prompted generators to
call  the Solid and Hazardous Waste Division Compliance Section with requests for
information   and   questions   regarding   technical   assistance  and   regulatory
compliance. The  waste minimization statement  now required on the manifest  has
been  a key  stimulus  to  these  queries.  The Compliance Section personnel are  not
authorized  to refer callers to private  corporations  specializing  in consulting  or

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pollution   control   devices   (personal   communication  with   Linda  Benevides,
Massachusetts DEQE, July 23, 1985). In the development of a comprehensive source
reduction program, however,  the Bureau  of Solid  Waste is considering a substantial
technical assistance component,  which  may include some inquiry response capability
(personal   communication    with    Richard    Bird,    Massachusetts    DEQE,
February 13, 1986).

            B.   Source Reduction Program Development

    Extensive work is ongoing in source reduction program development in the areas
of  regulatory  improvements, outreach   and  incentive  programs,   and  revenue
generation systems, as discussed  above.  As part of this effort, the Bureau of  Solid
Waste  Disposal  has undertaken  three  contracted  studies  to improve the  State's
ability to develop an effective program.

    The  first study  surveyed specific  industries in  the Commonwealth  to better
understand how  much waste  of particular types is generated  and how much source
reduction has been achieved.  This effort  yielded  extremely useful case studies and
qualitative input from generators on source reduction.  Its  primary value,  however,
  *
was to  further clarify the definitional problems posed  by evaluating source  reduction
needs or  accomplishments on the  basis  of  onsite  hazardous waste  generation as
defined  under  RCRA.   The  State  has been  able  to design its  source   reduction
program more precisely, focusing on the  quantities of hazardous constituents  used
and released through various routes from industry processes.

    The second  study evaluated  the business  characteristics of four industry sectors
in Massachusetts to determine incentive  programs for source  reduction that would
best match  their  needs.  This  study  has served  as a very useful  guideline for
evaluating more industry sectors in  the Commonwealth, and should provide a fairly
accurate basis for designing targeted incentive programs.

    The third study was a nationwide overview of source reduction program efforts
in States and organizations.  It has been instrumental in organizing the State's effort
to develop a comprehensive source reduction  program (personal communication with
Richard Bird, Massachusetts DEQE, February 13, 1986).
                                      J4-9

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    In addition, targeted economic incentive programs are vital to source reduction
program development in the Massachusetts program.


    VII.     Award Programs


    The State of Massachusetts currently has no award  programs to promote waste
minimization, but is considering such a program as part of its incentive system.


    VIII.    Publications and References
    Banning,  W.   1983.   The  role   of  waste   exchange  in   industrial  waste
    management:  identifying  offsite  recycling opportunities.   Presented at  the
    Commonwealth of  Massachusetts,  Department of Environmental Management
    Hazardous Waste Source Reduction Conference, 13 October 1983, Boston, Mass.

    Capaccio, Robert  S.  1983.  Process modifications:  case histories  in  source
    reduction.  Presented at the Commonwealth of Massachusetts, Department of
    Environmental Management Hazardous Waste Source Reduction Conference, 13
    October 1983, Boston, Mass.

    League of Women  Voters of Massachusetts.  1985. Waste reduction: the untold
    story.  Conference held  19-21 June 1985 at  the National  Academy of  Sciences
    Conference Center, Woods Hole, Mass.

    Department of Environmental  Management, Bureau  of Solid  Waste  Disposal.
    1983.   Hazardous   waste   management   in   Massachusetts:    Statewide
    environmental impact report. Boston, Mass.

    Roeck,  D.R.   1985.   Interim  report   on  sample  population   design   and
    questionnaire distribution.  GCA Corp.  Contract no. 84-198,  interim report for
    Bureau  of  Solid  Waste   Disposal.   Boston:   Massachusetts  Department  of
    Environmental Management.
                                    J4-10

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APPENDIX J.5






 MINNESOTA

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J.5       Minnesota

    Minnesota  has final authorization  status to operate its own hazardous  waste
program  under the  1980  RCRA amendments.  The Minnesota  Pollution  Control
Agency (MPCA),  which enforces environmental regulations, the Waste Management
Board  (MWMB), and  the  Minnesota Technical  Assistance  Program (MnTAP)  are
involved  with various programs  that promote recycling  and source reduction.  These
include regulatory  programs,  fee  and  tax  incentives,  loans  and  bonds, grants.
information programs, a technical assistance program, and an  award program.

    I.       Legislative Background

    The  Minnesota Waste Management  Board (MWMB) was formed in 1980 under the
Waste  Management Act passed by the  Minnesota State  Legislature.  The legislation
was enacted in response to  a  growing  concern over pollution associated  with the
management of  hazardous  wastes.   The  Legislature  charged  the   Board   with
(1) drafting   a  comprehensive  hazardous  waste  management   plan   including
recommendations and  guidelines for the implementation of a  sensible and effective
waste  management  policy,  (2) selecting  "preferred areas"  for  hazardous  waste
processing   facilities,  and  (3) locating  and  developing  at  least  one  site  for  a
hazardous waste disposal or long-term storage facility.

    In  early   1984,  the  MWMB,  in   the  draft  version  of its  hazardous  waste
management plan,  ranked   source  reduction   and  recycling  first  and  second,
respectively, as preferred alternatives in the management of hazardous waste.  The
Board's plan outlined a number of innovative approaches  to waste minimization, and
the 1984 Legislature  consequently adopted three of these recommendations: (l)tax
credits for pollution control   equipment, (2) grants  and   loans  to   support  the
development of hazardous waste processing  facilities and implementation of  waste
minimization techniques, and  (3) the  establishment of a technical and  research
assistance  program  for  Minnesota's hazardous  waste generators.  In  addition, the
State adopted an awards program  to recognize  successes in  reducing  or  improving
the management of hazardous waste.

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     II.      Regulatory Programs

     Minnesota has two regulatory programs that promote waste minimization.  The
first, found in  the  Hazardous Waste Rules, exempts waste that is to be "beneficially
used, reused,  or  legitimately recycled  or reclaimed"  from  Parts  7045.0205  to
7045.1030  (standards applicable  to  hazardous  waste generators)  and  from  most of
the MPCA's permitting requirements (Minnesota Rules Part 7045.0125).

     The second program is  actually a  permitting/siting  assistance  effort by  the
MWMB,  which is  a nonregulatory  body.  To alleviate  public  concern over facility
siting and the regulatory problems associated with obtaining permits and undergoing
siting  procedures,  the  Board  has  selected  21 preferred sites  for  three types of
hazardous  waste   processing  facilities:  chemical   processing,  incineration,  and
transfer/storage.   This  action  was  taken   in  response  to the  State's   Waste
Management Act of 1980,  which  mandates  that at least three sites  be  chosen for
each kind of facility.  If a private  developer submits a proposal for operating such a
facility, especially  in a preferred  area, and if the proposal is approved by the MPCA,
the Board  is empowered to  mediate disputes  between  the  developer and the local
government regarding the siting of the facility. If necessary, the Board can override
 i
local    objections   (personal   communication   with    Wayne    Sames,   MWMB,
January  7,  1986).  To  date,  the  Metropolitan  Recovery Corporation has  obtained
approval from  a  local government to  build a facility for the recovery of  heavy
metals in a preferred area, and has  submitted a RCRA Part  B  permit  application to
the MPCA.

    III.     Fee and Tax Incentives

    Minnesota's hazardous waste generators are charged a generator  fee  according
to  the  volume  and  waste category of waste  generated  in  addition to  a 50  percent
surcharge on  that  annual  fee.  A  generator  who recovers, reuses,  or  recycles  a
hazardous waste stream for his/her own use onsite is exempt  from  the  generator  fee
for that particular  waste stream.  Any  hazardous  sludges  or  residues  from  a
recovery process,  however, are subject  to  the generator fee  (Minnesota  Code  of
Agency Rules Parts 7046.0030 - 7046.0050).
                                     JS-2

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    The  MPCA reports that  the  generator fee has worked  well as a  mechanism  to
persuade generators to reduce hazardous  waste generation,  citing as evidence the
fact  that  many  generators have  switched  to  alternative  waste  management
practices or have stopped generation altogether.  The fee was originally established
by the 1983 Legislature not so much as a strategy to reduce  waste  generation, but to
provide  funds  for  ten  new  staff positions  within  the MPCA.   To generate  the
legislatively mandated revenues in 1985, MPCA was  forced  to double  the  original
fee, which  has  had the effect  of placing economic hardship  on some businesses.
Thus,  the  hazardous  waste  generator fee  has  posed  some  problems  from  an
administrative point of view. This would probably be the case whenever a  budgetary
goal is established based on the receipts of such a fee levy  (personal  communication
with Melba Hensel, MPCA, December 13, 1985).

    In addition  to  the fee,  hazardous waste generators are taxed  based upon the
volume and destination  of the waste.  These  "waste-end" taxes, however, do  not
apply  to hazardous   "wastes  destined for  recycling  or  reuse including  waste
accumulated,  stored,  or physically,  chemically,  or  biologically   treated  before
recycling or  reuse..."  (Minnesota Stat. Sec. 115B.22).  Thus, both the  fee  and tax
systems  in  Minnesota ' are  structured to  encourage  recycling  activities.   Waste
reduction activities are automatically encouraged by  such a system, since the fee
and tax levied are a direct function of  waste volume.

    IV.     Loan and Bond Assistance

    Loan monies are  available  for  construction  of  hazardous  waste  processing
facilities, which include both commercial  treatment  and recycling facilities.  Up to
75 percent of capital  costs  excluding  land acquisition may  be covered by  a  facility
processing    loan  (personal  communication   with   Jerry   Johnson,    MWMB,
December 13, 1985).  Bonding authority is set  by  the  Legislature  at  $10,000,000,
although other monies  may also be available (Minnesota Stat. Sec.  166M.07  Subd. 9).
                                      J5-3

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     The  program  is  jointly run  by the  Minnesota  Department of  Energy  and
Economic  Development  (DEED)  and the  MWMB.  Before  a  loan  application  is
processed, it goes to DEED  for financial feasibility  studies and  to the  MWMB for
technical feasibility studies (Minnesota Stat. Sec. 1 ISA.162 and 116M.07, Subd. 9).

     Thus far, one firm, Metropolitan Recovery Corporation, is expected to apply for
the loan as soon as its permit application is fully approved. The MWMB expects that
construction will begin in late  1986. Other  companies  have  made  inquiries about
available loans; the  MWMB believes that the  next  facility to  apply for  a  loan  will
most probably be a waste transfer/storage facility (personal communication with
Jerry Johnson, MWMB, December 13, 1985).

     V.      Grant Programs

     The MWMB oversees several of Minnesota's grant programs:

     •   $600,000 for feasibility and  development studies of  new  hazardous  waste
        processing facilities or services;
     •   $350,000 for the  study and development  of  a Statewide hazardous  waste
        transportation and collection system; and
     •   $350,000 to study  and develop hazardous waste reduction techniques.

     Though all three potentially could involve  waste minimization efforts as defined
in this  report,  the  third, Grants  to  Minnesota Businesses  for  Waste  Reduction
Feasibility Studies, is specifically related to source reduction and  recycling.

     The third grant program  provides a  total of $350,000, to be  awarded over three
years in increments of up to $30,000, for investigating new  methods of  reducing
hazardous  waste generation, or  for studying the  applicability  of  known  waste
minimization techniques to a production or handling process.   Any hazardous  waste
generator or group  of generators in Minnesota may apply for these grants (personal
communication with Wayne  Sames, MWMB, January 7, 1986).   The program, fully
operational  since January  1985, is  administered by two MWMB staff members, who
allocate  approximately 50 percent of their time to the project.

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    The  MWMB  received  few  applications for grants in the  first  grant period
because slow progress was  made in publicizing  the program.   Application  requests
were  mailed to 2,500 small waste-generating  firms, but just  over $100,000 of the
fiscal year  1985  allocation of $150,000  was  disbursed (a total of  6  grants).   A
follow-up study of  why only six of the 80 firms that requested applications actually
submitted applications produced a variety  of reasons.  The  firms  cited:   (1) the lack
of preparation time,  (2) the  prevalence of other business  matters, (3) the narrow
eligibility range, and (A) the extensive  information requirements as factors weighing
most heavily against their participation in the program.

    The  requirements of the grant program were changed  to  broaden the range of
eligibility and  to reduce information  demands.  The  schedule  was also revised to
allow more lead  time than was given in the previous year.  The program was first
announced in October 1984 and the application deadline fell in early  January  1985.
For 1985-1986, materials announcing the grant  program were available in September
and the application  deadline was late January.  A total of $150,000 was allocated for
this  year's  program.  Results of the  studies are available to the public  (personal
communication with Wayne  Sames, MWMB,  August 23, 1985).

    VI.     Information  Programs -  Minnesota Technical   Assistance   Program
            (MnTAP)

    The   Minnesota  Technical  Assistance  Program  (MnTAP) is a  nonregulatory
program  that works  with  hazardous waste  generators  to reduce hazardous wastes,
find cost-effective  alternatives to land disposal, and  provide regulatory compliance
guidance. MnTAP can provide assistance through several mechanisms including:

    •   Outreach programs,  including  onsite  technical consultations,   information
       seminars,   a  telephone  hotline,  and  technical   workshops  and  training
       programs;
    •  The  active  assembly, cataloging,  and   dissemination  of  information about
        hazardous waste reduction and waste management methods;
                                      ]5-5

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     •  The evaluation and interpretation of  information needed by generators to
        improve hazardous waste management;
     •  Information  and  technical  research  to  identify  alternative  technical
        solutions;
     •  An engineering intern program  to implement  in-plant changes resulting in
        waste minimization; and
     •  Coordination  of its efforts with other agencies working  towards  hazardous
        waste reduction.
     The Legislature  specified that the program  must focus on  assisting  smaller
generators of hazardous waste,  who lack the technical  and financial resources to
research and implement waste  reduction techniques.  However, MnTAP  also helps
manufacturing   firms  and  service companies  of any  size,  industry   and  trade
associations, consultants, and waste management firms.

     MnTAP was initially funded at $150,000  for its  first  year of  operation,  which
officially began  in November  1984.  Of this, the  University of Minnesota received
$97,000  to  establish  the location and  operation  of  the  program,  including  the
necessary data  base, and the Small Business  Development  Center received  $40,000
to develop  information  seminars  and  newsletter  articles and  to conduct direct
mailings of  the  MnTAP information.  The program has been re-funded for the next
two  years at $200,000 per year.  Two professional  personnel and one staff assistant
currently operate MnTAP.

