Recycling or Disposal? 
Hazardous Waste Combustion in Cement Kilns 

II. EPA'S National Hazardous Waste Minimization and Combustion Strategy

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In May, 1993, the U.S Environmental Protection Agency announced a major hazardous waste policy initiative. EPA's new strategy focuses on five goals: 1) making reduction of hazardous waste at the source the number one priority; 2) strengthening the role of the public in shaping national hazardous waste policy and in the local permitting process; 3) upgrading pollution control standards and requirements at hazardous waste combustion facilities; 4) ensuring waste combustors do not pose unacceptable risks to human health or the environment and strengthening enforcement of those standards; and 5) continuing to advance scientific understanding of waste combustion issues.

The EPA announced a number of short-term actions to carry-out these goals within the existing permitting and enforcement process, including a) assigning low priority to issuing permits to new combustors except those which are replacing existing units; b) using "omnibus" permitting authority under RCRA Sec. 3005(c)(3) to include dioxin emissions standards and/or more stringent particulate matter/metals emissions limitations in new permits; c) requiring site-specific risk analysis for new permits, including risks from indirect exposures; d) expanding public participation in the permitting process; and e) enhancing inspection and enforcement for existing combustors. To implement these measures, EPA intended to review all "commercial" (i.e., facilities which charge fees to accept waste from outside sources) BIF and hazardous waste incinerator permit applications for approval within 12 months, and all other permit applications for approval within 24 months.

Over the longer term, EPA intends to rewrite its administrative rules concerning pollution controls at hazardous waste facilities. EPA has initiated a rule-making procedure to upgrade its BIF rules with the goal of having new rules in place by September, 1995. EPA has also convened a task force of state and federal officials to evaluate the role of source reduction and combustion in the nation's waste management hierarchy.

EPA's rule-making procedure, currently underway, is a critical element in the overall hazardous waste strategy. The EPA's chief goal is to establish a strong preference for source reduction over waste management. The EPA believes that the greater expense of new environmental requirements will eventually encourage industry to find new ways to reduce generation of hazardous waste, along with assuring greater protection of human health and the environment in the communities where combustors are located.

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