Plenary Session on Waste Minimization Goals · - - Health and the environment - Regionalization/localizat ion - Cost effectiveness Elimination of multi-media shifting of releases

I * - & = A I

-

Z Z k g - 3 f 2 6 Slides

Plenary Session on Waste Minimization Goals November 15, 1993

Hazardous Waste Management Facilities Group

HAZARDOUS WASTE MANAGEMENT FACILITIES

- Focus on P2 in all aspects of waste management recognizing the need for a multi-media approach and flexibility in management options

Redefine the waste minimization/combustion strategy by reorganization into a P2 strategy that considers all management approaches

- Source reduction - Waste minimization - Recycling - Reuse - Treatment

-

- LDRs

Waste minimization should be viewed as a concept that extends beyond the generator, and involves the actions of waste generators, recyclers, and treaters

No relaxation of standards in the name of waste minimization

- i

-

A - 6 - 4

Slides Plenary Session on Waste Minimization Goals

November 15, 1993 EPA and State Regulator Group

The national goal is at least a 50% reduction of multi-media pollutants through source reductioin by the year 2000

Sub-God

- To demonstrate maximum source reduction that is technically and economically feasible at specific sites

Important Concepts

- Multi-media - Flexible and accountable - - Public involvement and empowerment - Adjusted for output - Credit for prior achievements

Eliminate "bad incentives" - create "good incentives"

A - 6 - 5

"

Slides Plenary Sessions on Waste Minimization Goals

November 15, 1993 Public Interest Group

GOAL

To empower "grassroots" and other environmental groups and people in implementing a RCRA strategy to:

- -

Reduce toxic chemical use and hazardous waste generation through P2,

Phase out production and release of persistent toxics. organochlorines and heavy metals, and

Eliminate combustion of such wastes. -

GOAL SHORTHAND

- Local input - EPA action based on input - Phase out persistent toxics - TUR/Source Reduction Planning and materials accounting - Eliminate combustion (toxic waste incinerators)

A d - 6

. .

Slider Plenary Sessions 00 Waste Minimization Goals

November 15, 1993 Technical Assistance Centers Graup

GOAL - FOCUS ON THE PROBLEM NOT ON THE SYMPTOMS

.

f

. .

Re-orient EPA to make pollution prevention a d priority

- Consolidate single-media programs into a multi-media program with focus on

- Prevention - Compliance Assurance

Require all EPA managers to be accountable for P2 and to facilitate state and local P2 activities.

- - - - -

Remove or change non-P2 beans Factor P2 needs into allocation of grants to states Include P2 flexibility in all regulations Establish goals for P2 to be included in compliance agreements (25% by '95. 50% by '96) Coordinate federal research and development and technical assistence activities to support P2 (;.e. DOD. DOE, NIST, SBA)

Provide technical assistance through universe of existing providers at the federal, state, and local level.

Provide incentives and adequate resources causing continuous action to reduce waste to a minimum through multi-media source reduction.

No uniformity, promote flexibility.

Clearly identify P2 expectations to industry.

Move to multi-media reporting systems which allow measurement of P2 progress.

Level the playing field.

JUST DO IT!

Slldes Plenary Session on Waste Minimization Goals

Identification of Goals November 15, 1993

Hazardous Waste Generator Group

CONSENSUS

ELEMENTS OF RISK GOAL

- Risk Driven (goals, priorities)

- Voluntary - Self implementing - of 100% participation - Broad but flexible

- Multi-media

- Cost-effective

- Public involvement-dialogue

- Use hcirarchy to drive

- incentives

- Remove barriers

- Systematic planning

- Flexible protocol

Use existing data, public scorecards

TRI and hazardous waste and nonhazardous waste

- -

- Corporate openness

- Participation of public in dialogue - a level

- Tracking, reporting

A d - 8


Identification of Coals November 15,1993

Hazardous Waste Generator Group (rontlnued)

1.

2.

3.

4.

POINTS OF CONCERN

500% Comorate Particioation is a G a

- Small Firms - Commercial Firms

Particioation at Lo cal Level is a Goa I

- Small Sites - Low Waste Volume

of 11/15 - I6 Discuss’ 104

- Waste Min -D RCRA - Integrate into National P2 Strategy

Attack Risk Broadly

- Westes/Releases - Employee Safety - Community Safety

A - 6 - 9


November 15, 1993 Heterogeneous Group

The a for waste minimization should be

toward a dori t lzed SDoroach for the reduction of generatioq and release$ of toxic wrsk , Including

persistent toxlcs.

The fpllls should be on the generators of products with emphasis on:

- Health and the environment - Regionalization/localizat ion - - Cost effectiveness

Elimination of multi-media shifting of releases

An inter im milestone of 50% voluntarv reduct ion of hazardous waste generat ion shou Id bp W e v e d bv 20Qz

Impact on &ineration and combustion

- Would not close down - Would reduce waste available for combustion

Would increase the already evident effect: - "Waste minimization is driven by cost."

i

A-6- 10

Slides Plenary Session on Waste Mlolmlzatlon Goals

November IS, 1993 Heterogeneous Group (continued)

w c t e d Reaction of Soecific Stakeholders;

Industrv - Will want details - Fear of/concern

dous waste management facil I&$ ...

- Incineration business concern - - New business opportunities

Recyclers may see increases and decreases

&xulato-

- - Vague and not enforceable

May not understand its impact on them

-assistance Centen

- Need to keep separate from regulatory programs

Public interest erouDS

- - Vague, meaningless

Not enough, need more front-end efforts

A d - 11

1.

2.

3.

4.

OWNERS, OPERATORS O F TSDFs

(not mandates)

a. Work with generators in pursuit of FZ 1. Already a role for many 2. Limitations - CBI - Large generatordmultiple TSDFs

b.

m i o n Gather inelClearinghousg

a. FZ methods, techniques b. LDRddisposal, treatment requirements

m e r on- or off -site. Dro vide BAT to generators

a. Recycling, treatment, transportation, disposal b. Minimize toxic components c.

Particular emphasis on small, medium quantity generators.

Ensure residuals management is protective of human health and the environment - i.e., pollution oreventioq

Workine with state and federal remlatou

a. Develop, strengrnen environmental stanuaras b. Close loopholes C. Protect human health and the environment

Slides Plenary Session on Waste Minimization Roles

November 16, 1993 Hazardous Waste M k g e m e n t Facilities Group

OTHER STAKEHOLDERS’ ROLES

1. Generators

a. Communicate progress in P2 b.

Public Inte rest G r o w

a.

Recognize/accept lead role in cradle -> grave system

2.

Emphasis on P2, not merely shutting down combustion or other viable waste management tool

Promote use of good science, mutli-media approach

Establish a construdive linkage in the dialogue between generators TSDFs and their resident communities

3. al Assistance Center

b.

C.

a. Focus on small generators b. Greater university/academia involvement

4. R e d -

a. Multi-media, good science b. c. d.

e. F2 technical assistance

Eliminate loopholes and disincentives that may diminish P2 Devise system of measurable indicators to assess P2 Promulgate and consistently enforce standards protective of human health and the environment

..

