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OCR for page 177
Appendix I
Defining Waste and Waste Reduction
DEFINING WASTE
Both SARA Section 313 and RCRA in-
volve the collection of information on re-
ducing waste generated at manufacturing
facilities. Under RCRA it is necessary to
report only the generation of hazardous
wastes, which include some wastes destined
for land disposal and some nongaseous
wastes that are treated as typical solid wastes
and wastewaters. Missing from the account-
ing are air emissions and other nonhazardous
solids or wastewaters. Under SARA releases
of certain chemicals to any environmental
media are reported, but waste is not
explicitly defined.
Data obtained under these two programs
may lead to different conclusions regarding a
facility's waste reduction progress. The
basic reason for this potential discrepancy is
that the two programs consider different
universes of waste: hazardous wastes are re-
ported under RCRA, while quantities of in-
dividual chemicals are reported under SARA
Section 313. There is no information col-
lected under either statute that can indicate
whether a reduction in hazardous waste
177
quantities generally correlates with reduc-
tions in releases of a specific chemical.
Reductions in total hazardous waste but not
· ~-
a specific component may occur and be
documented under RCRA reporting, while
the reductions of a specific chemical but not
of total hazardous waste may occur and be
documented under SARA.
A complex system is employed by RCRA
for determining whether a material is a solid
waste which is subject to regulation as a
hazardous waste. The definitions of solid
waste and hazardous waste depend on both
material type and the way in which the
material is managed. For example, if a
material is a characteristic byproduct that is
reclaimed, it is not considered a solid waste
(Code of Federal Regulations, 1989~. The
RCRA definition of solid waste also ex-
cludes large quantities of ignitable
(flammable) materials commonly recycled
throughout the petrochemicals industry. In
addition, materials used as effective sub-
stitutes for commercial products or used as
ingredients (nonreclaimed) are also not con-
sidered to be solid wastes when they are re-
cycled. On the other hand, those wastes de
OCR for page 178
178
fined as spent solvents are considered to be
hazardous wastes and are subject to report-
ing and regulation, unless they are reclaimed
in a closed-loop recycling system that re-
turns the recycled material back to the pro-
cess.
This discussion should not leave the im-
pression that it is a simple task to define
what is a hazardous waste and what is not.
The EPA's final rule (Federal Register,
1985), which consumed over 50 pages in the
Federal Register, consists of a very complex
series of definitions that have numerous ex-
clusions and exemptions to account for the
many ways a material can be used legiti-
mately as a nonwaste.
Conflicts arise, however, because of the
inherent complexity of defining a waste.
Recently, the U.S. Court of Appeals for the
District of Columbia reviewed the definition
of waste as it relates to the use of a listed
hazardous waste in the manufacturing pro-
cess. In this case the petitioners argued that
even though a material may be a listed
waste, it should not be subject to regulation
if it is introduced into a process to be
reclaimed and converted into a product. The
court agreed, stating that "Congress clearly
and unambiguously expressed its intent that
solid waste (and therefore EPA's regulatory
authority) be limited to materials that are
discarded by virtue of being disposed of,
abandoned, or thrown away." The court
went on to say that it was clear that
''discarded" did not include "in process
secondary materials employed in ongoing
manufacturing processes." (American
Mining Congress vs. United States
Environmental Protection Agency, No. 85-
1206, D.C. Cir., July 31, 1987; pp. 33-34.)
DEFINING WASTE MINIMIZATION
AND REDUCTION
As stated in Chapter 5, the committee
chose to define waste reduction broadly so
that its analysis of mass balance information
would apply to any facility reporting waste
information, regardless of the way the facili-
ty deals with the waste it generates. This de-
finition of waste reduction is consistent with
the one presented in a previous NRC report
(NRC, 1985~. The activities included in the
definition of the terms waste minimization
and waste reduction and their role in the
LESS BAL~4NCE INFORAL4TION
.
.
waste management hierarchy have been the
source of continuing debate (Wolf, 1988~.
