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Suggested Citation:"Front Matter." National Research Council. 1985. Reducing Hazardous Waste Generation: An Evaluation and a Call for Action. Washington, DC: The National Academies Press. doi: 10.17226/315.
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Suggested Citation:"Front Matter." National Research Council. 1985. Reducing Hazardous Waste Generation: An Evaluation and a Call for Action. Washington, DC: The National Academies Press. doi: 10.17226/315.
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Suggested Citation:"Front Matter." National Research Council. 1985. Reducing Hazardous Waste Generation: An Evaluation and a Call for Action. Washington, DC: The National Academies Press. doi: 10.17226/315.
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Suggested Citation:"Front Matter." National Research Council. 1985. Reducing Hazardous Waste Generation: An Evaluation and a Call for Action. Washington, DC: The National Academies Press. doi: 10.17226/315.
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Suggested Citation:"Front Matter." National Research Council. 1985. Reducing Hazardous Waste Generation: An Evaluation and a Call for Action. Washington, DC: The National Academies Press. doi: 10.17226/315.
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Suggested Citation:"Front Matter." National Research Council. 1985. Reducing Hazardous Waste Generation: An Evaluation and a Call for Action. Washington, DC: The National Academies Press. doi: 10.17226/315.
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Suggested Citation:"Front Matter." National Research Council. 1985. Reducing Hazardous Waste Generation: An Evaluation and a Call for Action. Washington, DC: The National Academies Press. doi: 10.17226/315.
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Suggested Citation:"Front Matter." National Research Council. 1985. Reducing Hazardous Waste Generation: An Evaluation and a Call for Action. Washington, DC: The National Academies Press. doi: 10.17226/315.
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Suggested Citation:"Front Matter." National Research Council. 1985. Reducing Hazardous Waste Generation: An Evaluation and a Call for Action. Washington, DC: The National Academies Press. doi: 10.17226/315.
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Suggested Citation:"Front Matter." National Research Council. 1985. Reducing Hazardous Waste Generation: An Evaluation and a Call for Action. Washington, DC: The National Academies Press. doi: 10.17226/315.
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Suggested Citation:"Front Matter." National Research Council. 1985. Reducing Hazardous Waste Generation: An Evaluation and a Call for Action. Washington, DC: The National Academies Press. doi: 10.17226/315.
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Suggested Citation:"Front Matter." National Research Council. 1985. Reducing Hazardous Waste Generation: An Evaluation and a Call for Action. Washington, DC: The National Academies Press. doi: 10.17226/315.
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Reducing Hazardous Waste Generation An Evaluation and a Call for Action Committee on Institutional Considerations in Reducing the Generation of Hazardous Industrial Wastes Environmental Studies Board Commission on Physical Sciences, Mathematics, and Resources National Research Council NATIONAL ACADEMY PRESS Washington, D.C. 1985

NATIONAL ACADEMY PRESS 2101 CONSTITUTION AVENUE, NW WASHINGTON, DC 20418 NOTICE: The project that is the subject of this report was approved by the Governing Board of the National Research Council, whose members are drawn from the councils of the National Academy of Sciences, the National Academy of Engineering, and the Institute of Medicine. The members of the committee responsible for the report were chosen for their special competences and with regard for appropriate balance. This report has been reviewed by a group other than the authors according to procedures approved by a Report Review Committee consisting of members of the National Academy of Sciences, the National Academy of Engineering, and the Institute of Medicine. The National Research Council was established by the National Academy of Sciences in 1916 to associate the broad community of science and technology with the Academy's purposes of furthering knowledge and of advising the federal government. The Council operates in accordance with general policies determined by the Academy under the authority of its congressional charter of 1863, which establishes the Academy as a private, nonprofit, self-governing membership corpora- tion. The Council has become the principal operating agency of both the National Academy of Sciences and the National Academy of Engineering in the conduct of their services to the government, the public, and the scientific and engineering communities. It is administered jointly by both Academies and the Institute of Medicine. The National Academy of Engineering and the Institute of Medicine were established in 1964 and 1970, respectively, under the charter of the National Academy of Sciences. Library of Congress Catalog Card Number 84-62248 International Standard Book Number 0-309-03498-1 Printed in the United States of America

Committee on institutional Considerations in Reducing the Generation of Hazardous Industrial Wastes RAYMOND C. LOEHR, Cornell University, Chairman WILLIAM M. EICHBAUM, Maryland Department of Health and Mental Hygiene ANTHONY O. FACCIOLO, JR., Alexandria Metal Finishers, Inc. (deceased) SAMUEL GUSMAN, Taos, New Mexico ROBERT A. LEONE, Harvard University MICHAEL R. OVERCASH, North Carolina State University PHILIP A. PALMER, E.I. du Pont de Nemours & Co. STEFFEN W. PLEHN, Fred C. Hart Associates, Inc. ROBERT B. POTASEK, Chas. T. Main, Inc. MICHAEL E. STREM, Strem Chemical, Inc. Staff RUTH S. DEFRIES, Staff Officer PAUL B. SCHUMANN, NRC Fellow JOYCE E. FOWEER, Administrative Secretary