A-8 - 5

, ,.


November 16,1993 EPA and State Regulator Group

@rove Measu res of Success (What we measure)

- Compliance - Pollution prevention in pennits

B&a”

- goals and priorities

- reporting - pilot for specific industries

Regulators take responsibility for resolving inconsistencies

- definitions

Develop requirements for F’2 plans for all media permits and generators - flexible and accountable

Il!aw&% - More resources - More flexibility with existing resources (50%)

Information Reoonine S v w (How we track)

- efficient eihct‘{ i

- b a e r rmxsures or progress

-Incentives/Address Barriers

F) common Threads

- Multi-media - Flexible and Accountable - Preference for source reduction (TQI) - Recognize Waste Management Hierachy - Public involvement/dialogue/empowerment (consumer) - Real resources (EPAlstatdcompany)

Improved measures (both what & how) Recognize difference and needs of different groups - regulations - technical assistance

Priorities should be based on environment and human healttdmnsiderations and goalslrisks

- -

-

A-8 - 7

Slides Plenary h i o n on Waste Minimization Roles

November 16, 1993 Public Interest Group

1. l&G&!l

- information on pollution prevention progress

- materials accounting data

- destination of wastes

- clearinghouse for alternatives

2. Labor/citizen committees

3. product reform

4. Developlsuppoa legislation

5.

6. Citizen suits

7. Revent siting

a. Federal procurement

Bring site-specific problem to attention of government

A-8 - 8

'I'

OTHER SI'AKEHOLDERS

- Pollution prevention plans, including public goals and plan summaries and publicly available materials accounting data (generators, regulators)

information on where wastes are going and what they are (generators, regulators)

-

- access to compliance and monitoring data (generators, regulators, owners and operators)

2. Develop a national plan for phasing out persistent toxics, especially chlorine compounds and heavy metals (EPA).

- Shift to "precautionary principal" - chemicals are guilty until proven innocent

Contribute % of profits to fund for safer alternatives review and P2 research

and develop clean tech (regulators, generators)

- and/or tax off-site shipments to fund P2 programs (regulators, generators, owners and operators).

- Establish mechanisms for greater labor and public involvement in P2

Technical assistance programs should involve citizens as well as industry (technical assistants centers).

Regulators need to get away from end-of-pipe mentality need to close

(generators, EPA).

-

- loopholes in existing regulations that promote shifting toxics between environmental media.

- Regulators should help develop onestop shopping for transition to p2 and

EPA set goal for reducing combustion'&pacity, including kilns and on-site

sustainable technologies.

- burning.

. ,.. :. . .. i:,

A-8 - 9

Slide Plenary Session on Waste Minimization Roles

November 16, 1993 Technical Assistance Centers Group

~

PROVIDE TECHNICAL ASSISTANCE

- Make business competitive through p2

Change established relationships between government and industry - - Facilitate business-to-business interactions

- Build information networks

- Should be located where best for state

- W U C E WASTE

LEADERSHIP

- Foster relationships with non-traditional partners

Support internal integration of P2 within state agencies - - Influence legislation advocating P2

- Risk Wglcreative solutions

YALL.L; a;*~ rdgu.a;Im., ,U ~ V ~ I U oar'iers LO fl

- Support voluntary programs

- Defend defmition

- CHAMPION

A-8 - 10

FUNDING

- Need continued support for state P2 programs

- Core grant funding

- Enforcement agreements

- Industry sources

- other

1. Generators

- Focus on continuous improvements

2. Hazardous waste management facilities

Direct customers to state technical assistance programs

3. Regulators

- Require hazardous waste management facilities to require F2 plans from customers

4. Public interest groups

A-8 - 11

, - Slide Plenary h i o n on Waste Minimization Roles

November 16, 1993 Hazardous Waste Generators Group

THE ROLE OF WASTE GENERATORS IN PROMOTING WASTE MIMMIZATION

Waste minimization &happening

0

3 tiers of a waste minimizationlPZ program

Element of a successful waste m i n i i t i o n P 2 program

- Business Roundtable Benchmaking Study Group identified 22 elements and crudely ranked them Does a represent a cook book!

- - Eiements 0 Integrate waste " i n t i o n into business strategy

- Must have a corporate commitment

0 Establish a tracking system to measure progress (internal)

- More than tracking pounds - Includes project stam

Empower every employee in company

Establish a stated goal and install it as a corporate expectation

e

- Once established though do ~f micromanage implementation

e Ueveiop a waste/emuions mentory and assign responsioility and accountablllty tor progress

e Communicate achievements to public

Prioritize FWwaste minimization activities by risk and cost. matching priorities with available resources

0 Establish waste minimization/P2 audit program - obtain commitment by management to implement findings

Conduct active advocacy to retain flexibility in achieving waste minimizatiodP2 0

A-8 - 12


November 16, 1993 Heterogeneous Group

ACTIVITIES

Lobby Congress for multi-media approachlregulations to allow for multi-media waste reduction. (all groups)

Identify and prioritize projects or action items and ensure alignment with goal. (all groups)

Close recycling loopholes to make waste minimization economydriven. (regulators)

Implement projects where benefits justify resources. (generators and EPA)

Defindwtle definition of waste minimization and pollution prevention. (all groups)

PROCESS

Commitment and support for goal

Inventory waste streams

Identify and prioritize projects

Implement projects where benefits justify resources

Measure and report performance (internal and external)

Recognition of success

Technoiogy transter where pOSSibk

A-8 - 13

Slides Plenary Session on Mechanisms to Achieve Waste Minimization

November 16, 1993 General Issues Group

1. GENERAL ISSUES

1. EPA/States should set waste minimization goals for themselves

- "Beans" do not relate to pollution prevention (need to fix)

OSW behind the curve on P2 (may be the problem)

AAs should have a regular dialogues on F?2 (and be consistent in approaches)

- -

2. Evaluate existing regulations and economic factors to determine what is being done (now)

- Implementation executive order on regulatory reform

3. We have in industry's attention need to provide technicallregulatory advice to "complete" P2 - get out of system

- Link enforcement and technical assistance

A-IO - 5


November 16, 1993 RCRA Federal Regulatory Group (Permits and Enforcement)

U. RCRA PERMITS/ENFORCEMENT

Permits

20 mechanisms identified

TOP IDEAS

Require P2 planning

Don't use permits requirement as & mechanism to drive (multi-media) waste minimization.

EPA should develop means indicators of P2 progress prior to using permitlenforcement mechanism.

Seek statutory clarification of clarify 300501) (certification)

EPA should develop industrial sector - specific indicators of P2 progress.

Deliberate effort to include the public in permit process (increase)

Increase general inspections to improve general ws te minimization performance.

Violations should be settled via Supplemental Environmental Projects

Expand RCRA permits to consider multi-media (air, water)

EPA should use omnibus authority to impose waste minimization permit conditions.

Citizen provision and inspections (encourage)

Multi-media source reduction performance standards.

