United States Solid Waste and
Environmental Protection Emergency Response EPA530-R-94-041
Agency (5305) November 1994
&EPA Executive Summaries
Of Roundtables on
Hazardous Waste
Minimization and
Combustion
EPA/530/R-94/041
Recycled/Recyclable
Printed on recycled paper that contains at
least 50% post-consumer recycled fiber
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CONTENTS
EXECUTIVE SUMMARIES OF ROUNDTABLES ON HAZARDOUS WASTE MINIMIZATION
AND COMBUSTION
National Roundtable, Washington, D.C.
November 15-18, 1993
Region IX Roundtable, San Francisco, California
April 16, 1994
Region VI Roundtable, Houston, Texas
April 23, 1994 15
Region V Roundtable, Chicago, Illinois
April 30, 1994 30
Region IV Roundtable, Atlanta, Georgia
May 7, 1994 36
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FOREWORD
On May 18, 1993, Administrator Carol M. Browner announced a series of steps, including the release
of EPA's Draft Waste Minimization and Combustion Strategy, that the Agency would be undertaking
to reduce the amount of hazardous waste generated in this country and to further ensure the safety and
reliability of hazardous waste combustion in incinerators, boilers, and industrial furnaces.
To facilitate public dialogue on both waste minimization and combustion, EPA held a series of
Roundtables. The purpose of the Roundtable discussions was to give a broad range of interested
parties and stakeholders, particularly those citizens, companies, and local officials who are directly
involved (e.g., local citizen groups, environmental organizations, regulated companies, industry trade
associations and state, local and regional regulatory officials) an opportunity to share their concerns
and information regarding waste minimization and combustion.
This publication is a compendium of the Executive Summaries of the National Roundtable, which was
held September 15-18, 1993 and a series of four Regional Roundtables held in April and May of 1994.
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ENVIRONMENTAL PROTECTION AGENCY
NATIONAL ROUNDTABLE ON HAZARDOUS WASTE MINIMIZATION
AND COMBUSTION: November 15 - 18, 1993
EXECUTIVE SUMMARY
This document summarizes the proceedings of a national roundtable on hazardous waste minimization
and combustion held November 15 through 18, 1993 in the Washington, D.C. area. Participants in
the roundtable, which was sponsored by the Office of Solid Waste, at U.S. Environmental Protection
Agency (EPA) Headquarters, addressed a variety of issues related to hazardous waste minimization
and combustion. To discuss topics, participants, including EPA and state regulators, and
representatives of public interest groups, hazardous waste management facilities, hazardous waste
generators, and technical assistance centers, were separated into breakout groups — six groups for the
waste minimization session and five for the combustion session. The groups developed ideas and
recommendations, which then were presented when the participants reconvened in plenary sessions
attended by all participants. Topics discussed during the roundtable included:
• Goals of hazardous waste minimization efforts
• Roles of stakeholders in achieving waste minimization
• Mechanisms to implement waste minimization
• Big picture issues related to waste minimization
• General issues involving combustion of hazardous waste
• Control of emissions of toxic metals from hazardous waste combustion units
• Control of emissions of toxic organic compounds from hazardous waste
combustion units
• Other issues involving combustion of hazardous waste
Many of the participants held similar views on the broadest goals that were expressed for waste
minimization. Most of the groups agreed that the goal for pollution prevention should be the
implementation of a flexible, multi-media approach. All groups believed that one goal should be to
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remove disincentives and create incentives (for example, tax credits) for progress in implementing
pollution prevention. All groups also agreed that research and development in pollution prevention
should be increased and that additional technical assistance for pollution prevention should be
provided to parties engaged in pollution prevention efforts. In addition, many groups agreed that
more combustion research should be conducted. Industry, represented by participants from hazardous
waste management facilities and generators, generally also supported the goal of including all parties
involved (for example, generators and treatment and disposal facilities) in a multi-media approach that
highlights pollution prevention. The public interest groups held that the goal of waste minimization
should also include the eventual phase-out of production and elimination of release of all toxins.
Finally, the groups discussed goals in terms of percentage reduction of hazardous waste, but no
consensus was reached on the actual percentages to be achieved or the time frames for doing so.
During discussions of roles of stakeholders in achieving waste minimization, most participants agreed
that it is the generators' responsibility to implement waste minimization, but that the other stakeholder
groups can play a large part in assisting generators. Some of the stakeholder groups believed that it
is the responsibility of generators to communicate their progress in pollution prevention to the public.
Many of the stakeholder groups believed that it is the responsibility of EPA and state regulators to
(1) develop better measures of success in pollution prevention and communicate those measures and
(2) eliminate disincentives to pollution prevention. Several of the groups saw the role of technical
assistance centers to be provision of technical and financial assistance to generators, particularly
small-quantity generators. Finally, the public interest groups saw their role to be education and
establishment of citizens committees to bring problems related to specific sites to the government.
During the discussion of mechanisms to achieve waste minimization goals, the participants examined a
variety of mechanisms under the Resource Conservation and Recovery Act (RCRA), other federal and
state environmental statutes, and nonregulatory mechanisms. Regarding the use of RCRA regulatory
mechanisms, several participants considered the current certification requirements for waste
minimization ineffective and suggested that EPA and the states require generators to demonstrate that
they have a "program in place" and demonstrate that such a program is achieving progress. In
general, members of the group discussing the use of RCRA permits and enforcement actions to
implement waste minimization concluded that permits may not be an effective means of implementing
waste minimization. The participants who discussed the use of non-RCRA federal regulatory
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mechanisms recommended that EPA develop a single, enforceable permit process to address
generation of pollutants across all media. Suggestions for the use of state regulatory mechanisms
included use of state multi-media permits, provision of flexibility for the states in implementing
pollution prevention regulations, and transfer of experience in implementing pollution prevention
between the states and EPA. Finally, members of the nonregulatory mechanisms group stressed the
use of technical assistance programs, dissemination of information, professional accountability, and
economic incentives to achieve waste minimization goals.
When asked to identify "big picture" issues that are important to the implementation of waste
minimization, many of the participants identified three of greatest importance: (1) adopting a multi-
media approach, (2) developing clear measures of progress, and (3) using EPA's waste management
hierarchy. Many participants believed that, if it is to implement an effective multi-media approach to
waste minimization, EPA must restructure its regulatory programs to remove barriers to the
implementation of pollution prevention. However, there was no clear consensus on what a list of
these barriers would contain or on how to accomplish that goal. Several groups also provided
suggestions for means of measuring progress in pollution prevention, including the suggestion from
public interest groups that increased reporting should be required of generators. Finally, several
comments were presented concerning the use of EPA's waste management hierarchy. Although those
comments were diverse, most of the participants agreed that stakeholders should focus their efforts on
the top of the hierarchy (for example, on source reduction). There was considerable disagreement
between public interest groups and some industry representatives about the status of combustion in the
hierarchy. Public interest groups maintained that combustion should be near the bottom, while
industry representatives maintained that, in some cases, it should be moved up.
In the discussion of general combustion issues, participants discussed several items, including the use
of technology-based versus risk-based standards, siting requirements, and future incineration capacity.
There was considerable agreement over the use of technology-based versus risk-based performance
standards. Most participants agreed that there is considerable uncertainty about the use of risk
assessments and that the science involved in risk assessment should be improved. Consequently,
many participants proposed the use of the risk assessments only as a backup to technology-based
performance standards. However, many of the public interest groups held that risk assessments are a
completely unacceptable tool and that their results are not trusted by the public. Industry
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representatives and EPA and state regulators generally agreed that joint RCRA, Clean Water Act, and
Clean Air Act technology-based performance standards should be developed. With regard to siting
requirements, the participants were divided on the question as to whether standards should apply
equally to existing and new facilities. All groups agreed that environmental equity and sensitive
environments should be considered when siting restrictions are developed. The public interest groups
felt that no new incinerators should be sited.
The participants discussed a variety of issues regarding control of toxic metals, including the
problems of using a particulate matter standard as a surrogate for toxic metals, the need for controls
on both particulate matter and metals, and limits on individual metals. The majority of participants
believed that particulate matter is not an effective surrogate for metals and that controls are needed for
both metals and particulate matter. No consensus was achieved on how to set limits on individual
metals. Industry representatives and EPA and state regulators suggested several approaches to
establishing limits for individual metals that involve various combinations of technology-based
standards, risk-based standards, or limits on the amount of metals that can be emitted. The public
interest groups generally maintained that metal-bearing wastes should not be fed to incinerators or
BIFs, but if they are, controls must be imposed on residues and products generated by such devices.
Industry representatives were divided on the question whether all combustion devices should be
subject to the same generic emissions standards (or whether source category-specific standards should
be developed), while most of representatives of the public interest groups held that all combustion
units should be subject to the same standards. Finally, almost all participants stated that the
technology does not yet exist to allow continuous emissions monitoring (CEM) of metals. EPA and
state regulators believed that CEM for metals should be pursued actively, while representatives of
industry were divided on the issue.
Participants involved in the discussion of control of toxic organic compounds focused on two major
issues: control of emissions of dioxin and control of emissions of other toxic organics. Many
participants preferred technology-based performance standards for organic emissions supplemented
with either (or both) a national generic risk assessment or a site-specific risk assessment to ensure that
the controls were adequate to protect public health and the environment. Most participants agreed
that dioxin emissions could be reduced through the use of good combustion practices. There was
considerable debate over whether a dioxin limit should be established based on total congeners or
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toxicity equivalents. Many industry and EPA/state representatives favored the use of toxicity
equivalents. The public interest groups maintained that past emissions of dioxin have been
unacceptably high and that no emissions of dioxin should be permitted. The participants also were
divided on the question of whether an exemption from the dioxin standard should be provided for
facilities burning nonchlorinated wastes. Many participants favored an exemption pending an
adequate demonstration of no harmful emissions from the facility, while others, particularly in the
public interest groups, opposed such an exemption because of the presence of naturally occurring
chlorine in feeds to hazardous waste combustion devices. Participants also disagreed on the adequacy
of surrogates (for example, carbon monoxide) used to control emissions of toxic organics, but they
generally agreed that better stack monitors are needed to ensure compliance with emission standards
for residual organic compounds.