     After  one   year  of  operation, MnTAP has  gained credibility and recognition
through  its  many services.  Initially, slow progress was  made in  making  services
known despite  a publicity  campaign of direct mailings, articles in newspapers,  and
speaking engagements.  The MnTAP staff cited the program's recent  formation as
the  reason  for  the  lack  of  recognition and established  credibility.  During its
operation, the  program has produced  information  brochures and  a  series  of  fact
sheets,  and  has participated in many  meetings  and  conferences  to  help  hazardous
waste generators achieve waste  minimization.  The  program operates a  telephone
hotline   that gives  free  advice   and  assistance.   MnTAP  also  conducts onsite
consultations, which are described as informal  plant surveys.
                                     J5-6

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    In the summer  of  1985,  MnTAP  sponsored  an  intern  program, in  which seven
university  students  (one  mechanical,  one  civil,  and  five  chemical  engineers)
conducted  in-plant  surveys/studies  of  electroplating  companies,  a  painting  and
coating operation, and  a variety  of  other  operations.  Interns  were  able  to help
participating companies  implement practices or operations that have reduced or will
result in reducing the quantities of waste being  landfilled. In addition, each  intern
produced a report that  documents case studies to be used by MnTAP as examples of
methods in which waste minimization can be achieved.

    MnTAP  hopes  to  establish  a  program  of research  grants  to  educational
institutions in Minnesota this year.  These grants, limited in amount to  $5,000 each,
are intended to  support  research  on  new methods to reduce  hazardous wastes.  A
total  of $20,000 has been allocated  for this year, although MnTAP is investigating
the possible availability of  Federal EPA grant funds to accelerate this program.

    VII.    Award Program

    Minnesota's   award   program,   the    Governor's   Award    for   Outstanding
Achievement  in  Hazardous  Waste  Management,  is  a  method  of  recognizing
companies or institutions and publicizing their projects.  To qualify  for the award, a
project must achieve one or more of  the following: (1) represent a worthy effort at
reducing hazardous waste  generation, (2) reclaim energy  or  materials  from waste,
(3) reduce  the  quantity  of wastes  going  to treatment  and  disposal  facilities, or
(A) reduce  the risk of hazardous waste release into the environment.   A  project  is
evaluated on the following  criteria:

    •   Environmental benefits;
    •   Technological importance of its processes or equipment;
    •   Economic benefits  - profits, annual  savings, and payback periods; and
    •   The  potential  award  winner's commitment  to  sharing   information  and
        expertise resulting  from the project.
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Entries are received in  March  for  awards presented in  April.  There has been  no
limit  to  the  number of  awards given, although in  the  future, the number may  be
limited.  Award  winners receive  a  certificate and special flag  as a  symbol  of
achievement.  Achievements are also publicized in a booklet published by the MWMB
(MWMB [1985]).  The publicity associated with  the award provides an attraction  to
companies  seeking  favorable  exposure.   The  program  therefore  encourages  the
development  of waste minimization among other desirable waste management goals.

    In April  1985, seven projects  were submitted and seven winners selected.  One
was further singled  out to receive special recognition.  The panel of judges felt that
all projects demonstrated worthy efforts at hazardous waste management.

    The  response to the  program was considered favorable, especially  since  1985
was its first year of operation.  Participants expressed  some dissatisfaction  about
the short  time  limit  given  for project  description.  With a  few  improvements,
however, the  MWMB  hopes  to attract greater participation in the coming  years
(personal  communication  with  Patrick  Hirigoyen  and  Wayne  Sames,  MWMB,
October  1,  1985).

    VIII.    Publications and  References
    Frank,  M.A.   1985.  Minnesota  Technical  Assistance Program intern report:
    reduction of copper and nickel sludges.  Minneapolis:  MnTAP.
    Hamann,  R.D.  1985.  Minnesota  Technical  Assistance Program intern report:
    final report on the in-house internship.  Minneapolis:  MnTAP.
    Kuchibhotla,   P.M.   1985.   Minnesota  Technical  Assistance  Program  intern
    report:   hazardous  waste  reduction   and   metal  reclamation.   Minneapolis:
    MnTAP.
    Larson, C. 1985.  Minnesota Technical Assistance  Program intern  report: final
    report for Midwest Finishing.  Minneapolis: MnTAP.
    Marxen, R.   1985.  Minnesota  Technical Assistance  Program  intern  report:
    intern project: Micro Parts, Inc.  Minneapolis:  MnTAP.
    Minnesota   Household   Hazardous  Waste  Task  Force.    1985.   Summary:
    management   of hazardous wastes generated  by households.  Crystal,  Minn.:
    Waste Management Board, State of Minnesota.
                                     J5-S

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MnTAP.   n.d.   Hazardous  waste  fact  sheets:  acids  and  bases;  solvents;
polychlorinated  biphenyls (PCBs); heavy  metal  sludges; paints and inks; waste
oils; and pesticides and herbicides. Minneapolis:  MnTAP.

	.  1986.  A year of service:  Minnesota Technical Assistance  Program  1985
annual report. Minneapolis: MnTAP.

MWMB.  1985.  Minnesota  Waste Management Board.  Foresite.   April  1985.
Crystal: State of Minnesota.

	.  [1985]. The  Governor's award  for  outstanding achievement  in hazardous
waste management.  State of Minnesota.

Sandberg, J.  1985.  Minnesota  Technical  Assistance  Program  intern  report:
final  report  in  the internship  served  at Gage  Tool  Company.   Minneapolis:
MnTAP.
                                 J5-9

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APPENDIX J.6
NEW JERSEY

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J.6        New Jersey

    The  State  of New Jersey has recognized the potential  benefits of hazardous
waste minimization.  The Bureau of  Hazardous  Waste Planning and  Classification
and the  New Jersey  Hazardous Waste Facility  Siting Commission  are the State
agencies addressing minimization with  legal authority.  Disposal restrictions, permit
exemptions, and special allowances for certain industries are examples of regulatory
programs that directly or indirectly promote  minimization. Seminars, conferences,
and a waste exchange have  served  to  educate concerned parties about minimization
opportunities, strategies, and techniques.   In  the  future, New  Jersey plans to
establish a technical assistance program to focus on this issue.

    I.       Legislative Background

    Two  laws  form  the  fundamental  legal  structure for  New Jersey's hazardous
waste programs:  the Solid Waste Management Act of  1970  and the  Major Hazardous
Waste Facilities Siting Act  of 1981.  Aspects of  waste minimization are part of the
responsibility of agencies implementing these laws.

    The  Division of Waste Management (DWM) of the New Jersey Department of
Environmental  Protection (NJDEP) is  responsible  for implementing requirements of
the Solid  Waste  Management  Act  (personal communication  with  David  Potts,
NJDEP,   December 12, 1985).   The  Bureau   of  Hazardous  Waste  Planning  and
Classification within  the DWM is the  unit whose  duties include implementation of
both  regulatory  and nonregulatory programs (with  the exception of  siting)  that
affect waste  minimization.   The Bureau  recently sponsored  a  source reduction
seminar  held at  Rutgers  University  (August 1985);   however,  the efforts  of  this
Bureau  are currently focused  on  planning   (personal communication  with  Kevin
Gashlin,  NJDEP, December 12, 1985).

    The  Major Hazardous Waste Facilities Siting  Act (P.L. 1981, Ch. 279) forms the
legal  basis for a  method of  planning, licensing,  and siting  new  hazardous  waste
                                     J6-1

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facilities in New Jersey.  The Act  also  establishes  the  Hazardous  Waste Facilities
Siting  Commission,  a  nine-member  group  consisting  of  representatives  evenly
distributed from  industry, county  and  municipal governments,  and  citizens groups.
Each member is appointed by the Governor.

    Assisting the Siting Commission are the  Hazardous Waste Advisory Council and
the Hazardous  Waste Source Reduction  and Recycling Task  Force.  Like  the  Siting
Commission, the Council is composed of representatives from  various groups.  The
Task  Force,  whose  purpose  is  to  encourage  education   and dissemination  of
information  and  also  to  promote  recycling, is composed of representatives  from
environmental  organizations, academia,  and industry.  As part  of  its dissemination
activities,  the  group  sponsors an annual  roundtable.   The  Task Force  is  also
responsible  for advising the  Siting Commission  on options that  it may  use for
proposed legislation.

    II.      Regulatory Programs

    The  State  of New  Jersey's hazardous waste regulations contain provisions that
may directly  and  indirectly  promote   waste  minimization.   Specifically,  these
provisions are (1) restrictions applied to land disposal, and (2) permit exemptions and
special allowances for certain forms of waste recycling.

    Landfills are subject to the same requirements as the  HSWA of  1984,  as well as
requirements that go beyond these amendments.  For example, New Jersey requires
that all landfills must  have double liners (New Jersey  Admin.  Code 7:26-10.8(c)).
New Jersey  also has regulations requiring that landfills  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.).

    New Jersey exempts certain specific hazardous waste recycling activities from
the requirements of  submitting Part  A and B  permit applications.  One  exemption
related to recycling allows onsite-generated waste to be  burned as  fuel without the
operation's  needing a  full  TSD facility permit.  Some  of  the  provisions of  this
exemption are  as follows (New Jersey Admin. Code 7:26-12.l(b)7):
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    1.   Wastes must  be burned so that they are "used  or reused as a fuel  for the
         purpose  of  recovering  usable  energy and are limited to onsite wastes or
         specific  waste between intra-company and intra-State facilities under the
         control of the same person";
    2.   A "Permit to Construct, Install  or Alter Control Apparatus or  Equipment"
         has been issued  by  the regulatory agency;
    3.   Rate of gross heat  input must be greater  than 20 million Btu/hr;
    4.   Device must be continuously  monitored and recorded  for 02 and  either
         CO or total hydrocarbons;
    5.   A full-time, certified operator must  be  present when the  waste is burned;
         and
    6.   The device  must be located in an industrial facility.

Another  provision expands  the  onsite  provision to other  forms of "recycling" or
"reclamation."
    Though these  exemptions  are  currently  in  effect  as written, they  will soon
undergo revision.  The  new definition  of  hazardous waste will require that these
companies receive an  EPA  identification number. According to the New Jersey_
Division of Waste Management,  this difference will  be slight and its implementation
will  cause no  significant  change in the  exemption (personal communication with
David Potts, NJDEP, January 15, 1986).

    The  NJDEP, in developing its  new  definition of solid  waste, is planning to
incorporate a  partial  permitting exemption for operations  that  recycle  precious
metals and other types of hazardous  waste. These businesses would then be allowed
to operate with a "Permit-by-Rule"  as  long as  they  function  within  guidelines
established by the State. They  would not be subject to obtaining a full TSD facility
permit.  This  relaxation  of existing regulations  will result in encouraging certain
forms   of  recycling   (personal   communication   with   David   Potts,   NJDEP,
December 23,  1985).

    III.     Fee and Tax Incentives

    New  Jersey  presently  does  not use  fee  or  tax  incentives to  encourage
minimization.
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     IV.     Loan and Bond Assistance

     Loan and bond assistance is  not  available  in New Jersey at  this time for waste
minimization efforts.

     V.      Grant Programs

     The Hazardous  Waste Advisement Program has  received a grant of $75,000
from EPA  to fund a Household Hazardous Waste Project.  County governments will
receive portions  of  this grant to execute specific programs.   These will  include
promotion  of innovative  methods of reducing the need for land disposal of home
hazardous  waste  (personal communication with Kevin Gashlin,  NJDEP,  December
12, 1985).

     VI.     Information Programs

     New Jersey  has  several programs and organizations involved in the effort  to
promote waste minimization by  providing informational  and technical assistance.
Groups  involved in this effort include the New Jersey Hazardous Waste  Facilities
Siting Commission, NJDEP Bureau of  Hazardous Waste Planning  and Classification,
the   Hazardous  Waste  Source   Reduction  and  Recycling   Task  Force,  the
Industry/University Cooperative Research Center, the New Jersey League of  Women
Voters,  and the New Jersey Chamber of Commerce.

            A.   Information Transfer

     The Hazardous Waste Source Reduction and Recycling Task Force is a  volunteer
group,  which  includes university   professors,  environmentalists,   and  industry
representatives.  The Task Force, with  assistance  from the Siting  Commission,  is
working on strategies to  provide incentives for waste minimization  based  on  the
Minnesota  and  North  Carolina programs (see Sections  J.5 and J.8 within Appendix J
for information on these programs).  Presently, the Task Force is involved  in a study
that will  provide  information  needed  to  make specific recommendations  to  the
Siting Commission  on the incentives  and disincentives necessary  to achieve  the
maximum degree  of reduction and recycling  in New Jersey.  Partial funding for this
project  came from the DEP's Office of Science and  Research, and the  balance came
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from the Siting Commission.  The scope of this project is to  analyze existing  source
reduction practices  and the potential  for increased reduction of hazardous waste
produced  by  the following industries:  Industrial  Inorganic  Chemicals  (SIC 2819),
Plastics  Materials and Resins (SIC 2821), Electroplating and Plating (SIC 3471), and
Electronic Components and Accessories (SIC 3679) (NJHWFSC 1985).

    The  Hazardous Waste  Advisement  Program sponsored the Source Reduction  of
Hazardous Waste Seminar  at Rutgers  University on August 22, 1985.  Papers were
presented on topics  that included waste minimization practices and technologies,
means of promoting  waste  minimization, and  waste minimization programs.  The
Hazardous Waste Advisement Program is part  of the  Bureau  of Hazardous Waste
Planning and  Classification in the Division of Waste Management.

    The  New Jersey Hazardous Waste  Source Reduction  and Recycling Roundtable,
held on  July 25,  1984,  was sponsored by the  Hazardous  Waste Facilities Siting
Commission,  the New  Jersey  League of Women Voters,  and Shell Oil Company.
Topics covered  at this roundtable included the Northeast Industrial Waste Exchange,
used  oil  recycling,  Minnesota's source reduction and  recycling policy, and case
studies of waste minimization.

    In July  1985, the Task Force and the New Jersey  League  of  Women  Voters
sponsored a second conference,  the New  Jersey Technical Assistance Roundtable, in
Princeton.  Representatives  from  Minnesota,  Pennsylvania,  North  Carolina,  and
California each  spoke  on  existing  technical  assistance  programs  within  their
respective States.   Presentations  were  also   made  by   the  Hazardous  Waste
Advisement  Program  and   the  Industry/University Cooperative  Research Center,
which operates  out of the New Jersey Institute of Technology.  Group discussions  at
the Roundtable centered on topics such  as  (1) the need for a technical assistance
program  in New  Jersey, (2) the  form of a potential program,  (3) the  location  of
program  headquarters, (4) staffing, and (5) funding.

    The  Industry/University  Cooperative Research Center  is an organization that
coordinates the resources and expertise of universities  to meet  the research needs
of participating industrial  firms.  Presently,  the Center is  focusing  on  identifying,

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evaluating,  and   developing  inexpensive  end-of-the-pipe  waste   treatment  and
recovery systems, and developing new uses for  waste materials.  Financial support
for the center  is generally provided by universities and industrial sponsors.  The New
Jersey Commission on Science and Technology has also  added  the Center,  and EPA
grants have  been  obtained to support many  of the research projects (Liskowitz 1985).