A-IO - 6

. , . , . .',q


November 16, 1993 RCRA Federal Regulatory Group (Generator and LDR Requirements)

REGULATORY MECHANISMS FOR IMPLEMENTING WASTE MANAGEMENT CERTIFICATIONS

Section 3002(b) - certification for large quantity generators

Revision of LDRs to promote other recycling techniques

la.

b. F2 should demonstrate progress

C.

d.

2.

3.

4.

5.

Program in place needs to be in writing

EPA should enforce the waste minimization certification but recognize flexibility

EPA should focus on requiring "real" programs and not just paper plans

Don't pursue command and control

Allow goal setting to be facility specific allowing for prioritization

EPA needs to speak with one voice addressing all media

EPA should ensure adequate funding to states to provide or aid in the review process

4. i i c w g n m U > Z wixe p j e s ire ;:p;:3: I ~ I [ : I ~ ~ I v ~ ~d ;.iiinoi oe uox i r a u j i a c G i y

7. Recognize other existing land already on the books

A-10 - 7


November 16, 1993 Non-RCRA Federal Regulatory Group

IV. NON-RCRA REGULATORY MECHANISMS

Create incentives and remove decintives for Tier 111 & IV P2

- Mandate goals

- Information Network

- "Waiver" for Promising projects

Multi-MediaFacility wide PermitKompliancelEnforcements

F'2 is

F'2 PLANS

an Add-on. It is changing how you do what you @PA) do

- Less Central command and control

- Multi-medialFacility wide

- Risk-based - Tradeoffs in Facility bubble

Confidence in Plan Quality - Certified Planners -

Trade Secrets

- Use Information Reporting

A-IO - 8

, -


November 16, 1993 State Regulatory Group

V. Promote multi-media P2

Organization change - Regulatory change

(1) Develop facility-wide P2 reporting system as part of national database (with states) to replace current reporting media-specific system

EPA should write regulations with P2 so that rules push P2 or give states option to push P2

EPA should encourage states to move toward multi-media permitting (or consider it in existing programs)

(2)

(3)

For instance:

- State permitting teams should be established to:

- Eliminate funding conflicts

- Encourage companies to make whole-facility pollution prevention

- Multi-media permitting should help stream-line and for permit decisions

(4)

cZA should learn trum the btates’ P2 programs (e.g., California incinerables)

- EPA should promote top of hierarchy to states

Need to be tradeoffs in state grant workplans to allow grant managers to push P2

States need assistance on & to incorporate P2 into regulatory programs

- -

”Foster the long view”

(5)

Federal Laws should give conditional states based on State Pollution Prevention initiatives (e .g . , tiindamentally different factors in Clean Water Act.)


November 16, 1993 Non-Regulatory Group

VI.

I .

2.

3.

4.

5.

6.

NON-REGULATORY MECHANISMS

Economic

- Tax incentives for P2 - Incentives structure for costs by Volume

Inherent economic inc through waste minimizatiodP2 -

Technical Assistance

- Improve funding - Target geographically - Openess to participation

- Mentoring Large/Small; Knowledgeable/Not Knowledgeable - Integrate into available groups (Public & Private)

Professional Accountability

- Responsible Care International Standard setting

Information Dissemination

On Technical Assistance Resources Strengthen Clearinghouse lead Education School Curricula Focus Group Facilitation by chemical usage by technology by status Industry Association Coordination

Consumers

- Clean product promotion - labeling

Voluntary Programs

Improvement to existing programs Identify and Use Multiple Steakholders

A-10 - IO

Slides Plenary Session on "Big Picture" Issues

November 16,1993 Group 1

WASI'E MANAGEMENT HIERARCHY

Consider actual effects on human health and the environment across media

Waste management hierarchy needs to he considered across the board

Use existing economic drivers coupled with protective regulations

F m on promotion of toxics use reductiodreduction in waste generation

Use hierarchy as a flexible framework for continuous improvement to reduce waste releases

EPA to focus 80 percent of resources on clean production (toxics use reductiodsource reduction)

Consistent signals from regulators

EPA waste management policies based on preventing pollution, not hierarchy.

Focus on impacts of all constituents at all hierarchy levels

PZ/source reduction is preferred in general - other elements in hierarchy in specific cases

~ -1, I ,_ ,;.- . *.. .b--d*;;. ... di, "1;,vi3; ;I, 11 -:_1,-17.-.. .-..-.,. I --.-.-..: -.. .l ..I ., L-... y.,'j.xr.: L-: __

Focus on entire hierarchy. energy recovery and recycling needs to be moved up

Reaame it "Toxic &'Hazardous Materials Hierarchy"

Drop combustion from hierarchy

. . ,-

A-12-1

MEASURJ3 PROGRESS

Need to focus on identifiable, measurable goals

or

0

0

Goals & measures should be multi-media and facility- and/or programspecific

institute waste minimization requirements for annual approval on wastestream by wastestream basis

0 Be creative! Perhaps GNP-type measure

0 Generators are not publicly reporting toxics in production. Should begin reporting.

PROBLEM/SOLUTIONS

0 How to track "reducing" waste & releases within hierarchy? Expand TRI by SIC code and chemical

Too many lists and attendant reports. Need to clearly and consistently identify potential pollutants of concern across media

How do you establish baseline? 0

- Flexible systems? Toxic use clusters?

Facility specific plans needed for valid measures. Confirm with audits, protective standards needed for materials balancing

A- 12-2


November 16, 1993 Group 2

WAsrEHIERARCHY

s

s

EPA needs to defme "clean fuels."

Clean fuels that are bumed for energy recovery are not waste and do not belong in the hierarchy.

EPA needs to define - Waste minimization - €2 - Recycling

s

'Dirty fuel" that is blended with other fuels and bumed for energy recovery is "treatment"

What do we consider "dirty fuel" that is treated and now becomes a "clean fuel" that is burned for energy recovery? recycling? waste minimization? treatment?

MULTI-MEDIA

- EPA should develop a consistent list of constituents to be regulated under all media, using highest standard appropriate.

". 3-1.; $.~;,-'.;. . - ~ . .Y.C.*,.. . . ~ 2Al:i'Ll"iI ti; illiilrr G-CC-.?. ,, ~ - . . . ,

- Develop all allowable emission/release/discharge levels based on risk.

- Allow facility to make waste management decisions based on risks.

Revise current media regulations to allow P2 to take place that reduces risk or develop P2 - regulations that "Trump" media regulations.

A-12-3

' .

LIMITING FACTORS

- Improve material safety data sheets

- Better product labeling; benefits:

- Allows facility to make appropriate P2 decisions or waste management

Allows consumer to select products based on toxicity that will reduce pollution

practiceslworker safety

- - Technical assistance to small generators

- Maintain high treatment standards (LDR) and close all regulatory loopholes that act as disincentives

A- 12-4

Slides Plenary *ion on "Big Picture" h u e s


1. WASl'E MANAGEMENT HIERARCHY

- Recognize role of combustion in hierarchy

Concentrate efforts to reduce impaas to human health and the environment

- industry flexibility

Devote agency resources to the top of the hierarchy

-

- encourage use of BAT under hierarchy

-

II. MULTI-MEDIA

- Responses to violations should be able to be responded to across all media

Enhance state, federal and local organizational structures to promote multi-media

Consolidate language (lead by EPA) (Congress is the culprit)

- approaches

-

..

