&EPA
United States
Environmental Protection
Agency
Office of the Administrator
& Office of Pollution
Prevention and Toxics
August 1992
EPA100/R-92/002
Source Reduction
Review Project
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W/mf is the SRRP?
'
F~~| r""lhe Source Reduction Review
Project is a new initiative of the
_1_ U.S. Environmental Protection
Agency to evaluate pollution preven-
tion alternatives during the regulatory
development process.
Wlwt is the goal of the SRRP?
The goal of the SRRP is to foster the
use of source reduction measures as
the primary means of achieving
compliance. Initially, the project focus
is to ensure that source reduction
measures and multi-media issues are
considered during the development of
air, water, and hazardous waste stan-
dards affecting certain industrial
categories. For the long term, the
project aims to provide a model for the
regulatory development process
throughout EPA.
these approaches have been incorpo-
rated into standards in the past. The
emphases of the Source Reduction
Review Project will be on rigorous
technical 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 responsi-
bility 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 key list of regulations mandated
by statute under the Clean Air Act,
Clean Water Act or Resource
Conservation and Recovery Act
(RCRA) during the earliest stages of
their development and to test different
approaches to fostering source reduc-
tion as the primary means to achieving
compliance.
Wtiy 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 deter-
mine 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.
§ Methods for achieving source
reduction include material substitu-
te-, tion, process changes, product
•— reformulation, improved efficiency,
^ and improved maintenance. Many of
i <.oENCY
WASHINGTON. D.C. 20460
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WJiat industrial/process cate-
gories will the SRRPfocus on?
EPA will focus initially on the follow-
ing industrial/ process categories:
Acrylic Fibers/Modacrylic Fibers
Degreasing Operations
Integrated Iron and Steel
Manufacturing
Metal Products and Machinery
Paint Stripper Users
Paints, Coatings, and Adhesives
Manufacturing
Paper and Other Web Coatings
Pesticide Formulating
Pharmaceuticals Production
Plywood/Particle Board
Manufacturing
Polystyrene Production
Printing/Publishing
Pulp and Paper Production
Reinforced Plastic Composite
Production
Rubber Chemicals Manufacturing
Styrene Butadiene Latex and
Rubber Production
Wood Furniture Manufacturing
In addition, since RCRA listing
determinations focus on particular
wastestreams that cut across indus-
tries, the project also focuses on the
following listings that overlap with
the 17 industrial categories: carba-
mates, dioxin, paint waste, and
solvents II/III.
For a technical description of the
types of facilities and wastestreams
covered by the SRRP, see pages 8-12
below.
What types of regulations are
involved?
This project will not develop any new
regulations; instead, the SRRP process
is applied to standards already sched-
uled for development, such as air
toxics standards (often referred to as
MACT standards), effluent guidelines
for water, and hazardous waste
RCRA listing determinations.
Who benefits from SRRP?
Industry, EPA, and ultimately the
environment will benefit from the
SRRP. Industry may find that compli-
ance with standards can be achieved
more cost-effectively through source
reduction measures that satisfy multi-
ple regulatory requirements; that the
"transaction costs" of dealing with the
government will be reduced in a situ-
ation of coordinated rulemaking and
permitting; and that early notice of
EPA's regulatory schedule allows for
long-range planning and investment
in new technologies.
EPA expects that an integrated
approach to regulation will result in a
more efficient rule-making process.
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Finally, the SRRP process will
benefit the environment by helping to
eliminate cross-media transfers of
pollutants that can occur when regu-
lations are written with a single-
media, end-of-pipe approach. Source
reduction measures are also expected
to result in reduced risks to public
health and the environment and
conservation of energy and raw mate-
rials.
What is the relationship of the
SRRP to existing law?
SRRP implementation is consistent
with EPA's statutory responsibilities.
The Pollution Prevention Act requires
EPA to examine the impact of
proposed regulations on source
reduction; other statutes provide EPA
the authority to use that information.