Finally, the participants discussed a variety of issues related to the combustion of hazardous waste,
including the regulation of fuel blending, trial burns, and recordkeeping. Participants noted that fuel
blending is already regulated under RCRA, and many agreed that the amount of energy recovered and
the degree of burning for destruction should be factors in determining how burners should be
regulated and that blending of high metal content wastes to dilute the metals prior to burning should
be banned. The representatives of public interest groups and industry disagreed about the value of
trial burns. The public interest groups believed that trial burns are not representative of true
operating conditions (e.g., operators are on "good behavior" during the test while the regulators are
looking over their shoulders), while most industry representatives maintained that, in fact, trial burns
represent the worst operating conditions under which they would (and could) operate given that permit
conditions (i.e, operating limits) are based on operating conditions during the trial burn. However,
all groups agreed that the methods of selecting principal organic hazardous constituents and the
analytical detection limits for quantifying emissions should be improved. Finally, several approaches
to the quantification of the destruction and removal efficiency for organic compounds, including the
use of surrogates and real wastes, were discussed, although no consensus was reached on the issue.
Representatives of the public interest groups also maintained that the records of operations of BIFs
and incinerators should be made available to the public, and that greater standardization of
recordkeeping procedures should be required. Industry and EPA and state regulators generally agreed
with these suggestions and stated that it may be helpful to require computerization of such data.
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U.S. ENVIRONMENTAL PROTECTION AGENCY - REGION IX
WASTE MINIMIZATION AND HAZARDOUS WASTE COMBUSTION ROUNDTABLE
APRIL 16, 1994
EXECUTIVE SUMMARY
U.S. Environmental Protection Agency (EPA) Administrator Carol Browner released the EPA's draft
waste minimization and combustion strategy in May 1993. In an effort to facilitate discussion among
a wide range of stakeholders on waste minimization and hazardous waste combustion issues, EPA
headquarters' Office of Solid Waste hosted a national roundtable meeting in November 1993, in
Washington, D.C. As follow-up to the national roundtable, EPA is hosting regional roundtables in
San Francisco, Dallas, Chicago, and Atlanta to stimulate the widest range of involvement and
comment from all participants, and to gain a more accurate and comprehensive understanding of
waste minimization and hazardous waste combustion issues and concerns from interested groups
nationwide. The roundtables will assist EPA and the states in developing a national waste
management strategy that will (1) better integrate waste minimization in the national hazardous waste
management program under the Resource Conservation and Recovery Act (RCRA) and (2) ensure that
hazardous waste combustion standards for all RCRA hazardous waste incinerators and boilers and
industrial furnaces (BIF) are fully protective of human health and the environment.
This document summarizes the proceedings of the EPA, Region IX Waste Minimization and
Hazardous Waste Combustion Roundtable held in the San Francisco area on April 16, 1994. The
meeting consisted of two panel discussions: a morning session that focused on waste minimization
issues and an afternoon session that focused on hazardous waste combustion issues. A Spanish
translator was provided for both sessions to allow for full participation by Spanish-speaking members
of the audience.
The format called for a panel discussion of the issues, led by a moderator who posed questions to 11
panelists. The panelists represented public environmental groups, trade associations, industry, EPA
and state regulators, local government, and technical assistance centers. The panel discussion was to
be followed by an hour and a half of questions and comments from the audience. While this format
was applicable to the morning session, the format for the afternoon session was changed to
accommodate the audience's interest in being afforded the opportunity to fully participate in the
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discussion. To allow for full participation, a process was set up whereby written questions from the
audience were posed by the moderator to ten panelists, following an initial question posed by the
moderator. All other questions and comments were provided by the audience throughout the session
and were presented to the panel by the moderator. Toward the end of the session, due to time
constraints and the large number of questions, the moderator combined similar questions. However,
some questions could not be addressed due to time constraints.
WASTE MINIMIZATION SESSION
Questions posed to the panel by the moderator during the waste minimization session are presented
below, followed by a synopsis of the discussions that took place during the session.
Should generators be held accountable for meeting quantitative waste minimization
goals? If goals and accountability are established, then how much flexibility should
generators be allowed in determining and achieving the goals?
How should progress toward waste minimization goals be measured or determined?
How should progress that has already been made be taken into account?
What roles can citizen environmental groups and the general public play in ensuring
that the nation's hazardous wastes are minimized? For example, could these roles
include public scrutiny of other stakeholders' waste minimization efforts? What other
roles might these entities play?
What is the most appropriate role for EPA and the states in advancing pollution
prevention?
What role should local government play in advancing pollution prevention?
The panelists were in general agreement that generators should be held accountable for achieving
waste reduction and that EPA should set goals. Additionally, waste minimization should be
implemented across media. Most panelists agreed that prescriptive goals may be necessary for those
generators who fail to meet quantitative goals set forth by EPA. Panelists representing industry
asserted that if specific goals are established, generators should be provided flexibility in determining
how they will meet the goals. Environmental groups and public representatives expressed concern
about ensuring accountability if generators are allowed greater flexibility. Environmental groups and
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public representatives held that there must be enforceable mechanisms to deal with noncompliance.
Regulators noted that simply setting goals to reduce waste volume does not take into account the
toxicity levels of different chemicals. Additionally, it is difficult to compare the toxicity levels of
chemicals.
All panelists agreed that a number of factors make waste minimization difficult to measure. These
factors include (1) fluctuations in Jie toxicity of constituents and (2) production fluctuations due to
consumer demand. Most panelists agreed, however, that an effort should be made to use currently
existing tracking methods, despite their shortcomings, to quantify both generation and reduction
patterns for all sources. Among such methods are the toxic release inventory (TRI) reporting
documents, hazardous waste manifests, and biannual generator reports. Once patterns have been
identified, efforts could then be focused on improving current methods of measuring waste streams
and identifying additional methods of measuring waste reduction. EPA is currently attempting to
identify a method for comparing fluctuations in constituent concentrations and adjust for waste
volumes generated due to fluctuations in production. EPA is also conducting pilot projects to
determine if any significant conclusions can be drawn from current inventory tracking data.
Environmental group representatives asserted that more effort should be focused on source reduction
rather than waste minimization.
Industry representatives, in general, expressed the need for industry and environmentalists to work
together to help educate the public about basic waste minimization issues including the environmental
impacts of their purchases. Industry representatives also expressed the belief that environmentalists
and industry need to work together to find workable, mutually beneficial solutions to reducing waste.
A panelist representing an environmental group maintained that it is difficult for industry and
environmentalists to work together to educate the public when industry, claiming protection under
trade secrecy laws, withholds information about the makeup of their waste streams. A state
regulatory representative asserted that, although trade secret provisions must be protected, industrial
waste reduction documents are available to the public. The panelist went on to say that a greater
level of trust is needed concerning industry disclosure of required information.
Panelists agreed that individual citizens must be responsible for reducing their own waste. However,
panelists also agreed that effective methods are needed to educate consumers about the environmental
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impacts of their purchases. One suggestion was that advance disposal fees and surtaxes be levied,
such as that on aluminum cans, as a means of making the public aware of the consequences of their
purchases. Another suggestion was to create a ranking system for products based on their
environmental impacts. A similar system could be created for ranking companies' waste reduction
achievements and pollution prevention efforts. Both systems would be created through a joint effort
of environmentalists, industry, and regulators. Several panelists noted that in considering the
environmental impacts of a product, it is essential to consider the product's life-cycle environmental
impacts and not just the immediate resulting waste.
In response to the question concerning the most appropriate role of EPA and the states in advancing
pollution prevention, the EPA representative stated that the states have taken the lead in providing
technical assistance, with EPA supplementing that role. Both state and federal governments have also
been active in investigating alternative technologies. The EPA representative suggested that federal
and state governments form a partnership with other entities in these areas. Some industry
representatives stated that government should take more of a leadership role by providing more waste
minimization incentives, such as loans and grants for small businesses. Government should also
provide more technical assistance in the form of seminars and informational materials. Environmental
group representatives suggested that government should do more to promote or require pollution
prevention. For example, policy or legislative initiatives should be enacted to require government
agencies to implement purchasing practices that focus on waste and toxic-use reduction. A number of
panelists believe that government should place more emphasis on waste reduction rather than
enforcement, and should lead by example. Panelists generally agreed that, in addition to leading by
example, the federal government should facilitate bringing together all diverse interests to find
mutually acceptable solutions to pollution prevention and waste reduction.
Panelists were in general agreement that local government should also be a facilitator in pollution
prevention efforts. An industry representative suggested that local government pursue a multimedia
approach to pollution prevention to encourage the exchange of ideas, technologies, and approaches
and help eliminate duplicative efforts. It was also suggested that local government be involved in
providing technical assistance programs. One panel member asserted that local government should be
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an equal partner with state and federal governments in providing assistance. There was general
consensus among panel members that local government is best suited to implement pollution
prevention initiatives and programs because of its understanding of local needs. One panel member
asserted that a hierarchy for federal, state, and local government roles should be established: the
federal government should establish a broad vision, state government should implement the vision,
and local government should implement specific programs consistent with that vision.
Following the panel's discussion of local government's role in advancing pollution prevention, the
audience was invited to address questions and concerns to the panel.