- Tax incentives for €2 activities and accomplishments

Waste generation fees (similar to air fee) for all media - - Require citizen TRI-type reporting

A-12-5



BIG PICTURE

1. LdtingFactors

2. Environmental Justice

3. MeasuringPmgress

4. Remediation Wastes

LIMITING FACTORS: ADMMSIXATIW

Need dear will and commitment from EPA Administrator and Clinton Administration - - Current structure, multi-media solutions/approach (don't need another layer of bureaucracy)

EPA needs to talk to Congress to change environmental statutes/policy - * Focus on consensus evident here

- Develop momentum

REGULATORY

- P2 limited by lack of flexibility in laws and their single-media nature.

* EPA tends to focus on end-of-pipe solutions

- Lack of Congressional mandate

A- 12-6

ECONOMICS

- Lack of resources at EPA and small firms

- Haven’t tapped market incentives

- Limit capacity (create disincentive)

- Lack of understanding of market forces

A-12-7

Slides Plenary Session on "Big Picture" IssueS


A. MULTI-MEDIA IMPACTS

1. Fundamental restructuring of EPA regulatory programs

- set up multi-media team

- develop legislative strategy - develop regulatory policies and programs; P2 as driver

2. Remember to fador in economic impacts when evaluating technologies, with preference for those that have additional benefits

Don't focus just on waste - look upstream to raw materials use, energy use, etc. 3.

B. MEASURING PROGRESS

1.

TRI as starting point

Restructure reporting requirements (big gap between what we want and get)

e timeliness 0 baseline 0 streamline

user-friendly (e.g., electronic) 0 additional data - to address gaps (e.g., materials going into faciiitiess)

Normalization of data, for comparison

2.

3. Statistical sampling

Report progress via (qualitative) pollution prevention plans

A-12-8



TOPICS TO CHOOSE FROM

Measuring progress Multi-media impacts Waste management capacity Remediation wastes Waste management hierarchy Limiting factors Environmental justice Resource allocation (what to do)

TOPIC CATEGORIES SELECTED

1. Resource Allocation

A. Require written multi-media F2 plans

- Promote F2 by establishing a framework that catalyzes facility efforts without overly specific regulations - Establish accountability

B. Need more all-encomoassinc definition of wastes released to the environment (multi- ..*-u.I .*--A} - _

C. Allow resources to be directed based on priority system that focuses on most serious environmental problems with local planning and community involvement

NON-CONSENSUS

A.

B.

Continue to develop stringent environmental protection goals (e.g., LDRs)

Pres for uniform enforcement of regulations across regions and states.

A-12-9

OTHER ISSUES

Multi-Media

A-12-10

.

Slides Plenary Sgsion on Technical Combustion General Issue


TECHNOLOGY COMBUSITON STANDARDS

am of General Issues

0 Technology- vs. risk-based standards

0 Future incineration capacity

0

0 Federal bad actor law

0 Siting requirementslrestrictions

Exemption for "nontoxic" hazardous wastes

TECHNOLOGY VS. RISK-BASED "ANDARDS

0 Must use best technology available (with technology standard), then look at risk on site-by-site basis -D MACT Standards

A 4 for OSWER yhoiild work C I O ~ P I V with A A for air to addyers a!l air tmics iwues <,wt.

Technology-based standards are starting point - cost effective control, then risk-based to make sure it is protective

Air emiasu- UG~UUU ..ru-i.~~~ waste)

Need good combustiordoperating practices

. R&k assessment should be rejected until all stack emissions are quantified

0 Difference exists between theory and practice of-combustion --+ must show need for combustion

B-5 - 5

FUTURE INCINERATION CAPACITY

Is there a need for additional hazardous waste incinerators in the U.S.?

0

Future needs should be marketdriven, EPA should not regulate capacity

EPA should strive to develop a level playing field for incinerators (in terms of technologies, costs, etc.) and then let market drive future capacity.

New capacity generally is better technology

Not enough capacity for some types of wastes (nerve gas, mobile capacity)

EXEMPTION FOR "NONTOXIC" HAZARDOUS WASX

0

0 Waste characterization is issue

Valid concept but implementation is difficult (for example, defining "clean" fuel)

If "clean" fuels then technical standards should handle issue

Should be able to reach an acceptable definition of "clean" fuel

Halogen and metals content is issue in defining "clean" fuel

B-5 - 6

1

. .

Slides Plenary Session on Technical Combustion General l s s u ~


1. RISK ASSESSMENTIHEALTH

A.

B.

C.

D.

F.

G.

H.

I.

J.

K.

L.

M.

Don't ship off-site unless there is a clear benefit

No Risk is acceptable if it is avoidable

Consider need for risk management as well as risk assessment

Zero discharge of all persistent or bioaccumulative toxic substances. This should also include all Superfund facilities, TSDFs and federal facilities

Citizen's health should be paramount priority - standard should be no health risk.

"Acceptable Risk" concept has created the current animosity between industry, regulators, and communities

Serious lack of data to support risk assessment

Consider whether combustion and generation of waste is cost effective

Risk assessment should consider accident scenario (transportation)

Emissions standards should apply to all combusters

Phase out of all organochlorines use. Substitutes are available for chlorine in these , . I__I.

Total U.S. Chlorine Use

I - PulplPaper - 14% - PVC - 32 96 - Polyurethane - 12%

" I(

Evolution of new risk assessment that considers alternatives to production and treatment of waste

8-5 - 7

II. TECHNOLOGY- VS. RISK-BASED STANDARDS

A. There should be no single technical standard - this leads to off-site treatment. Tailor standard to facility.

Emission conaols should be technical standards with risk assessment as a back-up; cost vs. reduction.

Technology-based standardshperior to risk-based standards - cost should not be a factor - install the best!

B.

C.

D. Coordinate with CAA standards

III. EPA RESPONSIBILITY

A.

B.

C.

D.

E.

Develop rules fairly and openly before implementation

Determine what is safe and good science - then stand behind it

Serious lack of data supporting risk assessment

Determine what is safe and technology can achieve it

Severe lack of data on MACT, BACT, and LAER - Develop data and make data accessible

All combustors should be addressed:

High temuerature metals recovery Smerting Thermal desorbers

Have no standards - but high volume of hazardous waste

F.

IV. CAA - TYPE STANDARDS MUST

A. Consider unit type

B. Standards based on BACT, MACT, or LAER, then stick to them

B-5 - 8

A.

B.

C.

D.

E.

F.

G.

H.

I.

J .

K.

