v>EPA
United States
Environmental Protection
Agency
EPA 100-B-93-002
April 1993
Office Of The Administrator (1102)
: OPPT (TS-792)
Source Reduction
Review Project
A Status Report-
Spring 1993
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1 I "his status report summarizes the progress of EPA's Source
JL Reduction Review Project through Spring 1993, and
describes many of the approaches that the Agency is
considering incorporating into 10 specific regulations expected
to be proposed during 1993 and 1994. Highlighted in the text
are the project's overall accomplishments to date, ongoing
efforts to introduce source reduction concepts into individual
rules and opportunities to address environmental impacts to the
air, water and land in a coordinated fashion.
Industrial Category
Pulp and Paper
Production
Pesticide
Formulating
Pharmaceuticals
Production
Printing/Publishing
(Coating)
Degreasing
Operations
Metal Products
and Machinery
Polystyrene
Production
Styrene Butadiene
Latex & Rubber
Production
Date of Proposed
Air Toxics (MACT)
Regulation
1993
1996
1993
1993
1993
Date Of Proposed
Water Regulation
(Effluent Guideline)
1993
1994
1994
1994
1994
Date of Proposed
RCRA Hazardours
Waste Regulation1
1994 (A)2
1993(C)
1994(B)
1994(B)
1 Hazardous Waste Listing of specific wastes. A) Dioxin; B) Solvents Ill/ll; C) Carbamates. The solvent listing
determination may indirectly affect many uses of the solvents.
2 May or may not occur, depending on outcome of Office of Water regulations
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To find out more about this project each of EPA's participating
offices have designated a SRRP Coordinator. They are:
Office of Air and Radiation
Jack Edwardson, 919-541-4003
Office of Enforcement
Charlie Garlow, 202-260-1088
Office Solid Waste
Ed Abrams, 202-260-4800 (listing determinations)
Donna Perla, 703-308-8402 (waste minimization)
Office of Policy, Planning & Evaluation
Wendy Cleland-Hamnet, 202-260-4001
Office of Pollution Prevention & Toxics
Julie Shannon, 202-260-2736 (overall coordinator)
Ward Penberthy, 202-260-1664
Office of Research & Development
Paul Shapiro, 202-260-4969
Office of Water
Vivian Daub, 202-260-6790
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What is the
Source Reduction
Review Project?
EPA's Source Reduction Review Project (SRRP) is
a major, agency-wide initiative that is
demonstrating the value and feasibility of taking a
source reduction approach in designing
environmental regulations. The Agency is
conducting an in-depth analysis of source
reduction measures and cross-media issues in the
development of 24 rule-makings for air toxics
(MACT standards), water pollution (effluent
guidelines) and hazardous wastes (listing
determinations).
What is the goal
of SRRP?
The project's goal is to foster the use of source
reduction measures as the preferred approach for
achieving environmental protection, followed in
descending order by recycling, treatment, and as a
last resort, disposal. Initially, the project will
ensure that source reduction measures and multi-
media issues are considered in the development of
24 forthcoming air, water, and hazardous waste
standards affecting 17 industrial categories. For
the long term, EPA hopes that SRRP will provide
a model for the regulatory development efforts in
all of its programs.
Why was the SRRP
established?
Section 4(b) of the Pollution Prevention Act (PPA)
of 1990 (P.L. 101-508) requires EPA to "review
regulations of the Agency prior and subsequent to
their proposal to determine their effect on source
reduction." Source reduction means reducing the
amount of a pollutant that enters a waste stream
or that is otherwise released into the environment
prior to out-of-process recycling, treatment, or
disposal.
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While source reduction approaches have been
incorporated into standards in the past, the
emphasis of the Source Reduction Review Project
will be on rigorous technical and economic
analysis as the underpinning for incorporating
source reduction into regulations, and on a
coordinated multi-media approach to rule-making.
While it is the individual responsibility of each
of EPA's offices to adhere to Section (4)b of the
PPA, the SRRP allows EPA to focus its review on
a list of regulations mandated by statute under
the Clean Air Act, Clean Water Act or Resource
Conservation and Recovery Act during the earliest
stages of their development and to test different
approaches to fostering source reduction as the
preferred means of achieving environmental
protection.
What are its
successes
to date?
In General:
• EPA has committed over $1.5 million in the
current fiscal year to support the project. The
President's fiscal year 1994 budget proposes $2.5
million to EPA's Office of Research Development
for continued work on SRRP.
• The Deputy Assistant Secretary of Defense for
the Environment has asked each military service
that is engaged in clean technology research to
share their research findings with EPA. SRRP
industrial categories being examined by the
Department of Defense include printing, paint
stripping, degreasing, and metal products and
machinery.
• The New Jersey Institute of Technology's
Emissions Reduction Research Center is working
to form an industry group to sponsor research on
pollution prevention technologies for a future air
toxics standard.