Many of the concerns expressed by the audience were site- or state-specific. Overall, the audience
believed that the focus of waste minimization should be on pollution and waste prevention and the
phasing out of persistent biocumulative and toxic chemicals, rather than on post-production waste
reduction and cleanup. Several members of the audience asserted that the continued identification of
sites for incinerators seems contrary to efforts to achieve successful waste reduction. Concern was
expressed about EPA's failure to curtail further permitting of toxic waste incinerators for additional
capacity. One individual questioned that if waste minimization efforts are successful, where will the
waste come from to supply the excess combustion capacity? Will the U.S. import waste from other
countries? The individual expressed concern that the stage is being set for a growth industry in toxic
waste. Along the same lines, another individual held that if EPA is to have an effective national
policy on waste minimization, the agency needs to account for a wide range of individual state's
pollution prevention laws. States with the most stringent regulations will ultimately transport waste to
states with less stringent regulations. A number of individuals agreed with members of the panel who
believe there should be more technical assistance and educational programs. On the topic of
technical assistance, a wide range of concerns were expressed: (1) communities should be provided
with the resources to be involved in the permitting process; (2) greater private-public partnerships for
technology transfer are needed to reduce stakeholders' resistance to implementation of new available
technologies; and (3) technical education programs are needed to educate engineers and others
involved in facilitating pollution prevention.
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Overall, the audience expressed a lack of faith in the efforts of government and industry in achieving
waste minimization. For example, many audience members contended that government and industry
narrowly focus on small portions of the problem and do not fully consider how each of the parts
make up and affect the whole. Some agreed with the panel member who stated that EPA should
establish a broad vision to provide direction and guidance. There was general agreement that EPA
should provide a greater leadership role. Many also held that regulators are not always effective in
their enforcement of regulations and that EPA should take the lead in this effort. It was also stated
that EPA's main role is to protect the environment. Additionally, the agency should provide more
opportunities for community input to balance industry input.
HAZARDOUS WASTE COMBUSTION SESSION
The questions and concerns put forth during the hazardous waste combustion session are summarized
below, followed by a synopsis of the responses.
Is there sufficient capacity nationwide in the United States? Should EPA be limiting
combustion capacity in the United States?
In light of the poor track record of incinerators and weak enforcement, should
incinerators be banned?
What is the scientific basis for EPA's draft combustion strategy? For example, does
risk data exist to justify the high priority EPA has lent to attacking the waste
combustion and recycling industries? What scientific evidence is there that
incinerators pose health risks?
There are two aspects of regulations to control hazardous waste combustion that will
ultimately be decided upon by EPA. These two aspects are (1) the control of dioxin
emissions and (2) the control of multi-pathway risks. Should the same standards or
risk thresholds be imposed on all sources of pollution?
Is EPA's dioxin reassessment update available to the public? What basis did EPA
have for lowering particulates and limiting carbon monoxide to 100 parts per million
(ppm)? What's the standard for health risk assessments?
What should by changed about the way agencies interact with the public in regard to
hazardous waste facilities?
Should facilities be allowed to continue to operate even though they fail their trial
burn? Is the trial burn the most effective way to determine whether a facility can
operate safely and should receive a permit? Would continuous monitoring be more
effective than a trial burn to determine if an incinerator is meeting regulations?
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Panelists generally believed that the United States has excess waste combustion capacity. One
industry panelist stated that his company provides supplemental fuels for cement kilns, which are
experiencing a capacity shortage in many locations. Several panelists noted that overcapacity within
the combustion industry may be more indicative of the national economy than a reduced need for
incineration. When there is full economic recovery, there may be a shortage of capacity. Panelists
representing environmental or citizen groups believe there is a direct relationship between excess
capacity and failure to implement pollution prevention programs. Concern was expressed by one
panel member that much of the currently available capacity includes substandard incinerators. One of
the panel members representing DTSC was concerned about illegal dumping and waste export if limits
are placed on combustion capacity.
Environmental and citizen groups and industry representatives were sharply divided as to whether
incinerators should be banned. Environmental groups held that incinerators should be phased out and
emphasis should be placed on research of alternative technologies and alternative products.
Additionally, environmental group panelists claimed that many incinerators are not in compliance with
EPA regulations. Some environmental group representatives also asserted that incinerator operating
standards are substandard and EPA is lax in enforcing the standards. On the other hand, industry
panelists held that enforcement of regulations has been rigorous and incinerators are shut down that
are not operated within required regulations. An EPA panelist recognized that incinerator emissions
standards could be upgraded and noted that EPA has been researching an effective method to factor
multi-pathway and exposure analysis into risk assessments.
A number of panelists asserted that, in considering whether incinerators should be banned, a
distinction should be made between poorly maintained and operated incinerators and well maintained
and operated incinerators. These panelists also contend that poorly maintained and/or operated
incinerators are cited and eventually shut down, if necessary.
One environmental group representative attempting to address the initial questions more directly cited
several studies on incineration health risks, including an Occupational Safety and Health
Administration (OSHA) survey that identified the health impacts on workers at incinerator sites.
Another environmental group panelist asserted that documentation of health impacts from waste
combustion in BIFs is difficult due to the complexity of the response of the human body. In general,
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industry panelists believed that the current methods for risk assessment are acceptable. Environmental
and citizen group panelists asserted that the current risk assessment approach is not acceptable and
incinerators should stop operating until proved safe.
An EPA panelist stated that two statutory mandates address hazardous waste combustion: RCRA and
the Clean Air Act as amended in 1990. Additionally, the draft combustion strategy focuses on
controlling hazardous waste incineration. Industry panelists generally believe that emissions from
metals, dioxin, and other organics should be regulated. One industry panelist asserted that regulations
should be developed in two phases. The first phase would be based on best available technology and
the second phase would factor in multi-pathway risk assessments to ensure protection of human health
and the environment. One panelist held that residue from incinerators and cement kilns should also
be addressed when assessing risks. This led to a discussion among panelists concerning cement kiln
dust (CKD). Generally, environmental group panelists asserted that CKD is hazardous because of the
pH level; industry panelists stated that CKD is not hazardous when dry.
In response to questions concerning health risk assessment standards and EPA's dioxin reassessment,
an EPA panelist acknowledged that EPA is working on a document that will reassess dioxin;
however, he stated he did not have any information on the specific details. The panelist stated that
EPA had established a lower target level for particulates to address concerns about metal emissions
from incinerators; currently, standards for metals emission levels are based solely on risk assessments
associated with direct inhalation and do not consider multi-pathway exposure.
In response to the question regarding agencies' interaction with the public, a panelist from DTSC
stated that regulatory agencies should be interacting with community members from the outset of the
permitting process and throughout the public involvement process in order to make better-informed
decisions. Environmental and citizen group panelists agreed and stated that regulatory agencies
should be more sensitive to the community's needs and issues including language barriers.
Environmental group panelists asserted that regulatory agencies involved in the decision-making
process should make a concerted effort to remain neutral and objective. An EPA panelist stated that
EPA is currently developing a proposed rule to increase public participation in the hazardous waste
permitting process.
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Questions about trial burns were grouped together due to time constraints. A regulatory agency
panelist explained that trial burns are conducted under worst-case scenarios. Regulatory agency
panelists generally believed that trial burns are the most effective, rigorous, and extensive test
available. One regulatory agency panelist stated that regulations are currently being proposed that
would restrict an incinerator from incineration in the categories in which the incinerator failed its trial
burn. A discussion followed concerning trial burns and why incinerators are allowed to operate at all
if they fail any portion of their trial burns. Environmentalists asserted that there should be more
periodic testing of incinerators to identify any significant changes or equipment deterioration. EPA
panelists agreed that more periodic testing should be done, and that there should be a means of
ensuring that waste burned during trial burns is representative of the waste that will be burned at the
facility. A representative of a citizens group in the audience expressed concern about the lack of
federal standards for identifying sites for hazardous waste incinerators. He held that establishing
federal standards could address many of the incineration issues, specifically placing incinerators in
inappropriate locations. Environmentalists held that the emphasis should be on pollution prevention,
which would address all issues in the long term.
EPA identified several recurring issues that should be addressed as priorities: conduct more
inspections of incinerators, enforce incineration regulations more aggressively, and levy heavy fines
on violators; enact location restrictions; and explore alternatives such as buffer zones for incinerator
site locations.
In closing, EPA thanked the panelists and the attendees and apologized that due to time constraints,
not all questions were addressed. EPA encouraged those who had additional concerns or comments to
provide them to EPA by April 30, 1993.
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U.S. ENVIRONMENTAL PROTECTION AGENCY - REGION VI
WASTE MINIMIZATION AND HAZARDOUS WASTE COMBUSTION ROUNDTABLE
APRIL 23, 1994
EXECUTIVE SUMMARY
The U.S. Environmental Protection Agency (EPA) held a Regional roundtable on the Waste
Minimization and Combustion Strategy in Houston, Texas on Saturday, April 23, 1994, at the
Marriott West Loop Hotel. EPA convened the roundtable so members of the public and local
regulators could provide input into EPA's decision making process. EPA hosted an "Open House"
the evening before the full session to help participants familiarize themselves with the issues.
Approximately 135 people from industry, environmental, citizen, and public interest groups;
regulatory agencies; and academia attended the roundtable.
This report summarizes the comments made during the roundtable. William Honker, Chief of the
Resource Conservation and Recovery Act (RCRA) Permits Branch, EPA, Region VI, Dallas, Texas,
opened the Roundtable by discussing the purpose of the meeting and the agenda for the morning and
afternoon sessions. He pointed out that Region 6 has many waste minimization and combustion issues
under consideration including environmental justice, capacity, and prioritization of permit issuance.
He also encouraged feedback from the participants on their concerns during the session.