FUTURE INCINERATION CAPACITY

45% overcapacity

Move toward eventual elimination of incineration

Look at existing evidence of exposure around operating facilities

Focus on source and waste reduction so no increase in capacity is needed

LDR program sbould be taken into account; capacity variances are still being given inconsistently

Expanding economy and accelerating clean-ups- may dictate expansion of capacity

Option to bum on-site

Effective planning for long-term management of wastes

LDR program should be talren into account

Permitting extra capacity could be disincentive to reduce

Limiting capacity - disincentive for industry to upgrade

B-5 - 9

Slides Plenary h i o n on Technical Combustion General Issues


REPORTER DID NOT USE SLIDES

B-5 - IO

Slides Plenary Session on Technical Combustion General Issues


GENERAL ISSUES

0

0

0 Establishlarticulate compliance goals

0 Enforce existing standards

0 Planned p h a s e a t of incineration

Conduct study on comparative risk for all treatment technologies before setting limits

Siting does not address national effects

SITING REQUIREMENTS

0 Existing facilities have options of addressing siting requirements with "other" controls (risk-based)

Siting regulations must be applied equally to existing facilities 0

S,liT??C

a Siting should be based on risk of materials handled commercial standards

Siting regulations need to address all human and environmental effects, including 'other" environmental effects (background exposure)

on commercial or non-

0

B-5 - 11

TECHNOLOGY- AND/OR RISK-BASED STANDARDS

8 Technology-based standards should be used with a risk-based safety net. Standards goals:

a)

b) Maximize thermal destruction

C) Minimize emissions

Technology-based standards to focus on pollutants of concern, ties in with source reduction and waste minimization

Prioritize resources based on comparative risk

Restrict nonburnable wastes, e.g., metals

8 surrogates which

8

- Develop standards commensurate with risk (technologically feasible and cost effective)

8 Both risk-based and technology-based standards should have zero discharge of persistent toxics

CONSENSUS ITEMS

1)

2)

3)

Standards should protect human health and environment

Compliance and enforcement of standards @resent and future)

Establish time frame or schedule for implementation

B-5 - 12

DOES COMBUSI'ION MERIT EPA'S PRESENT EMPHASIS?

Q'ing Combustion I Accepting combustion as viable

SITING WANDARDS UNIFORMITY?

a) New vs. existing

b) Commercial vs. noncommercial

c) Differentiation by material

d) Local vs. national

B-5 - 13

Slid= Plenary h i o n on Technical Combustion General Issues


2 GROUPS

Public Interest Groups

Other Stakeholders

2 ISSUES

0 CapacitylNeed

0 Standards - Technology-based vs. Risk-based

CAPACITY

PUBLIC INTEREST GROUPS

0

0

Available capacity is a disincentive to waste reduction

EPA policieslregulations should discourage incineration (and move toward eventual phase-out)

EPA should prioritize alternatives which do not result in releases (of persistent toxics) to communities

lo the meantime, look at capacity on national level

B-5 - 14

CAPACITY

OTHER STAKEHOLDERS

1. Capacity needs driven by market forces @ regulatory requirements

0 Let the market drive capacity needs but remember that other forces (rules, state/federal statutes; like CERCLA) have impact

2. Incineration should be compared to other waste treatment technologies in terms of efficiency, environment and health protection. This is EPA’s responsibility!

We @PA & states) need to look at capacity issues on a state-wide and region-wide basis

3.

e

There is not over-capacity in all areas of country

For example, California will lose Superfund monies because of a lack of incineration capacity.

4. Continued need for waste management; incineration is one of the safest technologies available

B-5 - 15

OTHER STAKEHOLDERS

RISK-BASED VS. TECHNOLOG Y-BASED STANDARDS

1. Regulations should drive best technology standards, then use risk assessment as a check

Same standards of review applied to incineration ought to be applied nationally to other waste treatment technologies

0

2.

Danger in lowerine other standards (LDRs) to encourage innovative technology over incineration

3. All sources of contaminants (cars, power plants, incinerators) ought to be considered equally - whether standards are based on risk assessment or technology

EPA needs to take lead in developing better risk assessment science; simplify application

All facilities (new and existing) ought to meet same standards - no "grandfathering"

4.

5.

RISK-BASED VS. TECHNOLOGY-BASED STANDARDS

PUBLIC INTEREST GROUPS

0 Risk assessment does not reflect reality. It is based on incomplete information and is theretore inappropriate as a tool to determine safety (may be a roie to prioritize if tool is appropriate on past not future problems). EPAs first question must be: Is this risk avoidable"? No risk is acceptable if it is avoidable. Risk-based vs. technology-based questions are secondary.

B-5 - 16

Slides Plenary Session on Metals Control Issues


1.

2.

3.

4.

5.

: 6.

- 8.

PM is not an effective surrogate for toxic metals - need both a PM and metal standard. MACT limits for individual metals on a mass and concentration basis -with risk check.

We need a goal for CEM for metals and PM

0

0

Need to know purpose of PM standard to know what the appropriate limit should be Example: control adsorbed organics

Any waste stream with metals should not he combusted

- Zero - discharge of metals

New source performance standard. Use existing NSPS and feed rate limits until CEMs available.

Push for CEM io regulations but we still need to control feed rate

In interim, require more stack monitoring

- Operate monitors to make sure system works

Equity in standards

. . , ,.;. .: j _ _ . . . .:.:...-.c:;:-; _ _ iz ~' :.:2.:.::,; ":,:- ,.'.:: ;:?.2ix!2. i;L:Li.,j

Look at restrictions on metals cocktailing

8-7 - 3

WASTE MINIMIZATION CONSIDERATION FOR =AIS

To maximum extent possible, keep metaIs out of incineration waste streams

Use LDR system in reverse - determine low % organics for restricting incineration of metal-bearing wastes

Remember that when metals are incinerated some metals are retained in ash and some metals converted to less-leachable forms (evaluation of environmental fate and matrix)

Highest % of metals wastestream should be evaluated for waste “izat ion opportunities - however, fully consider impacts of alternative approaches

Prohibit blending of metal bearing wastes

Metals issue complex; therefore, waste minimization decisions sbould not be made in vacuum.

Need multi-media approach, including look at other sources of metals emissions

Need incentives to keep metals out of combustion wastestream

Consider toxic use reduction vs. waste minimization approaches

E-7 - 4

. ..



1.

2.

3.

4.

5.

6.

METALS ISSUES

Properly evaluate/assess waste streams going into unit to monitor metals input (waste analysis plan, compliance issues)

Problems with ”blended fuels” containing metals.

- Don’t blend heavy-metal-bearing streams with solvents

Reclaim solvent rather than blend metals into solvents - Pretreat waste streams to remove heavy metals before blending or combusting

Some believe that metals ought to be restricted in feed, Le.. don’t bum metal-bearing wastes . . . others note that MACT for PM will help control metals

EPA needs to incorporate incentives in rule making to recovery metals.

EPA should increase rearch and development budget to study:

1)

2)

Impact of combustion on metals (mass balance-thermodynamics, etc.)

Better metals separation and recovery technology.

