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Introduction
SCOPE OF THE STUDY
Protection of human health and the environment through
the proper management of hazardous industrial waste is an
important societal goal. An essential component of
strategies for waste management is reduction in the
quantities of hazardous waste generated that require
attention through treatment and/or disposal (National
Research Council 1983, Office of Technology Assessment
1983).
The committee considers approaches that reduce the
quantities or degree of hazard of hazardous waste
generated to be beneficial to society. The relationships
between reductions in the quantities of waste generated
and risks to public health and environmental quality are
not clearly understood. The relationships are not
necessarily linear; for example, a decrease in the
quantities of waste generated does not necessarily imply
a directly proportional decrease in the risks to public
health and environmental quality. In its deliberations,
the committee did not distinguish between reducing the
quantities and reducing the degree of hazard of hazardous
waste because the current understanding does not permit
it.
Reducing the quantities or degree of hazard of
hazardous waste that is generated entails the application
of technology, such as modifications in the production
process or substitution of a product using different raw
materials. Not all considerations in reducing the
generation of hazardous waste are technical, however.
There is a wide range of nontechnical factors affecting
the generation of industrial hazardous waste, including
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economics, regulation, availability of resources such as
technology and information, and attitudes toward change.
In this chapter, several issues are raised regarding
the definition of hazardous waste; estimates of how much
hazardous waste is generated are discussed; the role of
waste reduction in a comprehensive waste management
scheme is described; and the committee's definition of
the term "waste reduction" is given. A schematic descrip-
tion of the phases in the development of industrial waste
reduction programs is also introduced.
In each of the phases of the conceptualized pattern of
implementation of waste reduction strategies, various
nontechnical factors affect industrial decisions about
waste generation. These factors are explored in Chapter
2. In Chapter 3, the public policy approaches to
encourage waste reduction are discussed in light of the
dynamics of these nontechnical factors.
DEFINITIONS OF HAZARDOUS WASTE
Virtually all industrial activity generates some
materials that are considered waste and are discarded
because they are perceived to have no further economic
use. The term waste can be defined as a "nonproduct
material or energy output, the value of which is less
than the costs of collecting, processing, and transporting
for use" (Bower et al. 1977). According to this
definition, materials that have economic potential for
reuse, recovery, or recycling are not truly waste.
Certain wastes are defined as hazardous under the
Resource Conservation and Recovery Act of 1976 (RCRA; PL
94-580) because they may
(a) cause or significantly contribute to an increase
in mortality or an increase in serious irrevers-
ible, or incapacitating reversible, illness; or
(b) pose a substantial present or potential hazard to
human health or the environment when improperly
treated, stored, transported, disposed of, or
otherwise managed (42 USC 6903).
Regulations implementing RCRA regard wastes as hazardous
if they are either "characteristics wastes, i.e.,
ignitable, corrosive, reactive, or toxic (40 CFR
261.20-261.24), or specifically listed as hazardous (40
CFR 261.30-261.33).
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Applying the formal definitions of hazardous waste to
specific uses is not a straightforward task. There are
many differences among state and federal governments,
industry, and other parties as to which wastes should be
included under the definitions.
Some states have elected to broaden the RCRA and EPA
definitions of hazardous waste to include additional
chemical compounds, waste produced by small-volume
generators, and wastes specifically excluded by RCRA from
regulation in the federal program (Office of Technology
Assessment 1983). Additional complications in collecting
data on hazardous waste generation arise because the
definition in the federal regulations considers a recycled
hazardous material a hazardous waste if it is a listed
waste. A manufacturer, in contrast, may not consider a
recycled material a hazardous waste if it is reused in a
subsequent process on-site, since the material is never
actually discarded. Also, a substantial fraction of the
legally defined hazardous wastes are wastewaters that
qualify as hazardous waste because materials specifically
defined or listed as hazardous waste have been mixed with
plant wastewaters; had the two waste streams not been
mixed, the quantity of hazardous waste would be much
less. Such differences as these pose substantial problems
for analyzing and comparing data on the generation of
hazardous waste.