            B.   Technical Assistance

    New Jersey hopes to facilitate waste minimization,  specifically in the form of a
technical  assistance program.  The  Hazardous Waste Facilities Siting  Commission
and the DWM are currently drafting a proposal that calls  for the following:

    •   Formation of a task force to oversee the project;
    •   Study of all technology for hazardous waste impact;
    •   Review of source reduction and recycling proposals;
    •   Determination of sources for grants for industry;
    •   Formulation of regulations to promote the use of innovative and alternative
        technologies; and
    •   A survey of existing hazardous waste activities in various industries for the
        purpose of minimizing  the waste of small-quantity generators.

            C.   The New Jersey State Industrial  Waste Exchange

    The New Jersey Chamber  of Commerce established a waste exchange in 1978 in
response to  a need expressed by the business community. The  service, known as the
New Jersey  State  Industrial Waste  Exchange, functions  as  a passive distributor  of
information  on available or wanted materials.  Both hazardous  and nonhazardous
wastes are included.

    Businesses  participate by  paying a yearly fee; they  are included in the  listing
and  receive a  year's  subscription  (3  issues)  to  its publication. Chamber  of
Commerce members may list  either "Wastes  Available"  or "Wastes Wanted"  for
$25.00. Nonmembers  may  do so for $35.00.  Additional  items  may  be listed  by
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members and nonmembers alike for $7.00  per entry. These fees are used to finance
this nonprofit exchange.  The New Jersey Exchange provides an information transfer
service, as opposed  to  exchanging the waste materials.  By assigning each item  a
code number, the Exchange maintains confidentiality for the participants.   When  a
subscriber  sees  a  potential match between what they  and  another business  want,
they contact the Exchange, which, in turn, gives the name of the inquirer to  the
company that paid for the listing.

    The  success of this  type of waste minimization  effort is difficult to assess. The
Exchange has received  some  letters of  appreciation,  but  it  is  not  common  for
participants to acknowledge the benefits  of  this service.  Occasionally, companies
have asked to be removed from the list after incorporating  minimization  processes
into  production.  Although this  is a  favorable waste  minimization step,  it is  not
necessarily a reflection  of the Exchange's success. Demand  for  the  Exchange is
strong, however, and it should  remain in operation for  as long as the  need remains.
There  are  about 65  items listed  currently.  This  value fluctuates  and  at  times
exceeds 100.  Subscriptions usually number  between 60 and 78.

    There  have  been  attempts  to  link  the New  Jersey Exchange  to others  to
increase  the potential for exchanges.  With  the exception of a one-time  event with  a
waste  exchange in Pennsylvania,  such   transfers  have  not  occurred.  Although
liability problems have  forced  the closing  of some material exchanges, this has  not
been a problem  for the  New Jersey Exchange, since they transfer information and do
not take  physical possession of the materials (personal  communication  with  William
Payne of the New Jersey Chamber of  Commerce, December 19, 1985).

    VII.     Award Programs

    New  Jersey  currently   does  not have   an  award  program to  encourage
minimization.

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VIII.    Publications and References
Auerbach,  A.,  and  Boyle,  5.,  eds.   1984.   Proceedings of  the  New Jersey
hazardous waste source reduction and recycling roundtable. Held 25 July 1984.
Hyatt Regency, Princeton, N.J.

Liskowitz,  J.W.   1985.  Industry/university cooperative hazardous waste source
reduction research in New Jersey.  Paper presented at the Source Reduction of
Hazardous  Waste  Seminar,  22 August  1985  at  Rutgers University -  Douglass
College,  N.J.

NJHWFSC.   1985.  Project-specific  request for  proposal:   source  reduction
project   under  term  contract  X-007  data  collection and  analysis  for  the
Hazardous  Waste Facilities Siting Commission and the Source Reduction  and
Recycling Task Force.

Resource Management, Inc.   1985.  New Jersey hazardous waste facilities plan.
Trenton,  N.J.: Hazardous Waste Facilities Siting Commission.
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APPENDIX J.7






 NEW YORK

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J.7        New York

    New  York  has  taken various steps to promote waste  minimization  through
State, regional,  and local programs. State programs  include:  the establishment of
the   Industrial  Materials  Recycling  Program  (IMRP)  within  the  Environmental
Facilities  Corporation   (EFC);   Generator  Certification   Requirements;   the
Environmental  Regulatory  Fee  System and  State  Superfund Program; and  Land
Burial Restrictions.  The latter three activities are implemented by  the  New  York
Department of  Environmental Conservation (DEC). A regional program, centered in
New  York  State,  is  the  Northeast  Industrial Waste  Exchange  (NIWE),  an
informational waste  exchange.  Finally, on the local level, Erie County conducts the
Industry-Specific Small Quantity Hazardous Waste Generators Technical  Assistance
Program.

    I.       Legislative Background

    The  New York  State Governor's Hazardous  Waste Treatment  Facilities  Task
Force  encouraged  the  practice  of   waste   minimization  by   recommending
implementation  of a four-part  waste  management hierarchy in the following order:
waste  reduction;  waste  recycling,  recovery,  and  reuse;  waste   treatment  or
detoxification;  and  land  disposal  only  for pretreated  residuals  that  have  been
detoxified so that direct or indirect human contact  does not have  a  significant
environmental or health risk.  The four-phase hierarchy  is implemented  by both the
New York Department  of Environmental Conservation  and by  the  New   York
Environmental Facilities Corporation.

    The  DEC was established  by the Legislature of  the State of New York as the
agency responsible  for  implementing regulations  established  under  the  New  York
State Resource Recovery Policy Act, the New  York State Solid Waste Management
Plan,  the  Federal  Resource  Conservation  and  Recovery   Act  of  1976,   and
amendments  thereof.  Waste  minimization is promoted directly and  indirectly  by
DEC through:  (1) the  HSWA of  1984 requirement for  generator  certification  of
waste minimization on  all manifests; (2) the Environmental Regulatory Fee System
and State Superfund  Fee  System; and  (3) restrictions  on  land  burial of specific
hazardous wastes at all commercial landfills.

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     The  EFC  was  established  under Chapter  744  of  the  Laws  of  1970  as  a
reconstitution and  continuation of the New York  State  Pure Waters Authority.  A
nonregulatory agency, it can  plan, design, finance,  construct, and  operate solid
waste,  hazardous  waste, resource recovery and pollution control facilities, and can
conduct programs regarding remediation of inactive hazardous waste  disposal  sites.
EFC also finances water management and pollution control facilities through the
issuance  of  industrial  revenue  bonds.   EFC  can render  advisory   services  for
authorized projects that include wastewater treatment, air pollution control, water
management, storm  water collection,  and  solid waste  management  facilities.  EFC
has been  an  active  participant in  New York State's hazardous waste  minimization
program since 1977.

     In  1981,  Chapter 990 amended the Public Authorities Law with the addition  of
Section  1285-g,   which  established  the   Industrial Materials  Recycling  Program
(IMRP).   The Industral  Material  Recycling  Act  (IMRA),  passed  by  the  State,
designated EFC  as the  State entity responsible  for implementing  the  program
responsibilities stipulated by law.  This  law mandates a  program  to  help  industry
reduce, reuse,  recycle,  and exchange industrial materials.  IMRA  is designed  to
provide industry with direct assistance in the reduction and recycling  of industrial
and  hazardous waste  materials as  an  economically  and  environmentally  sound
alternative to disposal.

     In  addition  to  the  programs  supported by New York  DEC and  EFC, the
Northeast  Industrial Waste Exchange (NIWE)  was established in  1981 to  promote
waste  minimization.  This waste exchange is operated by  the Central  New  York
Regional  Planning  and  Development  Board and  the Manufacturers Association  of
Central New  York, and  is funded in part  by the EFC  (see Section 4.3.2  for  more
information on waste exchanges).

    II.      Regulatory  Programs

    The New York Department of Environmental Conservation (DEC) has instituted
regulatory programs  to  implement  the   four-part waste  management  hierarchy
recommended by  the Governor's Hazardous Waste Treatment Facilities Task Force.
In  addition  to the  HSWA  of  1984  requirement  for generator  certification  on

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manifests regarding waste minimization, the DEC has placed restrictions on  the land

disposal of several organic hazardous  wastes at  commercial land burial facilities  in
New  York  State (personal  communication  with  Cliff  Van  Guilder,   NYDEC,

November 1985).


    The  land disposal restrictions were implemented  to provide an incentive  to use

preferred waste management practices.  The restricted wastes were selected based

on their effect  on liners in hazardous waste landfills.


    The  land burial  ban  of hazardous  organic wastes has the following time  schedule

and  requirements  (personal  communication  with  Cliff  Van  Guilder,   NYDEC,

November 1985):
     1.   Twenty-four  listed hazardous organic wastes (F001, F002, and 22 K-code
         wastes) are prohibited from land disposal unless it  is demonstrated that the
         sum total of  the "hazardous constituents" is less than or equal to 5 percent
         of  the waste  stream by weight. After December  31,  1985  this percentage
         was reduced to 2 percent.

     2.   No  bulk  or  containerized  hazardous  waste may  be land disposed that
         contains in excess of 5 percent by weight as  generated, of:

         (a)   Halogenated, nitrogenated, or aromatic chemicals;

         (b)   Low molecular weight organic chemicals; and

         (c)   Any organic  constituents  identified  in 40  CFR  261.33(e) and (f),
              individually or in combination.

         After March 31, 1986, this percentage will be reduced to 2 percent.

     3.   The New  York  DEC may approve the continued  disposal of certain  waste
         streams if  it can  be adequately demonstrated  that practical  alternative
         high  technology facilities for  managing  the  waste do  not  exist.  This
         approval  is  for a  maximum of  18  months and  may be  revoked  if  an
         alternative technology becomes available.

     4.   "Lab Packs" will be regulated according to guidelines established in 40 CFR
         265.316, and no lab pack may contain more than one gallon of liquid.

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     III.     Fee and Tax Incentives

     The New York State DEC has two  fee programs:  the Environmental Regulatory
Fee  System and the State Superfund Fee Program.  Both of these  programs impose
fees on  regulated facilities in  order to encourage  preferred  waste  management
practices.  The  fees are  based  on  the amount  of  wastes generated as well as the
waste  management practice.  Under the State Superfund Fee Program, wastes sent
to landfills are taxed at the highest rate; wastes sent for treatment are assessed the
lowest rate.  In  addition to the  tax on the waste generated, there are also special
facility fees assessed on landfills, lagoons, and other units. The fees that the owners
pay are thus passed on to the generator  shipping the  waste to the  facility (personal
communication with Cliff  Van Guilder, NYDEC, November 1985).  No fee is imposed
on waste that is recycled (GAO 1984).  By structuring the fee system  in  this way,
there is an incentive both  to generate less waste and to  reduce the amount of waste
that is land disposed.

     New York State did not collect the annual revenues from these waste-end taxes
that they expected. In a report prepared by the U.S. GAO  (1984), several possible
reasons were cited as to why this  may  have  occurred, including:  an inaccurate
projection; a  depressed economy;  a  loss of out-of-State  business at New  York
disposal  facilities;  misuse  of  a  materials  recovery exemption,  which   excludes
recycled wastes  from  taxation;  and to  a  lesser  extent  the  underreporting  or
nonreporting of waste.

     IV.    Loans and Bonds

     In  1974, the  Environmental Facilities   Corporation  (EFC)  was  authorized  to
make loans to private industry for  air and wastewater pollution control facilities and
solid waste management facilities.  This authority was extended by Chapter 639 of
the Laws of 1978 to  include industrial hazardous waste management facilities (which
include resource recovery facilities). The loans have no limit  and may be for a term
of up  to 40 years.  They may be  used to pay (1) the cost of land and  appurtenant
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buildings; (2) equipment  and engineering costs; and (3) design, legal, financing, and
other related costs.  These  loans apply to both new and existing  facilities,  and the
loan recipient may also use the accelerated depreciation deductions, investment tax
credits, and energy tax credits  allowable under State and Federal laws. Since  1976,
industry has been issued $123.2 million in bonds under this program (NYSEFC 1985a).

    The  EFC finances  these  loans through proceeds of special  obligation revenue
bonds. Because the interest on the  revenue bonds is usually  exempt from  New  York
State and Federal income taxes, the EFC can make  loans with lower interest rates.
The bonds are issued on  an individual company basis, so that neither the EFC nor the
State of  New  York is  under  financial  obligation.  An  additional feature of these
loans is that several environmental projects at one  or  more  of a company's  plant
sites  in New York State may be financed through a single  bond issue. A company
must  meet the debt service  to demonstrate financial ability to  qualify.

    V.      Grant Programs

    Presently, New York  does not have  a grant  program  that  directly promotes
hazardous waste minimization.

    VI.     Information Programs

            A.  Environmental Facilities Corporation (EFC)

    The  Environmental Facilities  Corporation (EFC)  is a  nonregulatory  agency
formed  by  the  Public Authorities  Law  of  New  York  State.   EFC  provides
informational, technical, and  financial assistance for industrial and hazardous waste
management, including  waste  minimization.  Within EFC, the Industrial  Materials
Recycling  Program  (IMRP) assists  industry  in  reducing,  reusing,  recycling,  and
exchanging industrial materials. This is accomplished through activities such as:
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     •   Technical information and assistance programs;
     •   Data collection, development, and maintenance; and
     •   An active waste exchange program.

     The  IMRP  offers  technical services to  industry  by  recommending  source
reduction, energy  recovery,  and treatment  and disposal  options.  Staff members
determine the availability of specific wastes and  judge their recovery  and reuse
potential.  Wastes are  identified from sources such as the New York State DEC
manifest  systems, the  NIWE  Listing Catalog,  and EFC  staff  contacts.   EFC's
services  also  include  regulatory  assistance,  technology  evaluations,  technical
feasibility studies, process analyses,  research of potential  markets for wastes, and
assistance in  selection of consultants. EFC's services are  offered to all  companies
located in New York  State, although  small- and medium-size  companies are the
primary users of this program.

     Data  collection,  development,  and  maintenance enable IMRP  to obtain the
information to support its technical assistance  programs, as  well as information to
disseminate to the public. Publications provide a means of transferring technology.
IMRP publishes the following:
    •   Industrial Materials Recycling Act  (IMRA)  newsletter (published quarterly)
        covering  topics  such  as  waste  exchange  information,  current  technical
        assistance and research programs, and recent papers and publications;
    •   Hauler's Directory (published annually) based on EFC's survey of permitted
        haulers;
    •   Laboratory waste management  manual - "A Guide to Informational Sources
        Related  to  the  Safety  and  Management  of  Laboratory  Wastes   from
        Secondary  Schools";  published  as  an  information  source  on  the  proper
        storage and disposal of small amounts of hazardous wastes; and
    •   Technical papers written by the staff.
    In addition, IMRP has library facilities for over 700 technical materials such as
books and  reports to aid its  staff members  in their own  research  and to provide
assistance to industrial clients.
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    IMRP operates an active waste exchange.  The IMRP waste exchange serves as

an intermediary between  the  generator  and the potential user, and locates wastes

for interested clients.


