HWIR Status -Reply

[EDWARD WEILER <WEILER.EDWARD@epamail.epa.gov>]

As a general proposition, I think your perception is correct.  The origian
purpose of HWIR was to "fix" what some saw as a requirment under
RCRA to treat constituents to levels below a risk-based level.  From my
perspective (I work in the Pollution Prevention Division of EPA--not in the
RCRA Program), HWIR in and of itself will probalbly not have much effect
one way or another on pollution prevvention--that's not the environmental
issue it  was/is designed to address.  That said, it would seem to me that
the "multipathway analysis" that is being designed to help set meaningful
risk-based exit levels should have benefical spillover effects for pollution
prevention, to the extent that it helps us get a handle on the cross-media
transfer issue.  

For additonal information, I recommend that you contact the HWIR
Workgroup Chair in RCRA, Mr. Al Collins.  Al has been with HWIR from
Day 1 and can give you all the ins and outs.  You might also ask Al for a
reality check on what I said to you above.  I'd be intrested to learn what
you find out.  

Ed Weiler (USEPA-Pollution Prevention Division)
Washington, D.C.
 Phone: (202) 260-2996 
 

>>> <Ronald_A_Del_Mar@rl.gov> 04/15/97 11:50am >>>
     Does anybody know the status of the proposed Hazardous Waste 
     Identification Rule (HWIR) amendement to 40 CFR 261.  Is this ever 
     going to become law?
     
     The reason I ask is that the proposed rule makes several statements 
     that the proposed "risk-based" hazardous waste listing process is 
     supposed to "encourage pollution prevention and waste minimization."
 
     I guess it depends on your definition of pollution prevention, but I 
     fail to see how the HWIR would encourage pollution prevention.  I 
     don't consider changing the regulatory status of a waste to be 
     "pollution prevention."  Is there something in here that I am missing? 
     
     I am putting together a justification section for a pollution 
     prevention program as part of an overall project proposal. In addition 
     to things like potential costs savings, environmental benefits, and 
     reducing a companies regulatory burden and liability, I am trying to 
     look at all of the regulatory drivers for having a pollution 
     prevention program. Somebody suggested I look at the HWIR. I guess
I'm 
     having trouble seeing how the HWIR (if adopted) would provide any 
     extra regulatory incentive for having a pollution prevention program 
     that is not already in RCRA (i.e., required certifying statements on 
     manifests, biannual/annual reports, and TSD permit applications).  Can

     anybody shed light on this?
     
     Ron Del Mar
     Fluor Daniel Northwest
     (509) 376-1967
     ronald_a_del_mar@rl.gov