Most performance standards allow
flexibility in how compliance is
achieved rather than prescribing
specific measures to be taken (except
in case of work practice require-
ments). Thus, air toxics rules and
effluent guidelines, which will be
written as performance standards,
will not prescribe source reduction
measures. Further, to be considered
as the basis of a performance stan-
dard, source reduction measures must
compete with end-of-pipe controls
within the statutory requirements for
"best" performance.
How will the Source Reduction
Review Project operate?
The project builds on EPA's existing
regulatory development process but
emphasizes two particular principles:
(1) an intensive analysis of source
reduction measures in addition to
traditional end-of-pipe controls;
and
(2) the consideration of cross-media
effects and impacts on energy,
water, and other resources when
developing industrial standards.
EPA's analyses will be consistent
with its statutory responsibilities and
will take into account other environ-
mental management options (e.g.
recycling, treatment, disposal) as
expressed in the PPA's hierarchy of
environmental management practices.
Here are the three main steps
through which the Source Reduction
Review Project operates:
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Step One: Conduct Source
Reduction Analyses
EPA identifies and evaluates source
reduction measures through industry
surveys, studies and additional data
collection activities. Source reduction
measures are evaluated along with
end-of-pipe control measures. Factors
to be considered include conformance
with statutory authority, performance
in all media, costs, and energy and
raw material requirements.
Step Two: Use the Analyses in
Developing Regulations
Where consistent with its statutory
mandates, EPA will use the analyses
to encourage source reduction when
developing regulations affecting any
of the 17 identified industry/process
categories. The analyses may support
the development of:
• Standards which can be based on
or met through source reduction
(although specific source reduction
technologies would not be
mandated);
• Regulatory incentives for adopting
source reduction measures as an
alternative means of compliance;
and
• Guidance materials that accom-
pany the final rule-making to
educate permit writers and indus-
try about the performance and cost
of source reduction measures.
Step Three:
Implement the Regulation
EPA will provide permit writers with
training and assistance to expedite the
review and approval of source reduc-
tion measures as a means of compli-
ance. EPA will offer targeted
assistance to industry to help identify
and implement source reduction tech-
niques that offer the most cost-effec-
tive means of compliance.
As an example of the SRRP in
action, EPA has formed a printing
industry cluster. Through the cluster,
EPA will coordinate the regulations
across programs that are under devel-
opment or planned, undertake a
cooperative initiative with the indus-
try to investigate substitutes for the
toxic chemicals currently used by the
industry, and conduct an integrated
permitting pilot project with one or
two states that will include the volun-
tary collection of materials accounting
data as a substitute for multiple
reporting requirements.
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What are EPA's internal
commitments to the SRRP
process?
EPA has committed to the following
principles and activities for coordinat-
ing the SRRP process and for
improving data collection and analy-
sis:
Organization:
• Each of the relevant EPA offices
will designate SRRP coordinators
to provide overall coordination of
all priority rules within their
programs and to serve as liaisons
with counterparts in other
programs.
• EPA will form rule development
work groups prior to survey design
or collection of data. EPA's Office
of Regulatory Management and
Evaluation will ensure that work
groups are formed in a manner
consistent with SRRP principles
and that draft proposed rules are
consistent with SRRP principles.
• EPA's Office of Pollution
Prevention and Toxics (OPPT) will:
(a) assign a staff lead to each rule-
making project; (b) track the status
of rule-makings and pollution
prevention analyses; and (c)
develop a training course for staff
involved in regulatory develop-
ment.
• EPA's rule-making work groups
will include representation from
multiple media program offices as
well as from OPPT and the Office
of Research and Development
(ORD).
Rule Development:
• To improve collection of source
reduction data, EPA will incorpo-
rate source reduction and
multi-media release questions into
industrial surveys. Surveys will be
written to identify those who have
eliminated pollutants and ask how
the generation of pollution was
eliminated.