    In addition  to IMRA, EFC  conducts  special projects.  This year  they  have

included  (1) a Hazardous  Waste  Management  Audit Program  for Small Quantity

Generators, and  (2) a Feasibility Study for  a Research and Development  Center for

Hazardous Waste.


    (1)   Waste Management Audit Program

         In August  1985,  EFC  was awarded an EPA grant  to help small-quantity
         generators (SQGs) manage  industrial wastes.  The  20-month program is
         being  developed  with  the assistance  of the Manufacturers Association of
         Central  New  York  and the Environmental Management  Council.  EFC
         selected  the  Central  New York-Syracuse region as  a  representative
         industrial region from which data about the types and quantities of waste
         as well as  waste management practices would  be collected, analyzed,  and
         incorporated in  the development  of a State waste management  plan  for
         SQGs. The data compiled are  expected to  highlight the needs  of SQGs in
         the State  for reducing, recycling, reusing, collecting,  transporting,  and
         treating  wastes.

    (2)   Hazardous Waste Research and Development Center

         EFC was appropriated $150,000 in the  1985-1986 State budget  to perform
         a  feasibility study for a research and development center for hazardous
         and  industrial waste.  It is anticipated  that the center  will conduct  basic
         and applied research  on hazardous waste in the area  of source reduction,
         treatment,  resource  recovery,  recycling,  and other  forms of  waste
         management,  as well as address  government and industrial policy issues,
         disseminate information, and  train industrial personnel. EFC  contracted
         with  the Rockefeller Institute of Government  Affairs to  perform  the
         study, which was released in January 1986.


            B.   Northeast Industrial Waste Exchange (NIWE)


    The  Northeast  Industrial   Waste  Exchange  (NIWE)   is  an  information  waste

exchange created  in June  1981.  In  the  State  of  New  York,  the  Manufacturers

Association  of Central New York and the Central New York  Regional  Planning  and

Development Board  are joint  sponsors  of  the  NIWE.  The  NIWE serves  industry
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throughout the  U.S. and  Canada.  The primary region served  by  the  NIWE  includes
New York, New  Jersey, Pennsylvania, Ohio, Maryland, and the New England States.

     As part of the IMRP, EFC began to cosponsor and provide funding for  NIWE in
1981; the Ohio Environmental Protection Agency became an additional cosponsor by
providing financial support  in  1983.  In addition  to  covering  printing expenses for
NIWE's Listings  Catalog,  EFC provides NIWE  with an informational supplement
containing regulatory, technical, waste  exchange, legal, financing, and publication
information of interest to generators and users (NYSEFC 1985a).

     The NIWE exchanges information by listing "Materials Available"  and "Materials
Wanted"  in  a quarterly  Listings  Catalog  with a  distribution  of  nearly 9,000.
Confidential  inquiries received by  NIWE are forwarded  to the company that placed
the listing. The  originator of the listing is then responsible for the negotiation.  For
nonconfidential inquiries, notification is sent to both the  originator and inquirer.

     NIWE has the first  computerized waste listing service  in the U.S. This online
computer service provides  industry  with  immediate access  to  listings  from  the
Northeast Industrial Waste Exchange, Industrial Material Exchange Service (Illinois),
and  Southern  Waste Exchange (Florida).  NIWE  plans to include  listings  from  the
Great  Lakes Exchange, Canadian Waste Exchange, and Piedmont Waste Exchange.
This  computerized  system  makes   waste   exchange  information  immediately
accessible to a large population of users (see Appendix D for a sample run from  this
computer system).
            C.  Erie  County,  New  York  -  Industry-Specific,  Small-Quantity
                Hazardous Waste Generators Technical Assistance Program
    The County  of  Erie, New York,  has  a Federal grant  to  develop,  field  test,
evaluate,  and  publish   guidebooks  on  the  management  of  small  quantities  of
hazardous waste from specific  business categories.  This program will be conducted
over  a  two-year   period  (August  1985   to  August  1987)  by  the  Erie  County
Department of Environmental Planning.
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    These guidebooks  will provide information on the technologies available to each

industry for  reduction, recycling, reuse, or treatment  of hazardous waste.  They will
also  provide  information  on  State  and Federal  regulations that apply  to small

quantity  generators and  the  specific industries  included  in  the  program.  The

industries are:  vehicle  maintenance, metal  manufacturing,  printing,  photography,

laundry/dry  cleaning,  construction,  motor  freight terminals, and educational and

vocational   shops.   Two   more  industries   (pesticide   applicator   and   general

government) may also be included if additional funds are available.


    VII.     Award  Programs


    New York presently  has no award  program that directly promotes hazardous

waste minimization.


    VIII.    Publications and References
    Banning, W., and Hoefer, S.H.  1984.  An assessment of the effectiveness of the
    Northeast Industrial Waste Exchange in 1983.  NYSEFC.

    Battelle Corp.  1982. A preliminary handbook on  the potential for recycling or
    recovery of  industrial hazardous wastes in New York State.  EPA contract no.
    68-01-6002,  final report prepared for  New  York State Environmental Facilities
    Corporation, U.S. EPA Region II Technical Assistance Panels Program.

    Deyle,  R.E.   1985.  Source reduction by hazardous  waste generating firms in
    New  York  State.   Technology  and   Information  Policy  Program.   Syracuse:
    Syracuse University.

    GAO.  1984.  U.S. General Accounting Office.  State experiences with taxes on
    generators or disposers of hazardous  waste. Pub. no. GAO/RCED-84-146, May
    4, 1984.  Washington, D.C.:  U.S. General Accounting Office.

    NIWE.  1985. Northeast Industrial  Waste Exchange.  Listings catalogue. (Issued
    quarterly).

    NYS  EFC.   1983.   New York  State Environmental  Facilities  Corporation.
    Annual report 1983.  New York State Environmental Facilities Corporation.

    	.   1985a.  Fourth  annual report:   Industrial  Materials  Recycling  Act
    Program.
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	.  n.d.  A  guide  to  informational sources  related  to  the  safety  and
management of laboratory wastes from secondary schools.

	.  1984b. Hauler's directory. (Published annually).

	.  1985b. Industrial  materials recycling  program:  quarterly status reports
(Winter, Spring, Summer, and Fall).

	.  1984a. Third annual report: Industrial materials recycling act program.

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  APPENDIX J.8






NORTH CAROLINA

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J.8       North Carolina

     North Carolina has  been relatively active in efforts  to  minimize hazardous
waste and other forms of  pollution. The lead agency addressing waste minimization
is the  Pollution Prevention Pays  (PPP) Program within the  Department  of Natural
Resources and  Community Development (DNRCD).  The PPP staff, the  Governor's
Waste  Management  Board,  the  Solid and Hazardous Waste  Management Branch of
the Department of Human Resources (DHR), the Department of Commerce  (DOC),
and  the  Board  of  Science and Technology work closely together to promote waste
minimization, using  strategies  of  information  transfer, technical  assistance, and
grants,  as well as  a  waste  exchange  and an  award program.  The  State  further
encourages minimization  through  special provisions in  the  tax  code for  reduction,
recovery, and recycling facilities  and industrial revenue bonds that  are available to
finance pollution control facilities.

     I.       Legislative Background

     The North  Carolina  General  Assembly passed the  Waste Management  Act of
1981 establishing  the  Governor's  Waste Management Board,  which  had the duty to
plan and  oversee  the safe management of hazardous  and  low-level  radioactive
wastes  generated  within  the  State. Two of its responsibilities  were (1) to promote
research and development of  new  methods to prevent,  reduce, recycle,  treat, and
dispose  of wastes,  and (2) to evaluate  and recommend ways to aid  governmental
activities concerning waste  management. Under the legislative  charter,  the  Board
sponsored  an  award  program,  the  Governor's Award  for  Excellence  in  Waste
Management.  The program was to provide recognition to  individuals,  companies,
and  institutes   that  have  shown  outstanding  commitment,   innovation,  and/or
technological advances through source  reduction, recycling, treatment, or other
management  of hazardous or low-level radioactive wastes.

    The official interest of  the  State of North  Carolina in pollution  prevention
began in 1982 with a Statewide  symposium on the question  of adopting economical
means  of reducing pollution  as a  State policy.  This  conference was attended by
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business,  government,  and  academic  representatives, who urged  the adoption of
pollution prevention as the official State approach to  waste management.  The State
responded  with  Resolution  54  of  the  1983 Sessions  Laws  (Senate  Joint Resolution
653),  which empowered the State  Legislative Research  Commission  to  study  the
"desirability and  feasibility  of  creating a Pollution Prevention Pays (PPP)  Research
Center  in  North Carolina."  The  Legislative Research Commission  appointed  the
Hazardous Waste Study  Commission  of  1983 to  study  the prevention, reduction,
treatment, incineration, and recycling alternatives to landfilling disposal as well as
the idea of a research center.

    The Study Commission  adopted a  "hierarchy of alternatives" in hazardous waste
management  and specified  the desirable  characteristics  and objectives  for  an
all-encompassing  PPP   Program  instead  of  a  typical  "research  center."   The
alteration of manufacturing  operations and the onsite  recycling of  materials, both of
which  reduce  the  overall   generation  of  waste, were  recognized  as  the most
preferred waste management strategies.  To promote  waste minimization, the Study
Commission directed that  the proposed PPP Program be  nonregulatory, yet still
operate in conjunction with regulatory  and other agencies to meet its goals.  The
PPP Program  was to be involved in research, education, and technical assistance for
the benefit of both the general public  and  the  industrial community, particularly
those in the industrial  sector  whose size and resources do  not allow independent
implementation   of  pollution   prevention  methods.   The  Commission   finally
recommended  that a PPP Program  be established within  the  DNRCD to formally
address positive methods of  waste reduction.

    II.      Regulatory  Programs

    North Carolina's hazardous waste  regulations for the most  part follow those of
the U.S.  EPA.  There  are  no   special exemptions or modifications  for recycling
practices other than provisions  codified in  40 CFR 266 for recycling materials used
in  a manner constituting disposal, for  hazardous waste burned for energy recovery,
and for  recyclable materials utilized for precious  metal recovery.
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    The  State's land disposal restrictions  present some tighter requirements such as
additional location  standards for hazardous waste  management  facilities (10 North
Carolina Admin. Code 10F .0032(q)) and requirements for landfills.  For example, no
hazardous waste landfill can be  built  until at least  one "comprehensive hazardous
waste  treatment facility is  fully operational" (10  North  Carolina Admin. Code 10F
.0032(o)). As the need for establishing a hazardous waste  landfill within the State
becomes greater,  a  requirement such  as the last  may serve as an  incentive to
building  a  recycling  facility,  depending on  the  interpretation of "comprehensive
treatment facility." At this time, no legal  definition exists.

    III.     Fee and Tax Incentives

            A.  Assessments

    Large-quantity  hazardous  waste  generators,  transporters,  and  treatment,
storage,  and disposal facilities (TSDFs) are all assessed a flat fee according to the
following classification (10 North Carolina  Admin. Code IOC .0701-.0704):

    Generator                                         $600/year
    Transporter      •                                  $600/year
    Generator and  transporter                          $900/year
    TSDF                                            $l,200/year
    TSDF and generator and/or transporter            $l,200/year

No distinction is made based  on volume, toxicity, or type  of waste management.

            B.  Tax Credits

    North  Carolina law gives special tax treatment to individuals and  companies
that purchase resource  recovery, recycling, and  volume reduction equipment or that
construct facilities for  waste treatment, resource recovery, recycling, and  volume
reduction equipment. Specifically, the cost of equipment and facilities  may be
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 deducted  from  capital stock,  surplus,  and  individual profits  in computing  the
 corporate  franchise  tax;  the  cost is eligible for 60-month  amortization  and is
 deductible from corporate and  individual income taxes (North Carolina Gen. Stat.
 105-147).  Equipment and facilities for  waste treatment,  resource recovery,  and
 recycling are  also excluded from the property tax base (North Carolina Gen. Stat.
 105-275).

     Since  "resource recovery and recycling  equipment" and "resource recovery  and
 recycling  facility"  are not  defined   in the  statutes, the Department  of  Human
 Resources (DHR) is  charged with developing and promulgating  standards  that  the
 equipment  and  facilities  must  meet  in order  to  qualify  for  the  tax  benefits.
 Individuals and corporations must  obtain certification from the DHR that  indicates
 such  equipment  and  facilities are "exclusively used  in the actual waste recycling,
 reduction, or resource  recovery  process" and  not  just in "incidental or supportive"
 roles (North  Carolina Gen. Stat.  130A  - 294(aX3)).

     Despite the  fact  that  generators of  hazardous waste in North  Carolina  are
 purchasing and installing  equipment  and building  facilities  for  waste treatment,
 resource  recovery,  recycling, and volume  reduction,  few of these taxpayers  are
i
 taking advantage of the available benefits.  Thus  far, most  of the equipment  that
 has  been  certified  is  used  for nonhazardous solid  waste  (Dunn  1985).   There is
 speculation that the program has not been widely used because it is not well  known
 (personal communication with Gary Hunt, PPP Program, DNRCD, December 1985).

     IV.      Loan and Bond Assistance

     North  Carolina  law  authorizes  the issuance of industrial revenue   bonds  to
 finance  a  pollution  control  facility,  which  includes reduction, recovery,   and
 recycling  facilities,  if the  project  meets  the  approval  of  the  Secretary  of  the
 Department  of Commerce and  the DHR.  Such a  determination would depend  on
 whether the facility would further the State's waste management goals and  not have
 adverse  effects  upon public health, the  environment, or  the economy (Bulanowski
 1981, in  reference to North Carolina Gen. Stat. 159C-7).
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    V.      Grant Programs


    See  discussion  on  Challenge  Grants and  Research  and Education  Grants  in

Section V/I.A, Pollution Prevention Pays Program.


    VI.     Information Programs


            A.  Pollution Prevention Pays Program


    The  PPP Program  encompasses a  number of strategies  for waste minimization

comprising  (1) information  transfer, (2) onsite  technical  assistance, (3) challenge

grants,  and  (A) research  and education grants,  each being effectively coordinated

with the  other.


    These strategies are discussed  below:


    (1)   Information Transfer

          The PPP Program provides  information transfer through its Information
          Clearinghouse  and  its  outreach  programs.  In  the  Clearinghouse,  an
          information   data base  provides  quick   access  to  literature  sources,
          contacts,  and  case  studies  on waste  reduction techniques for specific
          industries or  waste streams.  Over 1,200  references on waste  reduction
          methods  have  been   identified  and  organized  by industrial  category.
          Information is also made available  through customized  computer searches
          of literature data bases.  This  provides  access to current national and
          international  literature on pollution prevention  techniques specific  to the
          problem area.