BOlTOM LINE

- rnrre aen I good Iechnicd c n u l d i d rnoniioring PM .ind metal& ra- tme

Provide incentives for reclaiming metals

Use MACT for PM control

Avoid blending of metals into solvents (sham recycling)

AI1 measuring techniques are problematic - some believe that metals must be

- - - -

bumed in units

- After all available metals reduction at source (P2) then we reach this discussion.



SHOULD EPA WABLISH LIMITS ON METALS?

YES

0

a

Can certain metals be grouped together?

Some metals can't be measured by CEM

OPTIONS FOR SFITING STANDARDS

a

0 Risk-based augmented by technology

0

Using a MACT approach augmented by risk

Feed limits on metal influent where appropriate

- Should EPA require all types of units to meet same standards?

- No agreement by consensus

Should EPA change the way metals are regulated?

EPA should push to deveiop CEMs for metals - provide resources

EPA should revisit the issue of metals in residues from BIF's burning

- - -

hazardous wasta

NEED FOR BOTH PM & METAL mAN'DARDS

0

0

Should consider the hazardous-ness of the PM at issue

EPA should revisit the current list of toxic metals (add/delete metals)

8-1 - 6

~ ~~ ~

WAsIlE MINIMIZATION CONSIDERATIONS

0

0 Bevill

0

Waste minimization preferred prior to combustion

For mixed wastes special concerns; some metals regulated by M A

Should be required to show your waste burned for energy recovery actually involves energy recovery

8-1 - I



0 Limits on PM

0 Limits on individual metals:

- Forms of controls

- Variability in metal feed rate

- Generic vs. specific

- CEM

Need for both PM and metals controls

a Waste minimization considerations

GROUP 4 CONSENSUS

METALS

0

a

There is a need for both PM and metals controls on comhusters in the regulations.

There is no generic, across all industry sectors, way to correlate PM and toxic metal emissions.

B-7 - 8

GROUP 4 CONSENSUS

METALS W A m MINIMIZATION

e With PM and metal standards in place, waste minimization will be an important way to achieve compliance.

Agency should work on a ban on combusting hazardous wastes containing very high amounts of heavy metals.

e

. GROUP 4 SUMMARY

DISCUSSION TOPICS/WITH HIGHEST VOTES

e Limits on individual metals:

- Form of controls

- Metal feed rate limits

- Generic vs. source-category-specific limits

- Continuous emissions monitor

- Variability in feed

e

e Restrict metals in feed

Need for both PM and metals controls

- Setting low level (de minimis)

- management controls (source reduction)

e Effect of chlorine on voiatility

e Understanding impact of metals in background

Zero release of persistent and/or bioaccumulative toxics

B-7 - 9

LIMITS ON INDIMDUAL MJ5TALS

0 Consider developing a risk-based concentration standard with site-specific alternative risk assessment

0

0

0

0

Develop controls on emissions through feedrate and systems performance controls

Develop uniform national metals trial bum guidance

Set de minimis levels of metals which should be integrated into clean fuels exemption

All sources should have to meet same emissions limits

0

a

0

0

0

Develop individual emission limits on metals - both mass and concentration

Risk assessment should consider indirect exposure pathways

Look at emissions from national standpoint (cumulative)

Consider existing exposure (background) as a comparison factor

Factor in halogen feed limits that influence metals volatility

FWTRICTION OF METALS FEED

0

0

0

0

0

Do not feed metals if possible at all

Use pretreatment to remove metals

Implement through source separation or process modifications at generation facilities

Metals limits should focus on emissions and should be a performance standard

Develop feedrate limits by individual metal - facility specific:

- considering the relation of emission to background

0-1 - 10



NEED FOR BOTH PM & M m A L CONTROLS

No, if we’re using particulates to address toxic metals

Yes, as long as . . . - control technology specific

- particulate standard is included

- MACT particulate limit is imposed

Maybe no, when PM level is too low. EPA should evaluate the relationship between PMlmetals.

TECHNOLOGY STANDARDS GROUP DISCUSSION

PM as a surrogate:

0 Depends on:

.->:A- p. -..lJ** .u.krb. I-~LIIpi;.-;rli

- Operating temperature

- Molecular and physical form

- Sampling method

0 Short Answer: NO - PM is NOT a surrogate for metals controllmonitoring

PM standard as a technology-based standard controls metals: .

- Establish lower PM standard and periodically stack test for metals.

B-I - 1 1

Slides Plenary Sessions on Organics Control h u e s


D I O X I N / F " EMISSIONS

EPA adopt APHA position on banning chlorine

MACT standards - no exceptions based on good operating practices and risk assessment

P M should not be used a surrogate

Regulating on TEq makes most sense from risk assessment viewpoint - start with EC standards

Minimize chlorinated compounds as a valid alternative strategy

Should not be an exemption for non-chlorinated waste

Do know what all sources of dioxidfuran are

- Need mass balance

OTHER ORGANICS EMISSIONS

P .-.-,p,.. -L"q3 <...- -.'. ' .l.-"r," -.,?.-- ... n (acq,..+; Jr ():": ., I . , - , , - ...... ,i.r .,-,. ~ .... enussions

Feel EPA surrogates currently close to mark - however, need to conduct more frequent stack gas testing to speciate emissions and verify appropriateness of surrogate usage

Important that we require good combustiodoperating practices; thru regs. need to limit upsets before EPA takes further action

EPA needs to push for better CEMs for organics thru regulations

7 pts. (public interest)

16 pts.

13 pts.

11 pts.

6 pts.

6 pts.

8 pts.

9:. .. . ._ : ' I .

(public interest)

32 pts.

15 pts.

13 pts

0-9 - 4

..

Slides Plenary Session on Organics Control Issues


CONTROLS ON DIOXINS/FURANS

- No Consensus - Public Interest Gro uo Comments

0 Entire discussion based on premise that allow some amount of dioxins; don’t accept this premise.

0

0 No dioxin is safe.

0

Need to move toward elimination of organochlorines.

All wastes burned should be screened for dioxins.

0 Do not study any longer, do something now.

Other Stakeholder Comments

- No Consensus - A. vs. Total Co neeneq

Several supoorters of TEo approach. although do not know what numerical limit , s&- - G>;d7.:..., ~ u. “*liLir. < - . , > I J P i b S \ .,.1 c2. _.“

Consider nondetectable for tetra congener plus TEq; should be stricter than municipal waste combustion standards.

Total limit & TEq may be needed because TEq does not capture some congeners.

Need to establish a safe limit based on wealth of existing scientific and health data.

From regulatory standpoint, TEq may be necessary for utilization of omnibus authority.

Any standard still needs to be backed up by site-specific, multi-pathway risk assessment.

0

0

0

0

B-9 - 5

CONTROLS ON DIOXINS/FURANS (continued)

B. Formation Mechanisms

0 Presence of chlorine alone does not mean dioxin formation; particulate, air pollution control temperature are also factors.

EPA & public need to work with industry re: gathering more data on formation mechanisms and source of TEq vs. total.

Dioxin formed in all combustion sources (fireplaces, diesel, etc.).

Control frontend wastes burned, coupled with combustion at high efficiency.

