v>EPA
United States
Environmental Protection
Agency
Office of the Administrator
& Office of Pollution
Prevention and Toxics
August 1992
EPA100/R-92/003
Source Reduction
Review Project
Guidelines for EPA
Work Groups
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The goal of the Source Reduction
Review Project is to ensure that,
in the process of developing a
regulation, the work group identifies
source reduction options and evalu-
ates them along with control options.
The purpose of the project is not to
force source reduction into all rules,
but rather to promote careful and seri-
ous analysis of source reduction
options in rule-making, and to set a
precedent at EPA for considering
source reduction options prior to
considering the other tiers of the
Pollution Prevention Act's environ-
mental management hierarchy.
The media programs have made a
series of commitments to adhere to
certain guiding principles for investi-
gating source reduction options in the
development of regulations for the
SRRP industry/process categories. In
addition, EPA's cross-media offices
(ORD and OPPT) have agreed to
commit resources for rule develop-
ment support in the form of joint
projects with media offices. As a
work group member, there are several
things to look for to ensure that the
principles are adhered to and that the
projects are fully integrated into the
regulatory development process.
Here are some guidelines:
EPA's Internal Commitments
to the SRRP
EPA has committed to the following
principles and activities for coordinat-
ing the SRRP process and for
improving data collection and analy-
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.
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• 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 tech-
niques for evaluating the
performance of source reduction
measures; and (d) make source
reduction information on indus-
trial/process categories available
through the Pollution Prevention
Information Clearinghouse.
Identifying Pollution Prevention
Options
• Will the survey's pollution preven-
tion questions yield enough
information to identify the indus-
try's source reduction practices?
• Is the survey designed to capture
those facilities which have elimi-
nated the toxics altogether?
• If the source reduction questions in
the survey are voluntary, and the
responses are limited, does the
program office intend to do any
follow-up surveys in which ques-
tions could be included on source
reduction measures and multi-
media impacts?
• The Office of Air and Radiation
(OAR) will be sending generic
Information Collection Request
(ICR) surveys that include an
example of a completed question-
naire. Work group members
should assist in developing exam-
ples for the source reduction
questions.
• Have inquiries been conducted to
identify source reduction technolo-
gies and practices through other
sources such as:
- The Pollution Prevention
Information Clearinghouse
- The International Cleaner
Production Information System
- The TRI database on pollution
prevention measures
- State regulatory agencies and
technical assistance clearing-
houses
- Industry trade associations?
• When the surveys are evaluated,
work group members should look
for those facilities that have lower
overall baseline emissions/
discharges as indicators that the
facility is a "clean" facility. Does
the program office plan to follow
up with these cleaner facilities,
either through site visits or other
means of contact?
• Are additional site visits to facilities
using source reduction measures
planned through SRRP support
from the cross-media offices?
• During testing or modeling to
determine maximum achievable
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emissions/effluents reductions, are
source reduction measures being
investigated, either on their own or
in conjunction with control tech-
nologies?
• How are the data on multi-media
impacts of control technologies
being collected? Are the data
collection methods adequate?
Evaluating Pollution Prevention
and Control Options for Standards
Development
Impacts to other media
• What are the impacts of each
option on the various environmen-
tal media?
• To what extent does pollution
reduction in one medium result in
increased pollutant loadings to
another medium? (e.g., do pollu-
tants removed from wastewater get
transferred to sludge?)
• Might the regulation create an
incentive for cross-media transfers
of pollution?
Material inputs
• What are the raw material require-
ments of each option?
• Are they highly dependent on non-
renewable resources?
• Does one or more of the technolo-
gies rely less on such inputs than
others?
Energy impacts
• What are the impacts of each
option on energy consumption?
• Do the options require use of
highly energy intensive machin-
ery?
Water usage
• How will the adoption of each
technology affect water usage?
Assessing costs and benefits
• Have the energy costs of each
option been calculated or
described?
• Has the need for increased or
decreased material inputs been
quantified?
• Have any transportation costs asso-
ciated with each option been
noted?
• In assessing the costs of end-of-
pipe control technologies, has the
cost of treating and disposing of
the residual waste been included in
the calculation?
• Have the social costs which the
public will bear been described?
For example, is one option heavily
dependent upon non-renewable
resources? Will reducing air emis-
sions result in more of the pollutant
being transferred to the publicly-
owned treatment work (POTW)?
• What are the relative effects of each
option on the local community?
• Does an alternative discount rate
have an effect on the relative cost-
effectiveness of the options?
Pollution prevention options often
require a higher initial capital
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investment than control technolo-
gies but may yield greater benefits
over the long term.
Is the standard designed in a way
that does not discriminate against
facilities using source reduction
measures as a means of compli-
ance? For example, is it measuring
the mass of toxics entering a
wastestream, water body or ambi-
ent air, or is it measuring the
concentration of a pollutant regard-
less of total mass? Does the
standard measure facility-wide
releases or just releases from a
specific emission/effluent
discharge point?
If a source reduction measure is
identified that will save industry
money (for example due to product
recovery), have the cost savings
been included in the Regulatory
Impact Analysis?
How is the work group planning
on conveying information on
source reduction to the permit
writers and the regulated commu-
nity? Is the information going to be
available through PPIC?
Questions and Answers
QMy work group incorporated
pollution prevention questions
into our survey of the industry, and
we received no responses from facili-
ties. Is that sufficient evidence that no
facilities in the industry are doing
pollution prevention?
A There are sources of information
on pollution prevention prac-
tices in an industry other than
surveys. Among the sources available
to you:
• EPA's Pollution Prevention
Information Clearinghouse
(Technical Support, 703-821-4800)
• EPA's Office of Research &
Development Risk Reduction
Engineering Laboratory (Ivar Lisis,
513-569-7718) or Air and Energy
Engineering Research Laboratory
(Betsy Shaver, 919-541-7915)
• Toxic Release Inventory data on
pollution prevention measures
• International Cleaner Production
Information System
(UNEP/Industry & Environment
Office, 33-1-40-58-88-50)
• State agencies
• Contacts with industry and trade
associations.
QWhat if there are no pollution
prevention measures that are
feasible to incorporate as the basis of
the performance standard?
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A The goal of the Source Reduction
-f~TL Review Project is to ensure that
pollution prevention technologies and
practices are identified and evaluated
during the development of regula-
tions. In some cases, a source
reduction practice will be the basis of
a performance standard; in other
cases, this will not be feasible.
The work group should also
consider other ways to encourage the
regulated industry to use source
reduction to comply with the stan-
dard. These may include developing
incentives and/or offering guidance
on the performance and cost of source
reduction practices.
9 Will OPPT non-concur if source
reduction is not included in the
..~^.
A OPPT is responsible for ensuring
that source reduction is given
careful consideration during regula-
tory development. If a work group
makes a serious effort to identify
source reduction options and evalu-
ates them along with control options,
OPPT will not non-concur.
We're working under a tight
deadline. Who's going to do all
of this extra work?
A OPPT has assigned a staff
JLJL person to each of the rules
targeted under the SRRP. S/he will
assist the work group in identifying
and evaluating source reduction
options. Program offices have also
made commitments. We will all have
to work together to accomplish the
goals of the project.
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