          The  Information   Clearinghouse  also  has  access  to  universities,  trade
          associations,  industries,  research laboratories, and government  agencies,
          which   can   provide  additional   technical,  economic,   or   regulatory
          information.   This network  includes  contacts  at  State,  Federal, and
          international  technical assistance and  research  organizations.  Reports  on
          waste  reduction   published   by  PPP  staff  are  available through the
          Clearinghouse.  These include:

          •  Pollution   Prevention  Bibliography,  which  references   literature
             organized by industrial category;

          •  Accomplishments  of  North Carolina Industries,  which provides  case
             summaries  of  the  technical  and  economic  aspects of   pollution
             reduction  efforts undertaken by  the State's industries;


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      •  Directory of North  Carolina Resource Recovery Firms,  which lists
         companies that purchase waste materials for reuse; and

      •  A  Handbook of  Environmental  Auditing,  which details  successful
         auditing programs used by the State's industries.

      Also available through the Clearinghouse are:

      •  Series  of "Pollution  Prevention Tips," which  provide  technical  and
         economic assessments  of  pollution  prevention methods  for  specific
         industries such as textiles, electroplating, and  furniture manufacturing;

      •  Handbooks developed  in conjunction  with PPP's workshops - Managing
         and Recycling Solvents, Managing  and  Minimizing  Hazardous  Waste
         Metal  Sludges,  Managing  and  Recycling   Solvents  in  the Furniture
         Industry,

      •  "Challenge Grants Information";  and

      •  "Information on Research Funds and Projects."

      During 1985, the PPP staff  responded to an average of 75 phone calls and
      letter  reguests  each month for  general information and literature. Staff
      also prepared detailed  information  packages for  over  25 industries  and
      communities. These information packages included copies of  references,
      case studies, contacts, and computer literature searches.

      As far as the outreach effort, in  1985 PPP staff conducted or cosponsored
      over  30  presentations on  pollution  prevention   for  trade  associations,
      professional  organizations,  citizen groups,  universities,  and  industrial
      workshops.  They have also sponsored several "Workshops on Implementing
      State Pollution  Prevention  Programs," attended  by  representatives  from
      numerous States, USEPA, and Ontario, Canada.

(2)    Onsite Technical Assistance

      Comprehensive  technical  assistance is provided directly  through a  visit to
      a facility.  During  an onsite  visit, detailed process  and waste  stream
      information  is  collected  and  plant personnel  are consulted  on current
      management practices.  Information is  analyzed  and a series of  waste
      reduction  options  for each waste  stream  is identified.  A short report
      outlining the management options is prepared for  the  facility.  The report
      package  includes   all  supporting  documentation  such  as   literature,
      contacts, case studies, and  vendor information, as well  as a preliminary
      assessment of reduction potential and economics.

      In  1985  the  PPP staff provided  onsite  technical  assistance to five  firms.
      Onsite  visits addressed  such waste  streams  as cooling  oils,  metal-
      contaminated wastewater, oily wastewater, acids/bases,  metallic sludges,
      and solvents.
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(3)    Challenge Grants

      The Challenge Grants Project provides matching grant monies in amounts
      up to $5,000 for projects that evaluate the feasibility of applying methods
      or  technologies to prevent  pollution or decrease waste generation.  It is
      aimed at small businesses and manufacturing firms, trade  associations,
      and  communities  to  develop   and  implement   waste  minimization
      techniques  for specific  waste streams and/or facilities.  Projects range
      from the characterization of waste  streams,  in order to  identify waste
      minimization techniques,  to in-plant pilot  scale  studies of  reduction.
      Funds are available  for the cost  of personnel, materials, or consultants
      needed to undertake a pollution prevention project.  Ideally,  the lifespan
      of a project is six months.

      Grant proposals  are  reviewed  on  the  basis of  several criteria  (PPP
      Program  1985b):

      •   Commitment  and   ability   of  applicant   to   implement  pollution
         prevention recommendations;

      •   Severity  of pollution/waste problems  or uniqueness of opportunity to
         prevent or reduce waste;

      •   Specificity of approach to reduction  of  waste  volumes  or toxicity
         through process modification, waste  stream  segregation,  equipment
         redesign, recovery for reuse, etc.;

      •   Potential  of  implemented  recommendations   to   be  economically
         beneficial to the applicant through payback  or cost savings;

      •   Potential  of  transfer  to other similar  waste streams, businesses, or
         communities;

      •   Measurable results and proposed project costs; and

      •   Consultant qualifications.

      During the first round  in the Spring of  1985, 16  projects were  funded,
      representing  over $190,000 in pollution  prevention  and  waste  reduction
      efforts.  These projects  addressed wastes from such areas as textiles,  food
      processing, hospital laboratories,  paper manufacturing, solid waste, waste
      oil,   and   drinking  water   treatment.   Waste  streams  and   industries
      addressed by projects during 1986 include electroplating, waste solvents,
      laboratory  waste,  meat   packing,   seafood   processing,  textiles,   and
      municipal solid  waste.  These projects will receive $100,000 in matching
      funds, doubling 1985's initial allotment of  $50,000.

(4)    Research and Education  Grants

      Research and education projects  are funded through the  North Carolina
      Board of  Science of  Technology  with  staff assistance from the  PPP

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Program.  Grants in amounts up to $30,000 per project  per  year are made available
to sponsoring universities and institutions for  research and education addressing the
following objectives (North Carolina DNRCD [1985]):

          •   Target waste streams and industries specific to North Carolina;

          •   Document  economic  and  technical  feasibility  of  waste  reduction
             techniques;

          •   Reduce  the  volumes  of the  State's  major  hazardous,  toxic,  and
             water/air waste streams; and

          •   Develop innovative approaches to environmental management.

          Research projects range from  in-plant demonstration projects  to applied
          research  on  new  technologies.  Some  of  the recent  projects include
          application  of pollution prevention techniques to  such industries as wood
          preserving,  chemicals,  electroplating,  textiles,  food  processing,  and
          microelectronics.

          Educational  projects  include onsite demonstrations  and  workshops  on
          waste minimization designed for businesses,  communities,  and citizens.
          Currently, two  projects are being developed for university students:  (1) a
          pollution  prevention  curriculum  for use  in  engineering  and  industrial
          technology  programs,   and (2) an  engineering  intern  project  to  place
          engineering students  with industries to develop waste reduction programs
          for individual  firms.
    A director's  position was first filled in  October  1983  to develop the program

and recommend a work plan.  In  January 1984, a business specialist  was assigned to

provide  part-time  staff  support.   Acting  on   the  Hazardous   Waste   Study
Commission's  recommendation, the 1984 Summer  Session of the General Assembly
approved a budget and  staffing  for the PPP Program, as well as  funding for research

and education. In January  1985, an environmental engineer and  a  secretary  were
added.  An  additional  engineering  position  has  recently  been approved  by  the

DNRCD.


    The  1985  full session of  the  General  Assembly  authorized annual  budgets of

$190,000 for the  PPP  Program and $300,000  for research  and  education for  fiscal

year 1986 - 1987. Research funds are appropriated to the North Carolina Board of

Science and Technology, with  staffing provided  by the  PPP Program.  Additional

funding of $100,000 annually through  1987 is made through the U.S. Environmental

Protection Agency to support research  for small business waste reduction.
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    The  initial  obstacle  encountered  in  implementing  the  PPP  Program  was
attaining the visibility and recognition necessary for the  promotion of the program's
goals  and intentions. The designation of the DNRCD as the lead agency in pollution
prevention provided a central  point of contact  and a  network  of  regional  DNRCD
offices  throughout the State.   Concurrently,  a publicity and information campaign
entailing the distribution  of PPP literature to trade associations and the insertion of
articles  in  trade  association  newsletters  also  helped  achieve  recognition.  In
addition,  the program  began  to  document  successful  industry-specific  pollution
prevention cases and to develop a bibliography and library of source material.

    Another early problem was  suspicion  by industry  of  technical assistance from
what  was  perceived as  a "regulatory  agency."   North  Carolina's  PPP  Program
attributes  its  success  in addressing  industry  reluctance  to  (1) developing its  own
identity through a  series of reports and publications,  (2) focusing on helping those
industries  that  want  assistance, and (3) continually stressing  that the  Program  is
nonregulatory in nature.

    In its first  two years  of operation,  the  PPP Program  has concentrated  its
efforts  on information and technology  transfer,  technical assistance development,
and research funding.  In the  coming  year, the  program will place emphasis on
expanding   contacts  through   technical  assistance and  onsite  consultation.   A
continuation of  research and education projects and Challenge Grant projects will be
pursued.  An evaluation of these projects will be undertaken to determine if  they are
meeting objectives and if they  can be improved.

    Successful technical  assistance, onsite visits,  and Challenge Grant projects will
be  compiled  into  case  studies and distributed  to respective  industries and trade
associations.  An engineering intern program similar to that of Minnesota's is being
developed.   Additionally,  the  program  will continue to provide staff support to a
"national  roundtable" forum of State waste reduction   programs  and will  seek to
organize the group more formally.
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            B.  Piedmont Waste Exchange

     The  Piedmont  Waste  Exchange  (PWE)  is  an  active  information  exchange
sponsored by  the  Urban Institute and the Department  of Civil Engineering at the
University of North Carolina at Charlotte.   Funding  is provided  by  the  Urban
Institute, the  Governor's  Waste  Management  Board,  Mecklenburg  County,  and
various industry and environmental groups and  trade associations.

     PWD distributes the Waste Watcher, a quarterly  bulletin listing companies that
want to  transfer both  hazardous  and  nonhazardous wastes.  The fee for an unlimited
number of listings  is $40 per year. Approximately 25  percent of the listings receive
matches. This waste  exchange works with other exchanges, such  as  the  Northeast
Industrial Waste Exchange, to increase  the potential  for successful waste transfers
(PWE [1984]).

     In  addition   to  arranging  waste  transfers,  PWE  prepares   and  distributes
educational  literature; makes presentations at industrial meetings, workshops,  and
conferences;  sponsors  technical assistance  workshops  for individual firms;  and
conducts surveys and studies on hazardous waste topics. Projects conducted by  PWE
include:  a survey  of small-quantity hazardous waste generators in  Mecklenburg and
Gaston  Counties;  a  study of  legal,  institutional, and policy  incentives for waste
prevention,  exchange,  and reuse; and a survey to identify potential waste transfer
pairs.

     VII.     Award Programs

     North Carolina  has operated an award  program  for almost four  years  for  the
purpose  of honoring individuals,  companies, and institutions within the  State  that
have demonstrated superior waste management practices for hazardous or low-level
radioactive wastes.  Each year in the fall, the Governor's Waste Management Board
distributes entry  forms  and  information letters  on the  Governor's  Award  for
Excellence  in Waste  Management  to generators, public  organizations,  and  local
governments throughout North Carolina.  By  December, the  entry forms  and an
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accompanying summary of the waste management projects are  screened  and  sent to
a five-member  judging  panel, representing  industry, environmental organizations,
and the scientific community. The entries are judged in the following categories:

       Commitment by management;
       Creativity;
       Environmental and economic benefits;
       Technological achievement;
       Superior management and engineering; and
       Leadership in  communicating technology to others.

    Early in the  new year,  the Governor presents the award winners in  each waste
category with a  plaque  and certificate.  Annual program costs, including printing,
postage,   plaques,  and  publicity,  are   approximately  $3,500   (based  on  1983
expenditures).

    The  award program  usually receives 15 to 20 entries each year, although in 1984
only 9 were  submitted. The  reduced number of participants was ascribed  to  the lack
of media publicity given in  the last year and  an expanded  entry form, which required
additional effort to  complete. Because of these comments, the  Board  has decided to
increase  the publicity  by providing more notice to the  news media. In addition, the
application process  has been simplified and the award expanded  to further encourage
participation, especially by  waste management  firms and small quantity generators
(personal  communication with  Edgar  Miller,  North  Carolina  Governor's  Waste
Management Board  on  November 20, 1985).

    Recipients of the Governor's  Award for Excellence in Waste Management have
thus for  included:    1982  -  Burlington  Industries  (Furniture  Division);   1983  -
Stanadyne,  Inc.  (Moen Division, Sanford Plant) and Duke Power Company (McGuire
Nuclear  Station); and International Business Machines  Corp.  (Research  Triangle
Park).  These recipients  and the honorable mentions (the number varies from year to
year) are listed along  with their accomplishments in a  booklet that is made available
to the general public (Governor's Waste Management Board 1982, 1983, 1984).
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VIII.        Publications and References
Dunn,  H.G.  [1985].  Special tax  treatment  of equipment and  facilities for
recycling, recovering, and preventing generation of solid and  hazardous waste.
Article  prepared for  the  N.C. Hazardous  Waste Report by Poyner, Geraghty,
Hartsfield, and Townsend, Attorneys at Law, Raleigh, N.C.

Governor's Waste Management  Board.  1982,  1983,  1984.  Achievements in
waste management.  Raleigh, N.C.

Hunt,  G.,  and  Schecter,  R.  1985a.  Accomplishments  of  North  Carolina
industries.  Raleigh:  N.C. Department of Natural Resources  and Community
Development.

	.  1985b.  Pollution prevention bibliography. Raleigh:   N.C. Department of
Natural Resources and Community Development.
Kohl, J.  1984a.  Managing  and minimizing  hazardous  waste  metal  sludges.
Raleigh: Industrial Extension Service, North Carolina State University.

	.  1984b.  Managing  and recycling solvents. Raleigh:  Industrial Extension
Service, North Carolina State University.

Kohl, J., Pearson,  J., and  Wright, P.  1985.  Managing and recycling solvents in
the  furniture  industry.  Draft report.  Raleigh: Industrial Extension  Service,
North Carolina State University.

McRae, G., Tooly, R., and Perry, D.  1985.  Hazardous waste in North Carolina:
a comprehensive analysis of  waste requiring offsite treatment and/or disposal.
Raleigh: N.C. Governor's Waste Management Board.

PPP Program.   1985a.  Directory  of  North Carolina  resource  recovery firms.
Raleigh: N.C. Department of Natural Resources and Community Development.

	.   1985b.   Grants  for  research and  education  in  pollution prevention.
Raleigh: N.C. Department of Natural Resources and Community Development.

	.   1985c.   Handbook  of environmental auditing  in  North  Carolina.
Raleigh: N.C. Department of Natural Resources and Community Development.
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	.  1985d.  Information on research  funds  and projects.  Raleigh:  N.C.
Department of Natural Resources and Community Development.

	.   1985e.  Pollution  prevention  tips:  furniture  manufacturing.  Raleigh:
N.C. Department of Natural Resources and Community Development.