0

0

0

C. "Exemotions"

0

0

0

Some support for limited exemptions, possibly like BIF approach.

& exemption for no-chlorine wastes.

EPA needs to develop a safe technology to address existing dioxin stockpile.

CONTROLS ON OTHER ORGANICS

- No consensus - Public Interest G rouD Comments

"Being trapped into giving opinions on issues that are not relevant."

e

0

e

Chlorinated & other halogenated waste should be a top priority for waste reduction efforts.

Need continuous monitoring of all wastes burned for PICs.

Due to complexity of combustion & potential for direct releases, monitor for all PICs (no CO surrogate).

Given that regulatory controls do not work, Carol Browner should extend her moratorium and shut down all incinerators.

0

B-9 - 6

c

. .

Other Commene

** Dioxin control is not adequate for other organic control (dioxin controls focus on post- combustion)

Health estimates on dioxins may over-estimate risk, but other organics pose different health risks by other pathways & need to be assessed.

Cannot monitor organics or dioxins on a real-time basis.

0

HC/CO/PIC Controls

Use HClCO CEMs to continuously monitor combustion efficiency wlstack testing for organics on a periodic basis (2 years).

Should not have to identify PICs if CO < 100 ppm; if CO > 100 ppm identify PICs under "worst-case" conditions. Need guidance from EPA re: "worst-case." Use SVOSTNOST.

CO/HC not appropriate indicators of combustion efficiency in some devices (cement kilns wirb organics in raw materials).

During trial bum, require testing for 30 priority chemicals. They are not common & public may be reassured.

During trial bum, need to identify all P IG listed in the 9/24/93 Denit memo. Allow no exemptions, because boilers had some of the highest levels (based on CO).

Combustion of organic wastes in industrial hoilers is a!! excellent way to manzge rhae wares

0

0

0

.A 2 i;bi ; . :2 - - . , 2z ..W&C..

B-9 - 7

Slid= Plenary Sessions on Organics Control Issues


DIOXINS

ALTERNATE OPINION

NO LEVEL OF DIOXINS EMllTED IS ACCEPTABLE. ALTERNATE DISPOSAL METHODS OR STORAGE UNTIL ACCEPTABLE ALTERNATE MEI'HODS DEVELOPED FOR CHLORINE BEARING WASTES. ABSOLUTE PHASE-OUT OF ORGANIC HALOGENS

DIOXIN LIMITS

Use European Standard

But How Was It Based?

Actual Experience in Germany - Need to Understand Better

- Use TEq - Use Both - Use Total Congeners

EXEMPTION FOR NON-CIUORINATED W.4SlT.S

- Potential for formation with almost any level of CP but may not occur with specific wastedspecific processes

- Consider relief if test data indicates no dioxin emissions of concern

- Relief - long term testing with demonstration of no dioxin production or no CP production

B-9 - 8

"RIAL BURNS

Education need - To educate public on risk issues

Research need - To identify PICs - measurement devices; quantificatiodtoxicity

QUANTIFYING EMISSIONS

Who does risk assessments? EPA/States/Generators/Facility7

l-phase or Z-phase

Before trial bum & AAer

Is there an alternate to DRE?

Risk analysis

.

B-9 - 9

Slides Plenary Sessions on Organics Control Issues


CONSENSUS POINTS

1)

2) 17/1 (almost consensus)

Fund/research/establish on-line monitoring system for halogenslPICs

Identify halogens in waste stream

ISSUES RAISED FOR DISCUSSION

Controls on dioxins/furans

Controls on other emissions

Avoid possibility of dioxin generation in ai llution control iuipment

Avoid possibility of generation by control of combustion process

On-site operations vs. commercial

- known & unknown wastes - degree of variability or knowledge of the waste

Validation and/or limitation of current quantification methods

Eliminate halogen-containing products

B-9 - 10

RECOMMENDATIONS: CONTROLS ON DIOXINSlRlRANS

*

a

Prioritize and focus national resources on key areas

Start with tight dioxin standard to enable implementation of best technologies for waste “ i i t i o n and chlorine limits

Identify and eliminate all sources of dioxin

Consider other sources of dioxin in assessing whether other controls are needed

0

0

a Disallow exemptions

0 Adopt toxicity equivalents approach rather than a total congeners approach

RECOMMENDATIONS CONTROLS ON OTHER EMISSIONS

0

0

0

0

Review existing database for existing information and trial bum data

Use CO, total hydrocarbon, HCP, and particulate CEM in addition to oxygen

Continue to control and measure other toxic organics

Consider using extractable organic matter methods as indicators of organics for trend analysis

B-9 - 11

. .

Slides Plenary Sessions on Organics Control Issues


Move toward reduction/elimination of use of chlorinated feed stocks

- solvents - pulp and paper

Progress is beiig made - encourage continued progress

- industry commitment - recognize complexity of roles of CP

R&D should be a priority

- combustion - dioxin - PIC

Fundamental, pilot- and hit-scale R&D dollars need to do. Prevention as welt.

Funding - more dollars need to be spent

- No consensus on EPAlindustry funding - Needs to be addressed

8-9 - 12

Technology-based with risk evaluation as check

- Should be a performance standard (technology-based)

Risk assessment should only be used to make controls more stringent or relax them

Cost must be taken into consideration in developing technology-based standards

Dioxin controls adequate? No. Practice good combustion design and operating practices and will control organics

Trial burns should not focus just on dioxins, but on broad range of organics

Surrogate may not be representative of the waste

Need stronger enforcement directed toward risk and bad actors (disagreement)

- better QAlQC on feed - more frequent trial burns - level of controls tailored to type of burner

O2 should be included in regulations, continuously monitored & recorded.

4 cutoff limits should be established in all pennits based on trial bum

B-9 - 13

Slides Plenary Session On Other Combustion Issues


TRIAL BURNS . T.B. represents worst case scenario - therefore, effective tool

0 Value of T.B. is in setting operating conditions - therefore, more appropriately termed "performance test"

Burn what you are permitted to bum at representative volumes and speciate stack emissions

Need more frequent validation of T.B. operating conditions

0

0

- more frequent performance testing with real wastes stack testing during normal operating conditions - - ambient air monitoring - P.C. output

FUEL BLENDERS

0 Some fuel blenders are operating without permits - all blenders should have permits and standards

Fuel blending should be prohibited

Metals waste and low-BTU waste should not blended

0

0

low-BTU waste does not necessarily = high metals

0

0

Need +o control wastederived nroducts from health nennective

Failure to have minimum specifications for hazardous waste fuel has created an unlevel playing field between BIFs and incinerators

Part of T.B. is establishing good operating practices, including adequate oxygen, under worst- case scenarios + operator certification

T.B. is only mass balauce testing performed on any waste management technology today

Tailor T.B. requirements to take into account consistency of waste burned

Need clear procedures to deal with T.B. failures

*

0

0

0

0 Energy recovery vs. desmction

B-11 - 4

..



PUBLIC PARTICIPATION GOAL:

Make certain that citizen views are considered throughout the permitting process, implementation, operation, and enforcement

1.