Environmental Studies Board STANLEY I. AUERBACH, Oak Ridge National Laboratory, Chairman WILLIAM E. COOPER, Michigan State University I. CLARENCE DAVIES, The Conservation Foundation JOHN W. FARRINGTON, Woods Hole Oceanographic Institution GEORGE M. HIDY, Environmental Research and Technology, Inc. MARGARET HITCHCOCK, Fairfield, Connecticut, Consultant WILLIAM G. HUNTER, University of Wisconsin JULIUS JOHNSON, DOW Chemical (retired) RAYMOND C. LOEHR, Cornell University ROGER A. MINEAR, University of Tennessee CLIFFORD RUSSELL, Resources for the Future EDITH BROWN WEISS, Georgetown University Law Center Stab MYRON F. UMAN, Staff Director WILLIAM M. STIGLIANI, Staff Officer RUTH S. DEFRIES, Staff Officer PAUL B. SCHUMANN, NRC Fellow JANET A. STOLL, Staff Assistant TOYCE E. FOWLER, Administrative Secretary - 1V

Commission on Physical Sciences, Mathematics, and Resources HERBERT FRIEDMAN, National Research Council, Chairman ELKAN R. BLOUT, Harvard Medical School WILLIAM BROWDER, Princeton University BERNARD F. BURKE, Massachusetts Institute of Technology HERMAN CHERNOFF, Massachusetts Institute of Technology MILDRED S. DRESSELHAUS, Massachusetts Institute of Technology WALTER R. ECKELMANN, Sohio Petroleum Company JOSEPH L. FISHER, Office of the Governor, Commonwealth of Virginia JAMES C. FLETCHER, University of Pittsburgh WILLIAM A. FOWLER, California Institute of Technology GERHART FRIEDLANDER, Brookhaven National Laboratory EDWARD A. FRIEMAN, Science Applications, Inc. EDWARD D. GOLDBERG, Scripps Institution of Oceanography CHARLES L. HOSLER, TR., Pennsylvania State University KONRAD B. KRAUSKOPF, Stanford University CHARLES I. MANKIN, Oklahoma Geological Survey WALTER H. MUNK, University of California, San Diego GEORGE E. PAKE, Xerox Research Center ROBERT E. SIEVERS, University of Colorado HOWARD E. SIMMONS, TR., E.I. du Pont de Nemours & Co., Inc. JOHN D. SPENGLER, Harvard School of Public Health HArrEN S. YODER, JR., Carnegie Institution of Washington RAPHAEL G. KASPER, Executive Director LAWRENCE E. MCCRAY, Associate Executive Director v

Preface The Committee on Institutional Considerations in Reducing the Generation of Hazardous Industrial Wastes was organized in September 1983 to explore the nontechnical factors that influence decisions by industrial management to reduce the generation of hazardous waste. The committee, sponsored by the Andrew W. Mellon Foundation and National Academy of Sciences Endow- ment funds, was asked to examine the public policy approaches that may lead industries to reduce generation of hazardous waste. The report therefore fo- cuses on reduction in generation of hazardous waste and not treatment, al- though the committee recognizes that treatment alone or in conjunction with reduction in generation can also be an effective approach to a specific problem. Industrial decisions about waste reduction are made for varied and complex reasons. The committee's task to understand these reasons was constrained by the lack of comprehensive and systematic data on the amount of waste reduction that has occurred over the broad range of industry and by the lack of extensive literature on the nontechnical aspects of waste reduction. Therefore many of the observations in the report are based on the presentations made to the committee, reports on topics related to waste reduction, and workshop discussions. In formulating its conclusions, the committee relied on these observations and on the collective experience of its members with large and small firms, public administration at the federal and state levels, and consultancy with industry (see Appendix E). After considerable discussion, there was little disagreement among members about the basic conclusions of the report. Among the "institutional," or nontechnical, factors the committee con- sidered were economic factors, such as capital costs of waste reduction equip- ment; regulatory factors, such as stringency of standards; and psychological factors, such as attitudes toward change. Many such factors were considered in the course of the study, and some of them were not discussed separately in the text for a variety of reasons. For example, public involvement and understand- ing of industrial efforts to reduce the generation of hazardous waste is a factor affecting decisions. Public involvement is related to many factors that are vat