For the purposes of this report, the committee did not
consider it necessary to define hazardous waste precisely;
instead, the RCRA statutory definition is the broad
working definition for the study. The difficulties and
differences in definition, however, themselves constitute
one of the factors affecting industry's decisions about
the generation of hazardous waste (see section on
regulatory issues in Chapter 2).
ESTIMATES OF HAZARDOUS WASTE GENERATION
Estimates of the quantities of hazardous waste
generated by industry vary widely, depending on the
definition of hazardous waste used. The EPA, state
agencies, and private organizations such as the Chemical
Manufacturers Association (CMA) collect data on hazardous
waste generation. EPA reported that about 264 million
metric tonnes (71 billion gallons) of hazardous waste
were managed in treatment, storage, and disposal processes
and were regulated under RCRA in 1981 (Westat 1984).
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Large portions of this quantity are mixtures of hazardous
and nonhazardous wastes, which are defined under RCRA as
hazardous. Using both state and federal definitions, the
Office of Technology Assessment (1983) reported that
industry generates some 255 to 275 million metric tonnes
of hazardous waste annually.
Almost all of the federally regulated hazardous wastes
(96 percent) generated in 1981 were managed at the site
of generation. Recycling appears to be of increasing
interest to waste generators. Of the 14,098 generators,
5700 indicated that recycling was used for some of their
waste prior to 1981, and 7800 indicated that they expected
to use recycling techniques after 1981.
The Chemical Manufacturers Association (1983) reported
that the quantity of hazardous wastewater generated by
the chemical industry (about 651 and 637 million metric
tonnes in 1981 and 1982, respectively) exceeds the
quantity of hazardous solid waste generated (about 6.4
and 4.5 million metric tonnes in 1981 and 1982, respec-
tively) by 2 orders of magnitude. Over 97 percent of
this wastewater is treated in wastewater treatment
plants, however, with over 80 percent being treated
on-site (Chemical Manufacturers Association 1983).
The differences in definition and the subsequent
inconsistent treatment of data on hazardous waste
generation make it difficult to obtain reliable historical
data on generation and to estimate the amount of waste
reduction that has occurred. While there are an
encouraging number of documented situations where waste
reduction has been implemented, data on the amount of
waste reduction that has occurred on a national scale are
lacking. Achievements in some specific cases are
substantial; examples of successful waste reduction
programs are documented in Campbell and Glenn (1982),
Ministere de ['Environment (1981), Royston (1979), and in
conference proceedings edited by Huisingh and Bailey
(1982). It is difficult, however, to tell from the
examples how much of the waste reduced is actually
hazardous and not nonhazardous sludge, wastewater, or
conventional air and water pollutants.
The lack of data on hazardous waste generation is
recognized by many investigators (U.S. General Accounting
Office 1984a; Petulla 1984). Because of the lack of data
on the amount generated and the amount of waste reduction
that has occurred at a national level, the committee
could not address the question of how much hazardous
waste is amenable to the use of waste reduction methods.
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Making this estimate is further complicated because the
obtainable level of waste reduction is strongly
influenced by economic and political considerations as
well as other factors. Although the committee cannot
reliably estimate the amount of waste reduction that is
possible, the committee's collective experiences reveal
that opportunities do exist for reducing the generation
of hazardous waste.
THE ROLE OF WASTE REDUCTION
IN WASTE MANAGEMENT STRATEGIES
Figure 1.1 shows the relationships between the options
a waste generator could consider in developing a strategy
for managing hazardous waste. This simplified diagram
has three levels of options: waste reduction; conversion
Hazardous Waste
~ .
1~;7
1~
Conversion of Hazardous to Less Hazardous or Nonhazardous
Physical/Chemical Biological Thermal
Treatment Trn~tm~nt Treatment
_ . . _ ..
Placement of Residuals in the Environment
In the
Land
In the
Water
In the
Atmosphere
FIGURE 1.1 Waste management options.
is the area focused on in this study.
The screened tier
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of hazardous waste to less hazardous waste; and placement
of residuals in the environment. The focus of this study
is on the upper tier. It must be recognized, however,
that the other options have an indispensable role in the
environmentally sound management of hazardous waste (see
Appendix A).