Mr. Honker concluded his remarks by introducing Matthew Straus, Director of the Waste
Management Division, EPA Headquarters, Washington, DC. Mr. Straus presented a discussion of
EPA's Draft Strategy on Hazardous Waste Minimization and Combustion, which was first announced
in May 1993. He told the audience that the comment process (which included the Regional
roundtable meetings) on the draft strategy provides the public with the opportunity to identify and
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discuss difficult issues with the goal of finding better solutions. He noted that government and
industry should look for ways to improve the process of exchanging information with the public
because a well-informed public can have a more effective voice in EPA and state decision making.
Mr. Straus continued by noting the controversial aspect of combustion issues and pointed out that
waste combustion facilities will continue to have a role in waste management as long as they are
operated in an environmentally safe manner. He expressed his hope that safely operated facilities
would eventually result in the public's increased confidence over issues related to health and the
environment.
In regard to waste minimization, Mr. Straus referred to industry's achievements in terms of greater
source reduction and recycling, but emphasized that these achievements needed to be better
communicated by EPA and industry to the public to increase public awareness of national policy and
site-specific issues. Mr. Straus also commented that he hoped progress with waste minimization
issues will aid progress on combustion issues.
To help further progress on waste minimization and combustion issues, Mr. Straus told the roundtable
participants that he welcomes new ideas. For example, at the roundtable held in San Francisco,
California, attendees suggested that EPA set overall goals in waste minimization and act as a
facilitator to states, industry, and other interested parties who should then take the lead in the
solutions to specific problems.
Mr. Straus concluded his remarks by encouraging the participants to look for ways to incorporate
these new waste minimization ideas into EPA's policy making process. He asked participants to
break new ground and identify new ways to cooperatively pursue environmental protection and to try
to understand other points of view along the way.
Mr. Straus then turned the meeting over to the facilitators who had grouped written questions
submitted by the participants into subject matter categories. The facilitators began with the most
frequently asked subject categories. A group of nine panelists responded first to the questions,
followed by members of the audience. Participants introduced additional questions during the
sessions.
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Panelists included Sue Pope, Citizens Aware and United for a Safe Environment (CAUSE); Jim
Schermbeck, The Jobs and Environment Campaign; Wayne Roush, Shell Oil Company and member
of the American Petroleum Institute; Brian Engle, USPCI and member of the Association for
Responsible Thermal Treatment (ARTT); Dale Van Fossen, Systech Environmental; Shirley Elane
goldsmith1, Calcasieu League for Environmental Action Now (CLEAN); Jon Fisher, Texas
Chemical Council; Matthew Straus, U.S. EPA, Headquarters; and Susan Ferguson, Texas Natural
Resource Conservation Commission (TNRCC).
MORNING SESSION
The first issue introduced by the facilitator was whether waste minimization should be mandatory or
voluntary for industries. Discussion on this topic ensued and then branched off to other related
topics. The topics receiving the most discussion were (1) voluntary versus mandated waste
minimization programs, (2) measuring waste minimization, (3) the roles of stakeholders, (4) the
emphasis on source reduction, and (5) the role of energy recovery. The discussions on those topics is
summarized in the following subsections. Topics discussed only briefly are summarized together in
the section on Miscellaneous Issues.
VOLUNTARY VERSUS MANDATED WASTE MINIMIZATION PROGRAMS
Participants representing citizens stated that industrial waste minimization should be mandated. One
participant noted that industries which use waste as raw materials would not be in favor of having the
waste minimized. They expressed that there is currently no incentive for industry to minimize their
waste and that progress had not been made. Facilities allowed to continue operations for years under
interim status conditions do not make progress in reducing the quantity or toxicity of their waste.
One citizen stated that she had notified EPA of two cases where facilities had falsified their
certifications of compliance with the current voluntary system. One participant asked if waste
minimization could be encouraged by indirect, market-oriented methods, such as making a generator
pay a fee based on how much waste is generated or is released.
1 Ms. goldsmith indicated that she prefers to spell her last name with a lower case "g."
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The TNRCC representative observed that a voluntary program works best when generators calculate
the costs already associated with management of their waste. Once generators are aware of the
magnitude of these costs, they have an incentive to reduce their waste. A waste minimization
program could mandate this cost accounting but allow the generators flexibility in the methods for
achieving waste minimization at their facilities. Such a program is already in place in Texas. That
program also requires facilities to develop pollution prevention plans and set goals for waste
minimization.
Industry representatives stated that they have achieved substantial progress under the current voluntary
system, but recognized that there is a failure to communicate this progress to the public. One
representative reported that the petroleum industry is working together to identify industry-wide
opportunities for source reduction. In general, industry representatives felt that any waste
minimization program would have to be flexible and take a holistic approach to waste minimization.
Narrow efforts that focus on one industry or on the reduction of one source may not have the desired
impact and may have unintended consequences.
MEASUREMENT OF WASTE MINIMIZATION
An industry representative noted that the petroleum industry's waste minimization efforts resulted in
the development of a waste-tracking system for refineries which allows tracking of process waste and
its associated costs in a consistent way that is comparable to other refineries. Another noted that
EPA's Toxic Release Inventory (TRI) reporting system gives recycling credits to facilities whose
high-metal/low British thermal unit (BTU) waste is blended into high-BTU waste and then burned for
energy recovery.
The TNRCC representative felt that a better reporting method needs to be devised. The current
biennial report is not working according to her. A multimedia approach, which blends the reporting
requirements under RCRA, TRI and the Superfund Amendments and Reauthorization Act, should be
developed.
In general, citizens felt that waste minimization should be measured in such a way that facilities do
not receive credit when they transfer the waste and its associated risks into a product or another
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environmental medium. One participant felt that there should be a tracking system for metals because
when metals are transferred into a product, such as cement, they still pose an exposure risk. An
industry representative noted that EPA's study indicated that cement derived from waste-fuel burners
was the same as cement derived from non-waste-fuel burners.
ROLES OF STAKEHOLDERS
Citizens and industry participants both stated that industry has a responsibility for the pollution it
causes and the harm resulting from this pollution. Citizens generally expressed the view that industry
obstructs progress in waste minimization, and that industry should change its attitude. A citizen noted
that manufacturing sectors other than the chemical industry constantly adapt their processes to modify
existing products or develop different products. Only the chemical industry appears to be reluctant to
change its processes. Industry representatives responded that there have been changes, but they have
not been communicated to the public. One stated that industry agrees on the goals of waste
minimization, but may disagree with other stakeholders about paths that should be taken to achieve
those goals.
Several items were identified for EPA to address. The TNRCC representative stated that EPA should
take a look at combining the requirements of different statutes, develop a common list of pollutants to
facilitate a multimedia approach, and take the lead in developing a better reporting system. Citizens
repeatedly pointed out that there is an overcapacity of waste burners and that EPA should impose a
permit moratorium. However, an industry representative noted that total capacity calculations may
overestimate the actual intended operating capacity because an individual facility's operating capacity
is based on feed rates established during its trial burns. These test feed rates are set higher than a
facility would intend to operate under normal, day-to-day circumstances.
The TNRCC representative also noted that the TNRCC currently provides technical assistance to
industries to achieve waste minimization goals.
Citizens expressed that they should play an active role in all stages. One particular concern was
ongoing legislative efforts in Texas to limit public participation. Citizens felt that they could help the
regulatory agencies by influencing the legislatures that write the statutes under which the agencies
operate. One citizen submitted to the panelists a copy of testimony she had presented to Congress. A
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copy of this submittal is contained in Appendix D to this summary report and is available upon
request. Citizens also felt that they could let the industry know directly what their concerns are.
Several citizens expressed skepticism and disbelief that their participation in strategy sessions and
public hearings has any impact on final outcomes. Citizens gave local site-specific examples where
they felt that their input apparently had been ignored. One questioned the usefulness of these
roundtable sessions. EPA was expected to make a May 1994, announcement regarding its combustion
standards. EPA would make this announcement prior to the completion of all the roundtables. One
citizen also criticized granting interim status when it allows a facility to start construction before
addressing citizen concerns on issues such as siting. Citizens stated either that industry has the
"undivided attention" of the regulatory agencies or that, like citizens, the regulatory agencies were
outgunned by industry.
Citizen, industry, and regulatory agency representatives all agreed that stakeholders need to cooperate
to achieve progress and were optimistic that such cooperation was possible.
EMPHASIS ON SOURCE REDUCTION
Citizens generally expressed that source reduction was critical to achieving meaningful waste
minimization. Production of especially toxic compounds, such as dioxin, should be eliminated
entirely. Citizens supported a ban on chlorine production ostensibly because of its association with
dioxin. One citizen stated that EPA could make a positive indication of listening to citizen concerns
by supporting a ban on chlorine production.
Industry participants countered that a reduction in the use of toxic compounds might not result in
waste minimization or risk reduction, and that chemicals like chlorine have beneficial uses. A holistic
approach to waste minimization should be taken so that risks are legitimately reduced and not just
transferred.
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ROLE OF ENERGY RECOVERY
Representatives of burners and industrial furnaces stressed that although energy recovery may not
qualify as waste minimization, its value as a resource conservation method should not be overlooked.
Use of waste fuels in these units replaces the need to use.virgin fuels. Additionally, the end result
from waste burning in cement kilns is a useful product. One representative suggested that
incinerators be prevented from burning certain high-BTU wastes to avoid the waste of resources
that may otherwise be available by recycling the solvents.
Some cement kiln representatives expressed a willingness to meet the same standards as those for
incinerators. One representative stated that standards should be based on best demonstrated available
technology and that facilities that could not meet those standards should be shut down. Another noted
that some cement kilns are already doing testing for dioxin and are voluntarily reducing the metal
content of the waste being accepted. Other facilities are burning waste that is hazardous only because
it is ignitable. The focus, they stated, should be on how safely energy recovery is being
accomplished. They felt that boilers and industrial furnaces (BIF) had received undue attention
because they only treat a very small percentage of the wastes that are generated, most of which are
disposed of by deep well injection.
