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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 7

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8 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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9 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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10 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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11 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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12 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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13 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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14 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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15 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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16 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.