Section One
POLLUTION PREVENTION/
WASTE MINIMIZATION
1    POLLUTION PREVENTION OPPORTUNITIES IN RCRA, AIR
AND WATER PERMITS
Marie Bush way Zanowick, Manager
Hazardous Waste Minimization Program, U.S. Environmental Protection Agency,
Region VIII, Denver, Colorado 80202
INTRODUCTION
Since June of 1990, the EPA Region VIII Hazardous Waste Management Division has had a part-
time employee and two part-time assistants dedicated to develop and manage the Hazardous Waste
Minimization Program (Program). The work of the Program has resulted in a tangible multi-media
reduction in the generation of waste and promotion of pollution prevention concepts through use of
existing resources, regulations, and authorities.
The EPA Region VIII Hazardous Waste Minimization Policy is as follows:
It is the policy of EPA Region VIII to encourage environmentally beneficial source reduction and recycling of hazardous waste through the combination of:
1) assisting States in development of strong hazardous waste minimization programs and;
2) use of existing permitting, inspection and enforcement authorities at the Regional and
State levels.
In order to comply with the hazardous waste capacity assurance requirement mandated by Section
104(c)(9) of the Comprehensive Environmental Response, Compensation, and Liability Act (CER-
CLA), each of the EPA Region VIII States (Wyoming, Montana, South Dakota, North Dakota,
Utah, and Colorado), referred to as the States, submitted a Capacity Assurance Plan (CAP). As part
of the approval process of the CAP, each of the States agreed to develop a strategy to minimize
hazardous waste. This strategy includes the use of existing state personnel and regulatory authorities
to incorporate pollution prevention into permits, inspections and enforcement actions.
The Program recognizes that in order for EPA and the States to promote pollution prevention
concepts, they need to be incorporated into existing programs, since additional resources are usually
not available. In addition, technical training on this new initiative must be provided. To facilitate this,
the Program developed and presented training to the EPA and state RCRA, air and water programs.
These training programs were delivered at each state agency and consisted of a series of three courses,
"Pollution Prevention in RCRA, Air and Water Permits", "Waste Minimization During Inspections",
and "Pollution Prevention Language in Enforcement Orders". Although the main focus of the Program is hazardous waste minimization, it was felt that if pollution prevention was promoted through
RCRA regulations only, cross-media transfer of pollution could result. The most important feature of
these courses is that it brought together all three media programs to identify and discuss relevant
regulatory issues.
COURSE DEVELOPMENT
The purpose of the Pollution Prevention in RCRA, Air and Water Permits training course was to
investigate whether changes in permitting at the State level can bring about the desired change in waste
management practices to effectuate the protection of environmental resources.
In order to develop and implement this type of training program, EPA and its contractor conducted
research into the potential of incorporating pollution prevention concepts and technologies into State
RCRA, air and water permits.
47th Purdue Industrial Waste Conference Proceedings. 1992 Lewis Publishers, Inc.. Chelsea, Michigan 48118.
Primed in U.S.A.