Incinerator industry and citizen representatives offered a number of statements in response. First, the
burning of waste fuels caused a decrease in the rate of resource conservation through solvent
recycling and reuse. Incinerators use waste fuel for energy recovery similar to cement kilns. Some
cement kilns are inefficient at energy recovery and currently use outdated pollution control
technology. One citizen expressed that cement kilns were burning waste primarily to make a profit,
not to recover energy. He stated that the industry is paid for burning contaminated soils and
absorbents that are dubious replacements for fuel or feedstocks.
Incinerator industry and citizen representatives agreed with the statement that it is important that
energy recovery be done safely, but that this did not equate to waste minimization. Unlike the
cement kiln representative, the incinerator and citizen representatives stated that cement kilns treat a
large percentage of the waste that is not disposed of by deep well injection. Burning the same waste
fuel, cement kilns generate more waste (cement kiln dust-CKD) than incinerator facilities. They also
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observed that this waste is more toxic than ash from incinerator facilities burning the same waste
fuels, and that incinerator wastes are required to be handled in an environmentally protective manner,
unlike CKD, which is unregulated. One citizen stated that some CKD has a higher metal
concentration than incinerator ash. The states' position is that energy recovery should not be a part of
the definition of waste minimization.
The statement that cement kilns were voluntarily reducing the metal concentrations of treated waste
was also contested. A citizen stated that there is a documentable trend of fuel blenders attracting
wastes with more metals and solid content. Another citizen suggested that cement from waste fuel
burners be labeled so that consumers were aware of the potential risk.
MISCELLANEOUS ISSUES
The following issues were briefly discussed during the morning session:
A representative of the Aptus incinerator in EPA Region 7 identified one barrier to
waste minimization by noting that the facility requested a permit modification 9
months ago that would allow the facility to recycle more of its waste solvent. The
facility stated that the Region's review of the request was taking a long time and
wondered if something could be done to process the request more quickly.
Several citizens questioned the impact of the North American Free Trade Agreement
on waste minimization efforts. Some expressed concern that there were provisions
that would allow U.S. companies to generate waste in Mexico and then import it back
into the United States for treatment and disposal.
Citizens also briefly discussed siting issues. They expressed concerns that both
incinerators and BIFs are sometimes located too close to residential areas and that
regulatory agencies do not consider this when they allow facilities to achieve interim
status or when permits are issued.
Citizen and industry representatives discussed appropriate parameters for determining
which waste should be burned in BIFs. A cement kiln representative felt that a
10,000 BTU minimum was inappropriate because kilns in the past have used coal
which has much lower BTU. Both citizen and cement kiln representatives agreed that
other parameters, such as metal concentrations, should play in a role in this
determination. A representative of BIFs, which only burn ignitable waste, wondered
if EPA was working on a rule for "clean fuels." The state representative said that any
waste to be burned would have to have parameters that are equivalent to those of the
material for which it was being substituted. In that context, contaminated soils would
be inappropriate.
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AFTERNOON SESSION
The afternoon session of the Houston Roundtable focused on combustion-related issues. Three
primary topics were discussed during the afternoon. The three primary topics were: (1) combustion
facility standards; (2) permitting and public involvement; and (3) environmental justice. The
discussions on these topics are summarized below.
COMBUSTION FACILITY STANDARDS
Many participants commented about technology-based standards. Industry representatives endorsed
technology-based standards and stated that EPA should establish the highest technology standards for
all hazardous waste combustion devices. They stated that this would provide a "level playing field"
for all sources involved with hazardous waste combustion, rather than having different standards for
different combustion sources. This "level playing field" also includes mobile incinerators, which one
participant stated should meet the same standards as stationary units. Several citizen group
representatives agreed that the standards should be the same for all devices. An EPA representative
explained one reason for supporting technology-based standards was the concern over adequacy of
today's risk assessment process. In this case, a technology-based standard would be the minimum
standard and a risk assessment would be used as a supplement in assessing emissions from the source.
Some citizens group representatives stated that maximum achievable control technology (MACT) was
a poor way to judge what the standards should be. They suggested that only the top two facilities
should be considered when developing the standards, or that EPA should start with the European
Community (EC) standards.
Several participants from both industry and citizen groups endorsed either adopting or at least starting
with (and possibly surpassing) EC standards when developing U.S. technology-based standards. One
U.S. facility representative said it had purchased European technology. Apparently, this
representative believed that if it could meet the EC standard, then all facilities should. One industry
participant stated that was their understanding that the EC standards are not scientifically based. One
industry participant also stated that EPA should think globally when setting standards for hazardous
waste combustion devices because the U.S. is considered a leader in this field, and EPA should assert
this position worldwide; this also would assist U.S. industry in obtaining work internationally.
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There were several comments about the risks of incineration, the adequacy of the risk assessment
tool, and the use of risk assessment during the permitting process. Citizen groups and industry both
stated that risk assessment should be part of the permitting process; however, the faults of the risk
assessment tool make the results questionable at best. One of the areas where citizen groups
expressed the risk assessment tool should be improved was considering background air quality when
evaluating emissions from the RCRA combustion source. Also, citizen groups stated that the risk
assessment tool was too subjective; two different scientists could use the same tool for the same site
and come up with two very different risk assessments. Many citizens groups expressed complete lack
of faith in the current risk assessment process. Their concerns focused on the perceived inadequacy
of the tool, the timing of conducting the risk assessment, and the capacity of the tool to handle
sources located in areas of concern. They stated that the risk assessment should be conducted before
startup of the facility. If an existing facility shows some health-effects problems in the area, then the
facility should be shut-down until a risk assessment is completed. Also, the health-effects levels of
protectiveness should be strict for those facilities near residential areas, or where industry is
concentrated.
Regarding the establishment of limits of toxic metals, one citizen group representative stated that
metals should be banned from hazardous waste incinerators and BIFs.
Also, one incineration industry representative suggested that only high-heating value and low-metal
concentration wastes be allowed to be burned in BIFs.
Another incineration industry representative stated that different particulate matter (PM) standards
should not be set for different combustion sources; all combustion sources should meet the same PM
limit. One cement kiln industry representative stated that although cement kilns could meet the same
PM standard as incinerators, since the majority of PM emissions from cement kilns are raw material
(such as sand, clay, and limestone) and not hazardous waste as for incinerators, cement kilns should
be allowed to operate with a higher PM limit. One citizen group participant stated the need for strict
emission limits for PM with a diameter of less than 10 microns (PM10) from hazardous waste
combustion devices.
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Regarding controls on emissions of dioxins and furans, citizen group representatives stated that dioxin
emissions should not be allowed in any amount from incinerators or BIFs. Several citizen group
representatives commented on the health risks of dioxin emissions. Representatives shared studies on
the adverse impacts of dioxins on animals and commented on the current level of dioxins in the
human body. An industry representative described an industry facility that has measured less than 1
nanogram per dry standard cubic foot (dscf) of dioxin emissions on several stack-testing occasions.
The representative also mentioned that Texas has established a dioxin limit of 10 nanograms per dscf,
which is lower than the EPA-proposed limit and EC limit of 30 nanograms per dscf.
Regarding controls of total congeners compared with toxicity equivalents, one citizen group
representative commented that it was not clear why both approaches could not be used for establishing
limits. Industry representatives expressed their endorsement of using total congeners in setting the
limits.
Regarding control on chlorinated as compared to nonchlorinated wastes, representatives of citizen
groups stated that organochlorides and other halogens should be severely limited or banned as feed for
hazardous waste combustion sources.
Regarding fuel blenders and blender permits, a fuel blending industry representative stated that the
only hazardous wastes being sent to combustion devices from their fuel blending facilities were those
wastes that could not be recycled any further. An EPA representative reminded the audience that fuel
blenders need RCRA permits because they are considered a hazardous waste treatment facility.
However, there is no guidance due out on this issue; EPA probably will issue a reminder
memorandum.
Regarding clean fuels for BIFs, a citizen group representative stated that the term "alternate fuels"
was a misnomer and should not be endorsed by EPA because it made EPA look like a lobbyist for the
cement industry. An industry representative felt there should be some allowance or exemption for
waste that is hazardous only because of ignitability.
A few citizen groups expressed concerns about the adequacy of trial burns. Some felt that the trial
burn provided perfect conditions for burning the waste, not the worst case conditions. Also, there
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were concerns over the infrequency of trial burn testing, the small amount of samples collected, and
high relative error in the sampling and analysis results.
Several citizen groups commented on the need for and usefulness of incinerators and BIFs. Many
citizens commented that they wanted incineration phased out completely and that with today's
technological advancements, there should be better technologies available than incineration. Several
other participants stated that they understand that incineration capacity is in excess of the current
demand. The State of Texas report on cement kilns supported their argument that no more
incineration capacity is needed in the state.
Citizen groups stated that minimizing the amount of waste sent to combustion devices should be the
goal. Another citizen participant stated that waste minimization should be a required, not a voluntary
program, while an industry representative stated that it should be voluntary and dictated by the
market. One industry representative stated that in Europe the only waste burned in combustion
devices is waste that cannot be further recycled; thus it is the residue of a waste.
A citizen group representative expressed that funding should be redistributed to those programs that
endorse pollution prevention rather than those that establish emission standards. Another
representative also inquired whether federal disaster relief monies could be appropriated for areas that
have suffered adverse health affects due to emissions from hazardous waste combustion devices.
Regarding management of residues and safety of products, a citizen group representative stated that
cement kiln dust should be managed as a hazardous waste and that cement made from a facility that
burned hazardous waste should be labeled as such. Industry representatives agreed that ash and
residues from all hazardous waste combustion devices should be regulated as a hazardous waste; this
would help create a "level playing field." Another industry representative stated that EPA should be
very aggressive in ash management so that its policies force the development of alternative
technology.