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• The Office of Water's Effluent Guidelines Task
Force has established a subcommittee to address
cross-media issues and pollution prevention. The
group will be advising EPA on incorporating
these considerations into the development of
water pollution standards.
• EPA is considering targeting pollution
prevention technical assistance to small businesses
through a cooperative project with the
Department of Commerce's Manufacturing
Technology Centers.
• EPA's Office of Pollution Prevention and Toxics
is investigating the feasibility of using the Toxics
Substances control Act (TSCA) to require public
reporting of media transfers that result when
treatment and disposal are the chosen pathway for
compliance with effluent guidelines.
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For Specific Rules:
Pulp and Paper Effluent Guideline
and Air Toxics (MACT) Standards
Rule Development
• Development of air and water standards will be
integrated for kraft and sulfite mills that bleach;
• The level of performance for the air and water
standards is likely to be based on pollution
prevention process changes along with add-on
controls (though not requiring a specific
technology for compliance).
• One of the points of compliance being
considered for the effluent guidelines may be in-
process (at the end of the bleach line) in addition
to end-of-the-pipe (post treatment or after
pretreatment);
• For sulfite mills, EPA is evaluating totally
chlorine-free (TCP) options as applied in Europe.
EPA is considering language in the preamble
addressing long-term goals for pulping and
bleaching (including TCP for paper-grade kraft
mills). EPA expects to gather additional data on
process changes implemented at mills after the
rule is proposed.
• EPA's regulatory development workgroup is
considering providing incentives in the proposed
rule for kraft mills to go to TCP bleaching.
Multi-Media Issues
• Benefits to sludge management that result from
a cleaner sludge exiting low-chlorine bleaching
processes will be considered in the integrated rule.
• Process changes used to comply with effluent
guideline are also likely to result in high air
emission reductions.
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Contact: Don Anderson, Office of Water (OW)
202-260-7137
Penny Lassiter, Office of Air and Radiation
919-541-5396
Jocelyn Woodman, Office of Pollution
Prevention And Toxics (OPPT) 202-260-4418
Tom Holdsworth, Office of Research and
Development (ORD), 513-569-7675
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Degreasing MACT Standard
Rule Development
• The regulatory option being considered is an
equipment/work practice standard with a solvent
consumption indicator, and, as an alternative
standard, an idling emissions limit with an overall
solvent use limit. Almost all measures that are
being considered as the basis of the equipment
standard option are source reduction measures.
The alternative standard would provide flexibility
to encourage technological innovation.
Rule Implementation
• EPA is developing a database system (Solvent
Alternative Guide- SAGE) to assist companies,
state and local technical assistance programs and
others in the case-by-case evaluation of alternative
cleaning systems.
Multi-Media Issues
• Analysis of potential substitutes to halogenated
solvents, such as aqueous and semi-aqueous
systems, will inform industry of any potential
cross-media impacts that might result from
solvent substitution.
Contact: Paul Almodovar, OAR, 919-541-0283
Eun-Sook Goidel, OPPT,202-260-3296
Chuck Darvin, ORD, 919-541-7633
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Pesticide Formulating Effluent
Guideline
Rule Development
• EPA is examining membrane technologies for
application to rule development. Membrane
technologies may allow for the separation of
dilute quantities of pesticides from wastewater,
which permits the pesticides to be recycled back
into the process as well as allowing the water to
be reused within the plant.
• Other potential source reduction approaches
being considered include: 1) in-process
housekeeping changes that reduce water use; and
2) recovery of active ingredient through improved
cleaning of equipment interiors.
• EPA is investigating how to incorporate the
cost-savings that result from product recovery
measures used to comply with the rule in the
economic analysis done to support the rule.
Rule Implementation
• This category is primarily comprised of small
businesses which would likely benefit from
pollution prevention technical assistance.
• EPA outreach materials will include a
comparative cost analysis of pollution prevention
measures versus add-on controls such as off-site
treatment to inform industry of the economic
benefits of source reduction measures.
Contact: Jan Goodwin, OW, 202-260-7152
Marty Spitzer, OPPT, 202-260-4342
T. David Ferguson, ORD, 513-569-7518
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Pharmaceuticals Effluent
Guideline and MACT Standards
Rule Development
The Office of Water's industrial survey is now
being analyzed to look for pollution prevention
practices at existing facilities.
Rule Implementation
• EPA and FDA are working together to identify
areas where expedited review of supplemental
drug applications for process changes might be
possible.
Multi-Media Issues
• While the two standards will not be integrated
(due to a court ordered deadline for the effluent
guideline), the Office of Water, which is further
along in rule development, is sharing its data with
the Office of Air and Radiation. To the extent
possible, the proposed effluent guideline will
provide information on the air office's strategy for
its rule so that facilities can anticipate cross-media
issues.