• To improve coordination of data
collection and minimize the burden
on industry, EPA will coordinate
its industrial surveys across media
programs where industrial sources
face multiple regulations.
• OPPT is conducting substitutes
analyses of the chemical groups
used by the industrial categories.
• ORD plans to: (a) assist in collec-
tion of information on source
reduction measures; (b) demon-
strate the efficiency of source
reduction technologies, both exist-
ing and advanced; (c) explore the
development of measurement
techniques for evaluating the
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performance of source reduction
measures; and (d) make source
reduction information on indus-
trial/process categories available
through the Pollution Prevention
Information Clearinghouse.
Rule Implementation:
• EPA will provide information and
training to help permit writers
identify and encourage use of
source reduction approaches to
achieve compliance.
• EPA will include information in the
development of enabling docu-
ments that accompany
performance standards on the
costs/multi-media benefits of
source reduction measures identi-
fied through the SRRP process.
• EPA will explore the feasibility of
an expedited permit process for
source reduction modifications
taken to comply with regulations
affecting the SRRP industry cate-
gories.
How can industrial facilities get
involved?
EPA encourages industry to help
further the goals of the SRRP in
several ways:
• First, by getting in touch with the
contacts listed below to let EPA
know what types of source reduc-
tion projects are underway and the
successes that have been achieved.
• Second, by considering a joint
project with EPA such as testing
the performance of source reduc-
tion technologies, developing
measurement techniques, or
collecting other specific data on
source reduction measures.
Whom should I contact about
SRRP?
The SRRP Coordinators for each
participating EPA Office are as follows:
Office of Air and Radiation
Jack Edwardson, 919-541-5573
Tim Mohin, 919-541-5349
Office of Enforcement
Charlie Garlow, 202-260-1088
Office of Solid Waste
Ed Abrams, 202-260-4800
Donna Perla, 703-308-8402
Office of Policy, Planning &
Evaluation
Wendy Cleland-Hamnet,
202-260-4001
Office of Pollution Prevention &
Toxics
Julie Shannon, 202-260-2736
Ward Penberthy, 202-260-1664
Office of Research & Development
Paul Shapiro, 202-260-3547
Office of Water
Vivian Daub, 202-260-6790
Region 9
Dan Reich, 415-744-1336
The chart on the following page
presents a detailed listing of proposed
regulation dates and EPA contacts for
each industry/process category.
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Date of Proposed Regulations and EPA Contacts
Industrial/Process Category
Acrylic Fibers/Modacrylic Fibers
Degreasing Operations '
Integrated Iron and Steel Mfg.
Metal Products and Machinery
Paint Stripper Users
Paints, Coatings, Adhesives Mfg.
Paper and Other Webs
Pesticide Formulating
Pharmaceuticals Production
Plywood Particle Board Mfg.
Polystyrene Production
Printing/Publishing
Pulp and Paper Production
Reinforced Plastic Composite Prod.
Rubber Chemicals Mfg.
Styrene Butadiene Latex & Rubber
Wood Furniture Mfg.
Date
1996
1993
1996
1996
1996
1996
1996
1999
1993
1993
1993
1996
1996
1993
1993
Air1
Bob Rosensteel/91 9-541 -5608
Paul Almodovar/91 9-541 -0283
Jim Maysilles/91 9-541 -3265
Jim Berry/91 9-541 -5605
Jim Berry/91 9-541 -5605
Jim Berry/919-541-5605
Bob Rosensteel/91 9-541 -5608
Jim Berry/91 9-541 -5605
Les Evans/91 9-541 -5410
Dave Salman/919-541-0859
Penny Lassiter/91 9-541 -5396
Bob Rosensteel/91 9-541 -5608
Les Evans/91 9-541 -5410
Les Evans/91 9-541 -5410
Karen Catlett/91 9-541 -0835
Date
1994
1994
1994
1993
Water2
Woody Forsht/202-260-71 90
Marv Rubin/202-260-71 24
Frank Hund/202-260-71 82
George Heath/202-260-71 65
Date
1994B
1994B
1994B
1996B
1996D
1994B
1993C
1994 B
1994B
4 A
1994 B
1994B
1994B
1994B
Hazardous Waste3
Ron Josephson/202-260-6715
Ron Josephson/202-260-6715
Ron Josephson/202-260-6715
Ron Josephson/202-260-6715
Ed Abrams/202-260-4800
Ron Josephson/202-260-6715
John Austin/202-260-4789
Ron Josephson/202-260-6715
Ron Josephson/202-260-6715
David Carver/202-260-6775
Ron Josephson/202-260-6715
Ron Josephson/202-260-6715
Ron Josephson/202-260-6715
Ron Josephson/202-260-6715
1 Air rules refer to MACT standards under the Clean Air Act. Dates were proposed in the Federal Register in February 1992.