	.  1985f.  Pollution prevention tips:  local  waste managers' associations.
Raleigh: N.C. Department of Natural Resources and Community Development.

	.   1985g.  Pollution  prevention  tips:  metal  finishing.  Raleigh:  N.C.
Department of Natural Resources and Community Development.

	.    1985h.   Pollution prevention  tips:  textile mills.   Raleigh:   N.C.
Department of Natural Resources and Community Development.

PWE.   1984.   Annual  report:  1983  -  1984.  Charlotte:   Urban   Institute,
University of North Carolina.

PWE.  1985.  Waste  Watcher.  Charlotte:  Urban Institute  and Department of
Civil  Engineering, University of North Carolina.  (Issued quarterly).
                                 J8-13

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 APPENDIX J.9






PENNSYLVANIA

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J.9       Pennsylvania

    The  Commonwealth of Pennsylvania has combined two strategies in its effort to
encourage  waste  minimization.   A licensing  exemption  is  in  effect  to  promote
recycling and  a  technical assistance program disseminates information  to facilitate
minimization.

    I.       Legislative Background

    In Pennsylvania,  the control of hazardous waste  is usually  provided  for  within
legislation covering solid waste.  In 1980, the Pennsylvania Solid Waste Management
Act established  requirements for  accurate recordkeeping, labeling, and manifesting
of hazardous waste.  In addition,  chemical users were required  to keep information
on chemical constituents and properties  and to report on hazardous waste activities
and emergency  contingency  plans.  The  Act also set down facilities  permitting,
siting  and  financial  requirements,  and  prescribed  penalties  and   fines   for
noncompliance.

    II.      Regulatory Programs

            A.  Hazardous Waste Regulations

    Hazardous  waste regulations  in  Pennsylvania appear  under  the Pennsylvania
Code,  Title 23,  Environmental  Resources, Chapter  75,  Solid  Waste Management,
Subchapter  D, Hazardous  Waste.  The  solid waste  regulations, which  contain  the
hazardous waste regulations, were  first adopted in  1971, but have been  amended
through  March  8,  1985.   The hazardous  waste regulations set standards  for  the
identification, listing, transportation, treatment,  storage, and disposal  of wastes.

            B.  Licensing  Exemption

    Under  Subsection  75.261  of   the   State's  hazardous   waste  regulations,
generators/transporters who use, reuse,  recycle, or reclaim  hazardous waste are  not
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subject to the State's transportation license requirement.  The  exemption does not
apply, however,  to  wastes having  commercial  value  and  a  history  of routine
commercial trade.   Also, recycling, reuse,  or reclamation facilities are  required to
submit a pre-operation plan describing  any proposed chemical  mixes to the State
Bureau  of  Air Quality  to  ensure  that  air  quality  standards  are met (Pennsylvania
Codes Title 25, Chapt. 75D).

    III.     Fee and Tax Incentives

    Pennsylvania offers no fee  or tax  incentives to promote minimization  at  this
time.

    IV.     Loan and Bond Assistance

    Loan and bond assistance has yet to be incorporated into Pennsylvania's efforts
to minimize waste.

    V.      Grant Programs

    Pennsylvania presently does not award grant  monies to generators  and  other
organizations as an  incentive for waste minimization efforts.

    VI.     Information  Programs

            A.  Pennsylvania Technical Assistance Program

    The  Pennsylvania Technical  Assistance  Program  (PENNTAP) is a  technology
transfer  and dissemination  service operated  by  the  Pennsylvania State  University
and the Pennsylvania Department of Commerce  under  a Commonwealth-University
partnership  agreement established in  1965.  The program employs five full-time
technical specialists with backgrounds in engineering and science. These specialists
are supported by two technical  librarians who maintain  PENNTAP's in-house  data
base.   The  program  is headed  by a director,  who  is  assisted  by  an  information
coordinator,  an office  manager,  and two  other office staff  members.  Program
                                     J9-2

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funding sources include  Penn State University's  Division of Continuing  Education,
the State legislature through the State Department of Commerce,  and  other  State
and Federal agencies for special  projects.  Advisory  services are provided  free  of
charge.

    The  bulk   of  program   advisory   activity   is   in   microcomputers   and
computerization  (143  cases in  1984), although  environmental  problems —  those
dealing with  handling, disposal,  and/or identification of hazardous wastes, with solid
waste  materials, and with other environmental concerns  — comprise a  significant
portion (62  cases  in  1984).  Other  major areas addressed by  PENNTAP  include
chemical  technologies,  energy  technologies,  safety/health  (including fire  safety),
productivity improvements, and  construction and maintenance.

    According to program literature, PENNTAP required  $4.43 million  to  operate
between 1972  and  1984.  In  that same  period,  19,343 problems  were  addressed,
resulting  in  $79.9  million in  benefits  to  the State's economy.  Since  1980, the
program has  been credited with  saving or creating more than  580 jobs. Program
impact figures for  1984 alone indicate that 1,242 cases were handled, 59.8  percent
of which  came  from  business/industry,  entrepreneurs, and consultants/engineers.
The economic impact was just under $10.8 million, not including the valuation  of  57
jobs  created  or  saved.   All reports  of  economic  and  job  benefits are made   by
recipients  of  program   services  on   a  post-assistance  evaluation  form; a 17.8:1
benefit-to-cost ratio has been  documented (personal  communication with  William
Arble, PENNTAP, January 31, 1986).

    VII.    Award  Programs

    The  Commonwealth currently  does not  use public  recognition  or honors  as
incentive  to promote minimization.

    VIII.    Publications and References

    Pennsylvania  Technical Assistance  Program (PENNTAP).   1985.   PENNTAP
    UPDATE 1984.  Prepared for  the Pennsylvania State University.
    (PENNTAP also provides informative pamphlets.)
                                      J9-3

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APPENDIX J.10
 TENNESSEE

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J. 10      Tennessee

    The  State of  Tennessee has recognized  the  potential  benefits of  hazardous
waste  minimization  and  has  addressed  the  topic   through   special  regulatory
requirements for  recycled  hazardous waste, fee incentives, loan and bond assistance,
and a hazardous  waste minimization  program  that  is  currently  doing  studies  on
waste reduction techniques for small businesses.

    I.       Legislative Background

    Tennessee's policies concerning hazardous  waste  minimization have their legal
basis in the Hazardous Waste Management  Act.  Part I (68-46-101  through 1 14) was
drafted  in 1975 and Part II (68-46-201  through  221) in 1983.  Of the two parts, the
latter is  focused more on resource recovery.  Modifications to Part II are currently
in  the process  of being adopted by the  Tennessee legislature.  Among these changes
are provisions to:  (1) promote efficient and  economical  management to  encourage
recycling,  (2) prohibit  land  disposal  of  certain   substances,   and   (3) subject
privately-owned wastewater treatment  and pretreatment plants to permits-by-rule.
                                                                       »
    The   Hazardous  Waste  Management  Act  is  implemented  by  the   Tennessee
Department  of  Health and Environment (DHE).   The  Division  of  Solid  Waste
Management administers Part I, while the Division of Solid Waste  Management and
the Division  of Superfund  share responsibility  for Part II.  The  Safe Growth Team,
which  was  previously  under  the Office  of  the  Governor,   is   now  under  the
Commissioner  of  DHE (personal  communication with Bobby Morrison,  Tennessee
DHE, January  30, 1986). Among its objectives, waste reduction and recycling  has
been adopted as  a high priority goal.  Initial  plans include the establishment of a
technical assistance program.

    II.      Regulatory Programs

    Tennessee has special  requirements for hazardous waste  that is used, reused,
recycled, or  reclaimed. The requirements allow the  generator  or other handler to
petition  to  the Commission  of  the  Tennessee Department  of Public  Health  to
                                     J10-

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exclude such wastes from  many of the requirements applicable for other hazardous
wastes as stated in Tennessee Rules 1200-1-11-.03 through 1200-1-11-.07.

     III.     Fee and Tax Incentives

     The State of Tennessee  charges  fees for the  State's remedial action fund and
for permit applications and permit maintenance.  The latter  are  intended to cover
the cost of  administering the hazardous waste regulatory program.  Both application
and maintenance  fees vary according  to  whether the application or permit holder  is
a transporter,  a  storage  facility, a treatment facility, or a  disposal facility.  For
storage and treatment  facilities, the  fees also vary according to design capacity,
with larger  facilities paying  higher fees. Disposal  facilities are assessed  a base fee
plus an  additional fee on  the  remaining design capacity  of their  landfill,  land
application, and injection well operations (Tennessee Rule 1200-1-1 1-.08).

     Under the Hazardous Waste Management Act of 1983,  fees for the  State's
remedial action fund are charged on the generation  and  transportation of  hazardous
waste.  The "generation fee," based on a size classification of generators, has  been
structured by  administrators  to encourage  recycling,  and  to  discourage  land
disposal.  No  fees are imposed  on generators who recycle  their wastes (for the
portion  recycled)  or have  their wastes recycled.  For  generators  in  fiscal  year
1983-1984,  the maximum  fee was $7,500 and the  minimum fee $300.  The "offsite
shipment  fee," an additional  fee, is collected  from generators who  ship  hazardous
waste offsite for treatment or disposal. In fiscal year 1983-1984, this fee was $7.00
per ton.  The Act allows annual adjustments to be  made in both fee structures to
reflect  any changes  in  the  revenue  needs  of the remedial  action  effort.  State
appropriations  to  the  fund  match revenue collections  dollar-for-dollar (Tennessee
Code Sec. 68-46-203, Rule 1200-1-13-.02).

     Generators who recover hazardous  waste  for recycling may receive exemption
from generator fees administered under the State's Superfund program.  Exclusions
are granted on approval of the generator's application to the Division of Solid Waste
Management (Tennessee Code Sec. 68-46-203(b)(2XO).
                                     J10-2

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    IV.     Loan and Bond Assistance

    Tennessee  has  a  program that provides  loans, in the form of revenue bonds, to
cities and  counties for resource  recovery  facilities.  The  current  capacity of the
State to issue  money as  needed  is $100 million.  Cities or counties must have the
capability to pay off the bonds, which are good for the life of the facility or up  to 20
years (personal communication  with Bobby  Morrison, Tennessee DHE, January 30,
1986).

    V.      Grant Programs

    Tennessee  presently  does not  award  grant  monies to  generators  and  other
organizations as an  incentive for waste minimization efforts.

    VI.     Information Programs

    The State  of  Tennessee  received an EPA add-on  grant  in Fall 1984 to aid in
promoting waste reduction activity.  The State, through its Department  of Economic
and  Community  Development, is  currently  using  the grant  to  fund  studies of
applicable  waste reduction  techniques in small businesses.  The  aim of  the program
is  to  select representative  facilities  within specific  industrial  categories  (e.g.,
furniture fabricators) and to conduct waste  audits to  identify cost-effective waste
reduction measures.  The results  will appear  in  the  form  of feasibility studies for
individual facilities,  generalized  studies for each industry  category, and  regional
studies.  A  consulting firm has been hired to perform the work.

    The consultant is also required to hold  waste  minimization technical workshops
in  the  regions of the  State  where generators are selected.  This is to  broaden the
dissemination of the information collected within the 15-month grant period.

    The add-on grant  was made  in the amount  of $90,000  and was matched with
$10,000 from the State of Tennessee. Depending on the success of the effort and
the prospects for future funding,  the State  may gradually phase in a waste reduction
program by allocating permanent  funding  and  staff,  or  by contracting  with  a
consultant.  To showcase  the  pilot program's successes, the Governor's  Safe  Growth
Team is planning a waste minimization conference to be  held March  4-6, 1986.
                                     JiO-3

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    VII.     Award Programs


    Tennessee currently  has no award program that provides recognition  and  honor

to individuals or organizations that have demonstrated outstanding achievement in

hazardous waste  management.


    VIII.    Publications  and References
    EMPE, Inc.   1985.  Tennessee hazardous waste minimization program.  Outline
    of program  prepared  for Existing  Industry Services,  Department  of  Economic
    and  Community Development,  State  of  Tennessee,  presented  at  Workshop  on
    Implementing   State   Pollution  Prevention   Programs,  31   October   1985,
    Washington, D.C.
                                    J10-4

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APPENDIX J.ll






WASHINGTON

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J.I 1       Washington

    Washington State  is active  in promoting  hazardous  waste minimization through
regulatory programs, annual fee assessments  on  generators  and facilities, and  its
Priority  Waste  Management  Study,  which attempts to determine  the  best  waste
management practices for different waste  categories and strategies to achieve such
management.

    I.       Legislative Background

    The State of Washington initiated  a  number of efforts to regulate hazardous
waste prior to the enactment of RCRA by the Federal  Government.  In 1976, the
State enacted the Hazardous Waste  Disposal  Act,  which charged  the  Washington
Department of Ecology (DOE) with the  responsibility for regulating  the  production,
transportation,  and  disposal  of extremely  hazardous  waste.  Federal  and State
regulations  were incorporated into  one set of "Dangerous  Waste Regulations"  in
1982.  They  were amended in  1984  to include  the regulation  of  polychlorinated
biphenyls under 50 ppm.

    In   1983,  legislation   was  passed  specifying  preferred   hazardous   waste
management practices.  Substitute Senate Bill 4245  established a set of priorities
for managing hazardous waste. These priorities, in order of importance, were:

     1.   Waste reduction;
    2.   Waste recycling;
    3.   Physical, chemical, and biological treatment;
    4.   Incineration;
    5.   Solidification/stabilization; and
    6.   Landfilling.

    The  bill  also directed DOE  to complete a  study  of  the  best management
practices for each category of waste by  July 1,  1986,  and to prepare new rules  to
promote priority waste management  practices.  DOE was  also authorized to offer
consulting and technical assistance services in this endeavor.

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     Substitute House Bill  1438 directed DOE to  determine by  July  1,  1986,  the
waste categories  that  are  most  suitable for landfilling.  Until that time, all land
disposal of  hazardous waste at commercial offsite facilities is prohibited, as is  the
construction of new landfill facilities.

     The Hazardous Waste  Control and  Elimination  Account Act is the legislation
that set aside funds for hazardous waste  activities. The account is to be used  (1) to
implement  the  hazardous waste  and substances regulation  control program,  (2) to
encourage  waste recycling  and reduction, (3) to  clean up sites,  and (4) to provide
CERCLA matching funds.  The account is supported by fees charged to generators
and facilities.

     II.      Regulatory Programs

     Washington's land disposal  bans  on  certain substances and legislative directives
for facility  siting  both indirectly  promote recycling and source reduction. The land
disposal of  all hazardous waste was  banned under  Substitute House Bill 1438 until
July 1,  1986, or until  a  study of  landfill suitability is  completed for each waste or
waste category.  To implement this  legislation,  a two-phase study (Phase A  and
Phase B) was  designed by DOE. Phase  A studies those wastes most likely to require
landfill disposal (inorganics).  Phase B studies organic wastes.  Phase A  of  the  study
has been completed and the landfill restrictions on inorganic wastes have been lifted.

