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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