2 Water rules refer to effluent limitations guidelines.
3 Hazardous Waste refers to RCRA listings of specific wastestreams: (A) Dioxin; (B) Solvents ll/lll; (C) Carbamates; (D) Paint Wastes. The solvent listing determination may indirectly affect many
uses of solvents.
4 May or may not occur, depending on outcome of Office of Water regulations.
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Industrial/Process Category Descriptions
Acrylic Fibers/Modacrylic Fibers
Production
Integrated Iron and Steel
Manufacturing
This category includes any facility
engaged in manufacturing fibers in
which the fiber-forming substance is
any long-chain, synthetic polymer
composed, at least 85 percent by
weight, of acrylonitrile units. The
category includes polymerization
reactions, wet solvent spinning, dry
solvent spinning, solvent recovery,
washing, filtration, stretching, cutting
(into staple), crimping, twisting,
baling, drying, and packaging
processes.
Degreasing Operations
The degreasing operations (halo-
genated solvent cleaners) source
category includes any facility engaged
in any type of solvent cleaning activ-
ity occurring within a solvent cleaning
unit; it does not include wipe cleaning
or other cleaning occurring outside
the confines of a cleaning unit. This
source category includes, but is not
limited to, the following solvents or
solvent blends: 1,1,1-trichloroethane
(TCA), trichloroethylene (TCE),
perchloroethylene (PCE), and methyl-
ene chloride (MC). These activities
include, but are not limited to, open
top vapor cleaning, cold batch clean-
ing, and conveyorized (cold and
vapor) cleaning. The sizes of the units
range from bench-top units to large,
industrial units. The emission points
to be considered for regulation in this
source category include equipment
leaks and process emissions.
This category includes any integrated
iron and steel facility engaged in
producing steel. Integrated iron and
steel manufacturing includes the
following processes: sinter produc-
tion, iron production, iron preparation
(hot metal desulfurization), steel
production, semifinished product
preparation, finished product prepa-
ration, and handling and treatment of
raw, intermediate, and waste materi-
als. The iron production process
includes the production of iron in
blast furnaces by the reduction of
iron-bearing materials with a hot gas.
The steel production process includes
basic oxygen furnaces and open
hearth furnaces.
Metal Products and Machinery
Facilities that process metal parts,
metal products, and machinery,
including manufacture, assembly,
rebuilding, repair and maintenance.
The Phase 1 effluent guideline rule
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will tentatively cover seven major
industrial groups: aircraft; aerospace;
hardware (including machine tools,
screw machines, metal forging and
stamping, metal springs, heating
equipment, and fabricated structural
metal); ordnance; stationary industrial
equipment (including electrical equip-
ment); mobile industrial equipment;
and electronic equipment (including
communication equipment).
