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Re: The real definition -Reply



At 04:15 PM 4/29/97 Lisa Brown wrote:
>With Ralph's response I thought I should add that for EPA "waste
>minimization" has a definition as well.  Under RCRA "waste
>minimization" is defined as source reduction and recycling
>(beneficial use/reuse and reclamation).  "Waste minimization" does
>not include treatment, volume reduction, or recycling activities that
>constitute disposal or burning for energy recovery.  Again this
>definition applies only to RCRA hazardous wastes.
>
>Lisa Brown
>EnSafe
>Memphis, TN
>lbrown@ensafe.com
>
Lisa may be right about the circumstance now.  But EPA really stirred up a
hornet's nest with its first definition of "waste minimizaton" which
included burning for energy recovery and could be (and was, by some,) read
to include incineration and other treatment which reduced the volume of
waste disposed in land disposal units.  And the definition had only to do
with RCRA wastes that were land disposed, there was not a scintilla of
concern in the original definition about media swapping, etc.

That original definition led to some environmental groups treating "waste
minimization" as a perjorative term for failure to do source reduction.

Just a little historical note from the oldest first year law student at CWRU!

Ralph


Ralph E. Cooper, Ph.D.
3475 Norwood, Suite N
Shaker Heights, OH 44122-4975
e-mail:	rec3@po.cwru.edu
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