To some, the term "waste reduction" is limited to
in-plant changes in industrial production processes that
reduce the generation of hazardous waste. The committee,
however, includes both changes in production processes
and recycling and reuse of hazardous materials, either at
or away from the site of generation, in the definition of
waste reduction. To simplify the terminology, in this
report waste reduction is divided into four general
categories: abatement, minimization, reuse, and
recycling. The first two terms generally apply to
in-plant process modifications. The other two refer to
techniques that can be used either on or off the site of
generation. Table 1.1 provides definitions and examples
of the four terms.
Waste abatement refers to changes in industrial
processes that eliminate or drastically reduce the
quantities of waste produced. Technologies employing
abatement are also called low-waste and nonwaste
technologies. Substitutions of chemicals or changes in
production processes can achieve waste abatement.
Chemical substitutions may include the use of new
reactants, solvents, or ingredients in processing.
Process changes include those that increase internal
recycling and those that produce a product through the
use of alternative chemical routes. In the extreme case,
the product might be replaced by a substitute, the
production of which would generate smaller quantities of
hazardous waste or waste that might be more easily
treated to a nonhazardous form. Significant capital
expense or extensive research and development activities
are often needed with this approach.
As in the case of abatement, waste minimization
reduces the quantity of waste through modifications
within the production process, but in this case through
good housekeeping practices that entail relatively low
capital costs. Waste minimization can be used to reduce
the amount of waste that must leave the site, and it can
lower handling, shipping, and even treatment and disposal
costs.
The categories of recycling and reuse are often used
interchangeably, though differentiation between them can
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TABLE 1.1 Categories of Hazardous Waste Reduction Methodologies
Examples
1. Waste abatement: Substitution
of a new primary industrial process
for an old process to eliminate or
drastically reduce the quantity of
waste produced.
2. Waste minimization: The reduction
of the quantity of waste through good
housekeeping practices or by the
application of concentration technology.
Often included is the reduction in
hazardousness of waste through
simple in-plant treatment.
3. Waste reuse: The direct reuse
of a waste stream, as is, or with very
minor modification either by the plant
that produces the waste or by others.
4. Waste recycling: The reclamation
of value from waste streams through
the application of unit processes
such as distillation, etc.
Replacement of cyanide in
electroplating solutions
Replacement of solvent-based
paints by water-based ones
Separation of waste streams
to permit recovery
Recovery of metals from
electrodialysis
Neutralization of waste
and precipitation of
smaller volume sludges
Use of solvents from
electronics industry in
manufacture of paints
Use of refinery caustic in
pulping of wood
Use of paint sludges as
sealants
.
Waste oil refining
Solvent distillation
Secondary aluminum smelting
Iron salts from pickle liquor
be useful. Waste reuse generally occurs with little
modification to the waste, whereas recycling generally
occurs only after the valuable components of the waste
have been separated from the other components of the
waste stream. A residue of some sort is therefore
produced when materials are recycled.
It is important to note that the reuse and recycling
of hazardous waste must be undertaken with caution to
avoid risks to public health and the environment. For
example, improper storage of waste at recycling facilities
and reuse of contaminated oil for dust control on roads
could lead to severe problems. Some sites that currently
require extensive cleanup action are, in fact, former
sites of recycling and reuse facilities (e.g., U.S.
General Accounting Office 1984b).
It is sometimes hard to decide whether a particular
process in a particular case is a waste reduction or a
treatment methodology. For example, incineration can be
viewed as a technique for treating or detoxifying waste.
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On the other hand, certain by-products in industry have a
high solvent content and can be burned for their energy
content. In this case, the burning may be considered as
waste reduction via recycling or reuse. In general,
waste reduction methodologies attempt to go further back
in the production process to the source of the waste than
does conventional end-of-pipe treatment of pollutants.
Reduction methodologies employ engineering and chemical
principles to reduce their generation or recover useful
materials from them.
DYNAMICS OF WASTE REDUCTION STRATEGIES
The considerations affecting decisions by individual
firms to reduce the generation of hazardous waste depend
not only on technological and economic factors, but also
on the stage of development of their waste management
program. Ideally, public policies to encourage waste
reduction would be flexible enough to allow shifts in
emphasis as conditions change. The approaches that are
appropriate to reduce the risks to the public and the
environment at one phase of development differ from those
that are appropriate at another time. For example,
dissemination of technical information is important when
generators begin to explore the possibilities for waste
reduction. When generators require more capital-intensive
techniques to achieve additional reductions, public
policies for financial support become more important.