     To  expedite  the siting of  hazardous waste facilities, both houses  of  the  State
legislature   have passed  bills that allow the State  to preempt  local   government
authority in determining feasible  locations for incineration  and  disposal facilities.
These bills  also require county governments to  develop waste  management  plans
that  include potential  sites  for  treatment,  storage, and  recycling facilities.  The
State's  responsibilities under  the  provisions of  these bills are for  incineration and
disposal  facilities,  whereas  responsibility  for  treatment,  storage, and  recycling
facilities is  left to the local government.
                                      Jll-2

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    III.     Fee and Tax Incentives

    The  Hazardous Waste  Control  and  Elimination Account  Act established  a
system of annual fee assessments on hazardous waste  generators and facilities.  The
amount of the  generator's fee depends on:  (1) risk classification, which is assigned
according to the  type  of waste produced and  the  amount  produced per year,  and
(2) the gross income of  the waste generator.  As an  example of the generator  risk
classification, a generator producing  between  0.1  tons and 0.2  tons of  extremely
hazardous waste per year or between 2.0  and 3.5 tons of dangerous waste per year
would be designated G3.  The amount of the hazardous waste facility fee depends on
the facility risk classification  alone, which is  determined according to the type of
waste disposed, the amount disposed, and the method of disposal.  A facility treating
between  3  and  26  tons of extremely hazardous waste per year or between 30 and 260
tons of dangerous waste per year would fall under facility risk classification F5, for
example.

    The  schedule  of  fees for  generators and facilities  is as follows  (Washington
Admin. Code 173-305-030,-060,-070):

                             Schedule of generator fees
                              Generator gross income (M equals millions)
    Risk class
       Gl
       G2
       G3
       G4
       G5
       G6
       G7
       Risk class
           Fl
           F2
           F3
           F/i
           F5
           F6
           F7
Less than
$ 15
40
65
90
115
140
150









$1 M $1 M - $10 M
$100
300
500
600
675
725
750
Schedule of facility fees
Amount per annum
$ 750
1,500
4,000
5,000
6,500
7,250
",500
Greater than $10 M
$1,000
3,000
5,000
6,000
6,750
7,250
7,500









                                     Jll-3

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     IV.     Loan and Bond Assistance

     Washington currently  offers no credit assistance in the form  of loans or bonds
for waste minimization efforts.  The Priority Waste Management Study, however, is
considering such a strategy (Moellendorf 1985).

     V.      Grant Programs

     Washington presently  does not  award grant  monies to  generators  and other
organizations as an incentive for waste  minimization  efforts, although this approach
may be  considered  for  future programs, especially  for research  and  development
(Moellendorf  1985).

     VI.     Information Programs

            A.  Priority Waste Management Study

     Under Senate Bill 4245,  DOE  is directed to  conduct  a study to determine  the
best management practices for each  waste category  and  make recommendations on
implementation of  waste  management priorities.  These  efforts  are  currently
underway.  DOE is  working with a subcommittee composed of representatives from
major  industry, local government,  and public  interest groups to develop a  list of
recommendations.  Tentative suggestions include technical  and  public  information
programs, a waste  exchange, financial disincentives to landfilling,  and  additional
restrictions  on certain hazardous  wastes  going to  landfill facilities  (Moellendorf
1985).

     VII.     Award  Programs

     Washington State currently has the Environmental Excellence  Award  Program.
Washington DOE  proposes  to expand  the program and to  liberally  give awards as a
positive  way of  recognizing  achievements in  managing  hazardous  waste  by  the
higher  priority methods (Moellendorf 1985).
                                     Jll-4

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VIII.         Publications and References
Moellendorf, G.V.  1985.  Progress report:  priority waste  management study for
Washington  state  hazardous  waste.   Olympia:   Washington  Department  of
Ecology.

Washington  DOE.   1983.  1982 Annual  dangerous  waste  report.  Office  of
Hazardous Substances and Air Quality Programs.

        1984.  Hazardous waste:   1983  annual report.   Office  of Hazardous
Substances and Air Quality Programs.
                                Jll-5

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                  APPENDIX K

TWO PROPOSED REGULATIONS ON HAZARDOUS WASTE
         MANAGEMENT BY TWO COUNTIES
                IN CALIFORNIA

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K.I Sacramento County

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r
  EXHIBIT n (continued)
                  a)   Uses permitted outright
                      Assembly of small  electronic equipment
                      Computer programming/software and  system design
                      Data processing service
                      laboratory, medical,  dental, or optical
                      Office,  administrative, of bank, saviir-s and loan,
                        finance,  loan, credit
                      Office,  business or professional
                  b)   Uses permitted subject to issuance of a  use permit
                      by the Project Planning Concussion:

                      Laboratory, materials testing
                      Laboratory, research  and analysis, including but
                      not ^""ted tos
                        Biochemical
                        Chemical
                        Genetics
                        Environmental and natural  resources
                        Film and  photography
                        Electronics
                        Fiber  optics
                        Instrumentation
                        Laser  Optics
                        Medical,  dental, surgical
                        Metallurgy
                        Pharmaceutical
                        Robotics
                        Solar
                        Sanies and Sound Imaging
                        X-Ray
                      Educational, training facilities related to other
                      permitted uses.

             19.   Comply with  all Federal,  State,  and County Hazardous
                  Materials Regulations.

             20.   Handlers of  hazardous  materials  shall prepare a
                  hazardous materials management plan (IftMP) ,  to be
                  submitted to the Planning Director, including the
                  following standards and elements:

                  a)   All storage tanks  for hazardous materials shall be
                      designed with leak detection systems  and secondary
                      containment.
                 b)  Underground storage of hazardous mafwjaip shall
                     be  limited to Class I flammable
                 c)  All air emissions including, but not limited to,
                     process emissions and tank venting, shall be
                     treated to remove or reduce hazardous air
                     contaminants.  Systems to remove or reduce
                     hazardous air emissions shall be reviewed and

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        EXHIBIT II (continued)
                            approved by the Sacramento County Air Pollution
                            Control Officer prior to any handling of hazardous
                            materials.. •

                        d)  Prior to any handling of hazardous materials,
                            handlers shall prepare a contingency plan for
                            spills, fires, or other incidents involving
                            hazardous materials accidents.  Such contingency
                            plans shall be prepared in cooperation with and
                            reviewed by Hie Citrus Heights Fire Department,
                            the Sacramento County Sheriff and the California
                            Highway Patrol.

                        e)  Wastewater shall be treated to minimize the
                            content of volatile organic solvents, heavy or
                            toxic metals, halides, and other hazardous
                            matgriaip, and to avoid extremes of pH in the
                            waste stream.  Treatment protocols shall be
                            reviewed and approved by the Regional Sanitation
                            District.
                                                                              '>
                        f)  Prior to any handling of hazardous materials,
                            users shall prepare a mass balance analysis
                            program  (MBAP), subject to review and approval of
                            the Planning Director in consultation with the
                            County Health Department.  The MBAP shall provide
                            a means of monitoring and accounting for all
                            hazardous materials at all times from arrival on
                            site through ultimate disposition, including
                            material storage, movement, processing or
                            fabrication, analysis, waste storage, treatment,
                            discharge, product storage and shipment off-site.
                            Adequate monitoring shall be provided to detect
                            any losses, which shall be immediately reported to
                            appropriate agencies.                            _j

                        g)  Hazardous wastes stored on-site shall be
                            inventoried and reported to the Citrus Heights     /
                            Fire Department at intervals not to exceed fifteen
                            days.
                    21.  A Native American person as r
                                      ended by the Native
     American Heritage Commission should be consulted for
     the cultural resources survey.

22.  Dedicate or grant to SMUD all necessary easements for
     needed electrical facilities to serve the development.

23.  The applicant should coordinate with SMUD staff to
     assure implementation of the following Conservation
     and Load Management Measures:
Iib0027ed

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K.2 Santa Cruz County

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                     ORDINANCE NO.
           ORDINANCE REPEALING CHAPTER 11.38, REPEALING
             CHAPTER 11.39., ADDING CHAPTER" II. 37 AND
           AMENDING SUBSECTION- Cc) OF SECTION 18.10.111
                   OF  THF SANTA CRUZ  COUNTY  CODE
                 RELATING TO  HAZARDOUS  MATERIALS

  The Board of Supervisors of the County of Santa Cruz do ordain
as follows:

                            SECTION  I

  Chapter 11.38 of the Santa Cruz County Code is hereby repealed.

                            SECTION II

  Chapter 11.39 of the Santa Cruz County Code is hereby repealed.

                            SECTION III

  Chapter 11.37 is added to the Santa Cruz County Code to read as
follows:

                        HAZARDOUS  MATERIALS

  Sections:

                              PART I
                        GENERAL PROVISIONS

  11.37.010  Findings and Intent
  11.37.020  Purpose
  11.37.030  General Obligation - Safety and Care
  11.37.040  Specific Obligation
  11.37.050  Definitions
  11.37.060  Designation of a  Hazardous  Materials User
  11.37.070  Professional Assistance  for County Determinations

                              PART II
                        MATERIALS REGULATED

  11.37.100  Materials Regulated
  11.37.110  Exclusions

                             PART III
                  STORAGE OF HAZARDOUS MATERIALS

  11.37.200  Containment of Hazardous Materials
  11.37.210  New  Storage Facilities
  11.37.220  Other  Storage Facilities
  11.37.230  Variance
  11.37.240  Abandoned Storage Facilities
                                                          [1449-3>

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                            PART  IV
              HAZARDOUS  MATERIALS MANAGEMENT PLAN

11.37.300  The Hazardous Materials Management Plan
11.37.310  Standard Form Hazardous Materials Management Plan
11.37.320  Short Form Hazardous Materials Management Plan

                            PART V
              HAZARDOUS  MATERIALS DISCLOSURE FORM

11.37.400  Filing a Hazardous Materials Disclosure Form
11.37.410  Content of the Disclosure Form
11.37.420  Exemption to Disclosure
11.37.430  Trade Secrets and Exemptions from Public Disclosure

                            PART  VI
                       RESPONSIBILITIES

11.37.500  The Hazardous Materials Permit
11.37.510  The Hazardous Materials Management Plan
11.37.520  Unauthorized Releases - Reporting
11.37.530  Unauthorized Releases - Repair
11.37.540  Unauthorized Releases - Cleanup Responsibility
11.37.550  Unauthorized Releases - Indemnification
11.37.560  Handling, Emergency Procedures and Access

                           PART VII
                    INSPECTIONS AND RECORDS

11.37.600  Inspections - Authority
11.37.610  Inspections
11.37.620  Maintenance of Records - County
11.37.630  Maintenance of Records - Applicants

                          PART VIII
                        PERMIT PROCESS

11.37.700  Requirement for Permit
11.37.710  Required Information for Permit Application
11.37.720  Permit Issuance,  Amendment and Transfer
11.37.730  Fees for Permit
11.37.740  Appeal Procedure

                            PART  IX
                         ENFORCEMENT

11.37.800  Revocation or Suspension
11.37.810  Criminal Penalties
11.37.820  Civil Penalties
11.37.830  Citizens Right to Act
11.37.840  Civil Action  for  Retaliation
11.37.850  Remedies Not  Exclusive
                                                        [1449-3]

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                              PART X
                           MISCELLANEOUS

  11.37.900  Duties are Discretionary
  11.37.910  Disclaimer of Liability
  11.37.920  Regulations
  11.37.930  Conflict with Other Laws
  11.37.940  Severability
  11.37.950  Initial Compliance Schedule

11.37.010  FINDINGS AND INTENT.  The County Board of Supervisors
finds and declares:

  (a)  Hazardous materials present in the community may pose acute
  and chronic health hazards to individuals who live and work in
  this County, and who are exposed to such substances as a result
  of fires, spills, industrial accidents, or other types of
  releases or emission.  Additionally, many hazardous materials
  present a serious health risk, even when emitted in low levels
  over long periods of time.

  (b)  Mishandling of small amounts of many of these substances
  has resulted in widespread and serious contamination of soil,
  air and groundwater.

  (c)  The cleanup of soil and groundwater contaminated with toxic
  chemicals can cost 100 times more than the original cost of  •
  properly containing and handling the hazardous materials
  responsible for the pollution.

  (d)  It is the responsibility of all businesses to protect their
  workers and the public from hazardous materials they use.

  (e)  It is technically and economically feasible to design
  manufacturing and commercial facilities that eliminate or
  minimize the release of hazardous contaminants.

  (f)  Aggressive efforts to control hazardous materials will
 .enable companies to reduce technological obsolescense and
  eliminate the need to undertake expensive retrofit projects to
  comply with new regulations.

  (g)  Many state and federal programs have solved one type of
  toxic pollution problem by redirecting  the contamination to
  another part of the environment, rather than eliminating the
  hazard.  The County, however,  has the responsibility and the
  authority pursuant to the County's Environmental Guidelines to
  plan to protect human health  and the environment from all
  significant adverse effects resulting from the use and handling
  of hazardous materials.
                                                          [1449-31

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   (h)  It is the intent of the County Board of Supervisors that
   this Chapter shall recognize the County's responsibilities, its
   right to act to protect public health, life, and the environment
   from toxic contamination.  It is the intent of the Board of
   Supervisors that the Chapter shall foster the best available
   industrial processes and best practical control technology to
   minimize potential contamination.  This ordinance shall
   condition the use of hazardous materials by placing an
   obligation on the users to strictly control their emissions,
   discharges and releases.

   (i)  It is further the intent of the County Board of Supervisors
   to require that hazardous materials users monitor their
   emissions into the environment and keep records on the
   effectiveness of their hazardous materials management practices
   as a means of enforcing their obligation.

   (j)  The people who live and work in this County have a right
   and need td know of the use and potential hazards of hazardous
   materials in the community in order to plan for and respond to
   potential exposure to such materials.

   (k)  Basic information on the location, type and health risks of
   hazardous materials used or stored in the County should be
   available to firefighters/ health officials, planners, elected
   officials or residents.

   (1)  It is the intent of the County Board of Supervisors that
   this Chapter shall recognize the community's right to know basic
   information on the use and storage of hazardous materials in the
   County and that it shall establish an orderly system for the
   provision of such information.

   (m)  It is further the intent of the County Board of Supervisors
   that the system of the disclosure set forth in this Chapter
   shall provide the information essential to firefighters, health
   officials, planners, elected officials, and residents in meeting
   their responsibilities for the health and welfare of the
   community in such a way that any statutory privilege of trade
   secrecy is not abridged.

   (n)  The Board of Supervisors hereby finds and determines, on
   the facts relevant to disclosure of the precise location within
   a facility where hazardous materials are stored or handled, that
   the public interest served by not disclosing such information to
   the public clearly outweighs the public interest served by
   disclosure of such information.

