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Appendix J Uniform Waste Reduction Standard The Natural Resources Defense Council (NRDC) has proposed the most comprehen- sive approach for mandating a waste reduction standard (Clarence-Smith, l98Sa,b). This group defines efficiency as "the ratio of the total amount of each hazardous chemical released annually from the processes at a facility (and from subsequent recycling operations) to the throughput in the same year of that chemical at the facility. Total releases are the sum of losses from a manufacturing process prior to treatment, losses from on-site recycling, and losses leaving a facility as impurities in a product. Throughput is the sum of total releases, the amount leaving a facility in the product, the inventory change, the amount transformed on site, the amount recycled on site or sent off site for recycling, and the amount entering all downstream processes. If a hazardous or toxic chemical is not found in the raw material, then a raw 181 material other than that chemical is used in the throughput term, resulting in inconsistencies in reporting as discussed in Chapter 5. Clarence-Smith ( 1 988a,b) recommends that a uniform standard be set for all industries. Based on an analysis of the New Jersey data, he further suggests that an ~efficiency" or a star~dard of 5 percent be adopted. This implies that the total releases from all facilities must be less than or equal to 5 percent of the throughput. Annual reporting requirements would apply to the chemicals listed in SARA Section 313, and facilities would be allowed 10 years to comply with the performance standard. Clarence-Smith (l98Sa) gives an example of an efficiency calculation. He describes a facility in which TCA is used to decrease metal parts. TCA throughput includes 14,000 lb emitted to the atmosphere and 7,000 lb recycled off site, for a total throughput of 21,000 lb. Since the facility receives credit for the recycling, the efficiency is the ratio of the atmospheric loss to the throughput (14,000/21,000), or 67 percent The facility can meet the standard by

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182 lowering its measure of efficiency to 5 per- cent in at least three ways. First, it could substitute a chemical that is not on the SARA Section 313 list. Indeed, several hydrocarbon solvents are currently being examined for use in place of the listed chlorinated solvents. The disadvantages of these replacement solvents are that they are combustible and photochemically reactive, and their health effects have not yet been thoroughly determined. In effect, they are too new to have been adequately scrutinized and may eventually prove to be carcinogenic or to pose other threats to human health. The facility could also convert to an aqueous cleaning method. In this case, organic and metal contaminants would be released to the sewer, posing a different threat. In both instances-conversion to the hydrocarbon solvent or to the aqueous cleaner - the facili- ty could avoid the reporting requirement even though these processes may be hazard ous. The second way the facility can meet the efficiency requirement is to increase the amount of solvent sent for recycling. (Note that while the example credits solvent sent for off-site recycling, under present regula- tions reclamation or reuse may include usage of the solvent as fuel.) Thus the facility can simply sell the solvent to a recycler and the recycler can send it directly to an industrial furnace or an incinerator that does not per- form the expected reclamation. In fact, the facility would have no knowledge or interest in the final destination of the solvent as long as it could prove it was sent to an off-site recycler. The third method of meeting the efficiency standard is to decrease the atmos- pheric emissions of the solvent. For every pound of solvent used in a degreasing opera- tion, between 0.43 and 0.85 lb is lost to the MASS BALANCE INFORMATION atmosphere; the balance is contaminated liquid solid waste (EPA, 1985b). Through the purchase of more conservative cleaning equipment, emissions can be reduced signifi- cantly. This reduction of emissions trans- lates into a corresponding reduction in total solvent use. Even with this decline in the absolute level of solvent use, however, the proportions of solvent emitted and produced as waste remain roughly the same per pound of solvent used. Therefore for every pound of solvent used (Clarence-Smith's [198Sa] concept of throughput), the atmospheric loss still amounts to 0.43 to 0.85 lb. For cleaning applications with solvents, then, the 5 per- cent efficiency standard can never be met. There are probably hundreds of thousands of degreasers in the nation, ranging from small units holding less than a gallon to large conveyorized units containing thousands of gallons. These degreasers are used in numerous facilities that are classified under the SIC Codes in the Manufacturing Division and thus represent a significant number of the facilities covered by SARA Section 313. These facilities would be un- able, even with a 10-year compliance period, to ever meet the efficiency standard specified in Clarence-Smiths (l98Sa) model. Thus this model, like others that attempt to treat all industries and all facilities uniform- ly, would not accomplish the intended goals. Instead, they may increase the threat to pub- lic health or cause small- and medium-size generators to close their plants. Thus it is clear that significant problems arise when this uniform approach is used for even the most rudimentary processing situa- tions. Serious problems can be expected when this concept is applied broadly within the many complex processing situations found throughout industrial facilities covered by SARA Section 313.