Paint Stripper Users
The paint stripper users category
includes any facility engaged in
commercial or industrial paint strip-
ping. The paint stripping process
involves four basic steps. First, paint
stripper is applied to the surface to be
stripped. Second, the stripper is
allowed to penetrate or dissolve the
coating. Third, the paint and residual
stripper are removed from the treated
surface. Finally, the stripped paint is
cleaned up and disposed. The cate-
gory includes, but is not limited to,
original equipment manufacturing
and maintenance facilities engaged in
the paint stripping of paint spray
booths, paint stripping in large open
areas, paint stripping in dip tanks,
and other high volume/high usage
activities that use methylene chloride
or other hazardous air pollutants
(HAPs) in the removal of paints or
other coatings.
Paints, Coatings and Adhesives
Manufacturing
For the air toxics standard, this cate-
gory includes any facility engaged in
the manufacture of paints, coatings,
and adhesives without regard to the
particular end-uses or consumers of
such products. The manufacture of
these products may occur in any
combination at any facility.
For the RCRA listing determina-
tion, paint production wastes include
the following wastes: solvent cleaning
wastes (K078), water/caustic cleaning
wastes (K079), wastewater treatment
sludge (K081), and emission control
dust or sludge (K082) for which list-
ings were suspended on January 16,
1981 (46 Fed. Reg. 4614), and off-spec-
ification production wastes.
Paper and Other Web Coatings
This category includes any facility
engaged in the coating of paper, plas-
tic film, metallic foil, and other web
surfaces. The category may include,
but is not limited to, decorative coat-
ings on gift wraps or packaging. This
category does not include paper or
other web printing operations covered
under the source category of print-
ing/publishing.
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Pesticide Formulating
Pharmaceuticals Production
This category includes facilities that
purchase bulk quantities of concen-
trated pesticides ("technical grade")
from manufacturers and formulate
into final products for use by applica-
tors/consumers; and facilities that
package or re-package final products
for distribution and marketing.
For the RCRA listing determina-
tion, carbamate wastes include wastes
from the production of the following
carbamates: aldicarb, carbofuran,
oxymyl, methomyl formethanate,
bendiocarb, thiram, carbosulfan, trial-
late, carbendazim, benomyl, ziram,
ferbam, and propoxur. If, on or
before July 31,1996, EPA receives
information that aldoxycarb,
propham, or sulfallate is produced in
the United States, EPA shall promul-
gate a final listing determination for
wastes from the production of such
carbamates on or before July 31,1998.
For the air stoxics standard, the phar-
maceutical production source
category includes any facility engaged
in manufacturing, fabricating or
processing pharmaceuticals for either
human or veterinary uses. The cate-
gory includes both bulk
pharmaceuticals (active ingredients)
and final pharmaceutical products.
The main processes and operations
used in pharmaceutical manufacture
are chemical syntheses, fermentation,
biological extraction, fractionation,
botanical extraction, product coating,
formulation, and packaging.
Processes using HAP reactants,
producing HAPs (if any) or using
process aids that are HAPs will be
subject to MACT standards.
For the effluent guideline, this cate-
gory covers about 560 pharmaceutical
plants which conduct any of the
following operations: fermentation,
extraction, chemical synthesis, mixing,
compounding, and formulating.
Research-only facilities will not be
included.
Plywood/Particle Board
Manufacturing
This category includes any facility
engaged in the manufacturing of
plywood and/or particle boards. The
category includes, but is not limited
to, manufacturing of chip waferboard,
strandboard, waferboard, hard-
board/cellulosic fiber board, oriented
strandboard (OSB), hardwood
plywood, medium density fiberboard,
particle board, softwood plywood, or
other process using wood and binder
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systems. Emissions of HAPs have
been associated with, but are not
limited to, the drying of binders.
Polystyrene Production
This category includes any facility
which manufactures homopolymers
or copolymers consisting of styrene
units. Styrene may be copolymeried
with elastomers to form impact poly-
styrene or rubber-modified
polystyrenes. The styrene content of
impact polystyrene (IPS) is approxi-
mately 88 to 97 percent, by weight.
Polystyrene can be produced by bulk
(mass), solution, suspension, or emul-
sion polymerization.