The debate centers on whether waste
management should focus on all activities
that reduce the quantity of materials enter-
ing the environment, or whether it should be
limited to the reduction of waste at the
generation source prior to any treatment or
disposal. The latter approach is often
referred to as source reduction, rather than
waste reduction. The issue has been further
fractionated into whether or not recycling of
waste internal to the process or waste re-
claimed by a second party or an off-site
party should be included in source reduction.
Under RCRA, the EPA defines waste
minimization in terms of recycling and
source reduction (EPA, 1986b), as follows:
Source reduction refers to the reduc-
tion or elimination of waste genera-
tion at the source, usually within a
process. Source reduction measures
can include some types of treatment
processes, but they also include
process modifications, feedstock sub-
stitutions or improvements in feed-
stock purity, various housekeeping
and management practices, increases
in the efficiency of machinery, and
even recycling within a process.
Source reduction implies any action
that reduces the amount of waste
exiting from a process.
Recycling refers to the use or reuse of
a waste as an effective substitute for a
commercial product, or as an in-
gredient or feedstock in an industrial
process. It also refers to the reclama-
tion of useful constituent fractions
within a waste material or removal of
contaminants from a waste to allow it
to be reused. As used in the EPA re-
port 1986b cited above, recycling im-
plies use, reuse, or reclamation of a
waste either on site or off site after it
is generated by a particular process.
Waste minimization means the reduc-
tion, to the extent feasible, of
hazardous waste that is generated or
subsequently treated, stored, or
disposed of. It includes any source
reduction or recycling activity
undertaken by a generator that results
OCR for page 179
APPENDLY I
in either (1) the reduction of the total
volume or quantity of hazardous waste,
or (2) the reduction of the toxicity of
hazardous waste, or both, so long as the
reduction is consistent with the goal of
minimizing present and future threats
to human health and the environment.
[Note: Waste minimization could in-
clude some form of treatment after
generation to detoxify or reduce the
waste.]
Under SARA, the EPA has indirectly
defined waste minimization through the
TRI's Form R. For Part III Section ~ of
Form R. all on-site and off-site recycling is
included in waste minimization.
The EPA has recently provided a basis for
consistency between regulatory programs,
within the constraints of the various laws
that govern waste minimization. The EPA
has proposed a Pollution Prevention Policy
Statement (Federal Register, 1989) that is
designed to commit the EPA to "a program
that reduces all environmentally harmful
releases." The EPA is proposing to replace
the term Waste minimization," which it has
previously used in reference to source re-
duction and recycling activities in its
hazardous waste program, with the term
Pollution prevention." In this proposed
policy, the EPA indirectly defines source
reduction through the statement that "In-
dustrial Source Reduction can be ac-
complished through input substitution
179
product reformulation, process modification
improved housekeeping, and on site, closed
loop recycling. EPA continues by stating
that~although source reduction is preferred
to other management practices, the agency
recognizes the value of environmentally
sound recycling, and is committed to pro-
moting recycling as a second preference,
above treatment, control and disposal."
The OTA has concluded that waste
management should focus on source reduc-
tion (in process changes to avoid or eliminate
waste) and any recycling operation that is
"environmentally acceptable and is an in-
tegral part of the waste generating industrial
processor operation." Therefore, actions
such as treatment or off-site recycling are
not considered part of OTA's definition of
waste reduction (OTA, 1986, 1987~.
If the primary objective of waste
reduction is to reduce multimedia releases, a
variety of factors must be considered in
evaluating progress in waste reduction given
the complexities of industrial manufacturing
processes. In the case of off-site recycling
and reuse, it becomes apparent that there is
no clear definition of waste reduction, par-
ticularly when overall regional or national
reduction is considered. Is recycling a
practice that reduces the amount of waste
ultimately generated part of waste reduc-
tion? If so, then it should not be excluded
from data collected for assessing waste re-
duction progress.
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Representative terms from entire chapter:
waste reduction