2.

3.

4.

5.

6.

7.

8.

9.

10.

11.

12.

Meaningful dialogue has to involve public from very beginning

Need clear pathway for involving stakeholders upfront

Regional forums need to be in Regions where there are many combustors

Stop talking about health effects - go measure them in the surrounding communities

Need better communication between state, federal, local environmental offices

* "A regulation that is not enforced is no good."

Establish an on-site or convenient public site that is publicly accessible with full set of permitting and compliance data (e.g., releases, communication with government, manifests, etC.)

SKIPPED

Need guidance on how to maintain good public participation. This goes beyond the permitting process

Involve community early. Develop representative advisory committees.

Public needs to be educated on purpose/design of units and how they operate. Perception of old data still being used out of context.

- Public interest want to see the hard-core data - not boiled down

Local repository of facility information needs a facility representative who is knowledgeable and accessible to public. Should not be a PR person.

Increasehnprove public noticelannouncement of pending regulation development/proposaJ

B-11 - 5

13.

14.

15.

16.

17.

18.

19.

20.

21.

22.

23.

24.

25.

26.

21.

28.

PUBLIC PARTICIPATION GOAL (continued):

The FRN process is not user friendly. Give guidance on how to submit comments

Facility should sponsor repository upkeep

Detine what is "publicly available" info for public.

N e d ways to condense and rapidly convey data

Education needs to go both ways. Small groups are important.

Public information meetings needed for all BIFs, not just Class III permit modifications - these are productive

Public skepticism due to negative experiences. Need to overcome this for "meaningful public participation. "

Public notices are not posted in optimal, prominent, or consistent places.

Rior to public information meeting re: new permits & modification, need to have a public meeting devoted to actual health effects from incineration.

Public notice should reach the radius around the facility.

M&gs need to be accessible to the public.

Permits are modified after public hearing without additional public input

Public participation is lacking in the capacity assurance plan process. EPA should guarantee public access in future

Need 1-800 number for quick access to regulators re: local issues

Need flexible approaches to tailor public participation to different cases and areas (urban vs. "

Options for repository: on-site reading room, community college, library, others

B-11 - 6

FUEL BLENDING

Need closer scrutiny

- Move to removal of metals & CP sources

Permitting process needed for blending operation

- Transportation blending operations banned.

Waste-derived product specifications

Difficult to define waste characterization procedures during permit process because of variety ad volume of wastes

Blender must have permit and must comply with manifest system both ways.

Fuing M/D rule would help

Blending important to provide uniform feed to unit.

<5ooO BTUAb wastes must be tracked, in order to comply with LDR standards for products applied to land. Ban on blending <5000 BTUflb wastes since the ability to track is lost.

Regulations need clarification of difference between mixing & blending

B-11 - 7

Slides I Plenary Session On Other Combustion Issues


Approach -

Frequency - - -

Goals - Shakedown - Results - -

TRIAL BURNS

(Legitimacy) Public interest groups feel data not complete. Want broader, more realistic test covering all conditions. Industry groups: real waste, worst conditions

Surprise vs. bestday data Surprise would not push envelope like existing burns Some sort of confirmation test siteby-site

Performance standards, operating conditions

Maybe > than 720 hours needed. Need operating restrictions

> 90 days needed Mechanism to extend

F E E D m A M SAMPLING FREQUENCY

- SW-846 equivalent methods for mixed waste need to be identified

Address parity between cement kilns & incinerators. Blended fuel issues.

Develop guidance - rigorous and uniform vs. flexible.

- - - Ensure cement kilns used for resource conservation. Limit fuel to clean fuels. Pull back.

All waste combustors should meet same performance and operational standards. Disagreement over ability

B-II - a

CAMPAIGN BURNING

Disagreement. Regulators liked.

RECORDKEEPING

Bottom line, so that it can't be tampered with. Standardization would be good.

Public Interests Groups - publicly available, raw data & correspondence. FOIA may not do it.

S A T E REGULATIONS

Will authorized states regulate under new combustion strategy using omnibus or will EPA o v d e ? Answer needed.

States should work with EPA the whole way through process beginning with siting

B-11 - 9



BROAD ISSUES

1. Trial Bums

2.

3. Recordkeeping

4. Feed Stream Sampling Frequency

5. All Other Waste Combustors

6. Clean FuelsSuel Blending

7. AshQuality

8. AWFCO Frequencies

9. Role of Public

TME vs DRE vs DE

3 or more votes

RECOMMENDATIONS: TRIAL BURNS

0 EPA review current trial burn protocois & evaluate public concern & then respond to those concerns (on low concentration)

Work together to develop strategies to minimize dump-stack openings

0

0 Eliminate dump stacks

0

Phase surrogate and waste trial tests together

Utilize surrogates in concentrations similar to wastes of concern

4 or more votes

B-11 - 10

RECOMMENDATIONS: (continued)

almost consensus:

Collect & analyze more data before eliminating use of DRE

Conduct DREs with total organic feed minus total organic left in the ash

B-11 - 11



TRIAL BURNS:

Basis for determining combustion operation

Strengthen by expanding, # of POHCs, PIC'S, frequency of testing, new tech available

Useful for establishing feed limits & operational controls

Not representative of day-today operation

Effective for establishing metals partitioning

e

Need environmental monitoring of area background

Need community health survey

Need baseline for both above

T.B. should not use surrogates

T.B.'s a t adequate for real operating conditions

T.B. fuel should only use actual waste to be burned

T.B.'s to establish operating parameters are best tech today

D a y M a y operations mainly influenced by initial waste characterization

Should be consistent guidance on TBs

Problems with selection of POHCs

TBs not in fact being carried out consistently by regulators

B-11 - 12

TRL4L BURNS (continued):

0 DREs better than risk assessments

- because risk assessments are voodoo science

0 Real wastes are used in TBs after initial one

Unclear whether DREs necessarylinformative are tracking significant PICs and doing risk assessment on them

"€3 needs to be tailored to task of bumer (simple/complex); number of PICs of interest

starlr Gas S a m ~ l i ~ g

- Acwacy in measuring dioxins

- F'arts-per-trillion difficult to analyze

- not real-time - need outside labs

- Should all data be adjusted for spike recoveries before being used for risk assessment or other purposes?

Given measurement difficulties, should we adopt a precautionary principle? -

CAMPAIGN BURNING

tdssmmt - Trial bums aren't done on campaign basis

- Real operational difficulties

B-11 - 13

RECORDKEEF'ING

0 Guidance on identifying primary data source as point of regulation for TBs and ongoing operation (e.g., computer output vs. strip chart)

Public needs access to records (manifests) on where waste is coming from

Form community advisory groups community-run', independent resource base - selected membership

Information on number of violationslcitations & number of dump-stack events

0

0

0

0 Information on company/agency communication

* or partnership with industry & regulators

B-11 - 14

Documents

Plenary Session on Waste Minimization Goals · - - Health and the environment - Regionalization/localizat ion - Cost effectiveness Elimination of multi-media shifting of releases