11.37.020  PURPOSE.  The purpose of this Chapter is the protection
of healtn and life, the environment, and property by placing on
the users of hazardous materials the obligation to control
releases, emissions or discharges  of all hazardous materials, to
properly handle all hazardous materials and to disclose their
whereabouts.
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                              PART IV

                HAZARDOUS MATERIALS MANAGEMENT PLAN

 11.37.300  _THE  HAZARDOUS  MATERIALS  MANAGEMENT PLAN.   Each
 applicant  for a Permit  pursuant  to  this  Chapter  shall file a
 written  plan, for  the Health  Officer's approval,  to  oe known as a
•Hazardous  Materials  Management Plan  (HMMP),  which shall
 demonstrate  the safe handling and control  of hazardous materials.
 The  HMMP may be amended at  any time  with the consent of the Health
 Officer.   Those hazardous materials  users  that frequently initiate
 signficant changes,  as  defined in Section  11.37.050  and referred
 to in  Section 11.37.400,  in handling  of  a  hazardous  materials
 should indicate that information in  the  plan,  or  file an amended
 plan.  The HMMP shall be  a  public record,  except  for items
 designated as trade  secrets in accordance  with the provisions of
 Section  11.37.430  and except  for information contained in the
 General  Facility Description  and the  Facility  Storage map or line
 drawing  of the  facility,  as herein provided.

 11.37.310  STANDARD  FORM  HMMP.  The  Standard Form HMMP shall
 consist  of tne  following:

   (a)  Facility Information;

     1.  General Information.  The Standard  Form  HMMP shall
     contain the name and address of  the facility and business
     phone numner  of applicant, the name and titles  and emergency
     phone numbers of the primary response person and two
     alternates, the number of employees,  number  of  shifts, hours
     of  operation, and  principal business  activity.
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2.  General Facility Description.

   (i)  The Standard Form HMHP shall contain a map drawn at a
   legible scale and in a format and detail determined by the
   Health Officer.   It shall show the location of all
   buildings and structures, chemical loading areas, parking
   lots, internal roads/ storm and sewer drains, and shall
   specify the uses of adjacent properties.

   (ii)   The Health Officer may also require information as
   to the location  of wells, flood plains, earthquake faults,
   surface water bodies, and/or general land uses (schools,
   hospitals, institutions, residential areas) within one
   mile  of the facility boundaries.

3.  Facility Storage Map.

   (i)  The Standard Form HMHP shall contain a Facility
   Storage Map at a legible scale for licensing and
   enforcement purposes.  The information in this section is
   provided for purposes of ensuring the suitable and secure
   sto'rage of hazardous materials and for the protection and
   safety of emergency response personnel.

   (ii)   The Facilities Storage Map  shall indicate the
   location of each hazardous materials storage facility,
   including all interior,  exterior,  and underground storage
   facilities, and  access  to such storage facilities.  In
   addition, the map shall  indicate  the location of emergency
   equipment related to each storage facility, and the
   general purpose  of the  other areas within each facility.

   (iii)   For each  storage  facility,  the map shall contain
   information as prescribed below:

      (1)   A floor  plan to  scale and the permit quantity
      limit.

      (2)   For each hazardous material the general chemical
      name,  common/trade name,  major  constituents for
      mixtures,  United Nations  (UN)  or North American (NA)
      numoer, if available,  and physical state.

      (3)   For all  hazardous mateials, including wastes,
      stored in  each storage facility, the hazard class  or
      classes and the quantity  for each such class.

      (4)   For tanks,  the  capacity limit of each tank,  and
      the  hazardous material contained in each tank  by
      general chemical name, common/trade name,  major
      constituents  for mixtures,  United Nations  (UN)  or  North
      American (NA)  number,  if  available,  and physical  state.
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      The Facility Storage Map shall be updated annually o\
      whenever an additional approval is required for the
      facility..

(b)  An Environmental Audit.  Hazardous materials users shall
provide the Health Officer, and themselves, with an
environmental audit of each process using a hazardous material
or materials.  The environmental audit shall include:

   1.  A list of  all hazardous materials that will be stored,
   produced or used in production, assembly and cleaning
   processes (a copy of the Hazardous Materials Disclosure Form
   as provided in Part IV herein may satisfy the requirements of
   this subparagraph);

   2.  Diagrams showing the flow of all hazardous materials
   through each step of these processes;

   3.  Diagrams and descriptions of all processes that produce
   wastewaters, air emissions, or hazardous wastes;

   4.  Diagrams and descriptions of all treatment processes for
   hazardous materials, including information on their
   efficiency in  removing or destroying hazardous contaminants;

   5.  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; and

   6.  A description of the methods to be utilized to ensure
   separation and protection of stored hazardous materials from
   factors which  may cause a fire or explosion, or the
   production of  a flammable, toxic, or poisonous gas, or the
   deterioration  of the primary or secondary containment.

(c)  Control of Emissions, Discharges and Releases.  The
Standard Form HMMP shall indicate the measures employed to
control emissions, discharges and releases of each hazardous
material, by:

   1.  Showing that the user has a permit or license from the
   appropriate regulatory agency.

   2.  Explaining how the user adheres to existing laws,
   statutes, standards or regulations that do not require a
   permit or license, but do specifically cover the handling of
   each hazardous material and specifically require its control.

   3.  Documenting measures that will be employed to control the
   hazardous material in such a manner as to present the least
   acute or chronic hazard or risk to public health, and/or
   least damage to the environment, including, but not limited
   to:
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      (i)  The best available control technologies, practicable,
      or

      (ii)  Cnanges in process and manufacturing strategies to
      reduce handling of the hazardous material.

   4.  Demonstrating the adequacy of:

      (i)  Contingency plans for spills and unauthorized
      emissions, discharges and releases of the hazardous
      material; and,

      (ii)  Employee training and equipment for proper handling
      of hazardous materials, and in response to all emergencies
      involving the hazardous material.

   5.  Upon a showing the environmental fate of the hazardous
   material handled is such that it presents no harm or
   potential of harm to human health or to the environment, the
   HMMP need not indicate the measures employed to control
   emissions, discharges, and releases of each hazardous
   material.

(d)  Monitoring Plan.  For each hazardous material used, the
user snail document the efforts to verify that the hazardous
materials are controlled in accordance with all other elements
of the HMMP:

   1.  These efforts shall include, but are not limited to:

      (i)  Sampling of emissions discharges and releases;

      (ii)  Self-inspections of storage, manufacturing, and
      transportation operations; and

      (iii)  Testing of emergency procedures.

   2.  These efforts shall take place in such a manner as to:

      (i)  Include sampling, self-inspections and monitoring at
      those times during the production process when the highest
      volume discharges and the highest probable concentrations
      of hazardous materials are likely to occur;

      (ii)  Monitor, inspect or sample all hazardous materials
      used in the manufacturing process which have any potential
      for appearing in wastewater discharge; and,

      (iii)  Include periodic random sampling, monitoring or
      inspection.

(e)  Recordkeeping Forms.  The Standard Form HMMP shall contain
an inspection check sneet or log designed to be used in
conjunction with routine inspections.  The check sheet or log
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  shall provide for the recording of the date and time of
  inspection and, for monitoring activity, the date and time of
  any corrective action taken, the name of the inspector, and the
  countersignature of the designated safety manager for the
  facility or the responsible official as designated in the HMMP.

11.37.320  SHORT FORM HMMP.

  (a)  Any user handling an aggregate amount of less than 500
  pounds of solids or 55 gallons of liquids or 200 cubic feet of a
  gaseous material at standard temperature and pressure, whichever
  is lesser, of a product or formulation containing a hazardous
  material may opt to file the Short Form HMMP unless the Health
  Officer has provided notice that he or she has lowered the
  weight or volume limits for a specific hazardous material to
  protect the public health.

  (b)  The Short Form HMMP shall consist of the following:
             «
     1.  The Short Form HMMP shall contain the name and address of
     the facility and business phone number of applicant, the name
     and titles and emergency phone numbers of the primary
     response person and two alternates, tne number of employees,
     number of shifts, hours of operation, and principal business
     activity.

     2.  The Short Form HMMP shall contain a simple line drawing
     of the facility showing the location of the use or storage
     facilities and indicating the hazard class or classes and
     physical state of the hazardous materials being used or
     stored and whether any of the material is a waste.

     3.  The Short Form HMMP shall also indicate the use and/or
     storage of any quantity of any carcinogen or reproduction
     toxin as defined in this Chapter.

     4.  Information indicating that the hazardous materials will
     be stored in a suitable manner and that they will be
     appropriately contained, separated and monitored.

     5.  Description of adequate contingency plans for spills and
     unauthorized emissions, discharges, and releases of the
     hazardous material and, employee training and equipment for
     proper handling of hazardous materials, and in response to
     all emergencies involving the hazardous material.

     6.  Assurance that the disposal of any hazardous materials
     will be in an appropriate manner.
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                              PART V

                HAZARDOUS  MATERIALS  DISCLOSURE  FORM

11.37.400  FILING OF A HAZARDOUS MATERIALS DISCLOSURE FORM.

  (a)  Any user operating within the unincorporated areas of the
  County and handling hazardous materials shall submit a completed
  disclosure form to the Health Officer by January 1 of each year.

  (b)  In addition, any user shall file an amended disclosure form
  detailing the handling and other information requested on the
  form within 60 days of any:

     1.  Sigificant change in the handling of a hazardous material;

     2.  New handling of a previously undisclosed hazardous
     material;
             *
     3.  Change of business address;

     4.  Change of business ownership;  or

     5.  Change of business name.

11.37.410  CONTENT OF THE  DISCLOSURE FORM.

  (a)  The disclosure form shall include the following:

     1.  Identification information, including  but not limited to
     name, address and assessor's parcel number.

     2.  A copy of the MSDS for every hazardous material used by
     the person or business completing  the disclosure;  unless the
     MSDS has  been previously filed  pursuant to the requirements
     of this ordinance or  does not exist.

     3.  A listing of the  chemical name,'any common names,  hazard
     class and the CAS number and/or UN/NA number  of every
     hazardous material handled by the  person or  business
     completing the disclosure form;

     4.  The EPA waste stream code,  if  available,  of every
     hazardous waste handled by the  person or business  completing
     the disclosure form;

     5.  The estimated maximum amount of each hazardous  material
     disclosed in either subsection  2 or 3 which  is handled at  any
     one time  by the user  over the course  of  tne year;

     6.  Sufficient information on how  and where  the hazardous
     materials  disclosed in subsections 2  and 3 are handled by  the
     user to allow fire and safety personnel  to prepare  adequate
     emergency  responses to potential releases  of  the  hazardous
     materials;

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     7.   The SIC code of the business, if applicable;  and

     8.   The names and phone numbers of at least three persons
     representing the person or business and able to assist
     emergency personnel in the event of an emergency involving
     the person or business during nonbusiness hours.

  (b)  In an emergency, all users must immediately provide upon
  request information beyond that specifically required in the
  disclosure form to the agency of jurisdiction during the
  emergency if that agency has determined that such information is
  necessary to protect health and safety of the environment.

11.37.420  EXEMPTION TO DISCLOSURE.

  (a)  Fuel products that are regulated by the Uniform Fire Code
  shall  be exempt from disclosure under Part V.

  (b)  A subs-tance designated as a hazardous material by this
  Chapter solely by its presence on the Nuclear Regulatory
  Commission list of radioactive materials shall be exempt from
  the requirement that an MSDS be submitted with the disclosure
  form.

11.37.430  TRADE SECRETS AND EXEMPTIONS FROM PUBLIC DISCLOSURE.

  (a)  If a user believes that a request for information contained
  in the disclosure form or the HMMP involves the release of a
  trade  secret, the user shall complete the documents nonetheless,
  but shall notify the Health Officer in writing of that
  information in the documents that the user believes involves the
  release of a trade secret.  As used herein, trade secret shall
  have the meaning given to it by Section 6254.7 of the Government
  code and Section 1060 of the Evidence Code.

  (b)  Subject, to the provisions of this Chapter, the Health
  Officer shall exempt from public disclosure any and all
  information coming into his or her possession which is claimed
  to involve the release of a trade secret, pursuant to subsection
  (a).

  (c)  Subject to the provisions of this Chapter, the Health
  Officer shall also exempt from public disclosure that portion of
  a Hazardous Materials Disclosure Form, the HMMP or other record
  on file which states the precise location where hazardous
  materials are stored or handled.

  (d) Any information reported to or otherwise obtained by the
  Health Officer, or any of his or her representatives or
  employees, which is exempt from disclosure pursuant to
  subsections (b) or (c) shall not be disclosed to anyone except:
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   1.  An officer or employee of the County, the State of
   California, or the United States of America, in connection
   with the official duties of such officer or employee under
   any law for the protection of health, or to contractors with
   the County and their employees if in the opinion of the
   Health Officer such disclosure is necessary and required for
   the satisfactory performance of a contract of work, or to
   protect the health and safety of the employees of the
   contractor; or

   2.  To a physician when the Health Officer determines that
   such information is necessary for the medical treatment of
   the physician's patient.

(e)  For the purpose of this section, fire and emergency
response personnel and County health personnel operating within
the jurisdiction of the County shall be considered employees of
the County.
           «
(f)  Information claimed as a trade secret must be disclosed to
a physician by the Health Officer for the purpose of treating a
patient. ' Any physician who, by virtue of his or her treating a
patient has possession of or access to information the
disclosure of which is prohibited on this section, and who,
knowing that disclosure by this information is prohibited,
knowingly and willfully discloses the information in any manner
to any person not entitled to receive it, shall be guilty of a
misdemeanor.

(g)  Any officer or employee of the County or former officer or
employee who, by virtue of such employment or official position
has possession of or access to information the disclosure of
which is prohibited by this section, and who, knowing that
disclosure of the information is prohibited, knowingly and
willfully discloses the information in any manner to any person
not entitled to receive it, shall be guilty of a misdemeanor.
Any contractor with the County and any employee of such
contractor, who has been furnished information as authorized by
this section, shall be considered to be an employee of the
County for purposes of this Section.

(h)  Information certified by appropriate officials of the
United States, as necessarily kept secret for national defense
purposes,  shall be accorded the full protection against
disclosure as specified by such official or in accordance with
the laws of the United States.

(i)  Upon receipt of a request for the release of information to
the public which includes information which the user has
notified the Health Officer is a trade secret pursuant to
subsection (a) of this- section, the Health Officer shall notify
the user in writing of said request by certified mail.  The
Health Officer shall release the information, forty-five (45)
days after the day of mailing said notice unless, prior to the
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expiration of said forty-five (45) days, the user institutes an
action in an appropriate court;for a declaratory judgment that
such information is subject to:protection under subsection (b)
of this section and obtains a temporary restraining order or
preliminary or permanent injunqtion prohibiting disclosure of
said information to the general public.

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