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PERMITTING AND PUBLIC INVOLVEMENT
Some citizen group representatives stated that clarification is needed on the applicability of the draft
combustion strategy on Superfund incinerators. Also, they stated that more communication is needed
between the RCRA and Superfund programs so that information is shared. They expressed strongly
that interim status should be removed because the units are operating without any oversight and
interim status is in place to support industry. One industry representative stated that all BIFs should
be required to obtain RCRA permits immediately so that they have to meet the same regulations as
hazardous waste incinerators. Citizen group representatives also stated that no more permits should
be issued because EPA already has permitted too many facilities and there is no need for more
permitted facilities.
There were many comments throughout the day on the issue of public involvement. Many citizen
group representatives stated that it is not fair that there are no opportunities for public comment or
hearing during interim status operation; they have to wait until the permitting process begins in order
to provide comment. Citizen groups agreed with the idea of requiring preapplication public meetings
and proposed that a meeting like this take place during interim status. Citizen groups also stated that
there should be a better way of getting information out into the public to help them understand the
technical issues, because the media is only interested in big money stories and not public education.
A citizen group representative also stressed that EPA should take the role of the public during
rulemaking seriously and that public opinion should be considered. A citizen group representative
asked if EPA would accept video testimony. EPA said that video testimony was acceptable.
Industry representatives were supportive of involving the public in the permitting and oversight
process. One representative stated that an open-door policy works best at its site, where the public
regularly comes in for plant visits on Saturdays. Another representative stated that the public should
be involved very early in the risk assessment process so that its specific concerns can be addressed.
Also, a participant stated that the level of trust between the interested parties needs to be improved.
Many participants commented about enforcement activities. Citizen group representatives stated that
those operators with a poor operating history should be phased out and shut down. High costs force
facilities that spend the money to update their controls out of business, while sloppy operators
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continue to operate with outdated and unmaintained equipment at a lower cost. Also, citizen groups
stated that there should be strict enforcement and penalties when facilities are found to be out of
compliance. Many citizen group participants stated that enforcement activities were severely lacking
and that bigger fines would force better operation. One citizen stated that it appeared that EPA and
the states were going after the little guy rather than big industry because EPA was afraid of industry
lawyers. A citizen group representative stated that the responsible facility personnel should be the
staff at the plant, not executives in another state, because the local staff can be held accountable for
what happens in its neighborhood. Finally, one citizen group participant felt that the permitting
agencies should be held accountable for their enforcement actions against repeat offenders. Other
suggestions, such as "three strikes and you're out," were made referring to more shut downs of
facilities with repeated non-compliance records.
An industry representative stated that inspection frequency should be the same for all hazardous waste
combustion devices to help "level the playing field."
Citizen groups were very interested in the possibility of requiring computer monitoring hookups for
all facilities. These groups proposed that all facilities be run with computers rather than outdated
equipment, and they also discussed 24-hour video surveillance of facilities as a possibility. Some
citizen group participants expressed concern over facilities being able to circumvent their computer-
controlled systems.
Citizen group representatives commented that financial assurance and insurance requirements for
hazardous waste combustion facilities were inadequate to cover the costs of cleaning up the operation
should the company become financially insolvent. Other participants stated that the financial
assurance should be reviewed more closely and strictly to ensure the accuracy of the costs.
ENVIRONMENTAL JUSTICE AND SITING
Many comments addressed the issue of environmental justice and siting restrictions for hazardous
waste combustion devices. Many citizen group representatives expressed that it appeared that
industry sited hazardous waste combustion devices in areas of low income or minority residents.
Some citizens completed research in this area. Many participants also stated that siting restrictions
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should apply to existing hazardous waste combustion units, not just the new units. There were many
examples of situations with a density of cement kilns or other industries in an area that would not
otherwise be allowed to construct new units. Many existing facilities (particularly cement kilns) are
very close to sensitive receptors like schools and nursing homes. A citizen group representative also
asked how EPA would handle siting of several cement kilns in an area rich with raw materials.
Citizen group representatives suggested the following ideas for siting restrictions. First, the siting
restrictions must be established on a federal level because politics appear to block setting adequate
restrictions at the state and local level. Second, a buffer zone should be considered, starting at 1 mile
and extending to 5 miles. Third, the population density surrounding the facility should be considered,
and the ability of the facility to evacuate all affected community members should be reviewed. If the
facility cannot adequately evacuate the entire community, then the facility should not be allowed to
operate. The citizens stressed that these restrictions should be applied retroactively to all existing
hazardous waste combustion devices.
A few citizen group representatives stated that the states were not addressing the issue of
environmental justice. As an example, one citizen group representative mentioned that in the State of
Texas the Frost Amendment does not allow cement kilns to operate in areas with a population greater
than 500,000 unless the kiln meets all of the hazardous waste incinerator regulations. As a result,
operators of cement kilns appear to be avoiding this stringent regulation by operating in areas with
populations that are below 500,000.
An industry representative stated that cement kilns are sited based on where the raw materials are,
which is usually not in cities. The representative explained that industry does not decide to burn
hazardous waste in a cement kiln because of the community surrounding the plant. An EPA
representative explained that several task forces have been established to address the issue of
environmental justice.
CONCLUSION
The roundtable was concluded at approximately 5:00 p.m. by William Honker of EPA Region 6.
Mr. Honker thanked all attendees for their participation and time.
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U.S. ENVIROMENTAL PROTECTION AGENCY - REGION V
WASTE MINIMIZATION AND HAZARDOUS WASTE COMBUSTION ROUNDTABLE
APRIL 30, 1994
EXECUTIVE SUMMARY
INTRODUCTION
The U.S. Environmental Protection Agency (EPA) Office of Solid Waste and Emergency Response,
Office of Solid Waste hosted a regional roundtable meeting, April 30, 1994 in EPA Region V.
Through the meeting, EPA sought to stimulate the widest range of involvement and comment from all
participants to assist EPA and the states in developing a national hazardous waste minimization and
combustion strategy that will:
• Better integrate waste minimization into the national hazardous waste management
program under the Resource Conservation and Recovery Act (RCRA)
• Ensure that hazardous waste combustion standards for all RCRA hazardous waste
incinerators and boilers and industrial furnaces are fully protective of human health
and the environment
The roundtable was held in Chicago, Illinois. Representatives of concerned parties were invited to
participate in an open dialogue on hazardous waste minimization and combustion issues. Observers of
the discussions also were offered an opportunity to share their viewpoints. The organization of this
paper is parallel to that of the roundtable.
OPENING PLENARY SESSION
At the opening session of the Region V Waste Minimization and Combustion Roundtable, Margaret
McCue, EPA Region V Office of Public Affairs, welcomed participants and introduced the Region V
Administrator, Valdas Adamkus. Mr. Adamkus offered opening remarks on hazardous waste
minimization and on hazardous waste combustion in particular. Mr. Adamkus emphasized that the
issue of hazardous waste combustion is a serious one and that EPA is here to listen. Ms. McCue
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introduced representatives of EPA Region V and the states. She then introduced Matthew Straus,
Director, Waste Management Division, U.S. EPA Headquarters. Mr. Straus said that EPA
recognizes that the public wants to be involved in the issue of waste minimization and combustion.
He urged participants to use the roundtable as their opportunity to let EPA know what they think. He
said that EPA wished to focus discussion during the roundtable on waste minimization issues that
relate to the draft combustion strategy, rather than focusing on definitions of waste minimization and
pollution prevention. He stated that, under RCRA, waste minimization is source reduction and
recycling. He also stated that the public does not know that there already has been much activity in
the area. EPA must open dialogue with the public, he said. Mr. Straus then introduced
representatives from EPA Headquarters. Valdas Adamkus, with Mr. William Muno, Director, EPA
Region V Waste Management Division, then presented the Region V Special Waste Minimization
Awards. Three awards were made, and two of them were presented to representatives of Enamel
Products and Plating and Mead Packaging Division, who were present at the roundtable.
Ms. McCue then introduced the moderator of the roundtable from PRC Environmental Management,
Inc. The moderator explained the format of the roundtable and the basic rules of conduct. She
explained that the goal of the breakout sessions was to develop recommendations on each topic for
EPA decision makers. After a short break, the breakout sessions began.
BREAKOUT SESSIONS
After the introductory session of the roundtable, the participants were divided into 10 groups, and the
groups were assigned schedules for attending 5 breakout sessions. Every 45 minutes, each group
moved to another breakout session so that each participant could benefit from discussion of all five
topics. The five breakout sessions focused on the following subjects:
• General combustion
• Boilers and industrial furnaces (BIF)
• Waste minimization
• Health effects risk assessments
• Environmental justice
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A summary of the recommendations developed in the breakout sessions is provided.
GENERAL COMBUSTION
In the breakout sessions on general combustion, some of the participants questioned the need for the
combustion strategy. Their concern was based on the fact that combustible wastes make up only one
to two percent of the total amount of hazardous waste that is generated. In general, participants
thought that EPA should refocus its efforts and resources on other programs and regulations. A
common theme in the general combustion sessions was that EPA should improve public participation
and education on the comparative risk process and the general approval and permitting process for
both incinerators and boilers and industrial furnaces (BIFs). Participants thought that EPA standards
should be based on EPA's mission to protect human health and the environment. Participants also
believed that destruction removal efficiency (DRE) may not be the best measure of the performance of
an incinerator. Industry representatives stated that EPA should be doing much more to quickly
develop compound-specific continuous emissions monitors. Last, participants recommended that EPA
consider requiring that regulated industries submit to the regulatory agencies monthly operating
reports that describe any problems that occurred during the reporting period.
BOILERS AND INDUSTRIAL FURNACES
Industry representatives felt that BIFs provide a valuable waste management option, that energy
recovery is a positive effect of their use, and that these positive aspects should be reinforced by EPA.