Some firms in the United States have sophisticated
waste reduction programs and have successfully reduced
the volumes of waste they generate. In many instances,
significant cost savings have been realized in the
process. Other firms are in the early phases of devising
and implementing such programs. The experiences of the
committee members suggest that the major portion of the
waste reduction effort in U.S. industry is still in the
early stages, and considerable opportunities exist for
reducing the generation of hazardous waste.
Reductions in the generation of hazardous industrial
waste can be expected to occur through a series of
loosely defined and overlapping phases (Figure 1.2). At
any time, some firms will be affected by considerations
that operate most strongly in one phase, and other firms
by those that operate in other phases. In the aggregate,
national policy would have to address the full panoply of
considerations, though some policies may deserve greater
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INITIAL PHASE
~ DEVELOPMENT PHASE ~ MATURE PHASE
Firmsconsider changing //// firms develop end implement /// RedL'ctic~n in Generation
waste management practices /// comprehensive strategies
and implement low-cost // for waste reduction, often
waste reduction opportunities /~ involving morecapital- of,, ~ rat
~ intensive technologies ~//-
,,,, . . ;, . . . _ .
/ approaches technologically,
/~ politically, or economically
/ accents ble l ~ m it
FIGURE 1.2 Phases in the implementation or a waste
reduction program.
emphasis depending on the current stage of industry's
waste reduction program at the national scale.
The committee believes that distinguishing the phases
of implementation of a waste reduction program provides a
helpful guide for discussing the relative importance of
the nontechnical considerations at different times and
for different firms or industries. It provides a
planning framework within which to discuss possible
institutional and public policy approaches to achieve the
desired reduction in generation of hazardous waste.
In the initial phase, external influences such as
increasing costs of disposal, liability considerations,
improved knowledge of health and environmental effects,
increasing public concern, and increasingly stringent
regulatory requirements for land disposal cause industrial
management to become aware of the problem and begin to
develop waste reduction strategies. The first steps in
implementing a waste reduction program--the simpler,
quicker, often least costly waste minimization approaches
such as good housekeeping practices and separation of
waste streams--are implemented in this phase. These
approaches could substantially reduce the amount of waste
that is generated.
In the development phase of a waste reduction program,
the quantity or degree of hazard of waste generated is
reduced as more sophisticated waste reduction methods are
applied. During this phase, there is a sharper evaluation
of options, greater attention to production process
modifications that reduce the generation of hazardous
waste, and increased development of improved or new
control technologies. Implementation of newer and/or
improved technologies and process modifications for waste
abatement and reuse and recycling substantially decreases
the amounts generated during this phase. The techno-
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logical approaches generally result in greater capital
expenditures than in the early phase.
In the mature phase, firms would design and build new
plants with improved waste management practices and
improved technologies as integral parts of the process.
Eventually, the technologically, politically, or
economically acceptable lower limit of hazardous waste
generation would be approached. The acceptable limit
would vary as improved technologies for waste reduction
are developed and as political and economic conditions
change. To achieve the most waste reduction that is
technologically practical, it is likely that more capital
would have to be expended and increasingly sophisticated
waste reduction technologies implemented. As firms would
have to undertake large capital expenditures in this
phase, the need for a clear understanding of the relative
risks associated with the remaining waste and for sound
risk management increases. Risk management, though a
relatively young concept whose techniques need to be
developed, can be an effective tool for understanding the
trade-offs between protection of public health and the
environment through reducing generation of hazardous
waste and costs of developing and implementing tech-
nologies to achieve this reduction.
The concept of phases in the implementation of a waste
reduction strategy is not intended to define precisely
the nature of a firm's waste reduction pattern. Rather,
the concept is meant to convey the idea that as firms
develop and implement waste reduction strategies,
different factors become important. Public policy, to be
effective in promoting waste reduction activities, must
be responsive to these different considerations.
Representative terms from entire chapter:
waste reduction