Contact: Frank Hund, OW, 202-260-7124
Randy McDonald, OAR, 919-541-5402
Julie Shannon, OPPT, 202-260-2736
Thomas Holdsworth, ORD, 513-569-7675
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Metal Products and Machinery
Effluent Guideline
Rule Development
• EPA is attempting to develop a mass-based
standard instead of a concentration-based
standard which will promote water conservation
and which may also encourage reduction in
loadings of metals.
• EPA is looking into the applicability of BMPs
(Best Management Practices) in place of, or in
addition to, numerical standards in effluent
guidelines program to promote the use of good
housekeeping measures. Management practices
and/or BMPs could also be a vehicle through
which pollution prevention planning or waste
tracking could be required.
• EPA is costing in-process pollution prevention
technologies and will account for benefits such as
reduced raw material purchases and downsizing
of treatment systems.
Rule Implementation
• This category is primarily comprised of small
businesses which would likely benefit from
pollution prevention technical assistance.
Multi-Media Issues
• EPA is studying the treatability of terpenes that
are used to replace chlorinated organics in metal
degreasing.
Contact: Bill Cleary, OW, 202-260-9817
Jocelyn Woodman, OPPT, 202-260-4418
Glen Shaul, ORD, 513-569-7408
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Carbamates Listing
Rule Development
• EPA is analyzing wastestream data to evaluate
the technical/economic feasibility of recovery of
product from wastestreams. At one facility
studied, with a 98% efficiency in recovery of
product, the value of the remaining 2% of product
that is discarded with the waste stream was
roughly $1.6 million.
Multi-Media Issues
• Several of the process wastes from the
production of carbamates are wastewaters that are
discharged from Publically Owned Treatment
Works (POTWs), and thus subject to regulation
under the CWA. As part of the listing process, the
Office of Solid Waste (OSW) is analyzing these
wastes to determine what risks they might pose to
aquatic organisms, when managed under current
practices. Given the RCRA statutory exclusion for
wastewaters discharged to POTWS, a hazardous
waste listing in this instance would have little
substantive effect, regardless of the degree of
aquatic risks found. In the event that significant
risks from these wastes are identified, a
coordinated effort is contemplated among OSW,
OW, and the facilities involved, in order to
explore the possibilities for reducing their
generation.
Contact: John Austin, Office of Solid Waste, 202-
260-4789
Haile Marian, OSW/Waste Minimization,
703-308-8439
Ed Weiler, OPPT, 202-260-2996
Glen Shaul, ORD, 513-569-7408
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Solvents Listing
Rule Development
• The Office of Solid Waste included a source
reduction section in its industrial survey. Given
the timeframe for the rule-making, however, OSW
is uncertain as to whether the rule-making will be
specially designed to promote pollution
prevention.
• EPA is using OPPT's Design for the
Environment use cluster scoring system to
determine relative risk of the chemicals in this
listing.
Multi-Media Issues
• The listing may apply to collected air releases
and solvents in wastewater treatment sludges.
Contact: Ron Josephson, OSW, 202-260-6715
Haile Marian, OSW/WM, 703-308-8439
Paul Quillen, OPPT, 202-260-7689
Dennis Timberlake, ORD, 513-569-7547
Michael Dourson, ORD, 513-569-7533
Polystyrene Production
Rule Development
• EPA is analyzing pollution prevention
information collected from its industrial survey
request.
Contact: Les Evans, OAR, 919-541-5410
Conrad Flessner, OPPT, 202-260-3918
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Styrene Butadiene Latex
Production MACT
Rule Development
Wherever possible, pollution prevention
technologies will be considered in setting the final
MACT standard, considering such factors as
economics and technical feasibility. Among the
pollution prevention approaches under
consideration are: equipment changes such as
improved pump seal and floating roofs and leak
detection and repair (LDAR).
Contact: Les Evans, OAR, 919-541-5410
Nhan Nguyen, OPPT, 202-260-0697
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Printing MACT
Rule Development
EPA is in the process of collecting information on
this large industrial category.
Rule Implementation
EPA's Office of Research and Development is also
evaluating barriers to the use of radiation-cured
and water-based coatings. ORD is also
conducting a pollution prevention evaluation of
innovative ink feed systems.
Contact: Dave Salman, OAR, 919-541-0859
Julie Shannon, OPPT, 202-260-2736
Carlos Nunez, ORD, 919-541-1156
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Wood Furniture
Rule Development
EPA is exploring a regulatory negotiation for
development of the MACT standard and the
Control Techniques Guidance (for VOCs). A
pollution prevention representative (Office of
Waste Reduction, State of North Carolina) will
likely serve on the regulatory negotiation advisory
committee.
Contact: Madeline Strum, OAR, 919-541-2382
George Semeniuk OPPT,202-260-2134
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