A common theme was that the involvement of an informed public is essential early in the process,
whether for a specific permit or for the development of future regulations for BIFs. Participants
believed that burning of hazardous waste in BIFs should not be promoted as recycling or as a
beneficial use of hazardous waste. BIFs are a cheaper form of incineration and therefore do not
promote waste minimization. Participants also believed that more regulation of incoming waste to be
used as fuel is needed, particularly regulation of such aspects as specifications, testing, and
enforcement of restrictions on the feed that goes into such units. Last, participants believed that BIFs
should be subject to the same standards as incinerators.
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WASTE MINIMIZATION
Some industry representatives stated that they shouldn't be required to police all generators for
pollution prevention (P2) programs. Some participants also believed that other regulations and
agencies can be barriers to implementation of waste minimization. Some participants mentioned the
pharmaceutical industry as an example. The industry is regulated strictly by the Food and Drug
Administration; such regulation inhibits the industry's ability to substitute one solvent for another.
The participants also recommended that government encourage and promote state and federal
partnerships with industry for waste minimization.
Partnerships for economic and technical assistance could be valuable. Representatives of both the
public and industry recommended that a hazardous waste tax or fee be established and earmarked for
future assistance in waste minimization and in research and development efforts. Participants felt the
need for new measurement tools to examine and track progress in waste minimization. Industry
representatives believed that they have not received adequate recognition and credit for the waste
minimization efforts that they have undertaken to date. Participants recommended that EPA give
priority to risk reduction through waste minimization and recognize that there are multimedia
implications as companies make substitutions of products or raw materials. Finally, participants
recommended that EPA establish tighter regulation of combustion sources, a measure that generally
will drive up unit disposal costs, thus providing a strong economic incentive for the generator
community to implement waste minimization.
HEALTH EFFECTS RISK ASSESSMENTS
Participants raised the issue of whether risk assessment is really the best way to quantify the effects of
facilities on the community. Some participants advocated consideration of ambient data rather than
conduct of a risk assessment. There was consensus that health and safety questions can be answered
only through some type of risk assessment. Participants indicated a high degree of uncertainty about
and lack of trust in the current risk assessment process. Participants believed that until the science of
risk assessment is improved, the process may not be a valid tool in determining whether or not to
approve the operation of a given combustion facility.
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Representatives of public interest groups said that they are not included fully in the decision-making
process by either industry or EPA and that both groups should try to hold forums that will involve the
public from the beginning of the process. Industry representatives seemed to favor technology-based
standards, as opposed to risk-based standards, but they did not suggest that risk-based standards be
eliminated. Participants indicated that some form of balance must be struck. Participants
recommended that risk assessments focus on total environmental effects and total environmental
burdens, rather than simply on the incremental effects of a new source.
ENVIRONMENTAL JUSTICE
Participants recommended that EPA better define environmental justice and its associated terms.
Industry representatives said that EPA should help corporations identify and address issues related to
environmental justice, provide them more tools, and to define measures of success so that a
partnership can be established to address issues of environmental justice in affected communities.
Participants recommended that EPA overhaul the public participation process. The public would like
earlier, more frequent, and more meaningful opportunities to interact with EPA, both on facility-
specific issues and on regulatory developments. Participants also recommended that EPA increase
resource assistance to communities that have concerns about environmental justice. Suggestions
included grants to local communities for establishing a local spokesperson to act as a support person
for the community. Last, participants agreed that EPA should recognize that community members
have a right to choose whether or not they want a combustion source located in their community.
Communities also should not have to choose between protection of public health and economic
development.
CLOSING PLENARY SESSION
At the end of the day, the breakout groups reconvened in a plenary session moderated by Norman
Niedergang, U.S EPA Region V. Mr. Niedergang explained that Mr. William Muno would present
the highlights of the breakout sessions. Mr. Muno reiterated that EPA wishes to improve the
regulatory approach it has taken in waste minimization and combustion. He then provided a summary
of the recommendations generated in the breakout sessions, as discussed above.
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Mr. Muno stressed the importance of involving all stakeholders and pointed out that more industry
representatives than citizen and environmental groups attended the roundtable. He added that,
because of that disparate representation, some of the highlights that might be mentioned in the
summary may be more pro industry, but he reaffirmed that all comments and recommendations will
be submitted and reviewed on the same basis, and that no "voting" had taken place.
Mr. Muno concluded his remarks by emphasizing that every comment that EPA receives is important
and will be considered in future decisions.
After Mr. Muno's summary of the breakout sessions, Mr. Niedergang opened the floor for comments
and questions.
Most of the comments came from representatives of public interest groups. In general, they were
concerned about the operation of facilities near their communities and questioned the EPA about such
issues as enforcement policy, operation under interim status, the roles of states, and public access to
information. Other industry representatives expressed their appreciation of the roundtable, while
certain individuals asked about the future direction of the hazardous waste minimization program, as
well as the need for a combustion strategy.
Matt Straus closed the meeting by thanking the participants for their attendance.
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U.S. ENVIRONMENTAL PROTECTION AGENCY - REGION IV
HAZARDOUS WASTE MINIMIZATION AND COMBUSTION ROUNDTABLE
May 7, 1994
EXECUTIVE SUMMARY
INTRODUCTION
A United States Environmental Protection Agency (EPA) regional roundtable on hazardous waste
minimization and combustion was held in Atlanta, Georgia on Saturday, May 7, 1994 at the Marriott
Marquis Hotel. Members of public interest groups, industry, federal agencies, and regulatory
agencies were invited to attend as: (1) participants in breakout group discussions addressing waste
minimization and combustion or (2) observers of these group discussions.
The meeting began at 9:00 a.m. on May 7, 1994 and concluded at approximately 5:00 p.m.
Approximately 130 people attended. EPA representatives from Region IV and Headquarters also
were present to respond to issues raised. Because of concerns raised by representatives of public
interest groups at the beginning of the meeting, the planned format of the meeting was abandoned and
replaced with a day-long, open discussion.
Transcription services were supplied at the meeting, and supplemental notetaking was provided, as
well. This report summarizes the transcript. Morning and afternoon sessions made up the meeting.
Summaries of the issues discussed at each session are presented in this report.
MORNING SESSION
An EPA contractor called the meeting to order at 9:00 a.m. and announced the availability of
translation services for the roundtable. She then introduced the director of the EPA Region IV Waste
Management Division. At that time, a participant rose and asked to speak. After that participant's
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comments and other comments from the audience, the format of the meeting was modified in response
to the concerns of the representatives of public interest groups. An open forum discussion was held
until adjournment for lunch at approximately 12:30 p.m. A number of site-specific issues were
discussed at length, especially for several commercial facilities and Superfund sites. Some of the
common themes among the site-specific discussions included: public involvement, the permitting
process, Superfund, environmental justice, health effects, enforcement, and compliance with the
Resource Conservation and Recovery Act (RCRA) and the Clean Water Act (CWA). A summary of
the discussion of each of those topics follows.
PUBLIC INVOLVEMENT
Participants representing public interest groups and the citizenry generally stated that they had not
been involved adequately in the planning of this regional roundtable. They expressed frustration over
the presence of industry representatives at the roundtable, as well as the balance between
representatives of industry and those of public interest groups in each of the predetermined breakout
groups. They also expressed frustration about the topics for discussion in the breakout groups.
Finally, concern about the apparent conduct of private meetings between industry representatives and
EPA was expressed. The citizens felt that, as a result of prior meetings, EPA had already decided
upon technology-based standards instead of risk-based standards. The citizens thus concluded that the
roundtable should be deemed a citizens' meeting.
EPA Region IV responded by stating that attempts had been made to involve the public interest
groups in the planning of the roundtable. Public interest groups were identified by soliciting
involvement from the Region IV Office of Environmental Justice, as well as from EPA compliance
officers and permit writers who have been working with environmental groups in individual
communities. EPA further stated that the agenda was based on responses to a questionnaire sent out
by EPA Region IV for participants to complete and return with their responses to the invitation to the
roundtable. The proposed meeting format also was distributed with the invitations.
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THE PERMITTING PROCESS
Representatives of public interest groups raised the issue of the appropriateness of continuing interim
status for hazardous waste incinerators. The citizens questioned whether adequate safety and
assurance of freedom from associated risks can be provided under interim status operations and
whether there are meaningful opportunities for public participation before issuance of final operating
permits. In particular, citizens were concerned about risk to the community from carcinogens and
other contaminants of concern, excessive use of dump stacks, and why incineration facilities continue
to be allowed to operate. EPA also was criticized for pressuring state authorities to expedite the
permit process in relation to the Capacity Assurance Program.
EPA Region IV responded by explaining that operation under a permit is preferable to operation
under interim status because the permit can provide more stringent controls. Thus, the Agency would
like states to make final permit decisions. However, there is no preference for permit issuance over
permit denial. An EPA Region IV representative clarified that authority does exist to shut down a
facility if that facility poses an imminent hazard. He further stated that the Agency will exercise that
authority if it is convinced that an imminent hazard exists.
SUPERFUND
Representatives of public interest groups expressed significant alarm about the minimum protection to
human health and the environment that they perceive is provided at Superfund sites. Citizens were
concerned that incinerators continue to be sited under EPA's emergency removal program, and they
questioned why EPA still is using incineration under Superfund when there is supposed to be a
"moratorium" on incineration. A discussion ensued regarding whether Superfund incinerators are
subject to the requirements of the combustion strategy. EPA Headquarters responded that a policy
dictating how the combustion strategy affects Superfund incinerators will be published soon.