Printing/Publishing
The printing/ publishing source cate-
gory includes the application of inks
utilizing a graphic arts operation to
any substrate except fabric, including,
but not limited to, lithography and
rotogravure methods. The category
includes facilities that print products
such as magazines, newspaper
supplements, packaging, and wallpa-
per, on substrates that include paper,
plastic, metal foil, wood, vinyl, metal,
and glass.
Pulp and Paper Production
For the air toxics standard, the pulp
and paper source category includes
any facility engaged in the production
of pulp and/or paper. This category
includes, but is not limited to, inte-
grated mills (where pulp alone or
pulp and paper or paperboard are
manufactured on-site), non-integrated
mills (where paper or paperboard are
manufactured, but no pulp is manu-
factured on-site), and secondary fiber
mills (where waste paper is used as
the primary raw material). Examples
of pulping methods include Kraft,
soda, sulfite, semi-chemical, and
mechanical. The pulp and paper
production process units include
operations such as pulping, bleaching
and chemical recovery.
For the water effluent guideline,
this category includes all 600 mills in
the United States which manufacture
pulp, paper, and/or paperboard, both
bleached and unbleached.
For the RCRA listing, EPA may
promulgate a listing determination for
sludges from pulp and paper mill
effluent on or before the date 24
months after promulgation of the
effluent guideline. However, EPA
will not propose or promulgate such a
listing determination if the final rule
for the effluent guideline is based on
the use of oxygen delignification,
ozone bleaching, prenox bleaching,
enzymatic bleaching, hydrogern
peroxide bleaching, oxygen and
peroxide enhanced extraction, or any
other technology involving substan-
/;
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tially similar reductions in use of chlo-
rine-containing compounds.
Reinforced Plastic Composites
Production
The reinforced plastics composites
production source category includes
any facility engaged in the manufac-
turing of homopolymers and/or
copolymers which contain materials
designed to enhance the chemical,
physical, and/or thermal properties
of the polymer. This category
includes, but is not limited to,
processing techniques such as hard
layup and spray layup of gel coats
that incorporate styrene.
trile, furfural, epichlorohydrin, methyl
chloride, ethylene dibromide, benzyl
chloride, and p-dichlorobenzene, 2-
methoxyethanol, 2-methoxyethanol
acetate, 2-ethoxyethanol acetate, and
cyclohexanol.
Styrene-Butadiene Rubber and
Latex Production
This category includes any facility
which manufacturers copolymers
consisting of styrene and butadiene
monomer units. Styrene-butadiene
rubber and latex may be produced by
emulsion and solution polymeriza-
tion, although other methods may be
used.
Rubber Chemicals Manufacturing Wood Furniture Manufacturing
The rubber chemicals manufacturing
source category includes any facility
engaged in the manufacture of
rubber-processing chemicals. Rubber-
processing chemicals are synthetic
organic compounds that are added to
natural or synthetic rubber to produce
or enhance specific properties in the
final product. The category includes,
but is not limited to, the manufactur-
ing of rubber-processing chemicals
such as vulcanizing agents, accelera-
tors, antioxidants, antiozonants,
peptizing agents, tackifying agents,
vulcanizing retarders, bonding
agents, and lubricants.
Solvents ll/lll
For the RCRA listing determination,
solvents ll/lll includes the following
spent solvent wastes, still bottoms
from the recovery of the following
solvents, and spent solvent mixutres:
cumene, phenol, isophorone, acetoni-
The wood furniture source category
includes the surface coating and
manufacture of objects made of solid
wood, wood composition, or objects
made of simulated wood material
used in combination with solid wood
or wood composties. This category
includes, but is not limited to, facili-
ties that glue and coat the following
types of objects: kitchen and bath
cabinets; household furniture; uphol-
stered, household furniture; cabinets
or cases (televisions, radios, phono-
graphs, and sewing machines); other
household furniture; office furniture;
public building and related furniture;
office and store fixtures; partitions;
shelving; and lockers.
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