Waste Minimization Policy EPA strongly favors preventing the generation of waste rather than controlling it after it is generated. EPA's waste minimization program focuses on two main goals. First, to foster the use of waste minimization through technology and information exchange, and second, to report to Congress in 1990 on the need for regulations on waste minimization. According to a recent study conducted by EPA, a 20-30 percent reduction in waste volume should be possible through process changes, product substitution, recycling and "good housekeeping" practices. Concerns over economic and liability issues are already driving firms to reduce the volume and toxicity of the wastes they produce. Finally, a number of states have aggressive waste minimization programs; EPA will attempt to encourage and support such programs. Deep-Well Injection Regulation In accordance with the Hazardous and Solid Waste Amendments EPA must also determine whether to further restrict certain hazardous wastes from deep-well injection by August 1988. Currently, information is being collected to support the development of a regulatory decision. It is important to note that a large amount of dilute hazardous wastes (about 20-35 MMT per year) is disposed of in this manner. Deep-well injection is largely practiced in a few Southwest and Midwest states. Thus, a significant regional impact could be felt if this practice is inhibited. Domestic Sewage Sludge Regulation Under the Clean Water Act, municipalities are required to treat wastewater before discharging it to surface waters. This treatment process generates sludge which must be used or disposed of. Very large amounts of non-hazardous sludge are produced each year. The overwhelming majority of this sludge is landfilled and used for land application. A smaller amount (about 20 percent) is incinerated. RCRA contains an exclusion for hazardous wastes which are mixed with domestic sewage. EPA is developing information on the volume of hazardous waste being discharged to sewers, and is scheduled to propose regulations on domestic sewage sludge by September 1987. A major environmental issue currently involves whether domestic sewage sludge will be considered hazardous under EPA's new Toxicity Characteristic Leaching Procedure (TCLP). This could potentially bring large volumes of waste into the RCRA system. Ocean Incineration Regulation Regulations are currently being developed to provide a framework for possible applications for ocean incineration of hazardous waste. If and when successful applications are made to ocean incinerate these wastes, such operations could provide additional capacity for concentrated, liquid hazardous wastes. By October 1987, EPA is scheduled to issue final regulations on designating sites for burning hazardous waste at sea. Final regulations on ocean incineration will be promulgated in late 1988. The planned ocean incineration regulations apply exclusively to liquid organic wastes and do not cover solid wastes. Corrective Action Policies Corrective action involves cleaning up RCRA facilities which have been contaminated by hazardous wastes releases. This includes instances where past management practices involved the disposal of hazardous wastes in solid waste management units. Leaking underground storage tanks are another potentially large universe for corrective action. Presently, there are about one million underground storage tanks, approximately 5-20 percent of which may be leaking. The volume of contaminated soils and sludges generated from corrective action cleanups could be large. While most of the waste will likely be treated and disposed of on-site, some concentrated wastes may require off-site handling. These wastes will compete for existing commercial incineration and land disposal capacity. Superfund Off-Site Policy and Clean-up Standards Under the Superfund Amendments and Reauthorization Act of 1986 (SARA), EPA is required to establish standards for Superfund clean-up actions and also to identify the conditions for disposing of Superfund wastes off-site. The impact of these provisions could change the proportions of hazardous wastes managed on-site and off-site. For example, the new clean-up standards could increase the use of mobile treatment units and stabilization techniques to manage wastes on-site. Some of the more concentrated wastes will likely shift off-site for treatment and disposal. Furthermore, the off-site disposal provision of SARA restricts where Superfund wastes can be taken. Only those facilities which are in compliance with RCRA and the Toxic Substances Control Act (TSCA) and applicable state requirements are eligible to accept wastes from Superfund sites. Specifically, the unit receiving Superfund wastes must not be releasing any hazardous wastes and the overall facility must be controlled by a corrective action program. Several Superfund sites have experienced difficulties locating a commercial facility eligible to accept their wastes. Redefinition of RCRA Hazardous Waste Currently a waste is defined as hazardous under RCRA if it possesses certain characteristics or is listed in Subpart D, Part 261 of the Code of Federal Regulations (40 CFR). About half of RCRA hazardous waste possesses one of the four characteristic attributes: reactive, ignitable, corrosive, or EP toxic. The other half of the wastes are "listed" hazardous wastes. Under the current definition, RCRA regulates about 275 MMT of waste and about 3,000 facilities treat, store or dispose of RCRA hazardous waste. EPA is considering the use of such criteria as waste concentration and management practices in potential new definitions of hazardous wastes. Changing such criteria for defining a hazardous waste could significantly affect the volume of waste currently regulated by RCRA and the size of the regulated community. |