ENVIRONMENTAL JUSTICE
Siting of hazardous waste incinerators, boilers and industrial furnaces, and cement kilns was raised by
public interest representatives as an instance of environmental discrimination. These representatives
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comments and other comments from the audience, the format of the meeting was modified in response
to the concerns of the representatives of public interest groups. An open forum discussion was held
until adjournment for lunch at approximately 12:30 p.m. A number of site-specific issues were
discussed at length, especially for several commercial facilities and Superfund sites. Some of the
common themes among the site-specific discussions included: public involvement, the permitting
process, Superfund, environmental justice, health effects, enforcement, and compliance with the
Resource Conservation and Recovery Act (RCRA) and the Clean Water Act (CWA). A summary of
the discussion of each of those topics follows.
PUBLIC INVOLVEMENT
Participants representing public interest groups and the citizenry generally stated that they had not
been involved adequately in the planning of this regional roundtable. They expressed frustration over
the presence of industry representatives at the roundtable, as well as the balance between
representatives of industry and those of public interest groups in each of the predetermined breakout
groups. They also expressed frustration about the topics for discussion in the breakout groups.
Finally, concern about the apparent conduct of private meetings between industry representatives and
EPA was expressed. The citizens felt that, as a result of prior meetings, EPA had already decided
upon technology-based standards instead of risk-based standards. The citizens thus concluded that the
roundtable should be deemed a citizens' meeting.
EPA Region IV responded by stating that attempts had been made to involve the public interest
groups in the planning of the roundtable. Public interest groups were identified by soliciting
involvement from the Region IV Office of Environmental Justice, as well as from EPA compliance
officers and permit writers who have been working with environmental groups in individual
communities. EPA further stated that the agenda was based on responses to a questionnaire sent out
by EPA Region IV for participants to complete and return with their responses to the invitation to the
roundtable. The proposed meeting format also was distributed with the invitations.
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THE PERMITTING PROCESS
Representatives of public interest groups raised the issue of the appropriateness of continuing interim
status for hazardous waste incinerators. The citizens questioned whether adequate safety and
assurance of freedom from associated risks can be provided under interim status operations and
whether there are meaningful opportunities for public participation before issuance of final operating
permits. In particular, citizens were concerned about risk to the community from carcinogens and
other contaminants of concern, excessive use of dump stacks, and why incineration facilities continue
to be allowed to operate. EPA also was criticized for pressuring state authorities to expedite the
permit process in relation to the Capacity Assurance Program.
EPA Region IV responded by explaining that operation under a permit is preferable to operation
under interim status because the permit can provide more stringent controls. Thus, the Agency would
like states to make final permit decisions. However, there is no preference for permit issuance over
permit denial. An EPA Region IV representative clarified that authority does exist to shut down a
facility if that facility poses an imminent hazard. He further stated that the Agency will exercise that
authority if it is convinced that an imminent hazard exists.
SUPERFUND
Representatives of public interest groups expressed significant alarm about the minimum .protection to
human health and the environment that they perceive is provided at Superfund sites. Citizens were
concerned that incinerators continue to be sited under EPA's emergency removal program, and they
questioned why EPA still is using incineration under Superfund when there is supposed to be a
"moratorium" on incineration. A discussion ensued regarding whether Superfund incinerators are
subject to the requirements of the combustion strategy. EPA Headquarters responded that a policy
dictating how the combustion strategy affects Superfund incinerators will be published soon.
ENVIRONMENTAL JUSTICE
Siting of hazardous waste incinerators, boilers and industrial furnaces, and cement kilns was raised by
public interest representatives as an instance of environmental discrimination. These representatives
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noted the low attendance at the roundtable meeting by minority groups and suggested that EPA is not
doing its job to protect the environment of every living being. EPA Region IV reiterated that the
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Office of Environmental Justice was consulted in order to specifically identify interested minority
participants for inclusion in the roundtable.
HEALTH EFFECTS
Representatives of the public expressed concerns regarding various health problems in their
community, and several representatives noted the proximity of combustion facilities to public schools
in their communities. These representatives questioned whether EPA has provided funds to any
scientific organizations for the purpose of conducting health effects studies in actual communities.
EPA Region IV responded that it has asked the Agency for Toxic Substances and Disease Registry
(ATSDR) to perform health assessments at several sites. Public representatives stated that they do not
have any confidence in the health assessment process administered by ATSDR. They stated that they
believe ATSDR's methodology is skewed because it never proves a relationship between observed
health problems and combustion, and because it does not involve actual medical monitoring of the
local population.
Citizens group representatives also were very concerned about dioxin emissions, especially in light of
the dioxin reassessment. These citizens felt that combustion facilities should be shut down if there is
no safe level of dioxin. An EPA Headquarters representative explained that the dioxin reassessment
is not final yet, although this is a high priority for the Agency. He stated that, when the reassessment
is finalized, it will be used in making further policy decisions.
ENFORCEMENT
Regarding enforcement, citizens expressed concern about continuing violations and the lack of citizen
involvement in enforcement proceedings. Citizens also were concerned regarding the method by
which EPA assesses penalties and the Agency's inability to collect assessed fines. A representative of
EPA explained that Region IV applies the method of calculating penalties that is prescribed by EPA
Headquarters, and he agreed that collecting fines can be a long process. A representative of the state
of South Carolina indicated that the state understands citizens' request for more involvement in
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enforcement actions and stated that South Carolina is examining ways to solicit public involvement
before enforcement actions are settled.
AFTERNOON SESSION
The roundtable was reconvened after a one-hour lunch break. The open forum discussion format
continued. Many topics were discussed during the afternoon. They included: capacity assurance,
risk assessment, the relationship between pollution prevention and waste minimization, performance
standards for incinerators, public involvement, and miscellaneous topics. A summary of the
discussion of each of those topics follows.
CAPACITY ASSURANCE
A representative of an environmental organization commented that states need more clear direction
from EPA regarding the respective roles of incineration and waste minimization in assurances of
waste capacity. He stated that incineration is only appropriate when all adequate waste minimization
options have been exhausted.
RISK ASSESSMENT
Many issues were raised regarding risk assessment and the merits and disadvantages of a risk-based
decision making process. In particular, one representative of an environmental organization supported
a technology-based approach whereby EPA would first set health-based goals and them mandate that
technology achieve those health goals (rather than setting goals at levels of technical capability or
based on risk assessments). The EPA Region IV toxicologist responded that risk assessments tend to
be more conservative than health assessments because risk-based goals are normally so low that health
consequences cannot be measured.
Another expansive discussion ensued about the role of cumulative risk in the risk assessment process.
Many parties representing public interest groups, as well as regulators, expressed a preference for
assessment of cumulative risk when possible. One citizen in particular was concerned about
cumulative effects from incineration of radioactive and hazardous waste.
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Some citizens expressed distrust of risk assessments, noting that EPA has insufficient information on
stack emissions, synergistic effects, and health effects. An EPA Headquarters representative
acknowledged that EPA does not know 100% of the picture, but that risk assessment can be a useful
tool nevertheless.
Finally, on the topic of the timing of risk assessments, representatives of the public felt that it is most
useful to conduct a risk assessment before, rather than after, interim status is granted.
POLLUTION PREVENTION AND WASTE MINIMIZATION
Representatives of public interest groups stated that pollution prevention, rather than waste
minimization, should be the focus of the meeting and the draft strategy. It was suggested that EPA
set specific goals of zero discharge, regulate chemicals by class or category, and apply the
precautionary principles with regard to chemicals. Citizens representatives particularly emphasized
reduction of toxic metals and chlorine. Representatives of public interest groups also emphasized that
pollution prevention can be achieved through consumer education.
An industry representative stated that waste minimization should be treated as more than a policy
issue; it is a moral and legal responsibility. He suggested that EPA provide better coordination
among its program offices to support multimedia aspects of pollution prevention. He also supported
the use of an incentive-based approach, rather than mandatory goals.
PERFORMANCE STANDARDS FOR INCINERATORS
The role of emissions testing in demonstrating compliance with performance standards was discussed.
In particular, a recommendation was made that products of incomplete combustion (PIC) should be
measured as well as dioxins and furans. Citizens also criticized the process of conducting trial burns.
They indicated that trial burns are not representative of true operations because facilities have the
opportunity to optimize operations in advance of trial burns. These citizens suggested that surprise
tests by EPA would be more effective. An EPA Headquarters representative stated that surprise tests
are generally not feasible because of the time required to set up the sampling equipment. However,
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he noted that EPA is providing funding to support more research and development efforts related to
continuous monitoring.
PUBLIC INVOLVEMENT
Several issues related to public involvement were discussed during the afternoon session. Those
issues are summarized below.
Representatives of public interest groups queried EPA on the agenda for a meeting to be held between
EPA and environmental organizations on May 9, 1994. EPA Headquarters representatives responded
that the purpose of the meeting is to make the public aware of a study that has been performed in
support of upgraded performance standards for combustion facilities.
Representatives of public interest groups emphasized to EPA the importance of communication with
grassroots organizations as well as environmental organizations of national caliber. There was
general encouragement that EPA hold more citizens meetings without industry.
One representative of a public interest group suggested that EPA consider setting up a hotline to
address concerns like those expressed at this meeting. An EPA public affairs representative provided
a hotline number that already has been established in Region IV.
Another public interest representative admonished EPA for its slowness in responding to requests for
information under the Freedom of Information Act.
MISCELLANEOUS TOPICS
Representatives of the public expressed concern about coordination of permits with the U.S. Fish and
Wildlife Service, under the Endangered Species Act.
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CONCLUSION
The meeting was drawn to a close by Michael Shapiro, Director of the Office of Solid Waste, EPA
Headquarters. He expressed appreciation that citizens had participated so actively in the discussions
and summarized what EPA had heard at the meeting. He thanked all participants for their attendance
and assured them that the Agency would be working hard to respond to their concerns.
WRITTEN COMMENTS
A number of participants submitted written comments after the roundtable expressing disappointment
that the planned meeting format and agenda were not followed.
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