presented, such as the public's role in ensuring a predictable regulatory pro- gram; thus it is discussed in several different contexts throughout the report. Time constraints did not permit the committee to look in detail into several issues that members recognized as being important to the public discussion on waste reduction. As mentioned in several places throughout the report, small businesses face a unique set of nontechnical considerations in their decisions about waste generation and reduction. The complex issue of the generator's liability for remedial action and how it affects decisions about waste generation is also important. In addition, a uniform definition of hazardous waste is essential to devising an accepted way for collecting data on waste generation. The committee hopes that this report will stimulate future work on these and other issues that it has raised. In~considering the relative importance of the various factors, the committee concluded that no single factor or group of factors is the most important in all circumstances. The relative importance of the factors depends on the dynamic interplay of such variables as the type and size of the industry or plant and the amount of waste reduction that has already been achieved. In this report, the dynamic character of waste reduction programs is used as a framework within which to explore the relative importance of the nontechnical factors and the potential effectiveness of public policy alternatives at different stages in the nation's waste reduction effort. The committee conducted its study through a series of meetings and consulta- tions with experts in the field. It reviewed many documents about hazardous waste management and other related fields (see Appendix C), but, as mentioned above, its work was constrained by the lack of peer-reviewed literature in the area of waste reduction. Indeed, this is one of the first attempts at a comprehen- sive work on institutional considerations. Many examples of achievements in waste reduction were brought to the committee's attention. It is difficult to generalize, however, from a series of examples where there are limited data to suggest their wider applicability. Much of the report therefore represents the personal experience and judgment of the committee after consideration of the facts brought before it. To test this judgment, the committee organized a workshop in May 1984 at which a group of experienced people from industry, state and federal govern- ment, and environmental groups (see Appendix D) were asked to discuss the issues raised in this report. Discussion papers prepared by the committee were circulated in advance and served as the focus of the interaction. The papers discussed the institutional barriers to more effective waste reduction in the United States. The workshop participants responded that to focus on the barriers to waste reduction seemed unnecessarily negative, in that such a focus did not highlight the achievements that have been made with waste reduction and wrongly implied that opportunities for waste reduction are limited. The . . . vail

committee then framed the ideas in this report in a more neutral tone, focusing on "factors affecting industrial decisions about waste generation." The commit- tee is grateful to the participants for their candid contributions to the discussion and their helpful insights. It is with great sadness that the committee reports that one of the members, Anthony 0. Facciolo, Jr., passed away in June of 1984. He not only brought a unique perspective to the committee both as a lawyer and as a manager of a small metal finishing firm, but also brought pertinent insights and a personal warmth. The Hazardous and Solid Waste Amendments of 1984, the reauthorization of the Resource Conservation and Recovery Act by the 98th session of Congress, states that the national policy of the United States is, wherever feasible, to reduce or eliminate the generation of hazardous waste as expeditously as possible. Although this report was prepared before the final reauthorization of RCRA, it analyzes actions that would accomplish the reduction in generation called for in the Act. The committee thanks the many people who provided data and their insights. Adam M. Finkel assisted in the preparation of the text. Lori Segall catalogued a considerable number of reports and other background material that were most helpful. The committee also wishes to express appreciation to the NRC staff: Ruth DeFries, staff officer for this study; Paul Schumann, NRC Fellow; Myron Uman, executive director of the Environmental Studies Board; and Joyce Fowler, administrative secretary, for their patience, long hours, dedication, and competence. Finally, I want to thank my colleagues on the committee who provided excellent professional experience and insight and who worked with exceptional dedication and energy to bring this task to completion and this report to fruition. RAYMOND C. LOEHR Chairman 1X

Contents Summary of Analysis and Conclusions . Introduction...... Scope of the Study, 7 Definitions of Hazardous Waste, 8 Estimates of Hazardous Waste Generation, 9 The Role of Waste Reduction in Waste Management Strategies, 11 Dynamics of Waste Reduction Strategies, 14 2 Factors Affecting Industrial Decisions About Hazardous Waste Generation .............................. Introduction, 17 Cost of Land Disposal, 21 Attitudes Toward Change, 22 Availability of Information About Waste Reduction Methodologies, 25 Regulatory Issues in Reducing the Generation of Hazardous Waste, 28 Needs for Research and Development, 36 Capital Costs, 38 Issues in Assembling, Processing, and Sale of Recycled Materials, 39 Product Quality Standards, 42 Approaches for Encouraging Hazardous Waste Reduction Introduction, 45 X1 17 . .45

Approaches for Encouraging Firms to Reduce Hazardous Waste Generation in the Initial Phase, 46 Approaches for Encouraging Firms to Continue Waste Reduction Programs in the Development Phase, 52 Considerations in the Mature Phase, 53 References. . Appendixes A Hazardous Waste Management Methodologies ....... B A Typical Waste Reduction Program.............. C Additional Documents Reviewed by the Committee. . D List of Workshop Participants................ E Biographical Sketches of Committee Members x~ ..... 55 61 64 .67 73 74

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This is the first thorough exploration of how industry, government, and the public can use available nontechnical means to reduce significantly the amount of hazardous waste entering the environment. Among the approaches considered are modifications to avoid contaminating normal wastewater with hazardous by-products, education of management and engineering personnel about reuse and recycling, reform of regulations and enforcement procedures, and incentives for improvement in waste practices. A free digest of this volume accompanies each copy.

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