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 ------- 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. 1 ------- • 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 ------- 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 ------- 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? ------- 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. ------- |