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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
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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
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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: