Pollution Prevention 1997: National Progress Report


Office of Pollution'  •..
Prevention and-.Tbxics .
WasKiri.gton, DC •20460' "
'E'PA'742-R-97-OqJT '
June 1997 .  ".  ' '";

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In a work of this magnitude, a disclaimer is necessary: There is a lot of good prevention
work we could have highlighted here and have not for lack of space. In no way does our
failure to mention any project imply that we do not value its contributions to environmental
protection. Likewise, mention of programs, products, services, and organizations in this
publication does not imply approval or endorsement by the EPA.

Copies of this report are available from EPA's Pollution Prevention Information Clearing-
house. Comments on the report are welcome. Readers can direct their comments to the
Clearinghouse at:
                             401 M St., SW (7409)
                             Washington, DC 20460
                             Phone:202-260-1023
                               Fax: 202-260-4659
                         E-mail: ppic@epamail.epa.gov

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Contents
            ,                                                                      Page Number

Foreword by Carol M. Browner, Administrator of the U.S. Environmental Protection Agency	vii

Executive Summary	.•«•«	1

Chapter 1 — Promoting Prevention at EPA	.'.	 15
    EPA Perspectives on Pollution Prevention by Lynn Goldman, Assistant Administrator for
    EPA's Office of Pesticides, Prevention and Toxic Substances
    Theme 1: Incorporate Prevention into Mainstream Agency Work             •
   . Theme 2: Help Build National Network of Prevention Programs
    Theme 3: Pioneer Environmental Programs Emphasizing Cross-Media Prevention
    Theme 4: Establish New Federal Partnerships
    Theme 5: Generate Environmental Information and Track Progress
    Theme 6: Develop Partnerships in technological Innovation
    Theme 7: Change Federal Environmental Laws to Encourage Pollution Prevention
Chapter 2 — Looking at Industry.	•	43
    Industry Progress: TRI and Voluntary Programs
    Establishing Corporate Commitment to Pollution Prevention
    Helping Small Businesses to Undertake Pollution Prevention Measures
    Encouraging Industry-wide Initiatives
    Reaching Suppliers and Customers
    Making the Most of Community Involvement
    Selling Environmentally-Preferable Products
    Innovative Ideas     .          ;    '
 '   Guest Commentaries  from:
       Edwin L. Mongan, DuPont
       Craig Doolittle, The Dow Chemical Company
       Marc J.,Epstein, INSEAD                                  •
                                                                                               i

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                                                                                  Pae Number
Chapter 3 — The Role of Other Federal Agencies in Prevention.
    Federal Agency Pollution Prevention Activities
        Department of Agriculture
        U.S. Agency for International Development
        Department of Commerce
        Department of Defense
        Department of Energy
        General Services Administration
        Department of the Interior
        National Aeronautics and Space Administration
        U.S. Postal Service
        Department of Transportation
        The White House
    Guest Commentaries from:
        Fran McPoland, Federal Environmental Executive
        Sherri Goodman, U.S. Department of Defense
        Christine Ervin, U.S. Department of Energy
Chapter 4 — Preventing Pollution at the State and Tribal Level	
    Overview of State Programs
    State Program Activities
    Pollution Prevention on Tribal Lands
    Guest Commentaries from:
        Linda Bray Rimer, North Carolina Department of Environment
        Mary A. Gade, Illinois Environmental Protection Agency
        Andrea Farrell, The National Pollution Prevention Roundtable

Chapter 5 — Prevention at Educational Institutions: Engaging Future Leaders.

    K-12 Programs
    University-level Programs
,....129
  .163

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Page Number
Guest Commentaries from: . -
David Allen, The University of Texas at Austin
Michael Heiman, Dickinson College
Jonathan W. Bulkley, National Pollution Prevention Center at the University of Michigan
Chapter 6 — The Contributions of Community and Non-Profit Organizations.... « 187
Local/Community-Based Initiatives
Two Tools for Communities
Community Issues and Initiatives
National Non-Profit Organizations
Guest Commentaries from:
Paul Orum, Working Group on Community Right-to-Know
Mary Rosso, Maryland Waste Coalition
Naomi Friedman, National Association of Counties, and Karen Troccoli,
National Association of County and City Health Officials
Chapter 7 — Measuring Pollution Prevention....—... ..— • 21S
The Emerging Framework for Measuring Prevention
• Measuring Program Effectiveness in States and Communities
Measuring Pollution Prevented
. Other Measures for Pollution Prevention
Guest Commentary from:
Ken Geiser and Elizabeth Harriman, Toxics Use Reduction Institute
Chapter 8 — The Future of Pollution Prevention ; 235
Guest Commentaries from:
Joseph T. Ling, 3M - • . .
Warren R. Muir, Hampshire Research Associates, Inc.
David L. Thomas, Illinois Department of Natural Resources
Harry Freeman, University of New Orleans
iii

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 ' Table oi

                                                                                 Page Number
        Joanna D. Underwood, INFORM, Inc.
      .  Gerald Kotas, U.S. Department of Energy

 Appendix A - Available Resources	,	253

 Appendix B - Pollution Prevention Act of 1990	267

 Appendix C - Pollution Prevention: EPA's Statement of Definition	275

 Index	279
Iv

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Foreword

by
Carol M. Browner
Administrator of the U.S. Environmental Protection Agency
Washington, DC
, Moving from concept to reality — that's the progress on pollution prevention we are proud to document in Pollution
Prevention 1997: A National Progress Report.
Though it has been less than seven years since passage of the Pollution Prevention Act, the idea of reducing or
eliminating pollution at its source has already gained a firm hold in environmental policy and now manifests itself
in dozens of EPA programs and initiatives. After two decades of trying to control pollution at the end of a pipe, or,
by treating its effects, we are now operating under the principle that preventing pollution is cleaner, cheaper, and
smarter than simply playing the shell game — moving contaminants around, from air, to water, to land.
But the most encouraging progress is being made beyond the offices of EPA In local communities where citizens,
elected officials, business representatives, and other stakeholders are working together to find common sense solu-
tions to their local pollution problems. s ,
EPA has sought to encourage their efforts in a variety of ways. For instance, increasing the amount of publicly
available information on toxic chemicals that are released into the environment has proved to be one of the most
effective ways to reduce local pollution, because it gives citizens democracy's most powerful tool — knowledge.
That's why we have expanded our Toxics Release Inventory (TRI) to include more chemicals and more industrial
facilities that must report their toxic emissions.
Armed with TRI data, countless communities and industry officials have worked together to reduce and prevent
pollution. Literally thousands of companies, after seeing this comprehensive snapshot of their individual facilities,
have decided they must prevent pollution — and have taken immediate action to do so. Since 1988, reported
releases of toxic chemicals have decline.d by an astounding 46 percent nationwide.
A growing number of industry leaders are viewing environmental protection not as a regulatory problem but as a
business opportunity, and thus are doing a better job of monitoring their environmental costs. EPA's Project XL and
Common Sense Initiative are designed to encourage businesses to improve their environmental performance, and
thereby reduce their pollution of the public's air, land and water. •
States and tribes, as well, are taking measures to make pollution prevention the guiding force of their environmental
management programs. We at EPA are learning from their groundbreaking efforts and are proud to support them.
Through partnership efforts, thousands of organizations across America are voluntarily conserving energy and
water, reducing greenhouse gases, toxic emissions, and solid wastes — and building pollution prevention into the
heart of their products and their services.
This report, EPA's first national report on pollution prevention since 1991, details the progress that is being made on
all levels — from EPA initiatives and industry programs to the exemplary efforts of states, universities, communities,
non-profits and conscientious individuals. Across the country, from corporate boardrooms to individual house-

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kForevv'
f^y^ai^jn
holds, a greater awareness of humans impacts on the environment is developing. Herein you will read about the
nation's most promising examples of how Americans are preventing pollution and, ultimately, making our commu-
nities more sustainable.
To be sure, there are still many questions about the future of pollution prevention. They, too, are presented in this
report.
But this report offers a great deal of hope that no pollution challenge is too daunting to be overcome by the ingenuity
of the American people. I hope you enjoy reading it and that you find it a useful reference tool for developing new
and innovative ways to make our environment safer and healthier for future generations.
vi

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Executive Summary

Pollution prevention first emerged as a watchword for environmental protection in the
work of Dr. Michael Roy ston nearly 20 years ago. Royston's book, "Pollution Preven-
tion Pays," advanced an idea that has become the basis for an enormous range of
activity — that preventing pollution, rather than controlling it or cleaning it up, could
provide both environmental and economic benefits. Environmental protection and
economic progress could be complementary, not competing, goals.
Pollution Prevention 1997: A National Progress Report highlights activity in the pol-
lution prevention arena. This report is a sequel to the first such report, issued six years
ago (Pollution Prevention 1991: Progress in Reducing Industrial Pollutants). Much
has changed in that short period of time. The level of activity in pollution prevention
has mushroomed, the concepts underlying pollution prevention have become more
widely disseminated, and creative solutions and technologies have emerged to deal
with complex problems. Pollution prevention is on the move, from the boardroom to
the classroom and from the statehouse to the community center. If there is one
overarching and encouraging change in the last six years, it would have to be this
growing enthusiasm for pollution prevention, particularly in education. The spread of
pollution prevention to elementary schools and high schools, and the interest in "green-
ing" university campuses on the part of students themselves are among the most hope-
ful signs for the future.
Part of the resurgence of interest in pollution prevention reflects the common sense
understanding of most people that it is easier to prevent problems than to fix them.
This common sense understanding is reflected in the environmental management hier-
archy of the Pollution Prevention Act of 1990, in which Congress established as na-
tional policy that:
• Pollution should be prevented or reduced at the source whenever feasible;

• Pollution that cannot be prevented should be recycled in an environmentally
safe manner whenever feasible;
• Pollution that cannot be prevented or recycled should be treated in an environ-
mentally safe manner whenever feasible; and

• Disposal or other release into the environment should be employed only as a
last resort and should be conducted in an environmentally safe manner.

Environmental challenges have not gone away in the last six years. Increased popula-
tion and consumption patterns threaten to outpace the gains achieved through environ-
mental statutes. Persistent and bioaccumulative toxic chemicals are found in the envi-
ronment with long term effects that we are only beginning to understand. Waste treat-
ment technologies sometimes transfer pollutants from air to water to land or vice versa.
A legacy of waste sites presents frustrating challenges for remediation, while dispersed
and nonpoint sources of pollution represent some of the most intractable problems for

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 Executive Si
',	 ,	fOa&Ki
    ' enVifoaent
                            restoring and sustaining environmental quality. Pollution prevention is a primary tool
                            for dealing with all of these challenges.
                            The intent of this report is to highlight some of the widely differing activities that can
                            prevent pollution, and to give readers a sense of the creativity and diversity of partici-
                            pation in pollution prevention. Given the scope and pace of activity, we have not tried
                            to present a comprehensive picture of progress across the country.  (In the interests of
                            space, we have left international activities out of the report entirely, although we rec-
                            ognize that prevention approaches are not confined to this country.) The selection of
                            material inevitably reflects an EPA perspective. For this reason, we are particularly
                            grateful for the perspectives of a distinguished group of guest commenters, who are
                            dedicating much of their professional ! lives to pollution prevention. 'We are delighted
                            to hear their voices and to have this document strengthened by their views.
                            While this report points  to the great strides that have been made  in developing and
                            implementing pollution prevention programs, there is still much  to be done in pre-
                            venting pollution itself and measuring progress. We hope that readers will come away
                            with a renewed appreciation of the value of prevention, as well as ideas and new ap-
                            proaches that they can consider adapting to their own situations.
                                                                              •Each of the chapters in this
                                                                               report discusses the pollution
                                                                               prevention activities of a par-
                                                                               ticular. sector  of  society
                                                                               (summarized below). Guest
                                                                               commentaries are included in
                                                                               each chapter of this report,
                                                                               representing organizations
                                                                               as diverse as  the National
                                                                               Association of Counties, the
                                                                               Dow Chemical Company, the
                                                                              Department of Defense, and
                                                                              the North Carolina Depart-
                                                                              ment of Environment, Health
                                                                              and Natural Resources. All
                                                                              parts of society have an in-
                                                                              terest in preventing pollution
                                                                              — state and local govern-
                                                                              ments, educational jnstitu-
                                                                              tions,  community groups,
                                                                              non-profit organizations -
                           IZ'i"'. ..'• 'J ''1't \lr":''v.''':: . ':.  '.''",. 'IX  1: J   and each group has pollution
                                                                              prevention advocates.  Al-
                           though their specific issues may differ, one thing becomes clear as you read what they
                           have to say — - we share a common goal in preventing pollution.
F                                ,
t  Pollution "prevention is potentially, the most effective 'method, for reducing risks
t;td,liurnknhealith and the enworiment, rjecause: it is:    ••-*:••••-•. •-•- :^ •-.  -  •••  -

j  •  the surest way to avoid the inadvertent transfer of pollutants across media
1  "    that may occur with end-of-tne-pipe control approaches,    .

;  •  the surest way to'eliminate theBrisks, that are inherent in any release of
1      pollutants into the environment, and  -

  • " me surest waylto'proBcl¥atural resources
      avoiding excessive levels of. wastes and residues and by minimizing the
      depletion of resources.                                  .  '

  Pollution prevention is also potentially the most cost-effective method of envi-
  ronmental protection, because it:       ':•'.       ;  , 1                  •
  •   reduces r.aw material and energy losses,

  •  - reduces the need for "end-of-pipe" treatment and disposal technologies,  -

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Chapter One—Promoting Prevention at EPA
Dr. Lynn Goldman; Assistant Administrator for EPA's Office of Prevention, Pesti-
cides, and Toxic Substances (OPPTS), introduces this chapter, observing that "pres-
sures on the environment are on the rise, in the United States and around the world."
Dr. Goldman comments on the connection between the move to reinvent government
and pollution prevention, noting that both initiatives  have the ability to "save re-
sources that can be devoted to further environmental protection." The remainder of
this chapter is organized around the seven themes that have provided the focus for
the Agency's activities in prevention as identified by Administrator Carol Browner
in her 1993 Pollution Prevention Policy statement.
•  Incorporating pollution prevention into the mainstream work of EPA..  Much
    of what EPA  does involves promulgating, implementing, and enforcing,
    environmental regulations. To encourage regulated entities to undertake
    pollution prevention, this mainstream work of EPA must be focused on
    prevention. The Agency has undertaken a concerted effort in the past six years
    to find the best ways to incorporate prevention into regulations and permitting,
    through such  efforts as the Source Reduction Review Project and EPA's
    Common Sense Initiative. EPA has also looked inward, at activities in its own
    facilities, and committed to taking advantage of prevention opportunities.

•  Building a national network of prevention programs. EPA cannot force or
    encourage pollution  prevention on its own; rather it must work with state and
    local governments to' develop a national network of prevention programs that
    will assist regulators at all levels of government in promoting pollution
    prevention. EPA is providing funding suppprt, technical assistance, information
    dissemination, and forming federal/state/local government partnerships to focus
    efforts on pollution prevention as the national goal  for environmental manage-
    ment.
•  Pioneering cross-media prevention programs, representing new models for
    government/industry interaction. Voluntary programs such as Partners for the
    Environment  are EPA/industry interactions aimed  at educating industry,
    citizens, state and local governments, and other stakeholders on ways in which.
    they can participate in pollution prevention.  These partnerships include the 337
    50 Program, Climate Wise, Green Lights, WasteWi$e, Design for the Environ-
    ment, Project XL, Environmental Accounting.WAVE (Water Alliances for
  .  Voluntary Efficiency), and Pesticide Environmental Stewardship.

•  Establishing new federal partnerships. EPA is working with other federal
    agencies to promote pollution prevention across the federal government. The
    partnerships involve establishing policies, implementing programs, managing
   . facilities, and acquiring goods and services.

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•  Generating environmental information on pollution prevention. One key to
    pollution prevention is access to information on pollutant sources, types of
    pollution generated, and technologies that can help prevent pollution at the
    source.  Programs such as the Toxics Release Inventory (TRI) yield informa-
    tion for industry, government, and communities on major types of releases, the
    industrial and government facilities that are releasing them, and the environ-
    mental media into which the pollutants are being released. Environmental
    information can be a powerful tool to drive purchasing decisions.  EPA's
    Consumer Labeling Initiative is examining ways to provide consumers with
    better environmental information, including improved product labels.

•  Developing partnerships for technological innovation in pollution prevention.
    EPA's partnerships with industry and universities are developing new tech-
    nologies for future pollution prevention efforts. These partnerships include
    the Green Chemistry Challenge and an Environmental Leadership Program,
    both of which support facilities that have volunteered  to demonstrate innova-
    tive approaches to pollution prevention. EPA's Office of Research and Devel-
    opment has invested heavily in developing and analyzing prevention technolo-
    gies.
•  Changing existing federal laws to encourage pollution prevention as the
    preferred method for reducing risks to health and the  environment.

Chapter Two — Looking at Industry
Although pollution prevention has spread to a wider audience, industry remains at
the center of pollution prevention activities.  Studies have shown that the economic
benefits are  compelling arguments in favor of pollution prevention, but only when
managers are able to see the cost savings that pollution prevention would bring. Envi-
ronmental accounting is a key factor in demonstrating to businesses the value of pre-
vention.
One starting place for considering industrial pollution prevention is the TRI main-
tained by EPA. TRI data, which are collected and published annually, show a steady
decline in the volume of toxic chemicals released to the environment by the manu-
facturing sector.  Since 1988, the year TRI reporting was  first required,.releases of
hazardous substances have decreased by 44 percent, although the volume of waste
generated has increased, attributable at least in part to an  improving economy and,
therefore, increased production. One of EPA's best-known voluntary programs, the 337
50 Program, had'a goal of reducing releases of 17 selected chemicals by 33 percent as
of 1992, and 50 percent by 1995. This program achieved the 1995 goal a year ahead
of schedule.
Companies that serve as models for pollution prevention responses have common ele-
ments, beginning with strong management support and commitment. Five large cor-
porations fostering prevention are highlighted: Monsanto and Union Carbide, leading
                                                                 	1,	.it.

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chemical manufacturers; Public Service Electric and Gas, a utility that used materi-
als management to yield pollution prevention returns; AT&T, which has made inno-
vative use of environmental accounting methods to further its pollution prevention
goals; and Home Depot, one of the most active retailers promoting a pollution pre-
vention agenda among its clients and staff.
While larger companies frequently have both the financial and technical resources and
.expertise in-house to implement pollution prevention practices, smaller businesses may
have a greater need for assistance. These businesses may find it difficult to identify
opportunities for pollution prevention in their processes and products and may also
may have fewer resources available to implement the changes, whether in equipment,
accounting practices, or other areas.  Five examples of successful small businesses are
described, along with information on federal and state programs that are available to
assist small businesses, including EPA's Small Business Compliance Assistance Cen-
ters and state Small Business Development Centers.
Industry pollution  prevention initiatives go beyond changes in manufacturing pro-
cesses to include product stewardship programs to reach suppliers and customers with
a pollution prevention message; working with communities and stakeholders to create
more sustainable products and expand market share; and selling "green" or environ-
mentally-preferable products.  Innovative ideas and technologies in pollution preven-
tion, ranging from new soldering process for circuit boards to using ultraviolet light to
coat beer cans (thereby eliminating emissions of volatile organic compounds), con-
clude the chapter.    ,
Guest author Edwin L. Mongan of DuPont observes that the key to future success lies
in cooperative efforts involving companies, local communities, regulatory agencies,
and environmental  groups.  Craig Doolittle of the Dow Chemical Company points out
the importance of prevention for global competitiveness, and highlights the value of
"resource productivity" — using less raw material, to make more product with less
waste. Both authors emphasize the importance of flexible, performance-based envi-
ronmental regulatory programs, and the need to integrate business and environmen-
tal management systems. Marc J. Epstein of INSEAD focuses on three specific tools
for improving corporate environmental performance: capital investment decision-mak-
ing, cost management, and performance evaluation.                        .

Chapter Three — The Role of Other Federal Agencies hi Prevention
The federal government is the largest single buyer of goods and services in the United
States, and the largest property-owner. In its varied roles as purchaser of products,
facility manager, regulator, and policy maker, the federal government is uniquely situ-
ated to encourage pollution prevention through the example of its own actions. Fed-
eral agencies have become substantially more active in pollution prevention over
the last six years,  under the  guidance of legislation  and a number of Executive
Orders. This chapter highlights the varied pollution prevention activities  of 11
federal agencies:

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.
 - Executives
                             •   The U.S. Department of Agriculture's Sustainable Agriculture Research and
                                 Education Program provides competitive grants for research,-education, and
                                 extension projects hi four regions of the country. The projects help farmers
                                 reduce pesticide use, manage wastes, and reduce energy consumption.

                             •   U.S. Agency for International Development (U.S. AID) operates an Environ-
                                 mental Pollution Prevention Project which focuses on locally sustainable
                                 pollution prevention programs for urban and industrial waste in developing
                                 countries by providing technical assistance for diagnosing problems, training,
                                 information dissemination, and assistance in program development.

                             •   The Department of Commerce's National Institute of Standards and Technology
                                 is assisting industry in technology development through four programs: (1)
                                 Advanced Technology Program, which provides cost-shared grants for high-
                                 risk technologies with commercial potential;  (2) Manufacturing Extension
                                 Partnership for small and mid-sized companies; (3) collaborative laboratory
                                 research with industry; and (4) the Malcolm Baldrige National Quality Award
                                 outreach program.
                             •   The Department of Defense (DoD) engages in numerous pollution prevention
                                 activities affecting both military installations and weapon systems. As a major
                              '   user and generator of hazardous substances, DoD has focused on reducing the
                                 use of these chemicals in its own facilities and by its suppliers. Life-cycle
                                 assessment is an integral part of these projects.

                             •   The Department of Energy (DOE) also uses, generates, arid releases a large
                                 amount of hazardous substances; its recent successes in addressing this problem
                                 have earned DOE an "Environmental Champion" award. Each facility is
                                 responsible for developing pollution prevention goals and determining the best
                                 method for achieving them. DOE is also working with its contractors to
                                 encourage and assist them in implementing similar pollution prevention efforts.

                             •   The General Services Administration is one of the largest purchasing units of
                                 the government and, with EPA, is piloting several projects to evaluate and
                                 distribute information on environmentally-preferable products.

                             •   The Department of the Interior is approaching pollution prevention and waste
                                 minimization at the Bureau level. Organizations such as the National Park
                                 Service and the U.S. Geological Survey are proceeding with plans to reduce the
                                 amount of toxic materials used, stored,  and disposed.
                                                                                                 I
                             •   The National Aeronautical and Space Administration's (NASA) pollution
                                 prevention strategy has resulted in a significant reduction in releases of TRI
                                 reportable substances over the last few years. NASA is using facility-specific
                                plans to promote and implement pollution prevention goals.

                             •  The U.S. Postal Service's Waste Minimization/Pollution Prevention Program
                                has resulted in a 76 percent decrease of solid hazardous waste generation since

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     1992.  Changes have occurred in the painting of service vehicles, the use of   ,
     dry cell batteries, recycling of mail trays and pallets, and numerous other
     areas.

 •   The Department of Transportation (DOT) is moving oa several fronts to
     integrate pollution prevention into its activities. Reductions in energy use by
     encouraging walking and bicycling, use of recycled materials in asphalt,
     wetlands mitigation, and decreased use of polluting substances are some of
     DOT's initiatives.

 •   Through the "Greening of the White House" project, President Clinton has  .
     instituted numerous changes in the operations of the White House to transform
     it into  a model for energy efficiency, waste reduction, and environmental
     protection.

 Guest author Fran .McPoland, the Federal Environmental .Executive; highlights the
 challenges  of Executive Order 12873: waste reduction, increased recycling, and pro-
 curement of environmentally-preferable products and products with recycled content.
 Sherri Goodman with the Department of Defense points out the accomplishments of
 DoD hi environmental protection, and emphasizes its goal of continuous improvement
 in environmental performance through new technologies, new partnerships, smarf: busi-
 ness decisions, and an emphasis on eliminating pollution at its source. Christine Ervin,
 writing on behalf of the Department of Energy, also points out both the strengths and
 the limitations of existing environmental paradigms in the face of growing population
 and resource demands, and maintains that the future belongs to those who best inte-
 grate resource efficiency into products and factories.

 Chapter Four — Preventing Pollution at the State and Tribal Level
 States have been in the forefront of innovation in pollution prevention. State activi-
 ties have shifted over the last six years, from legislation — in 1992 over half of the
 states had  passed some form of legislation promoting pollution prevention — to
 implementation issues, integration of pollution prevention into existing regulatory
programs, and attempts to measure progress in pollution prevention.
 Some states administer their pollution prevention programs though regulatory agen-
cies  with media-specific offices such as air, water, or solid waste.  Other states  also
involve nonregulatory agencies, such as university-based technical assistance programs',
a small business program, and a technology transfer foundation. Implementing these
programs involves a variety of approaches including technical assistance and outreach,
mandatory facility planning, and regulatory integration. At least 40 states offer confi-
dential, on-site pollution and waste assessments for small, and sometimes larger, busi-
nesses.  Over 30 states operate information clearinghouses on pollution prevention
and 30 states have some form of pollution prevention facility planning program. States
also  offer hotlines to provide specific information and answer questions, computer
searches to  provide up-to-date information, research  on specific pollution prevention
techniques, workshop and training seminars, publications,  and grants and loans,

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Executive.
particularly to small businesses. States are also incorporating pollution prevention
into regulatory activities such as enforcement settlements, permitting, compliance
inspections, and waste management. Pilot projects in Massachusetts, Ohio, New
Jersey, Indiana, and Illinois are described in this chapter.
As state pollution prevention programs look ahead, they face two primary challenges.
The first is to evaluate and measure the effectiveness of their technical assistance and
outreach efforts, in terms of actual pollution prevention results at the company level.
Second is the ongoing need to integrate pollution prevention into state regulatory
programs.
Tribal governments have only recently been able to consider, both economically and
technically, pollution prevention as an alternative to end-of-pipe controls. Although
most tribal governments are still in the nascent phase of environmental manage-
ment, since 1992, tribes have received 18 Pollution Prevention Incentives to States
(PPIS) grants and 14 Environmental Justice through Pollution Prevention (EJP2)
grants. , Several tribes have taken steps to integrate pollution prevention into their
regulatory and voluntary programs. Critical issue for integration of pollution pre-
vention into tribal activities are the lack of communication among tribes and the
need for education and outreach on pollution prevention. Tribes, EPA, and state
agencies are hoping to overcome these barriers by increased tribal participation in
national conferences and membership in organizations such as the National Pollu-
tion Prevention Roundtable.
Guest author Linda Bray Rimer of the North Carolina Department of the Environment
points out the challenges that states face in moving pollution prevention beyond "spe-
cial project" and mainstreaming it into state environmental programs. Mary Gade of
the Illinois Environmental^Protection Agency emphasizes the importance of incen-
tives, collaboration, and partnerships in using prevention to address remaining envi-
ronmental problems, and Andrea Farrell of the National Pollution Prevention
Roundtable highlights emerging international partnerships for prevention as well.
l: • • ' . *i|H,;. • , „• • • , _ i
Chapter Five—Prevention at Educational Institutions: Engaging Future
Leaders
Pollution prevention education is available through graduate school. The last six
years have seen an explosion of interest in pollution prevention in educational
institutions.
In kindergarten through high school, pollution prevention is being added to educa-
tional curricula in order to encourage children to practice pollution prevention at
school and. at home. Educational partnerships and organizations have created mate-
rials that engage children's imagination and enable them to see the practical results
of pollution prevention. Examples of these educational programs include the Texas
"Learning to Be Water Wise and Energy Efficient," and the active participation cur-
riculum Environmental ACTION.

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A number of universities and nonprofit organizations are developing curricula]: ma-
terials incorporating pollution prevention into courses in business, accounting, engi-
neering, chemistry, finance, and environmental sciences.   For example, the Man-
agement Institute for Environment and Business is working with business schools to
encourage an understanding\of how source reduction and waste minimization can
improve the profitability of a company  through environmental accounting, design
for the environment, life-cycle analysis, and quality management.
Universities are leading research and development on new pollution prevention con-
cepts, such as life-cycle analysis and industrial ecology. Spurred sometimes by stu-
dents, some universities have become activists in implementing pollution prevention
on campus.  For example, The George Washington University in Washington, DC,
signed a formal agreement with EPA to incorporate pollution prevention and other
environmental concepts into all aspects of university life.
Universities are also a vital  source of information for industry and communities.
There are at least 35 university-based centers for pollution prevention. These centers
work with industry on technology development and information dissemination, data
collection, audits, and training and conferences. Many states have established their
compliance assistance/pollution prevention coordinators at a regulatory agency with
the technical assistance program located at a university. Universities are forming part-
nerships with federal and state agencies, industry, and local community organizations
to solve real world environmental problems on a local, regional, and national scale.
Guest author David Allen of the University of Texas at Austin comments that most
prevention activities at universities have been grass-roots, but that their long-term
viability depends on making these activities "the rule, not the exception." Michael
Heiman of Dickinson  College notes  that college prevention programs need not be
limited to the campus — students have the opportunity to build bridges between the
campus and the wider community through environmental monitoring. Jonathan W.
Bulkley of the University of Michigan adds that it is important for colleges and univer-
sities to establish links with pace-setting industrial locations where creative preven-
tion activities are underway.

Chapter Six—The Contributions of Communities and Non-Profit
Organizations
Community involvement has been crucial in achieving many of the pollution preven-
tion successes discussed in this report. Chapter Six discusses two entities that are
influencing pollution prevention at local, national, and global levels: communities
and non-profit organizations.
Community-Based Environmental Protection (CBEP) projects focus on local condi-
tions and problems, recognizing that each community is unique and that solutions for
one locale are not necessarily applicable to another. CBEP also encourages partner-

-------
ships between public and private entities to address local environmental issues and
resources. '
While community concerns over industrial pollution are a primary focus for preven-
tion, pollution prevention in the local and regional levels is often interwoven with
issues of transportation, land use, and building design/indoor air quality. Several local
initiatives are highlighted in this chapter.
Prevention has been a primary impetus for several, new professional associations,
including the American. Institute for Pollution Prevention and the National Associa-
tion of Physicians for the Environment. Established local government organiza-.
. tions, including the National Association of Counties and the Center for Neighbor-
hood Technologies, have found a new role in helping to advance prevention among
their members. Prevention has been the occasion for established environmental groups,
such as the Environmental Defense Fund and the Natural Resources Defense Council,
to take on new and expanded roles in collaborative projects. Other groups promote
prevention by supplying the public with data developed under the TRI.
Guest author Paul Orum of the Working Group on Community Right-to-Know stresses
that public access to complete environmental information is key to pollution preven-
tion. Mary Rosso of the Maryland Waste Coalition adds that resources and'education
are the critical factors that make it possible for communities to implement local
prevention programs. In a joint commentary reflecting the views of the National As-
sociation of Counties and the National Association of County and City Health Offi-
cials,. Naomi Friedman and Karen Troccoli discuss the importance of local govern-'
" ment involvement in prevention programs, acknowledging that one of the challenges
these kinds of initiatives face on a local level is that prevention is a long-term invest-
ment, in many cases longer than the political terms of elected officials.

Chapter Seven — Measuring Pollution Prevention
One sign of the success ahd maturity of pollution prevention activity is that the focus
of attention has moved from a concern with program definitions and implementation
to program outcomes and results. Our questions now are: Will these approaches
provide benefits, in line with the costs? Will there be a net improvement to the
environment? Chapter Seven provides an overview of both the need for measuring
progress in pollution prevention and the need for progress in measuring pollution pre-
vention. The chapter discusses two main ways to approach pollution prevention mea-
sures: assessing program effectiveness and determining pollution reductions.
New regulations and policies have contributed to a growing urgency in the need for
adequate measures of pollution prevention program effectiveness. As a result of the
Government Performance and Results Act, the federal government is under increasing
pressure to assess program effectiveness and eliminate federal programs that are not
successful. Therefore, a quantitative gauge of the success of pollution prevention
programs" is critical to-the long-term survival of these programs. In addition, the Na-
10

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tional Environmental Performance Partnership System, which allows EPA to grant
more regulatory flexibility to states, imparts an increased responsibility on the part
of states to demonstrate that they are still meeting environmental goals and objec-
tives. Due to the challenges associated with determining overall statewide pollution
prevention progress, many states have focused initially on measuring the success of
specific state pollution prevention program components.
States, as well as independent research organizations,, are determining the extent to
which specific components of state pollution prevention programs are resulting in
actual implementation of pollution prevention measures at facilities. Typical, mea-
surement methods, which can be used individually or in combination, include: analysis
of records, reports, and plans; surveys or in-depth interviews (either broadly cover-
ing the universe of relevant facilities, or narrowly focused on recipients of specific
services); focus groups; and case studies. This chapter describes studies conducted
by New Jersey, Washington, Massachusetts, North Carolina, and Iowa to evaluate the
effectiveness of facility planning and/or technical assistance. Studies showed mixed
results; some companies implemented pollution prevention recommendations result-
ing from on-site technical assistance visits, but costs and quality concerns formed sig-
nificant impediments. . ' • ,
Three methods of measuring pollution reductions are widely discussed: actual quan-
tity change, adjusted quantity change, and materials accounting. These methods rely
on data that are readily available to,facilities, states, and EPA. The data used to •
calculate actual quantity change or adjusted quantity change can be obtained from'
information reported to EPA's Toxics Release Inventory or under RCRA. Someistates, • "
such as New Jersey, .also require facilities to submit materials accounting data. Other
innovative techniques for measuring pollution prevention are also presented in the
chapter. For example, under a Pollution Prevention Incentives for States grant, the
Indiana Pollution Prevention and Safe Materials Institute devised a pollution pre-
- vention measurement that incorporates hazard rankings for chemicals. The increased
emphasis on pollution prevention program performance should spur the develop-
ment of better measurement techniques in the years to come. ...
Quest authors Ken Geiser and Elizabeth Harriman, writing for the Toxics Use Reduc-
tion Institute, provide a cogent argument for the need to measure prevention. 'While
they acknowledge the difficulty of counting something that is prevented ("measuring
something that exists, such as pollution, is always easier than measuring that which .
has been, prevented"), Geiser and Harriman stress that "to promote pollution preven- •
tion without metrics and without goals for measurement would promote activity in-
stead of movement and reward effort instead of achievement. Constructing valid arid
appropriate systems for measuring pollution prevention progress is critical to the fur-
ther development of this young field."

Chapter Eight — The Future of Pollution Prevention
"What does the future hold for pollution prevention? What are likely to be the great-
est challenges in the years ahead and are we prepared to meet them? Chapter Eight
- • ' • • ' ii

-------
                            highlights some of the issues that will affect the future of pollution prevention. We
                            have.invited a variety of views from long-time prevention practitioners.
                            •  Joseph Ling, retired from 3M where he served as Vice President for Environ-
                                mental Engineering and Pollution Control, outlines his vision for the next step
                                beyond pollution prevention and design for the environment — designing for
                                sustainability. Ling describes where we have been in environmental protection
                                over the past four decades and argues that, while we may not have all the
                                answers, it's time to forge ahead.  As he puts it "we need to take that step
                                today [toward sustainability], and not worry about stumbling tomorrow."

                            •  Warren Muir, president of Hampshire Research Associates, Inc., acknowledges
                                the progress that has been made in .recognizing the need for pollution preven-
                                tion and the increase in pollution prevention activities, put cautions us that
                                pollution prevention is far from a mainstream concept dnd is neither at the
                                center of environmental regulatory reform nor a top priority  for industrial
                                decision makers. Muir finds that pollution prevention "has had no discernible
                                impact on aggregate toxic chemical waste generation" wpile the number of
                                source reduction activities reported to TRI has declined each year.

                            •  David Thomas, director of the Waste Management and Research Center at the
                                Illinois Department of Natural Resources, notes that there is  work still to be
                                done, but affirms that much has been accomplished.  He sees pollution
                                prevention as one aspect of a larger environmental revolution that is shaping a
                                new, more sustainable future.  Challenges that lie ahead include properly
                                accounting for the true cost of waste and  incorporating pollution prevention
                                into the global marketplace. Industry must take a leadership role, colleges
                                need to be training youth to integrate environmental thinking into their
                                disciplines, and  new partnerships must be formed between industry and
                                consumers to evaluate environmental problems and design creative solutions.

                            •  Harry Freeman,  executive director of the Louisiana Environmental Leadership
                                Pollution Prevention Program at the University of New Orleans, argues that
                                "pollution prevention is a process rather than  an end" and suggests that the
                                focus of pollution prevention may shift to clean products rather than industrial
                                processes and wastestreams, and to federal agencies that have not been as
                                involved in the past,  such as USD A for non-point source runoff and the Depart-
                                ment of Transportation for mobile sources of air pollution.

                            •  Joanna Underwood, president of INFORM, Inc., argues that the concept of
                                pollution prevention has taken center stage in environmental thinking, but the
                                reality is not as bright: industry progress in source reduction "has only been
                                marginal." Underwood urges business to find innovative answers to source
                                reduction; better data available to the public through materials accounting data;
                               , and placing the burden of proof on manufacturers to show that new proposed
12

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chemicals are safe for intended uses. "Exposure prevention" should be one of
our new guiding principles.

Gerald Kotas, co-director of the National Climate Wise Program and senior
environmental scientist with the Office of Energy Efficiency and Renewable
Energy of the Department of Energy, traces the history of the federal response
to pollution and the context for the developing of pollution prevention efforts.
He calls for partnerships to be formed to develop creative solutions that will
lead to fundamental changes in our lifestyle that are necessary for a sustain-
able future. Kotas reminds us that at the core of what we are attempting is a
deeper understanding of the natural  connections between economic productiv-
ity,  sustainability, and enhancement of environmental quality.
                                                                                                   13

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14

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Chapter One
Pronioting PiteveMtloii at EPA
             EPA Perspectives o
             Dr. Lynn R. Goldman
             Theme 1: Incorporate Prevention into
             Mainstream Agency Work
             Theme 2: Help Build National Network of
             Prevention Programs
             Theme 3: Pioneer Enviroiimentsil Programs
             Emphasizing Cross-Media Prevention
             Theme 4: Establish New Federal
             Partnerships
             Theme 5: Generate Environmental
             Information and Track Progress
             Theme 6: Develop Partnerships in
             Technological Innovation
             Theme 7: Change Federal Environmental
             Laws to Encourage Pollution Prevention ^   ,
                                                         15

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16

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EPA Perspectives on Pollution Prevention

by
Lynn R. Goldman, M.D.
Assistant Administrator
Office of Prevention, Pesticides and Toxic Substances
U.S. Environmental Protection Agency .
Washington, DC
When I joined EPA's Office of Prevention, Pesticides and Toxic Substances four years ago, I joined a team of
pollution prevention advocates - a group of people with great ideas who were working hard to forward pollution
prevention at the Agency. Shortly thereafter, the "reinvention fever" took over the Agency, as President Clinton and
Vice President Gore announced their plans to fundamentally reinvent the way the federal government does business.
This push for greater change came in the context of both substantial progress in environmental protection and
continuing challenges facing society. For example, while fewer cities were violating ambient air pollution stan-
dards, we learned that asthma was on the rise in children and young people - increasing by 42 percent between 1980
and 1987. Some experts suspect that environmental exposures are playing a role in this increase. The dichotomy
between what has been accomplished and what remains to be done arises in virtually every environmental arena.
Meanwhile, pressures on the environment are on the rise, in the United States and around the world. This situation
highlights the strengths and the limitations of traditional regulatory approaches that have relied on end-of-the-pipe
treatment and disposal technologies. It is leading scientists, engineers, researchers, industry, regulators, local offi-
cials, and many others to look for ways to prevent pollution in the first place.
The emphasis on pollution prevention in reinventing EPA programs respects the fact that society faces many chal-
lenges and that financial resources are limited. It also respects the fact that the environmental problems facing society
are serious, long-term and fundamental to the health of the planet. Resources saved by preventing pollution,
reducing red tape, and finding cost savings are resources that can be devoted to further environmental protection.
While at EPA, I have promoted a mission of expanding the public's right to know as a way to encourage pollution
prevention. For example, my office has expanded the Toxics Release Inventory (TRI) significantly in the past three
years. In 1994, we nearly doubled the number of chemicals on the reporting list. More recently, we proposed to add
additional facilities to the TRI. And, we are considering a third phase of TRI expansion, focusing on identifying and
filling additional data needs or "gaps" in the current TRI data that limit the public's ability to actively participate in
environmental decision-making that affects their community. The Consumer Labeling Initiative is another important
part of our efforts to promote the public's right to know. This project aims to teach us how to effectively present
helpful environmental, safe use, health and other information on household consumer and pesticide product labels. In
providing the public information about environmental and health risks through our right-to-know program, EPA aims
to level the playing field so that all parties concerned about pollution, whether they are affected citizens or workers or
representatives of government or industry, can discuss the issues openly, speak from a well-informed perspective, and,
together, develop common-sense solutions. Multistakeholder involvement and public access to information at the
local level are key features of the new, reinvented system of environmental management.
I believe strongly in the benefits that come from partnering with industry to achieve mutually advantageous environ*
mental goals. The Office of Prevention, Pesticides and Toxic Substances has played a leadership role in coordinating
voluntary programs across the Agency, in addition to managing our own Design for the Environment (DfE) partnef-
17

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i Chapter,!IT!
t. ;, .,.,.._. . S«ulj4

ships, 33/50 Program, and the Pesticide Environmental Stewardship Program. Working closely with industry, profes-
sional organizations, and others, DfE has helped businesses incorporate environmental considerations into the design
and redesign of products, processes, and technical and management systems. The 33/50 program has challenged
1,300 companies, operating more than 6,000 facilities nationwide, to reduce releases and transfers of 17 high priority
TRI chemicals. They met that challenge a year ahead of schedule. The Pesticide Environmental Stewardship Pro-
gram, a broad effort by EPA, the U.S. Department of Agriculture, and the Food and Drug Administration, fosters
reduced pesticide use and risk in both agricultural and nonagricultural settings. By the year 2000, this program aims
to have more than half of U.S. agricultural acreage adopt environmentally-safer integrated pest management pro-
grams. •
The initiatives I have mentioned here are only a few of the prevention programs championed by my office. And they
are only a small part of EPA's overall pollution prevention activities, which have grown significantly since the first
Pollution Prevention National Report was published in 1991. As you will read in this chapter, all around the Agency,
there is impressive work being done in prevention. As you learn about some of EPA's newer cross-program initia-
tives, like the Common Sense Initiative and Project XL, you will notice that our approach to environmental protection
is fundamentally changing. This reinvention involves not only institutions, but individuals as well. The changes in
course mean Americans throughout society have the opportunity and the responsibility to participate in environmental
management decisions and to work creatively to prevent pollution that otherwise would contaminate lakes, rivers and
groundwater, ambient air, and land. Renewed civic responsibility is taking place at the local, regional, and federal
levels, and it is very exciting to watch.
It is equally exciting to me to note the contagious enthusiasm of new prevention advocates across the country. I want
to take this opportunity to thank in particular the guest authors in this report, who contributed their time and energy
to provide a diverse set of thoughtful and well-informed perspectives on pollution prevention. While this chapter
describes how EPA's prevention program has grown and evolved in these last few years, the examples in the rest of
this report and the comments of our guest authors demonstrate how enthusiasm for preventive approaches has taken
hold in industry, other parts of the federal government, state and tribal governments, communities, non-profit
organizations, and universities. With the commitment of these groups to further institutionalize pollution preven-
tion as the nation's preferred environmental protection strategy, I am optimistic that together we will continue to see
pollution prevention success as we enter the 21st century.
18

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Introduction

EPA's, pollution prevention program began in earnest in the late 1980s. The goal of
this program was to add a top step to the U.S. environmental management hierarchy
— to promote prevention as the preferred environmental protection approach before
implementing traditional control and clean up approaches. On Earth Day'1993,
EPA Administrator Carol Browner identified pollution prevention as "the principle
of first choice" and the new central environmental ethic for all EPA programs. As
part of its response to Vice President Gore's National Performance Review, EPA
accelerated efforts to integrate pollution prevention into all environmental regula-
tions, policy, and guidance.
This chapter describes some of EPA's pollution prevention initiatives concentrating on
how EPA's, pollution prevention program, as a whole, has grown since the 1991
Pollution Prevention National Report. The initiatives can be categorized into seven
different themes identified by Administrator Browner in her 1993 Pollution Preven-
tion Policy Statement to EPA staff. These themes are listed in the box below.
_ ^ ^ ^
Themes Characterizing EPA's Pollution Prevention Activities:
1. Incorporating prevention as the principle of first choice into the mainstream ;
of the Agency. ' ' ,'-."•'. . • , . •;
'1. Helping to build and facilitate a national network of prevention programs,
particularly among states and local governments.
3. Identifying and pioneering hew environmental programs that emphasize cross-
media prevention, reinforce the mutual goals of.economic and environmental i
, well-being, and represent new models for government/industry interaction.
4. Establishing new federal partnerships to promote prevention within the
national government. . .
5. .Generating and sharing environmental information to promote prevention,
track progress through measurement systems, and better empower consumer ;
•• decisions. '..-.-•
6; Developing partnerships in technological innovation with the private sector
to increase industrial competitiveness and enhance environmental stewardship. :
7.; Seeking changes, where justified, in federal environmental laws to encourage ,
. pollution prevention/source reduction.

Towards the end of the chapter, we provide some examples of how EPA's regional
offices have worked with state and local governments and other organizations to
develop and implement pollution prevention projects hi the regions.
19

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                           Theme 1:  Incorporate prevention as the
                           principle of first choice into the mainstream
                           work, of the Agency.
                                                                                            I
                           In 1992, EPA began a concerted effort to evaluate pollution prevention options for
                           numerous new regulations it had under development. Calling its efforts the Source
                           Reduction Review Project (SRRP), EPA asked its media offices to identify multime-
                           dia and pollution prevention approaches that could be used in developing and imple-
                           menting a number of air, water, and solid waste regulations.1 In February 1996, EPA
                           published an assessment of the SRRP experience.  The assessment identifies the
                           successes and obstacles encountered in SRRP and makes a number of recommenda-
                           tions. On the success side, EPA  identified pollution prevention approaches in nu-
                           merous SRRP rules that are partially or wholly adequate for compliance.  EPA also
                           found ways to increase flexibility in some instances by adding innovative incentives
                           in the rules to encourage businesses to choose pollution prevention/multimedia ap-
                           proaches. These incentives  allow companies to find the least-cost ways of meeting
                           standards, and will enable many facilities to achieve better environmental results.
                           Some specific examples of success in promoting multimedia  and pollution preven-
                           tion approaches through regulations are:
                           •  EPA's Pesticide Formulating, Packaging and Repackaging Effluent Guideline
                             .  (a water rule, promulgated September 30,1996). This is EPA's first rule to
                               offer industry two limits to choose from: (1) a zero-discharge limit, based on
                               benefits solely to water; or (2) a pollution prevention allowable discharge
                               limit, based on benefits to all media.  Choosing the latter will be cheaper for
                               some facilities and will result in fewer total loadings to the environment..      '<

                           •  EPA's historic effort regarding pulp and paper mills provides a model for
                               allowing EPA and its stakeholders to evaluate the cross-media effects of air
                               and water regulatory options at one time.  This has facilitated the exchange of
                               data, perspectives, and innovative ideas in a context broader than a single-
                               medium rulemaking. The promulgation of the first of these rules
                               (subcategorized by type of mill) is anticipated in 1997.

                           •  EPA's Carbamates Hazardous Waste Listing (promulgated February  1995)
                               identified significant unregulated air releases, uncovered through cross-media
                               analysis. The Listing created a concentration-based exemption for waste
                               streams related to the air releases, so as to encourage waste minimization of the
                               chemical being released to air.
                        '   ' EPA, Office of the Administrator and Office of Pollution Prevention and Toxics. Source Reduction
                           Review Project (EPA 100/R-92/002, August 1992). The SRRP was assessed in Preventing Pollution
                           Through Regulations: The Source Reduction Review Project, an Assessment (EPA 742-R-96-001,
                           February 1996).
20                                                                              ,

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 These new regulatory approaches are generally not as familiar to regulated entities as
 the more traditional command-and-control approaches. Accordingly, EPA wants to
 keep working in this area to expand these innovations to more rulemakings, and to
 highlight the opportunities for better environmental performance and flexibility when
 implementing specific regulations.
 Since the publication of its SRRP Assessment, the Agency has been moving forward
 to expand on its successes and to work on overcoming the institutional obstacles to
 pollution prevention and multimedia approaches identified in the Assessment.  In
 September 1996, six Office Directors from across EPA regulatory programs met to
 identify next steps. By March 1997, this group had expanded to more than ten when
 they met as the "EPA Office Directors' Pollution Prevention Forum." As a result of
 this meeting, they reached agreement on a list of agency regulatory and program-
 matic activities that are or will be targeted as priority pollution prevention projects.
 This is an interim list and subject to change, depending on the results  of data gather-
 ing in numerous rulemakings.
 In a step beyond SRRP, this list addresses both regulatory and programmatic aetivi-
• ties, and is designed to capture a more complete picture of the strategic opportunities
 for pollution prevention in the Agency's core work.  It is hoped that this will lead to
 a more synergistic interaction among various Agency programs in pollution preven-
 tion.  It is anticipated that, by taking a more expansive view — i.e., possibly combin-
 ing regulatory, programmatic, and maybe research and voluntary  strategies — the
 Agency may be able to surmount some of the obstacles encountered when promoting
 pollution prevention in a solely regulatory mode, coordinate more effectively inter-
 nally, and achieve more for pollution prevention nationally.
 Prevention benefited when the Agency in 1994 reorganized its enforcement pro-
 grams and created the Office of Enforcement and Compliance Assurance (OECA).
 This reorganization consolidated the Agency's enforcement activities under one pro-
 gram and provided a basis for a new approach  to enforcement that promotes and
 supports pollution prevention.  This new approach will allow EPA to maintain an
 imposing enforcement presence as a means of deterrence, but also view traditional
 enforcement as one of a number of tools for achieving the broader goal of compli-
 ance. It will also allow EPA to organize national compliance strategies around eco-
 nomic sectors, ecosystems, and other entities to best reflect real-world environ-
 mental problems and pursue whole-facility, multimedia strategies "whenever feasible.
 Already OECA has seen numerous accomplishments in incorporating pollution pre-
 vention in  its  enforcement and compliance programs.  Examples  of these accom-
 plishments include:
 •  The development of Compliance Assistance Centers for four industry sectors
    (automotive service and repair shops, metal finishing, agriculture, and printing).
    The Office of Compliance, within OEC A, 'is developing these multimedia,
    sector-oriented centers to provide "one-stop shopping" for businesses to obtain
   • comprehensive, easy-to-understand information on regulatory requirements and
                                                                                                     21

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The goal of the
Common Sense
Initiative is a
cleaner
environment at
, ,,l!
less cost to
taxpayers and
industry.
pollution prevention technologies. In addition, since the Office of Compliance
is organized around commercial sectors rather than by individual environmental
medium, the. Office will be able to take an industry sector perspective to ensure
that EPA programs and requirements fit together, are understandable, and favor
pollution prevention. Other Compliance Assistance Centers are under develop- •
ment.
• A recently initiated program to incorporate pollution prevention into enforce-
ment settlements through the use of Supplemental Environmental Projects
(SEPs).
'* ' . '- "
• The Federal Facilities Enforcement Office (FFEO) within OECA, together with
EPA's Office of Pollution Prevention and Toxics (OPPT), published the Federal
Facility Pollution Prevention Planning Guide to help federal facility environ-
mental coordinators strengthen their environmental programs using pollution
prevention approaches and comply with the pollution prevention planning
requirements of Executive Order 12856.

• FFEO conducted more than 30 multimedia inspections at federal facilities.
FFEO targeted facilities that had environmental compliance problems that could
be addressed using pollution prevention and whose processes lent themselves to
pollution prevention solutions that could be used as prototypes for other federal
facilities.2 ,
The Common Sense Initiative (CSI) is EPA's most visible effort to create a prevention-
oriented framework for environmental protection on an industry-by-industry basis.
CSI operates by sector subcommittees composed of representatives from industry,
environmental justice, labor, and environmental organizations, and federal, state,
and local governments. Six industries are serving as pilots in this program: auto-
mobile assembly, computers and electronics, iron and steel, metal plating and fin-
ishing, petroleum refining, and printing. The six sector teams were convened to
examine the full range of environmental requirements. Each team is looking for
opportunities to change complicated or inconsistent environmental requirements
into comprehensive strategies for environmental protection, with an emphasis on
pollution prevention, instead of pollution controls. Innovation and flexibility are
being encouraged. The goal is a cleaner environment at less cost to taxpayers and.
industry. :
EPA's Regional Program Management has been important to the "mainstreaming"
of prevention. Nearly every region has found important ways to encourage pollution
prevention and multimedia approaches in its management activities. For example,
Region I's New England Environmental Assistance Team is a self-directed team estab-
lished in 1995 to provide comprehensive, multimedia compliance and pollution pre-
vention assistance to selected sectors of the regulated community. Region IV is devel-
22
2 EPA, Office of the Administrator. EfA Pollution Prevention Accomplishments: 1994'— Incorporat-
ing Pollution Prevention Into Business Decisions (EPA 100-R-95-001, Spring 1995).

-------
 oping a new comprehensive Regional Pollution Prevention Strategy that engages all
 regional core media programs in creating and conducting pollution prevention activi-
 ties in mainstream activities. Region Vs.cross-program Pollution Prevention Team
 has created a "Waste Reduction in Our Workplace" initiative to further waste reduc-
 tion activities within day-to-day"regional activities, such as implementing pollution
 prevention-friendly contracts. In Region VII, pollution prevention support funds pro-
 vide interns to the regional media programs for pollution prevention through a com-
 petitive selection process.
 In its Pollution Prevention in Permitting Pilot Project, Region X partnered with Intel
 Corporation, the world's largest semiconductor manufacturer, to develop a model Clean
 Air Act Title V operating permit that incorporates both pollution prevention and per-
 mit flexibility. Region VI has begun similar work in this area with the Oklahoma
 Department of Environmental Quality and Imation Enterprises.

 Theme  2: Help build and facilitate a national
 network of prevention programs,
 particularly among states and local
 government.

 EPA recognizes that a key component in making pollution prevention the nation's
 top priority in environmental protection is support for state and local government
 efforts in the pollution prevention arena. The Agency has focused its efforts on
 building and facilitating a national network of prevention programs that assist state
 and local regulators in promoting pollution prevention initiatives. The cornerstones
 of this support to states and  local governments are: (1) EPA funding of state and
 local pollution prevention projects, (2) dissemination of pollution prevention related
 information and technical assistance, and (3) combined participation of federal, state,
 and local environmental leaders in supporting prevention as a main focus of achiev-
 ing environmental protection.

 Funding Support
 Through the Pollution Prevention Incentives for States (PPIS) grant program, EPA
 provides $5-8 million each year — a total of over $35 million since 1988 — for state
 and tribal, local, and community pollution prevention programs and initiatives. The
 goal of the PPIS grant program is.to assist businesses and industries in identifying
pollution prevention strategies and solutions for complying with environmental regu-
lations. EPA's Environmental Justice through Pollution Prevention grants assist com-
munity-based  groups in developing collaborative approaches to achieving environ-
mental justice through pollution prevention. In 1995, EPA awarded $4.2 million to
support this program. In 1996, these grants were funded at $1.9 million, but funds
rose again to $4.2 million in 1997.3
3 EPA, Pollution Prevention News (September/October 1995 and October/November 1996).
                                                                                                23

-------
                            While these focused grants provide substantial support to the pollution prevention
                            programs of state and localities, they are dwarfed in size by the annual $650 million
                            program development grants provided by EPA's media programs. EPA guidance now
                            encourages pollution prevention solutions in various program support and operating
                            grants provided to states each year.
                            In addition, great potential exists for funding pollution prevention activities with the
                            new Performance Partnership Grants (PPGs) and the related National Environmen-
                            tal Performance Partnership System (NEPPS). PPGs and NEPPS are new Agency
                            initiatives born out of a joint State/EPA Task Force on State Capacity in 1993.  This
                            task force recommended that EPA and the states adopt a systematic approach to
                            increase state capacity and allow for the management of state programs in a way that
                            allows each level of government to contribute according to its respective strengths.
                            In February 1995, President Clinton announced a "Performance Partnership" pro-
                            posing that the states be allowed the option of combining funds from individual EPA
                            programs in order to achieve improved program performance. Six states signed pilot
                            Environmental Performance Agreements with EPA for FY 96. Approximately 30 states
                            are working with their respective EPA Regional Offices to negotiate Performance Part-
                            nership Agreements for FY 97.4

                            Dissemination of Information and Technical Assistance
                            In order to assist states and local governments in achieving compliance with envi-
                            ronmental regulations, and to help promote prevention-oriented programs in gen-
                           , eral, EPA has established several programs that provide current pollution prevention
                            information and solutions from  around the world. Leading these programs is EPA's
                            homepage '(http://www.epa.gov), from which users can access information on all of
                            EPA's pollution prevention programs, and Enviro$en$e (http://es.inel.gov/envkosense/),
                            which provides users with information on pollution prevention technologies, proce-
                            dures, and experience across federal agencies, other governmental  organizations,
                            manufacturers, suppliers, researchers, and others. At the heart of Enviro$en$e is im-
                            mediate access, via the Internet, to pollution  prevention contacts, including ques-
                            tion and answer exchanges with environmental professionals world-wide, training
                            materials, databases, regulations, and the most recent prevention technologies.
                            The Pollution Prevention Act authorizes EPA to work with states to facilitate the use
                            of source reduction techniques by businesses in those states. EPA is in the process of
                            developing a national network of information centers around the country.  The goal
                            of the network is threefold: (1)  create new state pollution prevention centers for the
                            collection, synthesis, and dissemination of information within the state; (2) support
                            existing regional information centers; and (3)  coordinate work among the new and
                            existing centers to reduce duplication of effort and facilities training for the promo-
                            tion of pollution prevention technologies. The network will also establish informa-
      •       '              4 Performance Partnership Fact Sheet on EPA's homepage "www.epa.gov/states."

24                        '

-------
tion standards and peer review to ensure that the information is correct and up-to-date.
In addition, the. network will provide pollution prevention technologies information,
not only to state technical assistance staff, but to other small business assistance pro-
grams such as the Small Business Development Centers and the National Institutes of
Standards and Technology Manufacturing Extension Partnerships. Functions performed
by the network will include: making information accessible and easy-to-searcb, col-
lecting and updating technical information, identifying and maintaining a list of ex-
perts and other sources of information, and providing a standardized format for infor-
mation such as case studies, bibliographies, processes, and vendor information. EPA
is using a competitive grant format to identify eligible and interested states. By facili-
tating access to regional and other states' information, the participating states may
then focus their efforts on meeting the specific needs of industries in their communi-
ties and may also be able to specialize in the type of assistance they provide.

Federal/State/Local Government Partnerships
Bringing together federal,  state, and local government environmental leaders is an-
other goal  of EPA's pollution prevention program strategy. EPA has implemented
many pollution prevention initiatives that attempt to encourage and support a part-
nership between the Agency and state and local groups.  As an example, EPA pro-
vides support to the National Pollution Prevention Roundtable, an association com-
prised of state, local and other pollution prevention programs, and has supported the
National Association of Counties (NACO) as it works to introduce elected county
officials to pollution prevention.  The Agency has recently established agreements
and projects with county and city public health officials, physicians, and others who
believe pollution prevention is also disease prevention and who can have an immedi-
ate impact on local communities..
In addition, for the past five years, EPA has provided support to the Forum on State
and Tribal Toxics Action (FOSTTA). FOSTTA consists of toxics and prevention staff
at the state and tribal level  who share experiences with OPPT staff in an open forum
several times a year.
,EPA regions, working with states, are also developing multi-regional initiatives.  The
Tri-State Geographic Initiative, led by Region HI, is a multimedia environmental study
involving the states of Kentucky, Ohio, and West Virginia, EPA Regions HI, IV, and V,
the Ohio River Valley Water Sanitation Commission, and local environmental agen-
cies, whose purpose is toIdentify pollution prevention approaches to reduce pollution
sources in the tri-state area, addressing both businesses and citizens as sources of pol-
lution and as partners in prevention. The Great Lakes Regional Pollution Prevention
Roundtable, led primarily by Region V and involving eight states and Ontario, has
created a powerful regional pollution prevention information and assistance mecha-
nism to help states better address regulatory and other environmental challenges.
                                                                                                     25

-------

                                               *'        SSl
                          Theme 3: Identify and pioneer new
                          environmental programs that emphasize
                          cross-media prevention, reinforce the
                          mutual goals of economic and
                          environmental well-being, and represent.
                          new models for government/industry
                          interaction.

                          Over the last several years EPA has created an array of partnership programs de-
                          signed to promote prevention by challenging businesses and other partners to set and
                          meet voluntary pollution prevention goals and commitments.  These partnerships
                          with businesses, citizen groups, state and local governments, and educational groups
                          provide new models for government/industry interaction and are achieving more
                          cost-effective solutions to environmental issues than traditional regulatory approaches.
                          EPA's voluntary programs, collectively referred to as Partners for the Environment,
                          demonstrate that voluntary goals and commitments achieve real environmental re-
                          sults in-a timely and cost-effective way.5 The results of the Partners for the Environ-
                          ment efforts are impressive. Thousands of organizations are working cooperatively
                          with EPA to set and reach environmental goals such as conserving water and energy
                          and reducing greenhouse gases, toxic emissions, solid wastes, indoor, air pollution
                          and pesticide risk.  More  than 6,000 participants  from every major sector of the
                          economy — from Fortune 500 companies to small shop owners — were involved in
                          Partners for the Environment programs in 1995.
                          Together, EPA's Partners for the Environment programs have:
                          •  reduced toxic emissions by 750 million pounds;

                          •  eliminated 1.8 million tons of solid waste in one year; and

                          •  reduced greenhouse gas emissions by preventing 13.4 million-metric tons of
                             Commissions in 1995.

                          These programs do not just reduce pollution; they also save energy. The Partners for
                          the Environment programs saved 110 trillion BTUs in 1995 — enough to light 11
                          million households  for a year. The success  of these programs is growing dramati-
                          cally. By the year 2000, with continued participation from even more partners, these
                          pollution prevention numbers are expected to triple.
                          The voluntary partnerships fostered by EPA's programs are not just good for the envi-
                          ronment, they make good business sense and prove that pollution prevention pays.
                          Together, these partners saved $435 million in 1995 and expect to save $7 billion
26
                         5 EPA, Office of the Administrator. Partnerships in Preventing Pollution: A Catalogue of the
                         Agency's Partnership Programs (EPA 100-B-96-001, Spring 1996).

-------
annually by the year 2000.
Below are examples of some of
the Agency's partnership pro-
grams:
• Climate Wise Recognition
Program is a joint EPA/
Department of Energy
voluntary pledge program
that encourages private
industry and others to
adopt flexible, compre-
hensive approaches to
reducing greenhouse gas
: y: v -'-„•:•••> •-*, •;.:=

The '33/50 Pfbgiam,EPA!s first voluntary pollution prevention-reduction ini-
tiative, challenged corporate. America to voluntarily .reduce toxic emissions of
."l^xicrsub^i^^
firms metor exceeded ~;^nd by; 50|>er,cent to 19§5,; J3%receiyed: J,3()0;indt- ,
viduai commitment letters ftbmicbmpanieis mat agreed^ to reduce" emissionsi of '•
these toxic, substances by'50 percent in less than five years. Data from the 1994
•Toxics Release .inventory (TRI) show that more than 750 million pounds of
toxic waste have been eliminated by 33/50 participants, :allbwing the 33/50
program to claim success in meeting its 1995 goal a year early. This program
• was a recipient of Vice President Gore's Hammer Award for helping govern-
ment work better and cost less. ..-..-•
emissions. The program
provides technical assistance .and puts companies in touch with financial
services to "jump start" energy efficiency arid pollution prevention actions.
With 13 charter companies, Climate Wise companies already represent almost 4
percent of U.S. industrial energy use. Climate Wise participants expect to save
more than $80 million annually by the year 2000.

Green Lights, an EPA program designed to prevent pollution by encouraging
U.S. institutions to use energy-efficient lighting technologies. EPA forms
partnerships with individual institutions, including both public and private
organizations, and asks participants to develop 5 year action plans for reduc-
ing energy consumption through more efficient lighting technologies. In-
spired by the success of Green Lights, EPA introduced Energy Star Buildings, a
program that takes pollution prevention to new heights. Enjoying the same
rapid growth as Green Lights, Energy Star Buildings allow participants to
maximize profitability, increase productivity, and improve occupancy comfort
.through increased energy efficiency. To date, Green Lights and Energy Star
Buildings participants have distinguished themselves by preventing more than
4.5 billion pounds of greenhouse gas emissions per year (equivalent to
removing 480,000 cars from the road); and saving more than $250 million per
year (reducing operating'costs, making organizations stronger and more
competitive, and reinvesting in the American economy).

WasteWiifre is a voluntary partnership between EPA and U.S. companies aimed
at reducing inefficient materials use and thus reducing municipal solid waste,
and conserving energy arid natural resources. Through this program, firms
establish cost-effective goals of their choice to reduce their municipal solid
waste through prevention, recycling, and by buying or manufacturing recycled
products. Since the program's inception, more than 500 companies have
. participated and have saved millions of dollars through prevention and
recycling of their waste. WasteWi$e partners conserved nearly 344,000 tons of
materials through waste prevention activities in 1995 - a 40 percent increase
27

-------
'Chapter
L ., :..i.'...*-..j>
over 1994 figures. In addition, partners quadrupled the reported amount of
materials collected for recycling to more than four million tons. WasteWi$e
partners also reaped significant, cost savings. In avoided disposal tipping fees
alone, the amount of waste reduced represents a potential savings of more than
$143 million.6 Again, this voluntary partnership program clearly demon-
. strates the cost benefits of incorporating prevention programs into American
businesses. Both the "bottom line" and our nation's environment are
improved. A related program, the Waste Minimization National Plan, targets
prevention of hazardous waste. The Plan's goal is to reduce persistent,
bioaccumulative, and toxic chemicals in hazardous waste by 50 percent by the
year 2005.
Design for the Environment (DfE), through collaborative ventures, promotes the
design of safer products and processes in areas such as dry cleaning, screen
printing and electronics, and harnesses environmental information to advance
new prevention approaches and technologies among business and industry.
This program utilizes EPA's expertise and leadership to facilitate information
exchange and research on pollution prevention efforts. DfE works with
businesses, trade associations, and other stakeholder industries to evaluate the
risks, costs, and performance of alternative chemicals, processes, and technolo-
gies. In addition, DfE helps individual businesses apply specific tools and
methods to undertake environmental design efforts.

The Agency's Environmental Accounting Project, a collaborative effort with
business, academia and others, promotes sound management accounting and
capital budgeting practices which better address environmental costs. The
project encourages and motivates business to understand the full spectrum of
environmental costs, and integrate these costs into decision making. Cur-
rently, the project has over 650 members who are actively participating or
interested in environmental accounting. Implementing environmental account-
ing will make environmental costs more visible to company managers, thus
making those costs more manageable and easier to reduce. The project has
produced numerous tools, such as P2/Finance software, that help companies
incorporate environmental costs into their capital budgeting decisions.7

The Pesticide Environmental Stewardship Program (PESP) is a voluntary
public-private partnership of EPA, the Department of Agriculture, the Food and
Drug Administration, and groups that use or influence the use of pesticides.
The program's goals are to develop specific use/risk reduction strategies that
include reliance on biological pesticides, integrated pest management, and other
6 This figure is based on an average 1995 U.S. tipping fee of $32.19 per ton, a value reported by Solid
' Waste Digest in 1995. ' .
7 EPA, Office of Pollution Prevention and Toxics. Stakeholder's Action Agenda: A Report of the
Workshop on Accounting and Capital Budgeting for Environmental Costs (EPA 742-R-94-003,
December 5-7, 1993). ' . . '
28

-------
safer approaches to pest control. Voluntary partnerships with PESP will
significantly contribute to the Clinton Administration's goal that 75 percent of
U.S. agricultural acreage adopt integrated pest management practices by the
year 2000. PESP currently has 48 partners and 10 supporters (organizations •*
that influence pesticide use) that represent 45,000 pesticide users.- Each partner
has agreed to develop and implement formal strategies to reduce the use and
risk of pesticides and to tailor pesticide use to specific sites, crops, and regions
of the country.

Water Alliances for Voluntary Efficiency (WAVE) is another voluntary
program similar to Green Lights, that is dedicated to achieving water use
efficiency. Currently, hotel and motel chains are targeted for participating in
the program, but other groups such as hospitals and schools will soon be
involved as well. The primary goals of WAVE are to reduce water and energy
consumption through the installation of water-efficient equipment, linking
water-use efficiency  to reduced costs, and educating business staff and the
public on the benefits of reduced water use. The 26 hotel chains now partici-
pating in the program have each signed a Memorandum of Understanding
with EPA agreeing to develop and implement a plan for reducing water
consumption at their facilities.  Businesses participating in the program are
expected to cut water use by up to 30 percent and on average, recover the costs
of investments in water-efficient equipment in just 3 years or less.  .

In 1995, President Clinton launched Project XL, a program designed to
encourage development of alternative strategies to achieve greater environ-
mental benefits over  current regulatory programs.  As part of Project XL, EPA
is creating partnerships with states to provide a limited number of companies
with the opportunity  to demonstrate their environmental excellence and
leadership. These companies'will be given the opportunity to modify or
replace current regulatory system requirements at specific facilities with
company-developed  alternative, flexible strategies. Each alternate strategy
must meet a number of conditions, including: (1) it must produce environmental
performance superior  to that which would be achieved by full compliance with
current laws and regulations; (2) it must be "transparent" so that citizens can
examine assumptions  and track progress toward meeting promised goals; (3) it
must not create worker safety or environmental justice problems; (4) it must have
the support of the community surrounding the facility; and (5) it must be enforce-
able. EPA expects that the program will increase flexibility in adopting innovative
prevention-oriented solutions to environmental problems, improve compliance and
increase use of new technologies, and encourage a more cooperative relationship
among regulators, regulated businesses, and the community.

The Merit Partnership for Pollution Prevention (Merit) is a cooperative
venture of the public and private sectors. Merit, which was initiated by EPA
Region IX in 1993, is led by a Steering Committee made up of EPA, industry,
and other government representatives; and a Community Advisory Panel
"One of my favorite
DILBERT™ cartoons
says-Change is a
good thing--you
first." [Project] XL is
an experiment in
leadership in a
leadership-adverse
world."
- Charles McLean,    .
  founder of the
  Aspen Institute's
  Series on the
  Environment in the
  21st Century
                                                                                               29

-------
 Chapter 1 - j
      .. .: J>.dt.juu*-i
  Two Examples of XL Projects:                        -                         .       ,  ^-^,

t  1) Intel Corporation Proposes a Multi-media Operating Plan  ""                                  & "
t  The Intel Corporation signed a Filial Project XL Agreement in November 1996, beginning the implementation of
  a multi-media environmental master plan at its Ocotillo, Arizona semiconductor facility. The Final Project Agree-
  ment was developed by a stakeholder team with intense public participation, including public .hearings and .«.-•?,
  national comment period. The plan commits[Intel to:	„•...„•...,,.-	,-.....-,.....   .        .. .......v, ^.^--Vl^Atai
        i'"" '"• . „ — \^' ' ' • : ' ' ' •' ' -",'.' L', "'",- '•' •' •: .• " ':S '__' •  ' •-'  '• ' —.. . "" _ ' '"*• •' '    i-  ' •"            '   ' '  •   ,'  '  .'*', ; ". iV ; .; • £' {>-.V ij
     ^reducing;hazardous, solid and non-chemical hazardous waste;           '                     ti'*.'"*'"'
     reducing fresh  water Consumption;       "                          "
     using health-based guidelines for limits on emissions of hazardous air pollutants, and                *
     exceeding current.zoning setbacks for its facilities, and                   „             „»(,.*<
     maintaining a cap on air emissions below the minor source level, even if a new facility is built on the site
   «    '•-•-,   • /*  _   «*•»„*•*           "  _   j-   *    ^           " -*          ^ <•   4 f '
  Implementation of these project goals will allow Intel to modify production processes without revising its  air
  permits if emissions are below permit levels aridmake'operational changes if the aggregate limit for air pollutants
  is not exceeded and the varying levels do ttotexceed health-base'd guidelines  Participation in Project XL will help
  Intel increase its: operational flexibility and shorten time-to-market delays                           ,.
  2)  City  of Anaheim Proposes Prevention Activities                                          ».     „*  _
  In exchange for comrmtting to certain voluntary actions, the City of Anaheim, California, is seeking relief from
'"  monitoring requirements for the Acid Rain Program, this Project XL for Communities Proposal (currently in the
;  development phase) requires the City to close abandoned wells that currently threaten to contaminate drinking
  wafer supplies, implement a chlorinated solvents leductionprogram with local businesses, and implement demon-1
  stration projects for innovative technologies that reduce use of hazardous chemicals.                      "<•  |:

                                consisting of private citizens and community and environmental organization
                                representatives. Merit's mission is to develop and promote pollution preven-
                                tion practices and technologies that both protect the environment and contrib-
                                ute to economic growth. Merit does this primarily by developing and facilitat-
                                ing the implementation of pilot projects that demonstrate new and innovative
                                pollution prevention practices and technologies. Merit projects vary widely in
                                scope of effort and in the industries involved, but the one criterion they all
                                have in common is a focus on the environmental and economic impacts of the
                                technology or practice being tested.

                            In Region I,  the  CLEAN Program capitalizes on OECA's new small business' and
                            audit policies to help promote industry/state/EPA partnerships, initially with metal
                            finishers in Maine and New Hampshire. Region I's Environmental Capital Network
                            creates a private sector partnership, to help new pollution prevention and recycling
                            companies improve their business plans in order to attract venture capital.
                            The Great Printers Project in Region V has enlisted the Council of Great Lakes Gov-
                            ernors, the Printing Industries of America, the Environmental Defense Fund, EPA, and
                            state environmental and technical assistance agencies  to make pollution prevention
                            the standard practice in the printing industry. Region II has also targeted the printing

30

-------
'•'•-"~.-: m
sector in the New York City area by engaging the .New York State Department of
Environmental Conservation, other state agencies, and printing trade associations in a
Seminar Series for Printers. .
Under its South Phoenix Pollution Prevention Project for Metal Finishers, Region
DC has partnered with the State of Arizona, the Lawrence Livermore National Labo-
ratory, the City of Phoenix, and the local chapter of the American Electoplaters and
Surface Finishers Society to provide pollution prevention technology transfer to metal
finishers, first reaching those located in an environmental justice community and then
more broadly around the state.
The programs described above are just a few of the many successful voluntary part-
nership programs that EPA has initiated in the last 5 years. These programs are in
effect new models for government/industry interaction in environmental protection.
As demonstrated, these programs are achieving remarkable results in preventing
environmental degradation and at the same time are economically beneficial to U.S.
industries and the American people.

Theme 4: Establish new federal
partnerships to promote prevention within
the national government.

EPA is establishing partnerships with other federal departments and agencies to pro-
mote pollution prevention both within federal government facilities and within fed-
eral regulatory and guidance programs. Many federal departments and agencies are
now managing major prevention-oriented federal environmental initiatives.
Several Executive Orders signed by President Clinton require federal facilities to
report emissions, to take a leadership role in recycling, and under guidance from
EPA, to identify and procure "environmentally-preferable products."8 EPA's guidance
on environmentally-preferable products (EPP), published in the Federal Register oil
September 29, 1995, launched a national debate on "green procurement" principles.9
Included in the guidance are seven general guiding principles designed to help execu-
tive agencies begin the process of identifying and purchasing environmentally-prefer-
able products and services. The guidance also recommends implementation activities
for executive agencies, such as issuing policy directives and applying the principles to
acquisition. Ultimately, the goal is to establish the federal government, through its
enormous purchasing power, as a leader in pollution prevention by creating of a strong
Spending $200
billion annually,
the federal
government can
apply its
purchasing power
to create a demand
for products and
services that have a
reduced impact on
the environment
. 8 "Environmentally-preferable" products arid services have a lesser or reduced effect on human health
and the environment when compared to other products and services that serve the same purpose.
Executive Order 12783, Sections 201&503 (October 20, 1993).
9 EPA, Office of Pollution Prevention and Toxics. Environmentally Preferable 'Products - Proposed
Guidance (EPA 744-94-002, September 1995) and EPA, Office of Pollution Prevention and Toxics.
"Guidance on Acquisition of Environmentally Preferable Products and Services; Solicitation of Com-
ments," Federal Register 60 (189) (September 29, 1995).
31

-------
                             market for "green" products. Two of the environmentally-preferable purchasing pi-
                             lot projects that have been launched involve acquiring cleaning products'and con-
                             struction products. In both of these projects, EPA is partnering with other federal
                             agencies (the General Services Administration and the Department of Defense, re-
                             spectively) to couple its environmental knowledge with other agencies' acquisition
                             expertise.
                             Executive Order 12856, signed by President Clinton in August 1993, requires federal
                             facilities owned and operated by federal agencies to report annually to the Toxics
                             Release Inventory (TRI). This reporting will ensure that the public has access to infor-
                             mation on the releases and transfers of toxic substances from these facilities and en-
                             sures that the federal government is a good neighbor in the communities in which it
                             operates. In essence, the Executive Order extends private  sector reporting require-
                             ments to all federal facilities and directs each federal agency to voluntarily decrease
                             its toxic releases and off-site, transfers by 50 percent using 1994 (the first reporting
                             year) as the baseline. Over 190 federal facilities are subject to TRI reporting, (further
                             information on TRI reporting for federal agencies may  be found in Chapter 3 of this
                             report.)
                             Partnership programs between federal agencies are also instrumental in fostering
                             pollution prevention programs that serve the clients of the agencies. One example of
                             such a partnership is Agriculture in Concert with the Environment  (ACE), a joint
                             grant program funded equally by EPA and USDA's Sustainable Agriculture Research
                             and Education (SARE) Program. The goals of this competitive grants program are to
                             promote agricultural practices and systems that are environmentally sound, economi-
                             cally viable, and resource conserving.  In  1997, ACE  will be funded nationally at
                             $225,000.
                             EPA also provides* technical assistance to  federal departments or agencies seeking
                             assistance in establishing internal pollution prevention programs. Many federal pror
                             grams, EPA guidance,  case studies, and other pollution prevention initiatives are
                             available to federal agencies and are easily accessible via EPA's Enviro$en$e Web site
                             (see discussion earlier in this chapter).
                             The National Park Service Project in EPA's Region VIII has leveraged the pollution
                             prevention expertise of the region and the resources of the National Park Service to
                             successfully reduce or eliminate solid and hazardous waste streams in more than 35
                             national parks, thereby both lowering ecological risks and saving millions of dollars.
                             In its environmental workshops, the Long Island Postal Service collaborates with EPA
                             Region II to present information on the benefits of pollution prevention gathered from
                             several pollution prevention opportunity assessment done under a previous Region II
                             initiative.
32

-------
                                                                 Ml*
Theme 5:  Generate and share
environmental itif ormation to promote
prevention, track progress through
measurement systems, and better
empower consumer decisions.

A central element of EPA's pollution prevention strategy is motivating industries to prevent
pollution by empowering citizens and consumers with environmental information.
Section 313 of the 1986 Emergency Planning and Community Right-to-Know Act
(EPCRA) and section 6607 of the Pollution Prevention Act of 1990 require certain
manufacturers to  report to EPA annually the quantities of toxic chemicals they re-
lease to the environment and the amounts of waste managed on-site or transferred
off-site for management, elsewhere.  EPA compiles this information and shares it
with the public annually as the Toxics Release Inventory (TRI).  TRI also asks ques-
tions of industry about source reduction, energy recovery, and treatment and disposal
activities.  By making these data public, TRI provides a strong incentive for compa-
nies to reduce wastes. TRI milestones include:
•  The 1995 TRI data, announced in May 1997, showed that reported industrial
    releases declined by 45.6 percent (1.35 million pounds) from 1988. Of the
    •21,951 facilities that reported to TRI for 1995, nearly 29 percent reported
    implementing at least one source reduction activity.10

•  In 1994, EPA added 286 additional chemicals and chemical categories to the
    TRI, giving the public a broader picture of progress in preventing toxic waste
    generation and release.
•  In 1997, EPA expanded by 30 percent the number of industrial facilities
    required to report to TRI, to include the categories of metal mining, coal
    mining, electric utilities, commercial hazardous waste treatment, petroleum bulk
    terminals, chemical wholesalers, and solvent recovery services. In addition,
    700 chemical manufacturing facilities which already report right-to-know
    information to the TRI, will also be required to report on additional types of
    pollution, such as hazardous waste treatment activities.

•  EPA has reported to the President the benefits that chemical use reporting
    (materials accounting) would have on community right-to-know laws, and has
"Since pollution
prevention is
motivated in part
by public
information, one of
EPA's most
important tasks is
to collect and
disseminate user-
friendly data that
measures progress
in reducing waste
at its source."
-  EPA Pollution
   Prevention Policy
   Statement
'"These numbers are taken from an initial comparison of 1995 data with the 1988 TRI baseline year as
reported in EPA, Office of Pollution Prevention and Toxics. 1995 Toxics Release Inventory, Public Data
Release (EPA 745-R-97-005, April 1997) and 61 Federal Register 51322 (October 1996). The second
phase of the data release will occur in Fall 1997 and will serve to provide a more in-depth look at the data
and the .trends. This second phase will include the publication of an industry sector-based analysis of trends
as well as the publication of a comprehensive guide to TRI data use. The sector-based approach will
compare like facilities to each other and will allow for a sector-based assessment of future prevention amd
technology needs. This sector-based approach will also allow for goal-setting within sectors and across
facilities.
                                                                                               33

-------
 • Chapter!-,
  How to Obtain TRI Reports and Data Products
  Product            ""
       -t
 , 1995 TRI Public Data
  Release (annual report)
 TRI Information Kit
* (EPA 749-F-94-002)
                                 NCEPI
                                                      _-
                                                 Contact Information.
                                                EPCRA Hotline   -
                                               ^800f 535-0202 or
                                                (703) 412-3333 (fax only)

                                                (513) 489-8180
                                                (800f490-9198
                                                                                      t.

                                                                                -* a "f  f .
                                                                                            LX
 Accessing TRI Data Online
[ Data from Online Providers
 Right-to-Know Network (RTKNET)-    ftp //ftp*rtknet org
 Provides public access to TRI and       gopher://gopher rtknet org
, related environmental databases
f   i 11  *    «  •» ^    •"»  *•    j*-
 to community groups concerned
| about toxics.  For more
 information call (202) 797-7200
 National Library of Medicine
I (NLM) - Offers state of the art,
 user friendly searching of
 complete TRI database. For
 more information call (301}
 496-653J.      ( ^  ^
 EPA Internet Server - Access
1 a variety of reports, data
 files and TRI information from
                                      •Internet Address
                                      jittp7/ww\v rtk net
                                      toxnet.nlm mh gov
                                      ftp //ftp epa.gov
                                      gophen//gopher epa gov
                                      http //www.epa gov/opptintr/tn
 EPA. For more information
 call TRI-US at (202) 260-1531
                                                                 -Special Notes
                                                                                        f  *
                                                                  Set computer parameters to
                                                                  8,N,1 and log in as "public."
                                                                  No charge for Internet access
                                                                  Direct access by modem at
                                                                  (202) 234-8570; phone charge
                                                                  may apply                  ^     v
                                                                  $18-20 per hour charge  Password**
                                                                  required                   '  (
                                                                                            It*
                               begun an open process to determine how this might best be accomplished,
                               including issuing an Advanced Notice of Proposed Rulemaking in October
                               1996.

                           •  In 1994, under the direction of Executive Order 12856, EPA began to collect
                               (for the first time) toxics release data from federal agencies.

                           EPA's new Consumer Labeling Initiative (CLI), is examining ways to provide better
                           environmental information on products to consumers, including improved product
                           labels. CLI, a pilot project launched in March 1996, invites ideas from consumers,
                           industry, and health and safety professionals, on ways to improve the environmental,
                           health, and safety information appearing on household product labels.  The pilot
                           project is specifically targeting home and garden pesticides and household hard sur-
                           face cleaners.. The project's primary goal is to ensure that consumers have and un-
34

-------
derstand the information they need to make responsible product choices based on
their own needs and values. In addition, EPA hopes to encourage companies manu-
facturing these products to use substances in their products that are less harmful to
human health and the environment.''
Environmental management standards are increasingly used by organizations as a
means of focusing and managing all of their environmental responsibilities. In Sep-
tember 1996, the International Organization for Standardization's (ISO) Technical
Committee (TC) 207 published the first international consensus standard, ISO 14001,
for.environmental management systems. EPA participated actively in the develop-
ment of this and the other ISO 14000 series standards. EPA is testing the utility of ISO
14001 as a vehicle for enhancing pollution prevention, compliance, and overall envi-
ronmental performance. The EPA Voluntary Standards Network is the means by which
the Agency participates, with full voting membership, in the U.S. Technical Advisory
Group (TAG) to TC-207. Through the network, the official EPA representatives to the
U.S. TAG disseminate information throughout the Agency and coordinate EPA com-
ments on the documents.12

Theme 6: Develop partnerships in
technological innovation with the private
sector to increase industrial
competitiveness and enhance
environmental stewardship.

EPA is striving, through the use of voluntary partnership programs, to encourage
and support private sector development of pollution prevention technological, inno-
vations. Of particular note is EPA's Environmental Technology Initiative program for
new chemicals. The goal of this program is to identify and reduce barriers to the
development, introduction, and use of safer chemicals and technologies. This project
offers industry an opportunity to explore new, non-traditional ways to manage risk,
as opposed to the traditional regulatory approach.13
Another EPA project aimed at spurring development of innovative technology is the
.. Green Chemistry Program, which aims to reduce or eliminate the use or generation of
toxic substances in the design, manufacture, and use of chemicals. The program sup-
ports research in environmentally benign chemistry and promotes partnerships with
industry in developing green chemistry technologies. In March 1995, The Green Chem-
1' A Phase I Report on the Consumer Labeling Initiative is available on the Internet at http://www.epa.gov/
opptintr/labeling/phasel; or from the Pollution Prevention Information Clearinghouse
(tel: 202-260-1023, fax: 202-260-0178). For more information, contact Julie Lynch at 202-260-4000.

12 For more information on the Voluntary Standards Network, contact Mary McKiel at 202-260-3584.

13 EPA, Office of Pollution Prevention and Toxics. Environmental Technology Initiative for Chemicals
(EPA 743-K-96-001, May 1996). ' . • . '
35

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                                                                                istry Challenge program was
                                                                                announced  by President
                                                                                Clinton. This program pro-
                                                                                motes innovative uses of
                                                                                green chemistry for pollution
                                                                                prevention. EPA is working
                                                                                cooperatively with industry
                                                                                and the scientific community
                                                                                to establish this program.14
                                                                                                  i  '-,
                                                                                EPA's Environmental  Lead-
                                                                                ership Program (ELP) sup-
                                                                                ports facilities that have vol-
                                                                                unteered to demonstrate their
                                                                                innovative approaches to en-
                                                                                yironmental management and
                                                                                compliance, including pollu-
                                                                                tion prevention. EPA has se-
                                                                                lected 12 facilities to partici-
                                                                                pate in the pilot program and
                                                                                will work with these facilities
                                                                                to study and evaluate their in-
                                                                                novative approaches. The in-
                                                                                formation collected through
                                                                                this program  will be used as
                                                                                a tool to improve environ-
                                                                                mental management and
                             compliance throughout the regulated community. The purpose of ELP  is two-fold: (1)
                             to recognize facilities that develop and implement innovative environmental manage-
                             ment systems and "beyond compliance" programs, and (2) to work with these facilities
                             and understand their systems and programs and to share  that information with the
                             regulated community to improve environmental management and increase compliance.
                             In exchange for volunteering to demonstrate their innovative approaches,  EPA will
                             offer facilities several incentives, including public recognition by EPA as an environ-
                             mental leader, a limited grace period to correct any violations discovered during the
                             pilot program, and a guarantee of no routine inspections by EPA or the state.15 Fifteen
                             facilities participated in the pilot program, including ten private companies and two
                             federal facilities.                                                       '
                             Region DCs planned Pollution Prevention Through Technology Transfer pilot project
                             will help test OPPT's new pollution prevention risk assessment framework, developed
                             in an earlier OPPT/Kodak project, and will help regional industries promote facility-
  Green Chemistry Challenge
  The Green Chemistry grant and awards program provides financial support and na-
t-tional recognition for research, development, and use of industrially and economi-
k cally-viable chemical alternatives. Nominations for the Green Chemistry Challenge
  awards are made inthree areast CD use of alternative synthetic pathways, (2) use of
I  alternative reaction conditions, and (3) the dtesign of chemicals that are less toxic
  than current alternatives or that are inherently safer with regard to accident poten-
  tial. The 1996 winners of the award are                                     ^
          |                -<~J,=B|1      ""    „»    S     "       f^.
  •   The Monsanto" Company for creating a new "zero-waste" process for manu-
      facturing a key intermediate in their popular herbicide Roundup®;           :

  •   Dow Chemical Company for finding a way to replace the CFCs and other
      volatile organic compounds in the manufacture of foam products by using
i    . • carbori dioxide; and ••-_-, • \:,,'. •/. .-,••.,:•'•.: .;•;.-,  .. -.''!-..':    •-. .  .••  :'..   .  >•'   . .•  • i
I  • , The Dpnli^ Coji^qr^                                                  ;'•'•;'
'  •. "• polyaspartates, a pblyrrier^"alternative to toxic chemicals;in fertilizers that is
i      not only biodegradable but will actually increase nutrient uptake by plants
                         i f *•„        ~"              T           f
  •   Rohm and Haas Corporation, for designing its product "Sea-Nine" as a safer
      marine anti-foulant fof boat and ship hulls.

'  •  Professor Mark T. Holtzapple at Texas A&M  University, for research in using '
\ •   agricultural-wastes in-a wide variety of products, including animal feed, fuels, :
i     and high value chemicals.                       .         ,     •           •
Lj.\-^2.^^^s!i&SifM:&
                            14 EPA, Office of the Administrator, Partnerships in Preventing Pollution -A Catalogue of the Agency's
                            Partnership Programs (EPA 100-B-96-001).
                            !SEPA, Office of Compliance. Environmental Leadership Program Fact Sheet (April 1995).
36

-------
 based pollution prevention activities.

 Pollution Prevention Research in EPA's Office of Research and
 Development (ORD)
 ORD has maintained a significant research program in pollution prevention for several
 years.. Prior to 1994, the following were the main emphases of this research: assisting
 small business sectors (such as printing, metal finishing, dry cleaning) in achieving
 pollution reduction; developing tools (such as life cycle assessment) to analyze and
. measure pollution prevention potentials; partnering with industry (such as pulp and
 paper) in evaluating cleaner technology demonstration under the Effluents Guidelines
 Program; evaluating innovative waste reduction technologies (under the Waste Re-
 duction Innovative Technology Evaluation Program [WRITE]) developed in universi-
 ties, research institutes, and industry; working in partnership with other government
 departments in developing specific technologies or assessing opportunities for pollu-
 tion prevention; and creating databases for disseminating information about pollution
 prevention. There was also a program to examine the socioeconomic aspects of pre-
 venting pollution. Most of these programs are still being supported; however, there
 has been a strategic shift in research direction, the results of which will be felt in a few
 years.  The central theme to the strategic shift was the use of risk as a driver and
 motivator for doing prevention research. Thus, only the high priority problems need
 to be addressed first—problems in which either pollution prevention approaches will
 provide large environmental benefits or for which efficient tools and methods will
 provide knowledge and information to reduce uncertainty of prevention technologies
• or to lead  to newer prevention approaches.  An expanded grants program at ORD
 supports high-risk innovative pollution prevention approaches, and addresses socio-
 ''economic issues of pollution prevention.
 Current ORD research in prevention can be described in four categories:
 •.  Development of analytical tools and methods needed to assess or measure
     pollution, and quantify improvements;

 •  Development of generic technologies that have simultaneous appeals to many
     industry sectors and to agricultural practices;

 •  Development of, in collaboration with industry, sector-specific technologies
     requiring systems approaches; and .   "      '      '       .

 •  Demonstration and verification of cleaner technologies on large scales.

 Analytical Tools and Methods for Pollution Prevention
 Providing tools and methods that aid scientists, engineers, and technicians in choos-
 ing cleaner chemistry, materials, algorithms, design techniques, databases, and engi-
 neering methods  when they design for the environment, is effective insurance that
                                                                                                     37

-------
S.ChapteKJi:
38
industry will of its own accord meet or exceed regulatory requirements. Examples of
these tools and methods are:
• Life Cycle Assessment (LCA). The present thrust of ORD efforts is directed to
making LCA affordable through a streamlined LCA methodology.

• Simulation/Design Tools. The National Risk Management Research Laboratory
(NRMRL) has developed a computer-based algorithm, WAR or Waste Reduc- .
tion Algorithm, that follows the concept of pollution balance, a scheme based
on either pollution mass or potential environmental impact. WAR will shortly
be available commercially as a new capability of Chemcad, a product of
Chemstation, Inc., of Houston, Texas.

• Guidance and Design Tools. These computer-based tools (SAGE - solvent
alternative guide; CAGE - coatings alternative guide; AAGE - adhesives
alternative guide; and PARIS II) offer ways of selecting environmentally-
preferable substitutes. .

• AssessmentTools. ORD has developed guidance documents for systematically
assessing pollution prevention opportunities in production, service, and
maintenance facilities.
• Impact Assessment Tools. NRMRL is developing a generic program (TRACI)
for the reduction and assessment of chemical impacts, which assists in
providing aggregate impacts through user-provided weighing factors for
various disparate impacts, such as ozone depleters and greenhouse gases.

• Control Algorithms. ORD has developed control algorithms based on fuzzy
logic which allow better control of processes to minimize emissions.

Generic Process Technologies (Multi-sector)
Generic technologies have multi-sector impacts. These are products of traditional
unit operations (physical changes) or unit processes (chemical changes)-based re-
search except that environmental concerns are incorporated in the research process.
Unlike the analytical tools, which are mathematics- and computer code-intensive, re-.
search in generic technologies is largely experiment-based. The following are three
broad areas of particular interest:
• Green Chemistry and Green Processing. The ORD grants program, Technolo-
gies for Sustainable Development, provides significant support for a range of
generic technologies from cleaner chemical or biochemical pathways to
chemical synthesis or material formulation. For instance, synthesis in
supercritical carbon dioxide offers certain processing advantages. Biochemi- .
cal synthesis of feedstocks likewise is looked upon as a safer alternative to
synthesis based on petroleum-derived feedstocks. NRMRL is evaluating
innovative oxidation pathways that are environmentally benign. A large
number of valuable feedstocks are oxychemicals, commercially made in
Sharsher environments, thereby creating unwanted and toxic byproducts.

-------
• New Materials. ORD's grants program supports developing new materials.,
such as benign substitutes and materials, with enhanced environmental
performance. • .

• Separation technologies. The ORD grants program also supports research on
separation technologies. Separation technologies are particularly suitable for
making in-process recycle-reuse possible. As an example/consider absolute
alcohol, which is made from the azeotropic composition of alcohol-water
mixture. Benzene is added to the binary azeotrope and the ternary mixture is
further distilled to produce absolute alcohol. With a pervaporation membrane
this operation can now be done without the need of adding a carcinogenic
compound like benzene. Numerous opportunities of in-process efficient
separations are encountered in industrial applications. ORD is currently
exploring several promising generic separation methods — membrane,
adsorption, and a hybrid of the two. .

Sector-specific Technology Development
ORD is following the needs of technology developments in all the CSI industries.'
ORD works with the Office of Water in the Effluent Guidelines Program for evaluating .
cleaner technologies in identified industry sectors, and has recently started working , •
with the textile industry under the AMTEX program in developing pollution preven-.
tion technologies, such as recovering color from textile effluents and dealing with the •
solid waste problem. , .

Technology Demonstration and Verification
There are certain applications of clean technologies that need to be demonstrated or
verified for performance before the technologies will be adopted for industrial appli- .
cations. A small-scale application of this may be a technology for recycling chro-
mium or nickel from electroplating baths. A large scale application may be paper
pulp bleaching without using either chlorine or chlorine dioxide. To encourage v/ider
acceptance of environmental technologies in general, ORD has formulated an Envi-
ronmental Technology Verification (ETV) program, a part of which is dedicated to
pollution prevention technologies. '

Theme 7: Seek changes, where justified, in
federal environmental laws that will
encourage pollution prevention/source
reduction.

The federal Pollution Prevention Act is not the only legislation with significance for
pollution prevention. U.S. environmental laws have historically been oriented to-
wards .single-medium, end-of-pipe waste management solutions. Congressional re-
sponse to waste management problems has been issue- and media-specific, resulting
39

-------
                            in statutes such as the Clean Air Act (CAA), Safe Drinking Water Act, Resource
                            Conservation and Recovery Act (RCRA), and the Superfund law.
                            These statutes were not designed to encourage preventive approaches, although in
                            practice they often have that effect. For example, Superfund liability has been a long
                            standing incentive for pollution prevention, since the surest way to avoid future li-
                            ability is to avoid generating wastes in the first place. The single media approach
                           'also has its limitations. Because most environmental statutes focus on'a single envi-
                            ronmental medium or problem, they may allow for shifting of wastes between media,
                            and not highlight the advantages of eliminating waste at the source.
                          •  The National Academy of Public Administration (NAPA) has recommended that Con-
                            gress pass legislation encouraging businesses to go beyond mere compliance with EPA
                         .   regulations while at the same time giving industry more flexibility in its approach to
                            meeting or exceeding the regulations.  NAPA recommends that EPA and Congress,
                            working together, design environmental programs and regulations that permit busi-
                           • nesses to seek their own solutions to their individual or common problems. The re-
                            sults of this type of legislation and regulation are lower costs with the added benefit of
                            innovative technology as industries test new methods for achieving pollution preven-
                            tion targets.                      •
                            EPA's Statutory Integration Project came out of a recommendation by NAPA hi its -
                            Report to Congress..  They articulated what many recognize: namely,  that EPA is
                            fragmented by media, in part due to the statutory framework under which the Agency
                            operates.  The Senate Appropriations Committee asked the Agency to take a look at
                            statutory integration specifically, and also asked the Agency to better integrate its plan-
                            ning, budgeting, and accountability practices - a process now well under way.
                            EPA Administrator Carol Browner charged the Statutory Integration Task Force with
                            taking a broad view of the topic. The group is not focused solely on investigating a
                            complete statutory "fix," but is instead looking at a range of possibilities from a
                            single integrated statute to replace the existing environmental laws, to incremental
                            change working toward better coordination across statutes, to an integrating statute
                            which would overlay existing statutes. The task force has conducted approximately
                            80 interviews'within EPA, with industry,  with the regulated community, with envi-
                          . ronmentalists, academics, and Congress.  The task force is also working with Re-
                            sources for the Future on a comparison of international environmental laws, and are
                            performing a comparative legal analysis of existing statutes.
                            Some key points that are beginning to emerge include a set of objectives which would
                            provide EPA with more discretion to set priorities,  clearly articulate a mission and
                            goals, and'provide more flexibility to waive or adjust regulatory requirements.  This
                            project presents many opportunities to the Agency,  including gaining flexibility in
                            choosing the best authority to address a risk; functioning in a more integrated way on
                            such things as  regulation writing; operating with more consistency across authori-
                            ties; and managing resources more flexibly.
40

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This brief survey of Agency activity demonstrates how prevention perspectives and
approaches have taken hold.. It is not an assertion that the work of institutionalizing
pollution prevention across EPA has yet succeeded. In fact, one of the most daunting
tasks that has faced EPA is integrating pollution prevention into the Agency's own
culture and mission. Substantial progress has been made on this task in the last six
years. Throughout the Agency, EPA offices are rethinking their programs, making
pollution prevention a priority rather than an afterthought. A wealth of new partner-
ships have been created with the private sector to develop and experiment with pol-
lution prevention approaches. In many ways, pollution prevention has brought with
it a new sense of cooperation and exploration in tackling some of the most intractable
environmental problems. At this point, the Agency needs better tools to disseminate
these prevention innovations across the environmental community and to measure
the cumulative environmental impacts of these innovations.
In looking ahead, it is worth considering the five criteria for environmental manage-
ment policies established by the President's Council on Sustainable Development in
its 1995 report.16 These criteria are aimed at enhancing the efficiency of existing
regulatory systems and are a basis for future environmental approaches as well:
• Provide Greater Regulatory Flexibility with Accountability. The regulatory
system must giyecompanies and communities greater operating flexibility,
enabling them to reduce their costs significantly in exchange for achieving
superior environmental performance. While allowing flexibility, the system
must also require accountability to ensure that public health and the environ-
ment are protected.

• Extend Product Responsibility. A voluntary system of extended product
responsibility can be adopted in which designers, producers, suppliers, users,
and disposers accept responsibility for environmental effects through all
phases of a product's life.

• Make Greater Use of Market Forces. Sustainable development objectives must
harness market forces through policy tools, such as emissions trading, deposit/
refund systems, and tax and subsidy reform. This approach can substantially
influence the behavior of firms, governments, and individuals.
\ _
• Use Intergovernment Partnerships. Federal, state, and tribal governments
need to work together in partnership with local communities to develop place-
• based strategies that integrate economic development, environmental quality,
and social policymaking with broad public involvement.

• Encourage Environmental Technologies. The economic and environmental
management systems need to create an atmosphere that encourages innovation
and the development and use of technologies that will create jobs while
reducing risks to human health and harm to the environment.
^President's Council on Sustainable Development. Council Report. Washington, DC (1995). The
Report is available on the Internet at http://www.whitehouse.gov/PCSD.
' •' 41

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42

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Chapter Two
                 at
             I Industry Progress;Tlil ^nd Voluihtary
              Program?       ^ :';'':'•    : "''  '  ' .••'•""•'.''
             I Establishing Corporate Gdmmitiheiii t|c>
              Pollution Preyentioii
             I Helping Small jBtisinesses to tliidertake.
              Pollution Prevention Measures
             I Encouraging Industry-wide Initiatives
             I Reaching Suppliers and Customers
             I Making the Most of Community
              involvement
             I Selling Environmentally-PreferaMe
              Products
             I Innovative Ideas
             I Guest Comments:
              Edwin L. Mongan, DuPont
              Craig Doolittle, the Dow Chemical Compariy
              Marc J. Epstem, 3ENSEAD
                                                               43

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44

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Introduction

Reducing and preventing industrial pollution has been the primary focus of this nation's
pollution prevention agenda over the past decade. Quantifying the progress that in-
dustry has made in adopting a pollution prevention approach remains elusive. (See
Chapter 7 of this report for a more detailed discussion of Measuring Pollution Preven-
tion.) However, anecdotal evidence suggests that reliance on pollution prevention as
a primary environmental management tool is increasing and spreading beyond the
initial industry leaders. Still, much work remains to be done. This chapter begins with
some thoughts on motivating industry to prevent pollution. Why should industry prac-
tice pollution prevention?. How can those that influence industry decision makers (gov-
ernments, customers, suppliers, workers, non-profit groups, communities, etc.) effectively
encourage pollution prevention?
In 1995, EPA completed an ambitious project to examine how a pollution prevention
ethic could be promoted throughout industry. According to the findings of the Indus-
trial Pollution Prevention Project (BP3), the four most important general motivators
for pollution prevention in industry are economics, technical and financial assistance,
open communication, and flexibility (especially regulatory flexibility).1 The IPS found
that the key "trigger" for pollution prevention is a stringent regulation or enforcement
action. Research conducted by the non-profit group INFORM on the chemical and
paint and adhesives industries similarly found that the desire to avoid being subject to
regulations provided the most critical impetus for pollution prevention, not only moti-
vating source reduction initiatives but also ensuring their success hi the marketplace.2
Similarly, in a 1994 study of global competitiveness in six industries, environmental
pressures from regulations and from consumers and professional advocacy campaigns
created opportunities for companies to gain competitive advantage in domestic and in-
ternational markets.3 Such innovations resulted hi cost reductions, yield improvements,
market share increases, and/or export expansion.
The economic benefits of pollution prevention have proven to be me most compelling
argument for business to undertake prevention projects. In a 1992 follow-up study of 29
firms originally examined in 1985, INFORM found a heightened level of awareness and
activity related .to pollution prevention. Nearly half of the companies were saving be-
tween $45,000 and $1 million annually on their source reduction activities, with 15
percent saving $1 million or more. Payback periods were short; in nearly two-thirds of
the source reduction activities, companies recouped their investments in 6 months or
.less.4
1 EPA, Industrial Pollution Prevention: Incentives and Disincentives (EPA-820-R-94-004,. August
1994)." Also see: EPA, Industrial Pollution Prevention Project (IPS): Summary Report (EPA-820-R-
95-007, July 1995).
2 INFORM, Stirring Up Innovation: Environmental Improvements in Paints and Adhesives (New
York, NY, 1994).
3 Management-Institute for Environment and Business, Competitive Implications of Environmental
Regulations:'A Study of Six Industries (Washington, DC, 1994).
4 Dorftnan, Mark H., Warren R. Muir, and Catherine G. Miller, Environmental Dividends: Cutting
More Chemical Wastes (INFORM, 1992).
The four most
compelling
motivators for
pollution prevention
in industry are:
• economics
• technical and
financial assistance
• open
communications
• flexibility (especially
regulatory flexibility)
45

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                              Cost savings from prevention come not only from avoiding environmental costs like
                              hazardous waste disposal fees, but also from avoiding costs that are often more chal-
                              lenging to count, like those resulting from injuries to workers and ensuing losses in
                              productivity.  In that sense, prevention is not only an environmental activity, but also
                              a tool to promote worker safety.
                              So, if preventing pollution is so good for the bottom line, why don't companies al-
                             ' ways do what's good for them? One answer might be that managers don't always
                              realize the benefits that prevention would bring to their own firms. "Environmental
                              accounting" — a new type of managerial accounting that helps firms identify envi-
                              ronmental costs and benefits —-"is just now beginning to take hold and to demon-
                              strate to companies how much of their costs are attributable to environmental
                              activities.*                                               ,
                              The basic idea of environmental accounting is that an'organization's environmental
                              costs, like all its costs, need to be identified, quantified, and allocated to the process or
                              product that incurs them in order for such costs to be managed and reduced.  If
                              companies pay closer attention to the size and causes of their  environmental costs,
                              they will have ah economic incentive to prevent them from occurring  in the first
                              place.  Fewer than 10 percent of U.S. manufacturing firms routinely allocate envi-
                              ronmental  costs to the responsible  product or process  in  their internal  accounting
                              systems, according to a 1995 survey of 150 firms.6 Another study that closely exam-
                              ined the  accounting systems of nine industrial firms found that "the environmental
                              costs teased out of hiding turned out to be colossal."7
                              Similarly, pollution prevention can offer companies exciting opportunities to increase
                              market share, but only if managers have the foresight to realize these opportunities
                              and if their firms are well-positioned in the industry. Michael Porter of Harvard Uni-
                              versity and Claas van der Linde of St. Gallen University in Switzerland have devel-
                              oped a dynamic model of competitive business behavior showing that market share
                              can be captured by companies that continually innovate.8 But, as Porter and Linde
                              advise, "companies must begin to recognize the environment as a creative opportunity
                              rather than as a costly threat." Large companies in industries with a high rate of change
                              (e.g., computer and chip manufacturers) tend to have the most resources for innova-
                              5 See EPA chapter of this report for a description of EPA's Environmental Accounting project.  A
                              bibliography of sources for companies that have realized pollution prevention opportunities by using
                              environmental accounting tools, in addition to complete case studies from AT&T and Ontario Hydro,
                              are available through EPA's Pollution Prevention Information Clearinghouse at 202-260-1023.
                              6 Tellus Institute, Environmental Cost Accounting for Capital Budgeting: A Benchmark Survey of
                              Management Accountants (1995).                                       ' ,
                              7 World Resources Institute,  Green Ledgers: Case Studies in Corporate Environmental Accounting
                              (1995). The study examined the books of Du Pont, Amoco, Ciba-Oeigy, S.C. Johnson, Dow Chemical,
                              and three small firms in the Pacific Northwest. In the case of one Du Porit plant studied, environmen-
                              tal costs made up 19 percent of the total cost of manufacturing an agricultural pesticide.  At an Amoco
                              facility, aggregate environmental costs were estimated at nearly 22 percent of operating costs.
                              8 Michael E. Porter and Claas van der Linde, "Green and Competitive: Ending the Stalemate,"
                              Harvard Business Review (September/October 1995).
46

-------
tion. On the 'other hand, some industries cannot meet the challenge, particularly if
they are made up of small companies that are required to make large fixed invest-
ments.9 ' .....
Companies are often stymied by the up-front costs that pollution prevention appears to
require. According to the findings of the EPS, "while pollution prevention measures
can hold the promise of future cost savings, if capital investment is needed for such
changes, companies... can find themselves in a Catch-22 situation."10 Nevertheless,
relatively few companies have reached the point where only capital-intensive mea-
sures are available. A1992 INFORM report examined pollution prevention activities .
at a variety of facilities in the organic chemical industry and found that no capital
investment was required for one quarter of the 48 source reduction activities; invest-
mentsofunderSlOQ.OOOwererequiredforabouthalftheactivities.11 In addition, over . .
the past 5 years, loan and grant programs have become more readily available to assist
companies interested in investing hi pollution prevention. ,
This chapter begins with an overview of industrial pollution prevention progress
demonstrated through two prominent EPA initiatives —'• the required reporting of
toxic releases to EPA's Toxics Release Inventory (TRI) and EPA's voluntary partner-
ship programs, known collectively as "Partners for the Environment." The remainder
of this chapter reviews different approaches to industrial pollution prevention and some
of the lessons that have been learned over the past six years in promoting a pollution
prevention ethic.
The examples'in this chapter are drawn from a wide variety of industries. While
most industrial pollution prevention reports tend to focus on the chemical and manu-
facturing sectors, for this report, we have drawn from a wider range of industries —
from retail stores to utilities to agriculture — to highlight opportunities to prevent
pollution across the board. However, it would be impossible to cite all of the compa-
nies that have achieved impressive pollution prevention successes. The specific'ex-
amples described here are illustrative of diverse approaches to prevention.

Industry Progress: TRI and Voluntary
Programs

The clearest measure of industrial pollution in the manufacturing sector can be found
in companies' annual reports of environmental releases of toxic chemicals to TRI.
Correspondingly, one of the clearest indicators of corporate responsiveness to the need
for reducing chemical releases and preventing pollution has been a company's partici-
pation in EPA's voluntary programs.

9 Management Institute for Environment and Business, Competitive Implications, cited in EPA,
Pollution Prevention News (March-April 1995) pp. 4-5.
10 EPA, Office of Water. Industrial Pollution Prevention: Incentives and Disincentives (EPA 820-R-
94004, August 1994). p.2.
11 Dorfman, Mark H., .Warren R. Mnir, and Catherine G. Miller, Environmental Dividends: Cutting
More Chemical Wastes (INFORM, 1992).
47

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TRIData
The TRI data12 collected and published annually demonstrate a steady decline in the
volume of toxic chemicals released to the environment fay the manufacturing sector.
However, over the last several years, the total amount of wastes generated has been
rising. TRI data for 1995 show a decline of 4.9 percent in releases of core chemicals
reported in both 1994 and 1995. Overall, from the baseline year of 1988 until 1995,
total releases (for chemicals reported in each of the years) decreased by 1.35 billion
pounds, a 45.6 percent decline. However, total production-related waste generated
in 1995 from all TRI chemicals was over 35 billion pounds, a 6.8 percent increase
since 1991.
Companies report pollution prevention activities to the TRI, as required under the
Pollution Prevention Act of 1990. Of the 21,951 facilities reporting to TRI for 1995,
nearly 29 percent claimed to have undertaken at least one source reduction activity.
This is down from 32 percent in 1994. Most commonly reported were "good operat-
ing practices"followed by process modifications, arid spill and leak prevention. In
general, facilities project little change in how they expect to handle their waste in the
next several years.
Individual industries have had very different experiences with TRI chemical releases
and reductions. As Table 2-1 shows, several industries reported reductions of half or
more of total releases since 1988, led by the electrical equipment industry (79.7 per-
cent) and leather goods manufacturers (77.8 percent). In 1995, the chemical manufac-
turing industry continued to rank in first place with the largest amount of chemicals
released (36 percent of total releases), followed by the primary metals industry (15
percent), paper (11 percent), and plastics (5 percent).
The top 10 chemicals released into the environment (shown in Table 2-2) account for
over half the total amount of releases of the expanded list of 643 TRI chemicals. The
10 companies that reported the highest total releases of toxic chemicals in 1994 are
shown in Table 2-3. Although these firms represented fewer than 2 percent of all TRI
reporting facilities,, they accounted for 26 percent of total TRI releases in 1994.
It is important to note that the volume of TRI chemicals released does not necessarily
equate to the amount of risk posed to the public. TRI reports reflect release of chemi-
cals, not exposure of the public to those chemicals. Because health risk is dependent
not only on toxicity but also on exposure, release estimates alone are not sufficient to
calculate adverse effects on human health and the environment.
12 For more information on the 1995 TRI data, see: EPA, ^995 Toxics Release Inventory: Public Data
Release (EPA 745-R-97-005, April 1997). •
48

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Table 2-1. TRI Releases by Industry
Sindustry Change in Releases, 1995 j
i •',.'' .1988-1995 (millions of pounds) j
Electrical Equipment
Leather
Measurement/Photography
Tobacco
Machinery
Textiles
Chemicals
Printing
Stone/Clay/Glass
Transportation
Petroleum
Fabricated Metals
Primary Metals
Furniture
Plastics
Food
Paper
Lumber
Apparel
-79.7%
-77.8%
-74.2%
-72.2%
-67.6%
-56.1%
-49.8%
-48.3%
-47.1%
-44.4%
-40.6%
-40.1%'
-38.2%
-33.7% '
-31.1%
-27.5%
-12.6%
- 5.0%
. +33.6%
30.5
3.1
16.9
1.7
23.2
17.8
787.7
31.6
36.0
110.0
59.9
82.6
331.2 "
41.0
112.2
86.0
233.2
31.3
1.3
 Source: EPA, 7995 Toxics Release Inventory: Public Data Release (EPA 745-R-97-005,
 April 1997), Tables 4-10, 5-5.
Table 2-2. Top 10 Chemicals Released/Disposed, 1995
iff   *T V  1"
l Chemical
  Methanol
  Ammonia
  Toluene
  Nitrate compounds
  Xylene (mixed isomers)
  Zinc compounds
  Hydrochloric acid
  Carbon disulfide
  n-Hexane
  Methyl ethyl ketone  ,
     Total for top 10 chemicals
     Total for all TRI chemicals
 (millions)
  245.0
  195.1
  145.9
  137.7
   95.7
   87.6
   85.3
   84.2  :
   77.4
   70.0.
1,224.1
2,208.7
 Source: EPA, 7995 Toxics Release Inventory: Public Data Release, Overview (EPA 745-R-
 97-005, April 1997), Table 6.
 2fiSa:S:§l!3£M;S5^^
                                                                                                    49

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_, - ,
Chapter2- mavistxy --•.'
.,l?i!Z&&&<£*m~'i£M±Z'*2x^±j£~
Table 2-3. Top 10 Companies Based on Total Releases Reported to TRI,
1994
: Company Total Facilities Releases '
| •". '• ';'v"V': •'./'''' '• ' "'' .' " 7 ''" '.'"' ' • •"-' •'•' '• • " (mUHohisof pounds) '•'
Du Pont
ASARCO Inc..
Renco Group Inc.
IMC Global Inc.
international Paper Co.
General Motors Corp.
Courtaulds United States Inc.
Monsanto Co.
Arcadian Partners LP
Georgia-Pacific Corp.
Total for top 10 companies
Total for all TRI facilities
,70
11
. 12
13
71
112
9 .
27
8
90 '
423
22,744
203.6
, 69.4
66.1
47.7
43.1
36.8
34.5
27.4
26.4
26.2
- 581.2
2,260.2
Source: EPA, 7994 Toxics Release Inventory: Public Data Release, Executive Summary (EPA
745-S-96-001, June 1996), Table E-l. •
"When EPA

proposed the 33/50

Program, we

recognized that its

general objective

was'no different .

than ours."

--.Aristech Chemical
Partners for the Environment
EPA has been developing and aggressively promoting voluntary partnerships as an
alternative to the traditional command-and-control regulatory approach. Programs
such as Green Lights, the 33/50 Program, WasteWis$e, Climate Wise, and WAVE
-"• ~ --;,••-•"• •.•.».,--••;-.-.• .„,,,,„,-., .-......„...,....,.,, challenge businesses to pre-
Why Do Industries Jom El^^ltantery I^ogr^ms? ; Vent pollution and improve
Industry participation in the 33/50 Program has proven remarkably successful and \ their company's bottom line.
is responsible for an accelerated reduction in the 17 chemicals targeted by the i Collectively, these partner-
program. The 1,300 corporate participants in the 33/50 Program own more than a
quarter of the total number of TRI facilities, and were able to meet the program's
1995 goal of 50 percent reduction a year ahead of schedule. Participants in 33/50
applauded the program's flexibility and voluntary, "no-strings-attached" terms. An
interesting insight offered by Aristech Chemical in reflecting on the success of the
33/50 Program is that the program greatly improved government/industry rela-
tions: "When EPA proposed the 33/50 .Program, we recognized that its general
objective was no different than ours. Therein lies a major reason for the success of
the program! The progress realized under 33/50 typifies the success that can be
achieved when government and industry work in pursuit of mutually agreed upon
: objectives."13 • , •••.-'.•' . -'-I .-
ship programs are known as
Partners for the Environ-
ment, and they are produc-
ing impressive results. As
noted in Chapter 1, in 1995,
over 6,000 participants
saved $435 million while
helping to cut toxic pollu-
tion, reduce solid waste,
and lower greenhouse gas
emissions.
13 "The Smart Choice," Environmental Champions, a supplement to Chemical Engineering and
Environmental Engineering World, undated, p. 16.
50

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Figure 2-1. Participation in Partners for the Environment Continues to
Increase
18.568*
20000-1
1991
1992 1993 1994 1995 1996 2000*
* Projected
Interest in these programs continues to grow - participation increased by 25 percent
in the last year alone (Figure 2-1). EPA now projects that by the year 2000, the
number of partners will nearly triple and the total savings to firms will approach $7
billion a year. .

Establishing Corporate Comniitment to
Pollution Prevention

A1993 study by the Business Roundtable, ah association of business executives, con-
firms what many believe—successful corporate pollution prevention programs begin
with tangible forms of corporate commitment.14 The goal of the Roundtable's
"benchmarking" study was to determine the common, as well as the unique, ele-
ments of six "Best-In-Class" manufacturing facilities: Proctor & Gamble's Mehoopany,
PA facility; Intel in Aloha, OR; Du Pont in La Porte, TX; Monsanto in Pensacola, FL;
3M in Columbia, MO; and Martin Marietta in Waterton, CO.
Key findings of the study included:
• All facilities had strong management support and a focal point for the facility
level pollution prevention program.

• Successful facilities understood their corporate and plant cultures and imple-
mented their pollution prevention programs in a way that worked within those
cultures.
14 The Business Roundtable. Facility Level Pollution Prevention Benchmarking Study (November
1993).
51

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Corporations can be
threatened by their
i
substantial emissions
to the environment or
challenged by them.
They can be stymied
by long-standing
environmental
disputes or motivated
to solve them. They
can be defensive about
existing operations or
open to ideas for
.change. The decisions
they make at these
crossroads define the
role they will play in
environmental
decision making, as
well as their corporate
image.

— Linda Greer,
Natural Resources
Defense Council
(Quoted in Monsanto's
Environmental Annual
Review, 1995.)
• The majority of the facilities stated that the corporate role should be to •
establish corporate goals with facility input, develop and deploy pollution
prevention technology transfer across the company, and forecast future
compliance issues.

• Facilities were successful when they were not told how to approach pollution
prevention by corporate environmental groups or other outside forces. The
freedom to choose the best pollution prevention method for their organization
was key to success.

• Facilities had the ability to report progress against selected goals or initiatives
on a monthly or quarterly basis.

• To be able to sustain a pollution prevention program, the projects were, on the
whole, cost effective. Unlike compliance projects, pollution prevention
projects generally had to compete against capital improvement projects.

• Each facility measured the success of its program differently, using a combina-
tion of reduced cost, reduced volume, improved public image, results against
goals, ability to expand a facility, and other measures.

• Some facilities normalized waste volume to production; others did not. Each
facility used a different method for tracking wastes/emissions. All facilities
used PC-based systems to track waste streams and customized spreadsheet
packages to meet their own needs.

• Each of the facilities had matured from focusing on pollution prevention
within current manufacturing processes to integrating pollution prevention hi
the pre-manufacturing decision phases. The benchmark facilities were
working with raw material suppliers, equipment suppliers, and customers to
prevent pollution at each step. .

The following summaries of pollution prevention programs illustrate how pollution
prevention has been incorporated into five large corporations. Monsanto instituted the
Monsanto Pledge, a highly effective statement of principles and commitment which
has been backed up by competitions, awards, and other motivational elements. Union
Carbide has been recognized by EPA's Office of Pollution Prevention and Toxics for
innovative chemical design. Public Service Electric and Gas (PSE&G) provides an
interesting example of how materials management decisions can yield pollution pre-
vention returns, and how a company can engage in the successful marketing of by-
product materials. AT&T has made innovative use of environmental accounting meth-
ods to further its pollution prevention goals. And Home Depot is one of the most
active retailers promoting a pollution prevention agenda among its clients and staff.
52

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The Monsanto Pledge - > -
The Monsanto Pledge—seven principles that describe the company's vision for a
sustainable environment—was unveiled during a speech in 1990 by then Chairman
and Chief Executive Officer Richard J. Mahohey at a meeting of the National Wild-
life Federation.
• Reduce all.toxic and hazardous releases and emissions, workmgstoward an
ultimate goal of zero effect. . .
• Ensure no Monsanto operation poses any undue risk to our employees and
our communities. ' ' .
• Work to achieve sustainable agriculture through new technology and prac-
tices^ ,
y S? a. ->~ ^ *, ^
• Ensure groundwater safety.
• Keep plants open fcfour communities and involve the community in plant
operations. . •
• Manage all corporate real estate, including plant sites, to benefit nature.
Search worldwide for technology to reduce and eliminate waste from our
'"" -M&rae"'t^ •• :•••
Monsanto
, Monsanto.is a major manu-
facturer of high performance
chemicals, high-value agri-
cultural products, industrial
process control equipment,
food ingredients, and phar-
maceuticals. In March
1996, Vice President Al
Gore and members of the
President's Council on Sus-
tainable Development pre-
sented Monsanto with the
Presidential Award for Sus-
tainable Development for its
work hi pioneering sustain-
able technologies.
During the 1990-1994 time
period, Monsanto achieved a
55 percent reduction in TRI
-chemicals. In making this
reduction, Monsanto prioritized source reduction with the specific goal of not
transferring .pollutants Cross-media. Monsanto faced this challenge when con-
sidering two wastewater projects. Although the projects would have reduced
TRI chemical output, they would have increased levels of other wastes not in-
cluded in the TRI list. The company felt that following this strategy would
simply be pollutant transfer, not pollution prevention, and opted not to under-
take the projects. In the future, the company plans to continue focusing much of
its efforts towards sustainability and, consequently, further reduce TRI emis-
sions.15 • '.
' To achieve the 55 percent reduction, Monsanto completed more than 250 projects
that involved developing innovative new manufacturing technology and modify-
ing processes; phasing out inefficient operations; applying new pollution con-
trols; and using waste materials for recycling, reuse, and energy recovery. Spe-
cific pollution prevention accomplishments include the following:
• Teams from several Monsanto facilities developed a new process to make
4-aminosiphenylamine, an ingredient that makes rubber products more
durable. The new patented process called PPD-2 reduced raw material
.needs by 58 percent and cut organic and inorganic waste by a combined total
of 95 percent.16 '

13 Conversation with Dennis Redington of Monsanto on September 6, 1996. For further information,
he can be contacted at 314/694-6503.
16 Monsanto. Monsanto's 90 Percent Air Emissions Reduction Program.
53

-------
                             •   Monsanto switched from a well-established process using extremely hazardous
                                 substances including formaldehyde, ammonia and cyanide-based chemicals to a
                                 new, highly innovative process that eliminates these hazardous substances from
                                 the manufacture of the pesticide Roundup*®, replacing them with more benign
                                 chemicals. This new process is saving the company $4 million a year that used
                                 to be spent managing more than 5 million pounds of waste.  In July of 1996,
                              •   EPA presented a "Green Chemistry Challenge" Award to Monsanto for this
                                 achievement.17                                                   :

                             •   The Monsanto Butvar resin facility in Antwerp, Belgium, redesigned its facility
                                 to save energy, reduce water usaget and cut back effluent. Butvar is a material
                                 used in the plastic innerlayer of safety glass in automobiles and in certain paints
                                 and adhesives. The first part of the project captures heat from the hot water
                                 system overflow and uses it in the manufacturing process. The cooled overflow
                                 is used to replenish water lost in the system.  The result is a reduction of
                                 effluent to the Antwerp treatment plant of 16 tons per hour. The second part of
                                 the project involves saving and re-using wash water several times in different
                                 parts of the manufacturing process. Monsanto estimates that it saves more than
                                 $400,000 a year in water and energy use as a result of this new process.la

                             Union Carbide
                             OPPT's New Chemicals Pollution Prevention Recognition Project recognized the Union
                             Carbide Corporation for developing an innovative surfactant, or detergent, for use in
                             industrial settings.19 The material can be split prior to environmental release, which
                             results in two non-polluting fragments or byproducts.  Union" Carbide developed the
                             new surfactant to meet its industrial laundry and metalworking customers' needs for a
                             product that would satisfy the effluent composition limits of publicly owned treatment
                             works (POTWs). This new technology reduces biological oxygen demand (BOD) and
                             fats, oils, and grease (FOG) in effluents. Other prevention benefits of this new mate-
                             rial include: generating less solid waste; generating solid waste that is higher in or-
                             ganic content and, therefore, can be put to a more beneficial use as fuel; and reducing
                             the use and discharge of phosphates.

                             Public Service Electric and Gas
                             PSE&G is the fourth largest combination electric and gas utility in the nation, serv-
                             ing 2.2 million electric and gas customers over a 2,600 square-mile service territory
                             in New Jersey. PSE&G's  vast size and diversified  power generation and service
                             17 EPA Press Advisory (July 12, 1996) and personal conversation with Larry O'Neill, Monsanto,
                             (December 4,1996).
                             18 Monsanto. "Butvar™Solvent and Butvar™RB Utility Usage Reduction,"  Monsanto Backgrounder,
                             (1995).
                             19 For more information about OPPT's New Chemicals Pollution Prevention Recognition Project,
                             contact Ken Moss (202-260-3395) or Roy Seidenstein (202-260-2252) of EPA/OPPT.
54                        .                                                                       ••     •

-------
 activities require substantial materials support, the costs of which increased sharply
 during the 1980s.
 In 1990, in the face of escalating material costs, PSE&G formed a senior-level Mate-
 rials Management Study Team to, develop innovative strategies to reform its material
 management process to control costs, improve service to internal customers, and real-
 ize environmental benefits. This effort led to a wholesale paradigm shift in PSE&G's
 approach to materials management. For example, instead of managing materials
 under the old-fashioned notion of "just-in-case" (i.e., purchasing and maintaining
 surplus supplies to meet any unanticipated future needs), PSE&G's new approach is
 founded on a "just-in-time" concept (i.e., purchasing and stocking only that amount
 of material necessary to satisfy planned needs in the immediate future).  Similarly,
 instead of viewing used or surplus materials as wastes (and liabilities), PSE&G's new
 strategy emphasizes that such materials are potential resources (and assets).
 At the same time as the company changed its materials management system, it also
 focused immediate  increased attention on recycling and source reduction, setting
 goals of reducing by 30 percent the total amount of hazardous waste PSE&G gener-
 ates, and recycling 75 percent of all non-hazardous solid wastes. PSE&G was honored
 as a 1996 WasteWi$e Program Champion for its Comprehensive Waste Reduction
 Program. The company surpassed these 1995 goals a year early — it reduced hazard-
' ous waste generation by 43 percent and recycled 94.5 percent of all company-gener-
 ated non-hazardous  solid, waste. This percentage for non-hazardous solid waste in-
 cludes coal combustion by-products (principally coal ash) generated by the company,
 all of which it successfully marketed (e.g., cement/concrete admixture, flowable fill,
 structural fill, pavement base, asphalt filler, cement kiln feedstock, anti-skid road grit,
 blasting and surface prep products, and as a landfill cover). PSE&G estimates that it
 saves $19-24 million annually as a result of its new materials management system.
 The company attributes most of this savings to a decrease in the operations and main-
 tenance cost of maintaining an extensive inventory and increased procurement lever-
 age
20
AT&T
Changing the accounting systems of an industry giant such as AT&T21 is by no means
an overnight operation. AT&T began to develop such a change in 1993, when it named
Brad Allenby as Research Vice President for Technology and Environment, and set up
a Design for the Environment Coordinating Team, one of whose projects was "green
accounting."                                                •
                                                                        We do not see a need
                                                                        to choose between
                                                                        good environmental
                                                                        practice and good
                                                                        business operations.
                                                                        Rather, we believe in a
                                                                        Shared Vision - that a
                                                                        cleaner, healthier
                                                                        environment can,
                                                                        indeed, should go
                                                                        hand in hand with a
                                                                        strong economy and
                                                                        the highest standard
                                                                        of living and quality of
                                                                        life in the world.
—  Jaines Ferland,
   Chairman and Chief
   Executive Officer and
   Lawrence Codey,
 .  President and Chief
   Operating Officer,
   Public Service Electric
   and Gas ("Our
  -Commitment to the
   Earth," January 1993).
20 Public Service Electric and Gas Company. Initial XL Proposal of Public Service Electric and Gas
(December 1995).
21 EPA "Environmental Accounting Case Studies: "Green Accounting at AT&T." (EPA 742-R-93-003,
September 1995).           '     •
                                                                                                   55

-------
 •  _   • ^
 Chapter 2 '*
   '    "--.
                            Recognizing that green accounting must involve a number of traditionally separate
                            perspectives and functions, AT&T management saw a multi-functional team approach
                            as the only viable planning option.  Over time, the initial nine-member team ex-
                            panded to include members representing supply line management, design engineer-
                            ing, process engineering, environmental engineering, cost accounting, and financial
                            policies nationwide and overseas. Team meetings took place every month, gradually
                            shifting to one meeting every 6 to 8 weeks.
                            Among the early challenges faced by the Green Accounting Team Were the issues of
                            terminology and language, and the need for a baseline.  For example, should green
                            accounting include both "private costs" (costs that impact a firm's bottom line) and
                            "societal costs" or externalities (the impacts of pollution on society and the environ-
                            ment)? The team recommended that AT&T define green accounting, for now, in terms
                            of private costs and also proceeded to develop a glossary for the many terms specific
                            to environmental  accounting.22  In  addition, the team felt that given the variability
                            within the company in treating overhead costs, AT&T must set a baseline of current
                            practices to help target opportunities.
                            The green accounting team also embraced AT&T's use of the principles of activity-
                            based costing (ABC) and activity-based management (ABM).  ABC is a method for
                            assigning relevant costs to products by identifying the resources consumed by activi-
                            ties performed for these products (e.g., a telephone, computer, etc.). But, since "track-
                            ing costs alone does not drive improvements," AT&T also uses ABM to determine the
                            "causes" or "drivers" of activities and their costs—placing the focus on such areas as
                            product or process design, supplier qualification, etc.
                            In order to develop baseline information, the team developed a self-assessment tool
                            that AT&T plants could use as an aid in establishing baselines and goals for improve-
                            ment.  The self-assessment tool includes a status survey to raise awareness of how
                            decisions are currently made, what  information is used,  and whether environmental
                            activities are reflected in product and process costing; and a green activities/resources
                            matrix, which requires the user to identify what information is important.
                            Three sites reviewed the self-assessment tool, providing feedback on its usefulness
                            and suggestions for further refinements. As of June 1995, the Green Accounting Team
                            had identified an ambitious agenda of future projects, including bringing environmen-
                            tal cost considerations into play for any future plant start-ups and divestitures, and
                            tying in with the Green Index, an AT&T software tool being developed to assist de-
                            signers in scoring the environmental attributes of a product,

                            Home Depot
                            Home Depot,23 one of the nation's largest home improvement retailers, helped pio-
                            neer the  first U.S. private sector program to partner  retailers, manufacturers, and
                            22 Few companies outside of the utility sector in North America have moved to incorporate externali-
                            ties into their accounting systems. •    ,           .   ,
                            23 Source for this section is Home Depot's Web page on the Internet at http://www.homedepot.com.
56

-------
 third-party environmental certification to promote continuous environmental improve-
 ment in consumer products.
 Home Depot's efforts go back a number of years. In 1991, Home Depot published its
 Environmental Principles, subsequently adopted by the National Retail Hardware As-
 sociation and Home Center Institute, representing over 46,000 U.S. retail hardware
 stores and home centers. The company started using recycled content materials for
 store and office supplies, advertising, signage, and shopping bags, and established an
 evaluation process for suppliers making environmental marketing claims on product
 labels. A year later, Home Depot discontinued sale of lead plumbing solder, and pub-
 lished its first version of Environmental Greenprinf, which pinpoints 88 ways to bring
 about a "greener", home in making home improvements. Home Depot also began a
 program to recycle gypsum wallboard shipping packaging, with the goal of eliminat-
 ing an additional 10 percent of all solid waste. The program became the first reverse
 distribution effort in the hardware industry, as material was returned to the store for
 return to the manufacturers.                                            '
 By 1993, Home Depot stores were featuring permanent banners on their front walls,
 pledging commitment to continually improve environmental performance, commu-
 nity involvement, and social responsibility. The first of many Recycling Depots was
 opened on a one-acre site next to the Duluth, Georgia store, integrating shopping with
 a drive-thru recycling center.  Another first was the  "Environmental Report Card,"
 which offered consumers a comprehensive disclosure of a product's environmental,
 impacts on its label, based on the findings of a "cradle-to-grave" life-cycle assess-
 ment of the product.                                          '
 In 1994, Home Depot became the first home center to offer both tropical and temper-
 ate region wood products from forests independently certified as "Well-Managed"
 under Scientific Certification System's Forest Conservation Program. Home Depot
 led the industry in the changeover of interior doors to simulated wood from tropical
 rainforest wood. The company also implemented a program to replace all wood ship-
 ping pallets with returnable and reusable  "slip sheets," with the goal of minimizing
 solid waste and reducing energy used in transportation and consumption of hardwood
 resources used to make wood pallets.
 Home Depot's environmental efforts  were recognized in March 1995 with the
 President's Sustainable Development Award, which noted that "by disseminating ac-
 curate consumer information through eco-labeling, the program has built support for
 more sustainable product design and production policies."

 Helping Small Businesses to  Undertake
Polluticm Prevention  Measures

The dynamics of preventing  pollution can be different for small business compared to
large businesses. With managers closer to day-to-day operations, pollution preven-
tion opportunities may be easier to identify in small businesses. On the other hand,
                                                                                                 57

-------
Ttoble 2-4. Technical Assistance and Business Development Programs

EPA's Small Business Ombudsman
, EPA's SmaU Business'ombudsman assists small businesses in complying with environmental regulations. Contact
! Karen V. Brown, 800^368-5888 with questions or concerns. The Small Business Ombudsman's Office also coor-
dinates a network of state small business ombudsmen.
NIST's Manufacturing Extension Partnership
The National Institute of Standards and Technology (NIST) established the Manufacturing Extension Partnership
! (MEP) to increase the global competitiveness of smaller manufacturers. For general information, contact MEP at
301-975-5020. (See Chapter 3, Other Federal Agencies).

; SBA's Small Business Development Centers
The U.S. Small Business Administration ,(SBA) supports 57 state and territorial Small Business Development
Center's (SBDCs), along with over 900 sub-centers, to provide management and technical assistance to small
businesses. EPA and'SBA are developing a coordinated offering of business development and pollution preven-
tion technical assistance services through five pilot SBDC projects (in Iowa, Texas, Vermont, Virginia, and Wis-
consin). To locate the nearest SBDC, contact the Association of Small Business Development Centers at 703-
448-6124. • ' ' . ' ... •_..'• ' , . '
State Tectinical.Assistance Programs
Every state has a small business assistance program which, at a minimum, aids small businesses impacted by air
quality regulations, as required by the Federal CAA. These programs are coordinated nationally from EPA's
offices in Research Triangle Park, North Carolina (919-541-0800). EPA also supports a broader role of state
technical assistance programs through the Pollution Prevention Incentives for States program mandated by the
Pollution Prevention Act. -
EPA's Small Business Compliance Assistance Centers
EPA recently established national Compliance Assistance Centers to provide "one-stop shopping" for information
about complying wifli environmental regulations. Each Compliance Assistance Center provides some or all of the
following services via the Internet and toll-free telephone: easy access to federal regulations, interpretations, and
guidance; compliance tools and process-specific training; information exchange through "chat rooms" and confer-
ences; and databases of technologies and pollution prevention ideas. Currently, there are four Compliance Assis-
tance Centers covering agriculture, metal finishing, printing, and the automotive service industry. Four more are
: on the way, in the areas of transportation, local governments, small chemical manufacturers, and printed wiring
board manufacturers.iThe existing centers can be reached at: printing — http://www.pneac.org; automotive—
1-888-GRN-LINK (476-5465). or http://www.ccar-greenlink.org; agriculture: http://www.es.inel.gov/oeca/ag/
: aghmpg-html; metal rinishing — 1-800-AT-NMFRC or http://www.nmfrc.org. For general information, contact
tER&iiS Office of Cpn^li^e at ^564-2280.;; ' '. 7*, 7: : v: ',;'.: . •'• '' ^ ,' ; ^X/," ''v/i;.
58

-------
very small businesses generally have few in-house technical resources and may have
financial challenges to overcome, such as small capital budgets and difficulty obtain-
ing credit.
Over the past several years, a patchwork of state and local government and not-for-
profit financial assistance programs, which target environmental compliance and/or
pollution prevention activities, primarily by small businesses, has-emerged (see Table
2-4).24 This proliferation seems to .indicate that financing is the primary challenge
small businesses face in implementing pollution prevention. A recent pilot project
carried out for EPA by the Maryland Department of the Environment, however, sug-.
gests that financing is only one of a number of factors that influence pollution pre-
vention decisions by small businesses.
The pilot project, which was designed to assess whether small businesses are able to
obtain credit for capital investments in pollution prevention, focused on 800 dry
cleaners, 77 of which were required to retrofit their machines or purchase new ones
in order to comply with a federal air toxics rule. The cost of the retrofit was esti-
mated in the rule at $6,300, but due to the sudden increase in demand, the cost
escalated to $15,000 within two months of publication of the rule.
Contrary to expectations, the banks contacted as part of the project were .interested in
potential revenue associated with purchase of the new equipment, and were not con-
cerned with environmental liabilities associated with the dry cleaning industry. De-
spite the small size of the loans, the banks were willing to make the loans as long as an
intermediary organization (in this case, Maryland's Small Business Development Cen-
ter [SBDC]) had analyzed the financial status of these businesses and could show that
each would be able to meet the loan payments. One of the project's conclusions,
.however^ was that merely having a financial assistance program available does not
ensure that it will be used. The Maryland companies that ultimately took advantage of
the assistance available did so only after an active outreach program identified and
encouraged them to pursue the opportunities.25
Some small businesses are successful in implementing pollution prevention measures,
saving money or building markets along the way. Here are five examples:
24 This is not an exhaustive list of technical assistance programs for small businesses. Readers -
interested in pursuing this are encouraged to refer to EPA's Pollution Prevention Directory, available
through the Pollution Prevention Information Clearinghouse at 202-260-1023.
i
23 For more information, contact Liz Taddeo, Maryland Department of the Environment, 410-631-
4119, or Ed Weiler, EPA, 202-260-2996. Two related reports are: (1) Perkins, S.P., T. Goldberg, and E.
Weiler. "Myths and Realities of P2 Financing," Pollution Prevention Review (VTI:2, Spring 1997) and
(2) Great Lakes Environmental Finance Center. An Inventory and Assessment of Pollution Control
and Prevention Financing Programs (Draft) (February 1997). Contact Ms. Ziona Austrian at 216-
687-3988.
59

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Ocean State Power (Burrillville, Rhode Island)
Ocean State Power was selected as a pilot project in EPA's Environmental Leadership
Program.26 This.facility, which employs 100 people, is a 500 megawatt, natural gas-
fired, combined cycle electric generation facility located in rural Burrillville, Rhode
Island. It was the first power plant in New England to use natural gas as its primary
fuel. The state-of-the-art facility was designed with pollution prevention in mind.
Ocean State Power has made significant progress on two waste reduction activities:
• Eliminating the oil Waste created from test firing. The plant performs test oil
firing on the turbines for 15 minutes each week. If ignition does not occur
within the programmed time, the unit automatically shuts down and the oil has
to be purged from the system to allow for a clean refiring. In the past, the
plant disposed of this oil as waste. It now recycles the oil back into the oil
tank for reuse.
• , |
• Reviewing a method to eliminate ammonia waste. The trucks that deliver
ammonia to the plant do not have a method to capture the liquid remaining in
the truck's hose after a delivery. Currently, several gallons of ammonia are
collected and disposed of as waste product. Ocean State Power is evaluating a
system to pump this product into the on-site ammonia tank, thus eliminating
the waste.

Ecoprint (Silver Spring, Maryland)
Ecoprint is a printer based in Silver'Spring, Maryland, with fewer than 10 employees.
Ecoprint's clientele includes associations, environmental groups, and nonprofit orga-
nizations from the greater Washington, DC area. The emphasis of their work is on
newsletters, other publications, brochures, and some short-run direct mail.27 Ecoprint
has become recognized by its industry colleagues and others as a leader in environ-
mentally responsible printing. Going beyond compliance with environmental laws,
Ecoprint has spent years doing research with ink manufacturers and paper mills to
produce new products and processes that create a higher standard of environmental
excellence. Some of its pollution prevention achievements include the following:
' • Developed sheetfed offset printing inks based on non-heavy metal pigments.
New non-heavy metal inks, developed by Alden & Ott Inks, were formulated
from a soybean oil, non-petroleum base. This was done through a 1992
$25,000 EPA pollution prevention grant.

• Worked with Cross Pointe Paper Company to test a chlorine-free sheet
combined with 20 percent post-consumer waste content. The new sheet was so
successful that Cross Pointe invested the resources to make it a new product
line.
26 For more information on the Environmental Leadership Program, see Chapter 1 of this report.
27 Ecoprint. Environmental Initiatives Fact Sheet.
60

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• Eliminated alcohol and alcohol substitutes in press wetting agents. A com- -
pound based on non-toxic citric acid and gum arabic is now used in place of
the alcohol.

Frost Paint and Oil (Minneapolis, Minnesota)
Frost Paint and Oil, which employs 35 people, is a manufacturer of industrial paints
and linseed oil-based varnishes.28 A few years ago, Frost Paint and Oil reviewed its
waste streams, including paint sludge, varnish oil sludge, process water, and non-
hazardous solid waste, and established a goal of reducing them 10 to 15 percent a
year for 3 to 5 years. This goal was set in accordance with the Minnesota 50 Project,
a voluntary pollution prevention program modelled after EPA's 33/50 Program that
Frost Paint and Oil had joined. After evaluating a number of options for reducing
waste, the company decided that the quickest and least expensive way to reduce
waste generation was to implement an employee incentive program. The employees
were motivated by the promise that two-thirds of any resulting savings would be
passed on to them. As a result of the employee incentive program, Frost Paint and Oil
reached its Minnesota 50 Project goal in one year. The innovative approach reduced
hazardous waste by 55 percent and saved the company $25,000 in 1992. In 1993, the
employee incentive program resulted in a further reduction in hazardous waste genera-
tion of 22 percent. During these years of dramatic waste reduction, Frost Paint and
Oil's production rate remained fairly constant.
'' . I
Nachi Technology, Inc. (Greenwood, Indiana)
Nachi Technology employs 80 people in manufacturing precision ball bearings for
the automotive industry.29 To prepare the bearings for further processing, they must be
cleaned to remove any contaminants. Nachi replaced its 1,1,1-trichloroethane-based
cleaning system with machines that use centrifugal force to remove the contaminants;
this project was not merely a solvent substitution, but a solvent elimination. The me-
chanical cleaning machines eliminated 1,1,1-trichloroethane from this and all other
manufacturing processes, which will benefit Nachi employees and the environment for
years to come. Nachi Technology received two Indianan Governor's Awards in 1996:
one pollution prevention award for the solvent elimination and one recycling award
for reducing and reusing packaging materials.

Genencor (Rochester, New York)
Genencor is a company with 1,200 employees that supplies enzymes and other
biochemicals to industries. Genencor developed an environmentally friendly pro-
28 Most of the activity in this waste reduction program was undertaken a few years ago. The company
has since acquired another small paint company and has been renamed "Davis Frost." In total, the new
company has slightly less than 100 employees. •
29 State of Indiana List of 1996 Governor's Awards for Excellence in Pollution Prevention. Indiana
Department of Environmental Management, 317-232-8603.
, 61

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  Chapter.
  •
                            cess for manufacturing indigo dye, which is used to color blue jeans among other
                            things, using biotechnology.  Genencor's process uses an intergeneric microorgan-
                            ism, glucose, and other microbial nutrients instead of hazardous reagents like aniline,
                            formaldehyde, and hydrocyanic acid.  Eliminating the use of such hazardous chemi-
                            cal feedstocks reduces exposures, releases, and risks traditionally associated with the
                            manufacturing process. Genencor was recognized by OPPT's New Chemicals Pollu-
                            tion  Prevention Recognition Project for this innovative work.30

                            Encouraging Industry-wide Initiatives
                                                                                                i
                            A positive step forward in encouraging industry initiatives in recent years has been
                            the development of industry-wide pollution prevention programs by professional and
                            trade associations.  Such programs institutionalize the ethic of pollution prevention,
                            disseminate information on an ongoing basis,  and  help spur individual company
                            members on to more active and effective pollution prevention programs.  This sec-
                            tion  highlights several such initiatives.
                            In recognition of the expanding role of trade associations in helping industries in meet-
                            ing environmental goals, EPA has sponsored the Pollution Prevention Trade Associa-
                            tion  Workgroup to bring together representatives from disparate industries. The
                            workgroup develops tools to help trade associations promote pollution prevention in
                            their member industries, facilitates communication and information sharing between
                            EPA and trade associations, and showcases successful pollution prevention case stud-
                            ies with broad applicability.31
                            Another organization with a similar mission, the American Institute for Pollution Pre-
                            vention (AIPP), is a non-profit organization of professional and trade associations that
                            facilitates effective communication and promotes emerging pollution prevention ini-
                            tiatives, opportunities, and practices.32  The Business Roundtable's Industrial Pollu-
                            tion Prevention Council also seeks projects to champion preventive approaches.
                            Several industries have started their own umbrella pollution prevention organiza-
                            tions. STEP, or Strategies for Today's Environmental Partnership, was created by  the
                            American Petroleunxlnstitute in 1990 as a structure for measuring and reporting cor-
                            porate progress in the areas of environment, health, and safety.33
                            The Chemical Manufacturers Association (CMA) sponsors the Responsible Care
                            program, which assists member companies in  achieving a Code of Management
                            Practices.  Companies report implementation progress to CMA annually,  in ad-
                            30 For more information about OPPT's New Chemicals Pollution Prevention Recognition Project,
                            contact Ken Moss (202-260-3395) or Roy Seidenstein (202-260-2252) of EPA/OPPT.
                            31 For more information on the Pollution Prevention Trade Association Workgroup, contact Leah
                            Yasenchak, EPA, at 202-260-7854.
                           •32 Aipp internet site (http://www.es.inel.gov/aipp/)
                            33 STEP Internet site (http://www.api.org/step/ovintro.html)
62

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dition to conducting regular regional meetings among senior industry represen-
tatives to exchange information.34
CMA member companies must make continuous good-faith efforts to attain the goals
of the various codes: .
1. The Pollution Prevention Code commits industry to the safe management
and reduction of wastes.

2. The Community Awareness and Emergency Response Code promotes
emergency response planning and encourages dialogue with plant com-
munities.

3. The Distribution Code focuses on employee and public risks from the
shipment of chemicals, and applies to the transportation, storage, handling,
transfer and repackaging of chemicals in transit.

4. The Product Stewardship Code manages chemicals from initial research
through recycling and disposal.

5. The Employee Health and Safety Code protects employees and visitors at
plant sites. . "

6. The Process Safety Code is designed to prevent incidents and accidental
chemical releases at plant sites.35

Northeast Business Environmental Network
Established in 1994, the Northeast Business Environmental Network (NBEN) is an
example of companies creating their own self-help network to promote pollution pre-
vention among the businesses of their local communities. NBEN's members range
from large companies such as Raytheon and Gillette to small "mom and pop" print
shops and jewelers. Each company joining the network makes an explicit, long-term
commitment to seek and implement solutions that promote pollution prevention within
their own business communities. The network is self-supporting through the dues of
its members and holds monthly meetings. .
NBEN grew out of the Merrimack Project, a demonstration project developed under
EPA's Industrial Pollution Prevention Project. Its function is to provide a forum in
which members can communicate with government and environmental advocates, as
well as share pollution prevention information. NBEN currently has 53 members
and is sponsoring workshops oh watershed tools as well as Best Management Prac-
tices, on the Internet.
34 CMA Internet site (http://es.inel.gov/program/regional/trade/cnia-rprt.htnil)
-3S CMA Responsible Care Homepage (http://www.cmahq.com/rescare.html)
63

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                            American Textile Manufacturers Institute
                            The American Textile Manufacturers Institute (ATMI) is a national trade association
                            for the domestic textile industry.  Member companies process approximately 80 per-
                            cent of all textile fibers consumed by mills in the United States.  ATMI launched the
                            Encouraging Environmental Excellence (E3) program in March 1992 to demon-
                            strate an industry-wide commitment to environmental preservation and strategies for
                            new environmentally friendly manufacturing processes and products.  E3, a volun-
                            tary program, calls for textile companies to adopt a 10-point plan, which includes a
                            corporate environmental policy statement, a detailed audit of facilities, an outreach
                            program to suppliers and customers that encourages pollution prevention, recycling,
                            establishment of corporate environmental goals, and the development of employee
                            education and community awareness programs. Specifically, the program calls on
                            companies to establish annual pollution prevention goals and target dates  for air,
                            water, solid waste, and energy.  Each company must report annually on its successes
                            and failures in achieving its goals.36 ATMI was recognized in 1996 for its efforts
                            to promote  the WasteWi$e program  and encourage waste reduction among its
                            membership.
                            In 1994, several companies participating in the E3 program recorded accomplishments
                            in achieving their pollution prevention goals. For instance, Burlington's Denim Divi-
                            sion made some changes in the dyeing and finishing chemicals it uses (i.e., elimination
                            of free sulfurs in dyeing, reduction of indigo and dye with a sulfur odor). Other manu-
                            facturers .developed new environmental product lines, such as Avondale Mills and
                            Doran Textiles, which are offering organically grown, naturally colored cotton spe-
                            cialty apparel lines.37
                                                                                                      •~\
                            Great Printers Project
                            In 1992, EPA received a request for assistance in evaluating product environmental
                            claims from the Printing Industries of America (PIA). Through the involvement of
                            EPA's Design for Environment (DfE) Program, two pollution prevention projects
                            evolved. Each project was directed towards a different aspect of the printing industry:
                            the screen printing sector and the lithography sector. The Screenprinting and Graphic
                            Imaging Association played an important role in the development of the DfE Screen
                            Printing Project.38
                            In August 1993, a cooperative effort called the Great Printers Project was launched
                            to make pollution prevention a standard business practice in the entire printing in-
                            36 American Textiles Manufacturers Institute. America's Textiles: Encouraging Environmental
                            Excellence.
                            37 American Textiles Manufacturers Institute. ATMI speech at the Green Business Conference (April 7,
                            1995).
                           .3S EPA. "Enviro$en$e DfE Fact Sheet: Screen Printing Project on Designing Solutions for Screen
                            Printers" '(EPA 744-F-95-003, March 1995).
64

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dustry. The project is a partnership of the PIA, the Environmental Defense Fund
(EDF), and the Council of Great Lakes Governors. A project team of Great Lakes
regulatory agencies, EPA, printers, print buyers, printing industry suppliers, techni-
cal assistance providers, environmentalists, and labor are implementing recommen-
dations-to 'prevent pollution and waste from solvents used in cleaning, waste ink, and
photoprocessing materials, while enhancing industry growth.39 For example, in 1995,
. with funding from EPA, the Great Printers Project launched the Printers National Envi-
ronmental Assistance Center in 1995 as a small business compliance assistance center.

Reaching Suppliers and Customers

One way to reach out to customers is by enacting a product stewardship program. The
term "product stewardship" refers to practices where manufacturers essentially be-
come stewards of industrial products by retaining responsibility for their products un-
til those products reach the end of their life or are reused. Product stewardship prac-
tices are increasingly common in industry for a number of reasons, not the least of
which is minimizing environmental liability. Key to the development of product stew-
ardship programs is the realization that suppliers and customers are integral links .in
the life cycle environmental impacts of a company's products.
In this section, we provide some successful examples of companies that have worked
with their suppliers and customers in preventing pollution.

Digital Electronics
In recent years, the computer industry has'developed a reuse and recycling program
worthy of mention for its originality in coupling a unique customer service with
pollution prevention. As an example of a firm which practices this recycling ser-
vice, consider Digital Electronics. Digital's "Computer Asset Recovery Services" is a
prime example of a corporation extending the life cycle of a product. Because of the
fast-paced innovation in computer technology today,, computer-users tend to replace
their equipment frequently. This used to mean that they threw away their computers
frequently. Today, Digital's commercial customers can return their used computers to
Digital, which assumes "ownership" of the aging or obsolete computer, equipment,
meaning that it accepts liability for the material under the Resource Conservation
and Recovery Act (RCRA).. RCRA stipulates that if a discarded material causes
problems in a landfill and the ownership can be traced, then the owner of the waste is
responsible for the problem and its consequential cleanup. .By assuming ownership,
Digital Electronics assists its customers hi preventing the disposal of hazardous com-
puter materials.40
39 EPA, "Great Printers Project Announced," Pollution Prevention News (September/October1993).
*" Norm Alstar. "Old PCS Are 'Liability Scrap', But Digital Sees Opportunity," Investor's Business
Daily (November 6, 1995).
65

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 Chapter ilT-5
           ':"h""

                            Once the older equipment is in Digital's hands, the company attempts to sell second-
                            hand any computers or computer parts that are in decent working order.  The com-
                            puter equipment left over from this process are "demanufactured" — the pieces
                            are broken down into the most basic elements (mercury,  gold, steel, aluminum,
                            glass, and plastic) and then recycled.  The remaining  waste, totaling approxi-
                            mately one-half of one percent of the original,  is properly disposed of in a land-
                            fill.  Digital Electronics shares the profits from the selling and recycling pro-
                            cesses with clients, creating a "win-win" arrangement for both parties,  as well as
                            reducing the toxic load on the environment.41

                            Walt Disney Company
                            Purchasing agents at the Walt Disney Company have gone on record with vendors and
                            suppliers that the company "insists whenever possible" upon purchasing products
                            and services that are environmentally appropriate. This policy has manifested itself
                            in everything from the purchasing of bulk food products to printing millions of bro-
                            chures, pamphlets,  maps, and other documents  on recycled paper.  The company
                            believes that in some cases it has actually driven the market, not only towards the use
                            of recycled material, but also towards packaging and product minimization. One
                            outgrowth  of Disney's environmental purchasing policy is the replacement of Laiian
                            plywood, a product derived from tropical rainforests, with a product made from waste
                            wood. The Walt Disney Company was recognized in 1996 by the WasteWi$e Program
                            for its Comprehensive Waste Reduction Program.
                           .Because Disney is a leader in the entertainment field aimed at young people, it has a
                            unique opportunity to foster an environmental conscience in its young customers. For
                            example, the Walt Disney Studio works with the Environmental Media Association in
                            an effort to include environmental messages in  film and television programming.
                            These messages have appeared in episodes of the Golden Girls, public service  an-
                            nouncements entitled Disney's Magical Moments, Medicine Man, the award winning
                            This Island Earth, Dinosaurs, and, more recently, Disney presents Bill Nye the Sci-
                            ence Guy.
                            Other environmental education projects managed by the Walt Disney Company in-
                            clude the following:
                                                             1                              .   J
                            •  Developing, together with several participating agencies and organizations,  a
                               community  program to introduce urban youth, ranging in age from 8 to 12, to
                               a neighborhood camping experience. The program will kick off at City of Los
                               Angeles parks and will include programs in  wildlife observation, environmen-
                               tal resources, community service, and introductory camping.
                            41  Digital Equipment Corporation. "GSA Selects Digital for the Environmentally Safe Disposal of
                            Government Equipment," Digital Press and Analysts News (July 12, 1996).
66

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• Jimmy Cricket's Environmentality Challenge Program. This cooperative
learning venture promotes environmental education to all fifth grade classes in
California public schools. The challenge recognizes and honors those students
and teachers who demonstrate the leadership, creativity, and dedication needed
to promote thinking and acting environmentally.42

Donlar Corporation
Donlar Corporation has developed a product that embraces the product stewardship
ideal. The company manufactures thermal polyaspartate (TEA), a biodegradable al-
ternative to the polymer polyacrylic acid (PAC). Two manufacturing processes are
used to make TEA. The first process, a two-step system, is 97 percent efficient and
produces condensated water as its only waste stream. The second method uses a
recoverable catalyst, which minimizes the amount of created waste. These manufac-
turing processes are excellent examples of pollution prevention in industrial design.
TEA's end uses exemplify the concept of product stewardship. In the agricultural
sector, it improves fertilizer management by increasing plant nutrient uptake, yet
does not place an additional burden on the ecology of the land. It can also be used as
an alternative to PAC in the water treatment industry as well as the oil and gas
production industry, due to its scale and corrosion-inhibiting properties.
The designers of this polymer integrated pollution prevention into every aspect of
their product, and were duly rewarded with the Presidential Green Chemistry Chal-
lenge Award.'43

Making the Most of Community
Involvement

Sue Hall of Strategic Environmental Associates has argued that market restructuring
offers businesses a rather stark choice:
They can choose to deny the reality and continue with business as usual,
rather than innovating to create more sustainable products and services. •
In this case, their businesses will continue to cause environmental prob-
lems, fueling the market restructuring and ultimately creating a down-
ward competitive spiral for the company. Or, a company can decide to
learn from others ... in order to create more sustainable products for its
core businesses.44
42 The Walt Disney Company. "The Walt Disney Company Environmentally Significant Activities".
4J EPA. The Presidential Green Chemistry Challenge Awards Program: Summary of 1996 Award
Entries and Recipients. (EPA744-K-96-001, July 1996.) pp.5-6.
44 Sue Hall. "Sustainable Partnerships" In Context: Business on a Small Planet (No. 41, Summer
1995). -
67

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  Chapte

                            The following are examples of companies that are working with and learning from
                            their communities and stakeholders.
                            Church & Dwight
                                                                                               i
                            Church & Dwight is one example of a company that has gained considerable market
                            share by working with its environmentally-conscious stakeholders. Church & Dwight
                            is the maker of Arm.& Hammer baking soda.  Church & Dwight's  interest was
                            piqued when members of Canadian environmental groups asked the company why it
                            was not educating consumers about baking soda's use as an alternative, non-toxic
                            cleaner.  Three years later, baking soda sales had risen 30 percent, in an industry in
                            which sales had been stagnant for decades. After this experience, Church & Dwight
                            began to deepen relationships with stakeholders — including environmental groups,
                            educators, the media, and regulators. The company patented a new product line of
                            industrial cleaners following suggestions from stakeholders that Church & Dwight
                            investigate baking soda as a replacement for the toxic solvents used to clean printed
                            circuit boards. An analysis of the usefulness of the  stakeholder approach from a
                            financial perspective found that the company's stakeholder process added $10  to the
                            top line for every dollar invested in it — as opposed to $4 for a traditional marketing
                            program.45

                            Ciba-Geigy (San Gabriel, Louisiana)
                            The Ciba-Geigy San Gabriel plant is a highly automated chemical process complex
                            operated by Ciba's Crop Protection Division. The continuous herbicide production
                            process at San Gabriel produces more herbicides than any other manufacturing plant
                            in the United States. In addition, the Textile Products  Division operates a multipur-
                            pose dyestuffs facility on the site. This facility has developed an extensive community
                            and employee outreach program.  For eight years, the facility has conducted a survey
                            of East Iberville Parish residents asking general and specific questions on local prob-
                            lems, pollution, employment, emergency response, education, public perception, etc.
                            The facility also has developed a series of community outreach programs—a Citizen's
                            Advisory Panel, a community newsletter, an Odor Response Program, and a Summer
                            Teachers Program. A Ciba Ambassadors Program addresses employees' environmen-
                            tal concerns, and trains and encourages employees to answer questions on environ-
                            mental issues, including pollution prevention and waste management.
                            The San Gabriel plant is conducting a pilot project under EPA's, Environmental Lead-
                            ership Program in which it will evaluate its community involvement program and
                            identify the program elements other companies may include in their environmental
                            education and outreach programs to build trusting relationships.   .
                            45 Ibid.
68

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Selling Environmentally-Preferafole Products

Years ago, product labels rarely provided more information than the brand name of
the product. Today, grocery store customers walk down aisles turning product pack-
ages upside-down looking for nutritional information. Increasingly, these customers
will be doing the same looking for information on a product's environment impacts —
ranging from toxic chemical effects on health to energy use to recycling and
disposal.'*6 '
The question of what makes a product "greener" or environmentally more preferable
to another is a source of much debate and legitimate confusion. Some pollution
prevention practitioners have found that the complicated practice of life cycle assess-
ment can highlight environmental tradeoffs associated with products. Life cycle
assessment is a technique for assessing the various environmental impacts associated
with a product. The assessment involves taking an inventory of environmental ef-
fects during the various stages of a product's "life cycle" — from use of raw materials
such as energy, minerals, or .water, to packaging to waste management — and then
assessing the impacts of these inventoried effects. Whether life cycle assessment can
be developed to the point.that it can serve as a practical guide to determining the
overall environmental preferability of products is as yet unclear. In the meantime,
two independent organizations, Green Seal and Scientific Certification Systems, have
built businesses judging environmental attributes of products and allowing those
judgements to be displayed on product labels.
While debate continues over what makes a product "green", it seems that an increas-
ing number of consumers are taking environmental considerations into account when
they shop. A recent survey found that the environmental record of a company ranks
as an important factor in brand choice for 14 percent of American consumers, behind
brand loyalty, price, quality reputation, and how well the product is advertised.47
One industry analyst interprets these findings to indicate that environmental benefits
represent second-tier purchase criteria, which can break ties in purchase decisions
when brands are at price/quality parity.48 Increasingly, it appears, companies are
responding to this market force. The following are several examples of this trend:

The Henkel Company
The Henkel Company is one of Europe's largest chemicals and detergents compa-
nies. In the late 1970s, Henkel began to notice a rising concern in West Germany
surrounding the potential impact of phosphates in detergents on rivers and streams.
46 See Chapters One and Three of this report for a discussion of how federal consumers are applying
their purchasing power to create a demand for products and services that have a reduced impact on the
environment. • .
47 Roper-Starch survey.
48 Personal conversation with Frank Consoli, President and Founder of the Consoli Consulting
Company and a leader in the field of life cycle assessment, March 1996.
69

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At the time, Henkel manufactured 50 percent of the country's phosphates and sold 49
percent of its phosphate-based detergents. Instead of attempting to downplay the
problem, Henkel decided to invest in finding a substitute for phosphates. The
company's search for a substitute was successful; it patented zeolite and became
the first consumer products company to introduce phosphate-free detergents in
Europe, entirely replacing all its old product lines. As a result, the company in-
creased its market share from 16 percent to 23 percent for its top brand in Germany
and strengthened its foothold in the French market, gaining a 6 percent share for its
new phosphate-free brand.49

• •. • '
Wellman, Inc.
Wellman, Inc., one of the largest plastics recycling companies in the world, was able to
gear its services towards the future by creating a market for PET, a recyclable plastic.
Initially, the company teamed up with bottle producers, such as CocaCola and Pepsi
Co. (Pepsi Cola Bottling Company), to provide recycling for the plastics they had
been accumulating from Bottle Bill states.50 By tapping into this demand for recy-
cling, Wellman sustained a 40 percent growth rate and, a 21 percent return oh equity
over a 6-year period. Once Wellman's recycling competitors began to vie for a share
of this market, Wellman again thought ahead and expanded the business to include an
outlet for the recycled PET plastic: the synthetic fiber industry. This action not only
opened up a wider customer base for Wellman, but also allowed consumers the choice
of buying products containing recycled plastic.

Miles, Inc.
The Miles, Inc. company, based in Pittsburgh, Pennsylvania, has developed a polyure-
thane paint that allows repainting of bridges and other steel structures without the
need for hazardous abrasive blasting operations to remove toxic lead-based paint.
The benefits of this new paint include reduced occupational exposure to lead, less
environmental contamination, and less generation of hazardous waste. In addition,
with less surface preparation required, companies that repaint bridges considerably
reduce costs. This innovation also gave Miles a unique competitive advantage in
projects involving state highway departments and their contractors at a time when
regulations affecting bridge repainting were on the horizon.51
49 Sue Hall, "Sustainable Partnership." In Context: Business on a Small Planet (No. 41, Summer
1995). . . • .
50 The Bottle Bill requires states that pass this legislation to have beverage vendors be responsible for
their containers, once the consumer turns the container in for a rebate.
51 Young, Ambrose, and Lobo, Stirring Up Innovation: Environmental Improvements in Paints and
. Adhesives (INFORM, New York, NY, 1994).
70

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Innovative Ideas

To conclude this chapter, we present a list of innovative ideas that industry has devel-
oped in recent years to promote pollution prevention. The usual disclaimers apply
—- not all of these ideas will storm the marketplace, some may already be obsolete,
and EPA does not endorse any commercial products. But the range of possibilities
and achievements cited here in terms of new and cleaner processes, products, and
technologies is worthy of note.

Conserving Water by Changing Services
Developed by: Harrah's Hotel and Casino, Las Vegas, NV
The idea: Allow customers who stay more than one night to decide whether or not they
want their sheets changed daily. Previously, it had been the hotel's standard operat-
ing procedure to change and wash 1800 sets of sheets every day, assuming that cus-
tomers wanted this service. The energy management team developed a flyer which
stated the hotel's environmental policy and notified guests that if they still wanted
their linens changed daily, they should call and request it. In response; the majority
of guests opted not to have their linens changed daily. This change in hotel policy
saved the hotel $70,000 in energy and water costs the first year, as well as reducing
the pollutant loading at the wastewater treatment plant and increasing the longevity
of the sheets.52

Cost Reduction through Solvent Substitution
Developed by: Martin Marietta VAstronautics Group, Denver, CO
The idea: Phase,-out the use of two chlorinated solvents and a toxic chemical used in
hand-cleaning operations. The group first substituted Daraclean 282 for 1,1,1-
trichloroethane, which was used for rocket component degreasing. After incurring
$270,000 in up-front costs, the company saved $600,000 annually. Additional bo-
nuses are the increased cleaning ability and the recyclable characteristic of the new
solvent. The next solvent to be eliminated was CFC-113, which was used to clean
spacecraft components. The replacement was an alcohol-based spray that saved the
company $325,000 a year, with a payback period of 4 years (the start-up costs were
$1.3 million). The last solvent changed was a toxic chemical used to clean alumi-
num before adhesive bonding occurred. The switch to a citrus-based solvent saved the
company $250,000 annually, reduced toxic emissions by thousands of pounds, and'
improved worker satisfaction — it smelled more pleasant and worked better than the
old solvent.53
52 Romm, Joseph J. Lean and Clean Management. (Kodansha International. New York, NY, 1994).

33 Ibid.
.71

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 "• • -	
                            The Cascade Approach for Water Conservation
                            Developed by: Buckeye Cellulose Corporation, Flint River Plant, MI
                            The idea: Use a cascade approach for water, in which it is routed "through processes
                            requiring the purest water to those requiring  successively less pure water."  This
                            process change reduced the plant's demand on the municipality's water resources
                            and reduced the amount of wastewater requiring treatment. The company also al-
                            tered their method  for transporting reject wood scraps. Instead of using  water to
                            transport the wood scraps to a press and ultimately landf illing the waste, there is now
                            a closed-loop system for refining and recycling the rejects.   This process change
                            reduces the amount of wood being landfilled and reduces the biological oxygen de-
                            mand (BOD) in the water used for transport. Previously, water used to transport wood
                            rejects incurred a high BOD from microbial activity from the wood itself. The BOD
                            loading in the water made the water increasingly difficult to treat at the wastewater
                            treatment facility. With a closed-loop system, Buckeye was able to reduce BOD in
                            their wastewater to one of the lowest levels in the industry.54
                                                                                               i
                            Environmental Reengineering in the Citrus Industry
                            Developed by: Regal Fruit Co-op, Tonasket, WA
                            The idea: Examine the energy use of its fruit storerooms, which store produce at 31°
                            to 32° F in an almost pure nitrogen environment, with fans  running continually.
                            Upon further investigation, it was discovered that the cooling system was counteract-
                            ing heat produced by the fans. By installing a computer-controlled monitoring system,
                            the fans would run 75 percent less and create much less heat—realizing a total energy
                            savings of more than $17,000 annually.  The company also realized further energy
                            savings by reducing the amount of oxygen in the storeroom. Increasing the nitrogen
                            level allowed for increased storage temperature (and consequently less load on  the
                            cooling system) as well as better quality fruit, which increased the profitability of the
                            company.55
                            From Bigger to Smaller in Hazardous Waste Generation
                            Developed by: Echo Bay/Cove Mine
                            The idea: Reduce use of halogenated solvents by identifying solvents that were not
                            considered to be Toxicity Characteristic (TC) chemicals and develop a filtration sys-
                            tem to recycle the new solvent. The company screened all potential solvents to deter-
                            mine those that would give an acceptable level of cleaning for parts washing, had a
                            flash point above 140°F, did not have a RCRA hazardous waste code, would not oxi-
                            dize parts, were not costly, could be filtered onsite, were easy to handle, and did not
                            contain halogenated or EPA TC constituents.  Although the replacement solvent was
                            34 Ibid.
                            55 Ibid.
72

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more expensive than the halogenated one, costs were not prohibitive for the company
because the new solvent could be recycled. A filter system based on a high-flow
pump, stainless steel screens, and a paper filter was used and had the additional
advantage of also absorbing and reducing the heavy oils in the used solvent. This
new system required an initial investment of $11,400, but the return on investment
was 154 percent with a payback period of less than 18 months. Most of the annual
savings of $9,300 was in the form of reduced solvent costs. This system not only
reduced the toxicity of the waste but also permitted Echo Bay/Cove Mine to change
its status from Large Quantity Generator to a Conditionally Exempt Small Quan-
tity Generator with reduced regulatory requirements and environmental liability for
a cost savings of $16,000 per year because of fewer training needs.56

Newspaper Recycling of Waste Ink
Developed by: The Hartford Courant
The idea: Purchase an ink recycling unit in order to eliminate the generation of
hazardous waste inks and reuse the recycled ink in lithographic printing operations.
The waste ink is collected in a storage tank, then run through the recycling unit to
produce a reusable black ink. The recycling unit uses a vacuum distillation, filtration,
and blending process. The reusable black ink is mixed with virgin ink to the desired
property. The solvent present in the waste ink is recycled and, therefore, only water
and paper-dust paste are present in the recycling wastestream, which is no longer con-
sidered to be hazardous because the heavy metals and solvents are no longer present.
The company moved from having a 12,000 Ibs/year hazardous wastestream to a 1,500
Ibs/year nonhazardous wastestream.57

New Soldering Process for Circuit Boards
Developed by: Motorola Government Systems and Technology Group
The idea: Eliminate the use of chemical rinses containing ozone-depleting substances
when preparing metals for soldering. Working with the Department of Energy, Motorola
developed a soldering process that eliminated the need for chemical rinses after the
use of a chemical flux to remove oxides from the metal surface. The new process
replaces the flux with a mixture of adipic acid, a nontoxic organic acid, in isopropyl
alcohol. The mixture is sprayed onto .the circuit boards that are passed through an
inert gas section of a wave soldering machine. This prevents oxide formation during
the heating of the board to soldering temperatures. When the board then passes onto
the liquid wave of solder metal, the adipic acid acts as a scavenger for the oxides. The
only waste products of the system are carbon dioxide and water .vapor. No farther
cleaning of the boards is required as no corrosive residues are formed. This process
"Remarkably, our
scientific team
found a way to
dissolve high
performance
vegetable oil based
ink with a simple
water solution.
Now water and oil
do mix."
— TomRifkin,
Deluxe Corporation
56 EPA. Pollution Prevention Success Stories (EPA/742/96/002, April 1996).
"Ibid.
58 Ibid.
73

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has eliminated the previous use of 48 tons of chlorofluorocarbons and trichloromethane
per year. Although the new machines require a significant capital investment, con-
ventional wave solder machines can be retrofitted at a much reduced cost.58
t '
UV Coating to Cure Cans
Developed by: Coors Brewing Company
The idea: An alternative to current methods of decorating the 100 billion aluminum
cans produced annually, which does not result in VOC emissions. The technology.
uses UV light to cure the decorative image on the exterior of aluminum beverage cans,
rather than curing the cans in a gas-fired oven. Separate UV "fountains" supply the ink
to rollers, which coat individual plates. The plates, one for each color used, are raised
positive images of the graphic design to be printed on the cans. Clean cans are fed into
the printer and placed on a rotating steel mandrel; in rotating the can body against the
rotating blanket, the graphic image is transferred to the can. The cans are trans-
ported to the UV oven for curing with UV light. Overall energy costs are. signifi-
cantly lower for the UV curing than for conventional thermal technology if air emis-
sion controls are factored in, and fewer VOCs are emitted.59
: ,!

Printwise™
Developed by: Deluxe Corporation, St. Paul, MN
The idea: A system that eliminates petroleum-based solvents and their related VOCs
from the lithographic printing process. These solvents, generally consisting of 100
percent VOCs, have traditionally been used to clean ink from press components.
The resulting "press washes" are considered by EPA to be a significant source of
VOC emissions. The Printwise™ ink is 100 percent vegetable oil-based and matches
or exceeds conventional inks in press and printing performance. Most important, the
ink includes a solubility conversion mechanism that enables it to be cleaned with a
simple, VOC-free water solution, beluxe's breakthrough resulted when corporate sci-
entist Tom Pennaz began regarding lithography as a system in which ink and solvents
act as interdependent, not independent, elements. Pennaz developed a solubility con-
version mechanism that he incorporated into traditional ink formulations. Acting as a
"key," the solubility mechanism locks the oil-based Deluxe ink during printing but can
be unlocked and converted to a water-soluble state during cleanup. As a result,
although the Deluxe ink remains truly lithographic, it requires a water-based, VOC-
free solution for cleanup.60
74
39 EPA. Pollution Prevention News (May-June 1995). Featured in U.S. Department of Energy's
• Innovative Concepts Fair, April 1995.
' • • !
60 EPA, Pollution Prevention News (June-July 1994).

-------
Conclusions

Six years ago, pollution prevention in industry was the province of a handful of
leaders and visionaries, mostly in a few large corporations. That vision has spread to
a much larger universe of firms across a wide range of industries. EPA's early volun-
tary .industry programs, 33/50 and Green Lights, were instrumental in setting up a
framework for companies to act positively and cooperatively with EPA in undertak-
ing pollution prevention measures.
Companies appear to be motivated to adopt pollution prevention innovations by a
combination of factors. Some are attracted by perceived economic benefits, either in
the form of cost savings or increased market share. Some respond to the threat of
government regulation, still others to the willingness of regulators to be flexible. Some
companies are motivated by customer demand for "green" products; others by pubh'c
attention to their polluting practices. Thus, both the carrot and the stick seem to be
effective for different companies. And just as responses to incentives differ, so do the
ways in which different businesses undertake pollution prevention measures. .This
chapter has offered a glimpse of the manifold innovations and opportunities open to
industry in pollution prevention.
Among the challenges that lie ahead, three in particular stand out: achieving a more
widespread use of environmental accounting to ensure that corporate management is
fully aware of the costs of pollution and waste; disseminating information and techni-
cal assistance to small and medium-sized firms in order to increase their participation
in pollution prevention; and harnessing purchasing power of consumers to drive the
• market towards environmentally-preferable products.
75

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Comments on the Current and Future State of
Pollution Prevention

by
Edwin L. Mongan
Manager, Pollution Prevention Programs
DuPont Safety, Health and Environment
Wilmington, Delaware

Mr. Mongan is also the Chair of the Business Roundtable's Industrial Pollution Prevention Council.

As we review environmental progress during the past decade, industry can look back with satisfaction on its
accomplishments in reducing waste and emissions. Through practice of pollution prevention, companies have-;
enhanced their relationships with local communities, improved their products for their customers, and made real i
environmental improvements. Significantly, many companies have done all of this while improving their bottom i
line business results. The positive results achieved so far are a good beginning, but much more remains to be done
by industry in order to approach the full potential for combined business and environmental improvements. DuPont .
Chairman, Ed Woolard stated, "Our most difficult challenge continues to be eliminating waste at the source. This i
area also represents our biggest opportunity for business improvement since every pound of waste represents a :
pound of ingredient that has not ended up as a high-value product even though it should."
The most significant change that has occurred in industry since the Pollution Prevention Act was adopted in 1990
is not a new system or new technology, but rather a change in attitude. There is a rapidly growing realization by ;
companies that they can no longer afford to view the environment and business as two different topics, let alone ;
two competing topics. Thousands of large and small companies are establishing demanding waste and emissions ;1
reduction goals, enlisting in voluntary programs, and publicly reporting their progress. Once they commit to a
goal, company leaders are challenging employees to meet and exceed their public commitment in a way that saves
both money and valuable resources. Numerous success stories have been published .by the States, the EPA, and
private organizations. They describe hundreds of innovative solutions to difficult waste problems, resulting in
millions of dollars of cost savings and revenue increases, often for minimal or no capital investment. Sharing these
stories has served to energize, educate and enable other companies to build on these efforts. , .. .
The key to .future success lies in cooperative efforts involving companies, local communities, regulatory agencies,
i and environmental groups. This is the best way to create needed environmental improvements while at:the" s:am^
i time strengthening the competitiveness of U.S. industry in a global marketplace. Voluntary programs such as:
EPA's 33/50 Program of waste and emissions reductions have demonstrated that outstanding environmental, and
business benefits can be achieved in a spirit of partnership and cooperation. The 33/50 Program has served as a.
valuable tool to help focus, prioritize and measure waste and emissions reduction efforts. The national attention
accorded the 33/50 Program has helped companies like DuPont to sustain and accelerate their waste and emissions
reduction efforts. ' . . : . i /'.
National programs such as 33/50 will and should continue to play an important role in future pollution prevention
efforts. However, increasing attention is being given to partnerships with the local community as businesses direct
• their attention to the concept of sustainable development. Through national programs and local partnerships,
1 companies have made great progress in eliminating waste at the source, increasing recycling of waste and post-
f consumer materials, and developing products and packaging with greatly reduced environmental impacts,^ At

76 .

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 information, understanding, concerns and people flow freely between the plant and its surroundings. Economic
; growth, environmental protection, and strong educational systems must be addressed together as part of a vision
 of local sustainability.                                                      .                   ;
.EPA'can benefit both industry and communities by,providing a framework and tools for setting priorities for
. future pollution prevention efforts. This must start with a sound scientific assessment of which sources of waste ;.
 and emissions are of greatest concern to human health and the environment. Priority-setting must be done through
 an open and cooperative dialogue, with the agency, affected industry, community members, and environmental
 groups participating.  An example of a current effort is EPA's Waste Minimization National Plan, which has
 focused attention on persistent, bioaccumulative, and toxic compounds and targeted them for voluntary reduc-
" tions. As part of the process of developing the National Plan, stakeholder meetings involving industry, states, and
 pubMc interest groups were held to provide opportunities for input and dialogue.       .    '   . .    .
 EPA.and state regulators must seek opportunities to provide industry with the flexibility to adopt pollution pre-
. vention solutions as alternatives to end-of-pipe controls. Two concerns are paramount:  (1) provide ample time to
 investigate and' implement innovative source reduction alternatives versus end-qf-pipe controls, and (2) make
 regulations performance-based rather than mandating specific technologies.  In some cases, new regulations are
.continuing to drive industry to invest their limited capital dollars in expensive end-of-pipe control  technology.
 However, EPA's Permits Improvement Team has offered a new.paradigm for reinventing the permitting process.
 Their proposals would enable and encourage greater adoption of source reduction methods While at the same tune
 offering industry the flexibility to grow and make operating changes at the rapid pace needed to succeed in a .
 competitive global marketplace.                                                               .
 industry must provide the leadership and innovation  to create a step change in pur approach to  protecting the
 environment if we are to achieve our vision of a sustainable future -- a clean environment and healthy economic
 development! Industry must continue to share its accomplishments and build on the successes and learning of
•'" others.  Communities, large and small industries, regulatory agencies, and educators must form partnerships to
 establish priorities  for accelerated progress.  States and federal regulators must continue to shift their emphasis
.'.from end-of-pipe command and control regulations to promoting pollution prevention through flexible, voluntary.
'. programs, information sharing and recognition of successful efforts. There is much hard work to be done, but our
^efforts will ensure positive results for ourselves and future generations.  .            .    .          ,.
                                                                                                     77

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The Dow Chemical Company

by
Craig Doolittle
Manager, Pollution Prevention Issues
The Dow Chemical Company
Midland, Michigan
Industry in the 1990s is once again a focal point for environmentalisra. This time, however, U.S. industry" has a
challenge to be competitive in a global market while at the same time; it has the opportunity to play a leadership
role in advancing efforts to prevent pollution and waste. As the global marketplace rapidly expands, multinational •
businesses find themselves in a unique position to advocate and catalyze responsible and sustainable growth at
home and overseas. While striving to balance the need for mandated environmental controls with the entreprenural
needs of free enterprise in the United States, industry must leverage and integrate pollution prevention concepts
across its operations and businesses globally. • '
It is clear that waste cannot be tolerated in our operations if we are to stay in business in the twenty-first century.
While this is not exactly a revelation, the idea takes oh special meaning in the context of the changing and expand- '
ing marketplace. The new competitive business reality .brings the weight of market forces to bear on environmen- '
tal progress. Industry can use its expertise and resources to eliminate waste and increase productivity, while :
increasing the growing demand for our products worldwide. How industry actually manages the change to more
efficient production and use is the key to whether we will actually be sustainable. ;
Industry not only has the' opportunity to lead pollution prevention, we also have the motive and the tools to make ;
it a reality. Our motive is simple; to survive, we must provide the lowest-cost, highest-quality products and ser- '
vices. Our customers expect this more than ever before. Our shareholders want increased profitability and pro-
ductivity. At the same time, society calls for continuous improvements in our environmental, health and safety
performance. How do we assure all needs are met? By using the tools at our command to make cost-effective
pollution prevention an integral part of what we do and how we think both individually and as a corporation.

Tools for Responsible Growth
We have several tools to help us manage sustainable growth in a responsible manner. One such tool is standardiza- \
tion. We can apply the same state-of-the-art technology for manufacturing polystyrene, whether in Joliet, Illinois, •-.
or Map-Ta-Phut, Thailand. A network of global technology centers ensures that our sites utilize the latest innova- .
tions to maximize productivity and limit waste. We are also working to standardize our operating practices, to '.
ensure each pound of polystyrene (or other Dow product) is made with the same attention to quality, environmental ;
protection, safety and health, no matter where it's made. • . '.''.'.•
Plant engineering and design can further drive "resource productivity," which basically means making more with
less. We strive to make every new plant we build the best one we have ever built in terms of both process engineer-
ing, design and environmental, safety and health impacts. For example, an $800 million expansion.of our site at
Fort Saskatchewan, Alberta, Canada, includes a new closed-loop system that prevents the hydrocarbons plant ;
from sending any process waste water to the nearby river. This is the first plant of its kind in the'world, : ; J :.\
78

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''Another business; tool called "activity-based costing" (ABC) also can help businesses Identify areas where- .:
Jresources are being wasted. .Simply put, ABC assures that all the present and future costs of making our :
products is considered in determining that product's.profitability. For example, ABC asks each business to !.
factor in the future costs of production, which may include environmental considerations such as recycling,
waste disposal, treatment or remediation of future disposal. In this way, EHS costs can be accurately incorpo- .
rated into the profit or loss statement for each product. This approach also supports life cycle analysis, which
evaluates pur products from design to disposal or recycling. These tools help us to be more competitive long-
, term in the marketplace. . .
While we talk a great deal about being more competitive by reducing waste, we also realize that there are some
cases where improvements must be made to address important environmental, health or safety issues. The best
example of this at Dow is our emissions reduction gpal for 2005. We already reduced global emissions by 50
percent between 1988 and 1994. Further reductions to meet the new targets in our 2005 goals will require an
estimated capital investment of about $300 million over 10 years. This investment may not generate a dollars- ,
arid-cents return, but it will help us address an essential part of being a successful company, by meeting the :
'. public's expectations for lower eimssions.

Integrating Strategies
.The key to making some of these tough decisions is strategic integration. Companies must blend business and
environmental management systems and decision-making in order to achieve pollution prevention goals. This :
requires a new model for business, one that merges economic and competitive reality with environmental, health
and safety performance. Business and EHS management systems have often been managed separately. By fully
incorporating EHS 'goals, into business goals, product by product, corporations can make more informed decisions
on where, investments and resources are needed. Sustainbility then becomes determinable "on a cost basis.
What does the future look like? We will move further along the continuum from the end-of-pipe treatment phi-
losophy of yesterday to-today's focus on pollution prevention ~ to tomorrow's market mandate of "resource
productivity." Our businesses cannot focus on preventing pollution for its own sake. Long-term, the question we
must ask is not simply "How can I eliminate waste from this process?" Rather, it is "how can I use less raw
material to make more product with less waste?" When we fully integrate this flunking into our daily life, we will
have made tremendous progress along the path to sustainable development.
•It's one thing for the business community to talk about the opportunity and tools for merging economic and
: environmental decisions, but it's quite another to build a regulatory system that encourages such action. Many
of the laws and regulations with which businesses comply today are crafted according to the old command and
control paradigm. There is often little incentive for companies to make the changes or use innovative ap-
proaches mentioned previously. In fact, regulations can discourage companies from embracing innovation and
breaking from prescribed operating methods.
We need" a regulatory system that is performance-based, one that allows businesses to set goals based on their
distinctive set of issues and needs, while assuring the public can effectively monitor and influence that perfor- ;
mance. One-size-fits-all regulation doesn't match the rapid changes industry faces today. Instead, society must
embrace a flexible system that asks businesses to be responsible for performanceimproyements and accountable .,
for lapses in progress! Such a system requires trust and collaboration among all stakeholders: government, the :
environmental community, industry, and private citizens. - - .
79

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 j  Slowly, weare niakuig pro^ess"ofi%ouafe
 [•;  debated^d&afied^^^worked^^^
   ment of Energy on initiatives to test the concept of performance-based regulation. We've had some successes,
   and some failures, but ultimately, our success will depend on bur collective and ongoing commitment to work
 '
  * together.
                                                                                           r"
80

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Improving Botk the Environment and.
Corporate Profits

by ' ~ • ' ' . '
Marc J. Epstein
Price Waterhouse Visiting Professor-of-Accounting and Control
INSEAD
Fontainebleau, France
Professor Epstein is also a member of the EPA's National Advisory Council on Environmental Policy and Technology
(NACEPT). '
,
.fies.'and other 'activities. Increasing numbers of companies have seen improvement in both the envitonmerit'and [
>their profitability from proactive environmental management rather than merely.reacting to,environmental regula- •
lions'. Companies have discovered that techniques and technologies are available to improve environmental and |
corporate management and are beginning to use them. . ,
.- Many companies have been, moving swiftly to integrate the consideration of environmental impacts into, all as-
pects of management decisions including product cost, product price, product and process design, capital invest- .
''•merits,- and performance evaluations. But this is not yet widespread. Companies are often unsure about how ;
evaluations of changing regulations, changing environmental technologies, and changing costs of those technolo-
gies should be included in decisions. They also have difficulty evaluating the costs and benefits related to product :
life cycle impacts. Finally, even where techniques and technologies have been introduced in companies that both
reduce environmental impacts and improve long-term corporate profitability, these techniques are often not spread ,
among companies or even between the different business units or facilities of the same company. Sometimes this ;
• is blamed on decentralization and the inability of senior general managers or senior environment, health, and
safety (EH&S) managers to motivate business unit and facility managers to institute environment protection and
money-saving changes in products and processes.
Nevertheless, the techniques and technologies are available that can improve corporate environmental perfor-
mance and corporate profitability--win/win modifications. In many cases, financial analysis tools that are com-
mon throughout industry are not being used in EH&S departments. In other cases, companies are being man-
aged with .a focus on regulatory compliance rather than environmental planning.
Three of the areas of corporate improvement that have significant positive impacts for both the environment and •
'. corporate profits are capital investment decision making, cost management, and performance evaluation. ;
. Capital Investment Decision Making -- Throughout industry, techniques such as scenario forecasting, Monte
Carlo sittiulation, decision trees, and discounted cash flow analysis are commonly used for improving capital
investment decisions. Most major companies would find it inconceivable that such decisions would be made
without estimating the likely future cash flow and other impacts from the investment. Significant uncertainty
related to projections of sales, competition, production costs, and many other factors often exists and long time
horizons are not uncommon. Nevertheless, risk and uncertainty are appropriately factored into the decision ;
. analysis and the decisions are made. However, these techniques are typically not used in environmental equip-
ment decisions and the evaluation of quality improvements that have benefits for both the environment and

.81

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profits. Too often, companies view environmental improvements as driven by regulations and do not recognize the
tremendous opportunities that are created by proactive environmental management. , |
• •'.•,•','•"''' ' ' - ' ' ' ' •' ' : "".-•','.' ..r' '•'•'•".')
Companies that conduct product life cycle assessments oh a regular basis find that numerous opportunities for :
improvement exist and provide changes in'product and process design that not only reduce waste and increase
production yield, but also increase product marketability and sales. Those companies that broadly identify their :
stakeholders and measure their life cycle impacts gain competitive advantage through improved product and pro- j
cess design and reduced environmental impacts. The life cycle assessment and life cycle costing process also '
i provides the impetus for companies to bring together professionals from many parts of the company. This cross
functional approach provides the setting for consideration of the impacts of the environment on accounting,
finance, product and process design, legal, operations, marketing, etc. This is often the first time that many of
these professionals have been brought into the consideration of the product design early enough to have an ,
impact. Benefits are provided to the product, to the environment, and to corporate profits. ;
Cost Management— It is well known in industry that "we manage what we measure".'Unfortunately, too many
companies cannot identify their total environmental costs and thus do not recognize the significant impact that
those costs have on their bottom line. They.also don't recognize that many of these costs can be controlled .and
reduced through strategic environmental management. Companies need to identify their environmental costs,
track those costs, and then determine the causes of those costs through a system like activity based costing. The
life cycle assessment and life cycle costing process also provides information that should be included in the full '_
environmental cost accounting that is necessary to dramatically improve environmental management and reduce
environmental costs. By identifying the causes of the costs, products and facilities can be identified that poten-
tially make the most significant contributions to environmental cost reduction. Without this approach, the ;
, causes of environmental costs are often not clear and cannot be effectively managed. \
I have seen many companies that have dramatically underestimated their environmental costs because of inad-
equate costing systems and did not recognize the significant opportunities for both cost savings and environmen-
tal improvements that were available. Costs being understated by a factor of three or four is common and is
caused by the tendency of accountants to place environmental costs in various overhead or general administra-
tive expense accounts. This masking of the costs encourages the consideration of these costs as regulation-
driven and does not encourage the consideration of the tremendous benefits of voluntary-driven, proactive,
strategic environmental management. Full environmental costing is becoming even more critical as global
industry recognizes the obligation for product take back and the ultimate responsibility for post consumer waste.
Companies should be including these costs in capital investment, product-costing, and cost management deci- ;
f sions. ^ • ' ' • • _ . . , . • • ' • . ..'.,'.'.
i Performance Evaluation ~ Through the integration of environmental impacts into capital investment and
i product costing decisions, managers are encouraged to consider the long term environmental arid financial •;
! impacts of product and process decisions. But, if companies are to motivate proper decisions, they need to also
recognize the incentives created by the performance evaluation system and make appropriate changes to encour-
age managers to seek win/win improvements and make the proper tradeoffs when environmental improvements
have no clear business advantage. Often capital investments are discouraged by performance evaluation metrics
; that cause a manager to forego profitable long-term investments for increasing current period income. Further-
l more, if companies want to make significant environmental improyements or change the corporate cultureitoi
! encourage "enyironrnental sensitivity, an integration irito the performance evaluation system is essential. Ihclud-j
! irig an environmental performance metric into performance evaluations and bonus schemes can motivate changes
"-•;-"• -• •' •*•'• " " • " | '" " """, |
82

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Cliapte
' thit are congruent-with company stated goals. Both lagging indicators of performance (measures of past erivir6h-
•inental performance) and leading indicators (environmental management systems .and improvements to reduce
future environmental impacts)- must be included in these evaluations of performance of divisions, teams, and
managers. These measures will allow companies to evaluate and motivate performance, benchmark the. company's
performance against its competitors, and strive for continuous improvement. .'•... . .
Some companies still .do not recognize the benefits from proactive strategic environmental management. In
many cases they don't recognize how existing measurement and management tools can be utilized to improve both
;'thd'envirbimient and profitability. The'EPA'cOuldmipfovefte'environment and corporate
i; /development and promotion of the tools available for integrating enylronmentid impacts into management decir
Some companies see the measurement tools that can be used to improve costing and capital investment decisions
;. as less reliable than traditional business and accounting measurement approaches. But, this is typically not the
;- case. Increased usage pf these tools, in EH&S departments will improve environmental decision making, im-r
l: prove the^enyirpnment, and improve corporateprofitability.. ^ ; ; ,- :, . ' •
! EPA'S'involyement in promoting the use of'mese techhiques and'te'chnblbgies and me ehcouragemerit of.ftill'
| envkonmental cost accounting and life cycle costing to improve corporate decision making wiElead both cprpp-
[ rations and the EPA closer to their goals--the improvement of both environmental and financial performance.
83

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84

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Chapter Three
  I         • '   _   •  .
The R61e;.pf :
Agencies in Prevention
             Federal Agency Pollution Prevention
             Activities
             - Department of Agriculture
             - U.S. Agency for International
              Development          "  ~
             - Department of Commerce
             - Department of Defense
             - Department of Energy
            ,- General Services Administration
             - Department of the Interior
             - National Aeronautics and Space
              Administration
             - U.S. Postal Service
             - department of ;Trarispoi*tatioii
             - The White House
             GuestCommentst
             Fran McPoland,
             Executive     • ••: •,•;••• ,.;v;; ('•• /;'M;v :;.''.".'.-. -, ;V'VH
             Sherri Goodman, Department of pefense
             Christine Ervin^ Department dt^nergy
                                                         85

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86

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Introduction
With passage of the Pollution Prevention Act of 1990, pollution prevention became
the national policy of the U.S^ Government. The federal government is uniquely
situated to promote and implement pollution prevention through its various roles:
• As policy maker and regulator, the government can exert influence through
policies, education, regulations, and enforcement.

• As the nation's single largest consumer and purchaser of goods and services,
the federal government can help create markets for environmentally-preferable
products and technologies.

• As a manager of facilities and generator of pollution, the federal government
can set an example for excellence in pollution prevention and waste manage-
ment. The federal government is the nation's largest property owner and
holds one-third of the nation's land area.

• As an advocate for technology, the federal government can help accelerate the
flow of pollution prevention technologies through policies and programs that
support research and development and technology transfer.

A number of government-wide actions have begun to put the national policy of pol-
lution prevention into practice. An Assistant Secretary-level Interagency Task Force
oversees implementation of the government's long-term pollution prevention efforts.
The environmental review process established in the Pollution Prevention Act and
supported by the National Environmental Policy Act helps to ensure that adverse envi-
ronmental impacts of proposed government activities are adequately considered in the
decision-making process. • . .
Over the last six years, various federal agencies and departments have made signifi-
cant strides in promoting a pollution prevention ethic internally and externally. The
stimulus for much of this activity has been a series of laws and executive orders that
have pushed federal agencies to adopt pollution prevention measures and guided their
effbrts as they did so. A summary of major milestones since 1990 is presented in Table
3-1. EPA has also been encouraging federal agencies to find innovative ways to pre-
vent pollution both in their own activities and in the multiple interactive effects their
activities have on other segments of society.
One of the most noteworthy landmarks in federal agency activity was Executive Or-
der 12856, which requires federal agencies to report releases of toxic chemicals to
EPA's Toxics Release Inventory (TRI), to develop agency-wide and facility-specific
pollution prevention plans, and to reduce toxic chemical releases by 50 percent by
2001. . Sixteen of the major federal agencies have developed pollution prevention
strategies to achieve these and other pollution prevention goals.
Federal facilities reported a 23.6 percent decrease in releases of toxic chemicals from
1994 to 1995, according to TRI data. Whether that decrease is due to pollution pre-
The federal
government is
uniquely situated
to promote and
implement
pollution
prevention ;
through its
various roles.
87

-------
vention measures or the fewer number of facilities reporting in 1995 (144 rather than
193) is not yet clear. Table 3-2 summarizes the most recent TRI data for federal
agencies. As the table shows, five federal agencies account for 99 percent of all
federal agency reported releases — the Department of Defense (71 percent), U.S.
Enrichment Corporation. (8.5 percent), Department of Energy (7 percent), National
Aeronautics and Space Administration (6 percent), and the Department of Agriculture
(6 percent).
Several of the larger agencies achieved substantial reductions between 1994 and 1995.
They include a 21 percent decrease for the Department of Defense, 8 percent for the
Department of Energy, 14 percent for the National Aeronautics and Space Administra-
tion, and 12 percent for the U.S. Enrichment Corporation.
As strategies and policies are adopted and institutionalized, the emphasis is shifting
to bringing pollution prevention to the facility level. EPA maintains a computerized
Federal Facilities Tracking System with information on approximately 12,000 facili-
ties of civilian federal agencies. (The total universe of federal facilities, including
Figure 3-1. Total Number of Federal Facilities Per EPA Region
Source: EPA. Federal Facilities Sector Notebook: A Profile of Federal Facilities. Washington, DC (EPA 300-B-
96-003, January 1996).
~ ~
88

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those of the Department of Defense, is about 15,880.)  Figure 3-1 shows the geo-
graphic distribution of federal facilities by EPA Region.
Over 5,000 federal facilities are currently in the process of preparing field-level plans
in response to Executive Order 12856 and other requirements. Many federal facilities
have environmental management systems in place or are considering adoption of the
ISO 14001 Environmental Management Standard.  As another alternative, EPA re-
cently issued a Code of Environmental Management Principles, developed in consul-
tation with other federal agencies under Executive Order 12856. Individual facilities
and agencies are encouraged to adopt the Code, which embodies five principles: man-
agement commitment, compliance assurance and pollution prevention, necessary en-
abling systems, performance and accountability, and measurement and improvement.
This chapter presents a sample of the activities of federal agencies that have been
particularly active in pollution prevention. Federal agency pollution prevention ac-
tivities include program and facility management, research and development, tech-
nological innovation, information transfer, partnership programs, and acquisition.
                                                                                                   89

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  -  •".	
I
Table 3-1.  PoUution Prevention Milestones
     Pollution Prevention
       :   Milestone
September 1990 - Science
Advisory Board report calls
for pollution prevention
November 1990 - Pollution
Act of 1990
January 1991 - EPA issues
National Pollution Prevention
Strategy
April 1991 - Executive
Order 12759 (Federal
Energy Management)

October 1991 - Executive
Order 12780 (Federal
Recycling and Procurement
Policy)
                           Description
 In this influential report, Deducing Risk: Setting Priorities and Strategies for
 Environmental Protection, EPA's Science Advisory Board stated as a major
 recommendation that "EPA should emphasize pollution prevention as the
. preferred option for reducing risk." The report further points out that "some
 pollution prevention techniques...cah pay for themselves quite apart from
 environmental considerations."

 Congress affirmed its commitment to a new approach for improving Prevention
 environmental quality by passing this legislation.  Congress recognized the
 important leadership role that federal agencies must play in the pollution
 prevention arena. In the Act, Congress directed EPA to: (1) promote source
 reduction practices in other federal agencies and, (2) identify opportunities
 to use federal procurement to encourage source reduction.

 The National Pollution Prevention Strategy (FR 56:7849-64, February 26,
 1991) outlines EPA's pollution prevention policy.  EPA's National Strategy
 also commits the Agency to develop similar strategies for, other sectors of the
 economy, including agriculture, energy and transportation, and the federal
 government.

 This order directs all federal agencies, among other things, to reduce their
 energy use and increase energy efficiency in federal buildings and facilities
 by at least 20 percent from 1985 levels by the year 2000.

 This order was designed to promote a greater role in waste reduction and
 recycling on the part of all federal agencies and to set up a special council
 that will monitor and report on agency performance. Under the EO, each
 federal agency must initiate a waste reduction and recycling program, and
 must designate an Agency Recycling Coordinator responsible for coordinating
 agency activities on waste reduction and recycling and for reporting the
 information to EPA. The order also establishes a Council on Federal
 Recycling and Procurement Policy to encourage active participation in
 waste reduction, recycling, and procurement programs, recommend changes
 in federal agency specifications and standards to enhance acquisition of
 recycled products, and showcase effective programs being developed..
90

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 Table 3-1. Pollution Prevention Milestones (Cont'd)
          lirtion Prevention•
 i          Milestone
 April 1992 - EPA and the
 U.S. Department of Agriculture
 (USDA) signed a Memorandum
 of Agreement to implement
 increased pollution prevention
 September 1992 - Policy
 Directive issued by the
 Secretary of Energy
October 1992 - Energy
Policy Act of 1992
April 1993 - Executive Order
12843 (Procurement
Requirements and Policies'
for Federal Agencies for
Ozone-Depleting Substances)
 The Memorandum of Agreement (MOA) puts in place a plan to
 address agriculturally related environmental problems and to implement
 increased pollution prevention in the agricultural sector. The Agreement
 outlines four basic strategies to achieve environmental results:
 (1) implementation of a nationwide pollution prevention program to minimize
 agriculturally-related pollution and environmental risks; (2) establishment of a
 coordinated research, technology development, and technology transfer system
 that supports production practices that protect and enhance the environment;
 (3) implementation of a comprehensive marketing strategy to promote
 voluntary pollution prevention; and (4) strengthening of the working
 relationship between EPA and USDA in order to provide a unified force for
 positive change in the area of agricultural pollution prevention.

 The Directive commits DOE to participate hi the 33/50 Program and initiate
 full voluntary Toxics Release Inventory (TRI)  reporting for all DOE facilities.
 DOE agreed to strive to achieve, by the end of 1995, a 50 percent reduction in
 releases of 17 priority chemicals from facilities that are currently required to
 submit TRI reports; all other DOE facilities would initiate voluntary TRI
 reporting beginning in 1993, with a 33 percent reduction goal for the 17
 chemicals by the end of 1997.   DOE also agreed to initiate a review of its
 specifications and standards, beginning with reductions in the use of the 17
 priority chemicals hi the 33/50 Program.

 The law gives a major boost to energy efficiency and renewable energy.  It
 includes provisions on alternative fuels, electricity, global warming research,
 and more. To encourage energy efficiency, the law uses a mixture of voluntary
 and mandatory measures, requiring new efficiency standards for appliances that
 use energy and water.  The law promotes the use of alternative fuels, requiring
 certain federal, state and private fleets of cars to increase their number of
 alternative-fueled vehicles.  Tax credits, and federal loan support are provided
 for renewable energy projects;  a variety of research programs are authorized as
 well.  The Act also gives whole-sale power producers greater, more affordable
 access to transmission lines and transmission services.

Federal agencies are directed by this order to purchase products that contain
non-ozone depleting components to the extent economically feasible. Through
affirmative procurement the U.S. government will provide the leadership to
phase out ozone depleting products on a worldwide basis.
                                                                                                     91

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Ikble 3-1. Pollution Prevention Milestones (Cont'd)
                                                          Description
April 1993 - Executive Order
(Federal Use of
Alternative as Fueled Vehicles)

April 1993 - Executive Order
12845 (Purchasing Energy
Efficient Computer
Equipment)

August 1993 - Executive Order
12856 (Federal Compliance
with Right-to-Know Laws and
Pollution Prevention
Requirements)
October 1993 - Executive Order
12873 (Federal Acquisition,
Recycling and Waste
Prevention)
March 1994 - Executive Order
12902 (Energy Efficiency and
Water Conservation at Federal
Facilities)
Under this order, federal agencies are directed to aggressively procure 12844
alternative fueled vehicles in order to stimulate the market for such products
well as push the state of technology.                         >,

This order directs federal agencies to procure computers, monitors and printers
that meet EPA's Energy Star energy specifications. Equipment meeting specific
energy reduction criteria bears an Energy Star label.
                                                               i
This order requires federal agencies to comply with the following: 1) develop
a facility-wide pollution prevention .plan by December 31,1995, includi'ng a 50
percent reduction in toxic chemicals by 2001; 2) ensure that pollution
prevention plans support agency-wide reduction strategies and goals; 3)
establish agency plans and goals to eliminate or reduce acquisition of   .
products containing hazardous substances or toxic chemicals; 4) make all
pollution prevention strategies, plans, and TRI reports available to
surrounding communities; 5) comply with EPCRA emergency planning and
response requirements; and 6) report releases and transfers of toxic chemicals
to the TRI.         .
These federal agency pollution prevention plans will direct implementation of
EO 12856 at more than 2,400 covered facilities throughout the country.
                          j                       .
This order directs federal agencies to set goals for solid waste prevention and
recycling to be achieved by 1995 and to implement affirmative acquisition
programs for all designated EPA guideline items purchased (replaced EO
12780). EPA must issue guidance on environmentally preferable products and
expedite the process of designating products with recycled content The EO
establishes high-level environmental executive positions and staffing to
ensure implementation of the directives, establishes model facility and
recycling programs, and sets minimum recycled content standards for
printing and writing paper. Federal agencies that meet the objectives of this
order are recognized with the White House Closing the Circle Award
(discussed in the next table).
                          !   '                '    '       .     .
This order requires agencies to set goals of reducing energy consumption,
increasing energy efficiency, auditing their facilities for energy and water use,
purchasing energy-efficient products, increasing the use of solar and other
renewable energy sources, designating a "showcase" facility, and minimizing
use of petroleum-based fuel.
92

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Table 3-1. Pollution Prevention Milestones (Cont'd)
August 1995 - Executive Order    This order directs federal agencies to procure products with companies that
12969 (Federal Acquisition and    are in compliance with TRI reporting requirements.
Community Right to Know)
                                                                                                 93

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                    •off- JT*a)aE"gSM*«i-"pg'yag,-«py.~ %» WBT^. ~ t-- rfA*^^vra^^^w^YVVl. &'
Table 3-2. TRI Data for Federal Facilities
; Federal Agency
i • '• ' '. •' .' ' i:.r^, :.^ J:'£ Ir:ft|^^C^i^;^^A^i^ri4i&? '-:=
J> v'"" " ' '""j 'Jl'^V^ "' ^iiUjUi^' ^''L'^^
Department of Agriculture
Department of Defense
Air Force
Army
Army Corps of Engineers
Defense Logistics Agency
Marines
Navy
Department of Energy
Department of Health and Human Services
Department of Interior
Department of Justice •
Department of Transportation
Department of Treasury
Department of Veterans Affairs
Environmental Protection Agency
National Aeronautics and Space Administration
Tennessee Valley Authority
U.S. Enrichment Corporation
Total

Total 1995 Releases
•':. : (millions of pounds)
^.jr/.ic!.,1'!'^^
474.9
5,615.3
3,651.8
917.6
22.4
5.3
375.0
643.1
581.9
0
4.8
32.5
16.5
1
37.6
0
0
474.0 .
13.6
675.7
7,927.0

Percent Change in Chemicals
Rannrierl in 10Q»J'fcT/^A^X*' ' >' ,'-'*•-' i:
'i'.^.jU1^.:::^^;,'^:,:-.^/^1^.^^
1
-26.7
-25.5
-29.1
0.2
-83.1
-26.5
-28.9
-7.7
-100.0
1
316.5
1
-64.8
' -30.7
493.3
-
-45.0
-13.7
-100.0
-11.7
-23.6
  Source: EPA. 1995 Toxics Release Inventory: Public Data Release (EPA 745-R-97-005, April 1997). Tables 4-
  16 and 5-7.

                             Under Executive Order 12873, federal agencies are recognized for their
                             achievement in meeting the objectives of this order; for this purpose, the White
                             House Closing the Circle Award was established.  The categories of this award are
                             described in Table 3-3.                              :
94

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Table 3-3. Closing the Circle Awards1
f^lifspf ard Category
Waste Prevention
Recycling
products
Affirmative Procurement
Environmental Innovation
Model Facility
Demonstration
Sowing the Seeds of Change

                          Description
This award is given to nominees who have made significant reductions in:
• the generation of non-hazardous, solid wastes from a federal facility
through any changes in the design, manufacturing, or use of materials or
  products; or
• .the amount of toxicity in waste materials before becoming municipal solid
  waste.        '                                              -        •

This award is given for collection, separation and processing by which
  or other materials are recovered from the solid waste stream for use in the
manufacture of new products (other than fuel for producing heat or power by
combustion).

This award recognizes the most effective programs implemented to purchase
and use products containing-recovered materials at a federal site, facility, or
operation.  The award focuses on those products designated by the EPA
Comprehensive Procurement Guidelines (CPG), covering 24 different items.  ,

This award recognizes the best examples of:
• acquiring, using  or validating products or services that have a. lesser or
  reduced .effect on human health and me environment when compared with
  competing products or services that serve the same purpose;
• outstanding improvements to a process that result in significant monetary
  savings and benefit the environment; and,
• product testing that leads to the approval and use of environmentally sound
  products and services.

This award is given to federal facilities that have made outstanding
contributions to waste prevention, recycling and affirmative procurement
through leadership, investment in resources, and change in culture.

This award is given to programs that do not fall under one of the previous five
categories. The Closing the Circle Award Program does not limit consideration
for award recognition to strict parameters; its objective is to recognize all
applicable environmental innovations and successes.
1 Nomination forms for Closing the Circle Awards are available from the Office of the Federal Environmental Executive (OFEE) (202-260-
1297).  Recent winners of these awards are profiled in Closing the Circle News, also available from the OFEE.
                                                                                                     95

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Federal Agency Pollution Prevention
Activities
'• \ • •
Department of Agriculture
The U.S. Department of Agriculture (USDA) contributes to pollution prevention through
• a number of programs. Many of these.programs have emphasized reducing pollution
from excessive agricultural chemicals or soil nutrient management and soil conserva-
tion issues. Programs dealing with pesticide reduction and environmentally sound use
are found in several USDA agencies, including the Cooperative State Research, Edu-
cation, and Extension Service, which maintains several grant programs in research and
extension in this area, the Agricultural Research Service, the Forest Service, the Natu-
ral Resource Conservation Service, and the Animal and Plant Health Inspection Ser-
. i
vice.
One major pollution prevention program is the $12 million a year Sustainable Agricul-
ture Research and Education (S ARE) program, in which EPA also participates. This
program provides competitive grants for research, education, and extension projects
through four regions of the country. These projects help farmers reduce pesticide use
and manage fertilizers and animal wastes more efficiently and with less environmental
impact. The projects also assist farmers reduce other input use that could contribute to
water and air pollution, such as energy use. the program relies heavily on farmer,
involvement and is particularly supportive of projects taking a systems approach to
agricultural and environmental problems. EPA participates in all facets of the S ARE
program, particularly the joint USDA-EPA program, Agriculture in Concert with the
Environment (ACE). The ACE program provides grants aimed at pollution preven-
tion and other environmentally-related agricultural issues.

U.S. Agency for International Development
The U.S. Agency for International Development's (U.S. AID) Environmental Pollu-
tion Prevention Project (EPS) program is a global initiative focused on creating and
supporting locally sustainable pollution prevention programs to address industrial
and urban waste problems in developing countries.2 EPS provides technical assistance
to help participating countries understand how pollution prevention can be used to
address environmental problems. This assistance falls into four general categories:
diagnostic assessments and other technical assistance; training; information dissemi-
nation; and assistance in developing sustainable government and non-governmental
pollution prevention programs.
EPS has established pollution prevention offices in Santiago, Chile, and Tunis, Tuni-
'sia. Two additional offices are being established in Egypt and Ecuador. The program
also has a Headquarters (HQ) Clearinghouse that serves as a repository and distribu-
2 U.S. EPA, Envirosense EPS Program Summary.

-------
tion point for pollution prevention information. The HQ Clearinghouse contains ap-
proximately 1,000 items compiled into the EP3INFO data base. The HQ Clearing-
house, through its linkage with INFOTERRA/USA, has access to several hundred data
bases, EPA documents, and other information sources. This linkage allows the1 HQ
Clearinghouse to offer users worldwide access to a wide range of pollution prevention
resources. The EP3INFO data base also has been distributed to local clearinghouses
in Chile and Tunisia. Similar clearinghouses will be established as new program of-
fices are opened hi additional countries. .
As an example of EPS activities abroad, EPS's program in Chile has an independent
Pollution Prevention Center. The steering committee consists of the American-Chil-
ean Chamber of Commerce (AMCHAM), USAID/Chile, and EPS. EPS's office in
Chile is headed by a Chilean engineer, and a group of 16 in-country consultants are
providing pollution prevention consulting services beyond EPS project support. The
program has trained Chilean nationals in pollution prevention, and established a
clearinghouse with the Centra de Investigacion y Planificacion del Medio Ambiente
(CIPMA) in August 1994. CIPMA is an environmental information center that pro-
vides information to industry and academia through its main office in Santiago and
eight regional network nodes throughout the country.
EPS's office in Chile has also conducted assessments for a wide range of indus-
tries such as textiles, leather tanning, printing, paint processing, metal finishing,
and processing. -

Department of Commerce
Congress established the U.S. Department of Commerce Technology Administration's
National Institute of Standards and Technology (NIST) "...to assist industry in the
development of technology—needed to improve product quality, to modernize manu-
facturing processes, to ensure product reliability...and to facilitate rapid
commercialization...of products based on new scientific discoveries." The primary
mission of NIST is to promote U.S. economic growth by working with industry to
develop and apply technology, measurements, and standards.3 This mission is carried
out through four major programs:
• A competitive Advanced Technology Program that provides cost-shared grants
to industry for the development of high-risk technologies with significant
commercial potential (including pollution prevention technologies);

• A grassroots Manufacturing Extension Partnership that helps small and me-
dium-sized companies adopt new technologies (including pollution prevention
technologies);

• A laboratory effort planned and implemented in cooperation with industry that
focuses on measurements.'standards, evaluated data, and test methods; and
3 U.S. Department of Commerce, Technology Administration. Guide to NIST - National Institute of
Standards and Technology.
' . 97

-------
,
Chapter 3 - Qtlier
^
• An outreach program associated with the Malcolm Baldridge National Quality
Award.

. MEPs Information/Technology Assistance
. . • -The Manufacturing Extension Partnership (MEP) is a true partnership of federal and
state organizations working together to address the needs of small and medium-sized
manufacturers. At the heart of the MEP system is a network of regional manufacturing
'extension centers in all 50 states and Puerto Rico. MEP works with state arid local
organizations to either establish a new program or expand existing services for smaller
manufacturers. Located throughout the country, these centers are created through a match
of federal, state, and local funding. They are not federal offices, but instead are not-for-
,_ ,_........_...... —_T :r—~ - '" :'~" --^7- •"•:"•"'" '•":•""" f "; profit organizations.
Preliminary Census surveys of MEP clients indicate that the national system is ;
projected to create or save over 30,000 jobs annually and help companies achieve Centers provide dkect ser-
sales $550 mMon higherthan if they had riot received MEP services. vices to smaller manufactur-
LA'TldifeiSHrS;^ • ers, helping them address
then: most critical needs in areas such as production techniques, technology applica-
tions, and business practices.
The MEP Environmental Program works .to .strengthen the environmental competi-
. tiveness of small manufacturers. The Program works with MEP centers and affiliated
organizations to integrate environmental services into the manufacturing extension
services of the MEP system. The Environmental Program manages and funds the
development of environmental tools and supports the training of MEP field agents and
their local partners in providing environmental and manufacturing technical assistance
to small and medium-sized manufacturers.
MEP now has affiliate centers in all 50 states and Puerto Rico.

Department of Defense4
' "^ i i
The Environmental Quality Program is an integral part of the overall mission of the
Department of Defense (DoD). Environmental considerations permeate all aspects of
' . J the development and operation of an installation and the development, testing, pro-
curement, deployment, and final disposal of a weapon system. DoD's Environmental
Quality Program protects DoD personnel and surrounding communities from expo-
. sure to hazardous materials and reduces pollution to the air, land, and water.
The Secretary of Defense has identified three priorities for DoD, each of which is
clearly linked to the Environmental Quality Program:
• Readiness - DoD must be able to test its weapon systems and train personnel\so
• • that it has the ability to accomplish its mission.

• Quality of Life - DoD must provide its personnel, both military and civilian,
with a healthy environment in which to live and work.
4 This information has been extracted from DoD's Defense Environmental Quality Program, Annual'
Report to Congress for Fiscal Year 1995. For a cdpy of this report, contact Jim Kennedy at (703) 604-
1766. . .
98

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• Modernization - DoD must provide its personnel with state-of-the-art equip-
ment and facilities superior to that of any potential adversary.

DoD's Environmental Quality Program directly supports these objectives by manag-
ing the 25 million acres on which DoD conducts activities to provide realistic training
opportunities; managing the flow of hazardous materials and wastes to ensure a safe
environment for personnel; and introducing new materials and maintenance processes
for weapon systems that reduce costs and improve performance. , •
In the following sections, DoD's efforts in pollution prevention, conservation, educa-
tion and training, .and environmental technology are discussed
Pollution Prevention
DoD is focusing on source
reduction, reuse, and recy-
cling in lieu of "end-qf-
pipe" treatment and dis-
posal as its preferred
method of protecting hu-
man health and the envi-
ronment and meeting cur-
rent legal requirements.
This preventive approach
reduces future environ-
mental and legal risks and
Operations and Manage-
ment (O&M) costs.
During FY95, DoD in-
vested over $284 million in
pollution prevention. The
O&M accounts provided
55 percent of this invest-
ment. The procurement
account was another major
contributor (28 percent).
Figure 3-2 shows the dis-
tribution of pollution pre-
vention funds. Approxi-
mately 32 percent of the
funds were used to reduce
the use of ozone depleting substances (ODS), 31 percent to reduce the use of hazard-
ous materials and generation of hazardous waste, 25 percent to reduce solid waste
disposal and support recycling activities, 6 percent to reduce water pollution, and 6
percent to reduce air pollution.
The DoD Environmental Quality Program
DoD's Environmental Quality Program is divided into the following major functions:
Planning is the foundation of the Environmental Quality Program. DoD's planning
efforts focus on the development and operation of installations'and the development,
procurement, deployment, and disposal of weapon systems. ,
Compliance includes all activities required to meet the standards established by
laws such as the Clean Air Act (CAA), trie Clean Water Act (CWA), and the
Resource Conservation and Recovery Act (RCRA). These laws are designed to ;
protect human health and the environment. Failure to comply with environmental ;
laws can place personnel at risk; make surrounding air, land, and.waters unsafe; .!
„ and result in penalties, shutdowns, or restrictions on .mission activities.
Pollution Prevention protects human health and the'environment by reducing or ;
eliminating pollution problems rather than controlling them. Pollution prevention
can be used as a means of achieving compliance and usually involves good business
decisions that reduce overall costs. . ~ .'....'"• . •. .
Conservation involves the maintenance and protection of both natural arid cultural
resources that have been entrusted to DoD's care. A healthy natural environment
contributes to realistic training as well as quality of life. Protection of cultural
resources preserves the nation's'heritage. . . ;
Education and Training ensures that DoD personnel understand the environmental
responsibilities of their jobs and therefore support the achievement of DoD's overall .
Environmental Quality Program. ; ' . '
Environmental Technology seeks new technologies that meet environmental
requirements at less cost. . . .,- . ' •
99

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                            Figure 3-2.  DoD Pollution Prevention Funding for FY95 (by Media)
                                            Air Emission
                                              Reduction
                                                6%
                                   Wafer Pollution
                                     Reduction
                                        6%
Hozmat/Waste
  Reduction
-   31%
                            * Other includes nonpoint source pollution reduction, toxic release reductions, solid
                            waste reduction, and "other."
                            DoD has encouraged installations to seek smarter ways of doing business and to re-
                            duce environmental costs through the establishment of goals.  One goal is to reduce
                            the amount of hazardous waste disposed 50 percentby 1999 from a 1992 baseline. As
                            the first step in achieving this goal, installations were required to complete opportunity
                            assessments and develop pollution'prevention plans by the end of 1995. The assess-
                            ments identified the users of hazardous materials and 'the generators of hazardous wastes.
                            The plans identified alternative materials and processes and prioritized them based
                            upon return on investment and environmental performance.                 .
                                                          |                   :                  j
                            A large reduction in the purchase of hazardous materials and the disposal of hazard-
                            ous wastes can be attributed to  improved business practices.  DoD components are
                            establishing centralized systems, known as pharmacies, for buying, storing, distrib-
                            uting, and disposing of hazardous materials at many installations and on most ships.
                            Materials are distributed to industrial shops on a "just-in-time" basis and in quanti-
                            ties sufficient only for the immediate task.   This practice reduces:  the amount of
                            hazardous  materials  purchased, losses due  to shelf-life expiration, the number of
                            accumulation points (and the potential for violations), and the amount of hazardous
                            waste disposed. The Navy is implementing this program at 73  shore facilities and on
                            140 ships and estimates a cost avoidance of more than $20 million for FY95. Simi-
                            lar successes are reported by the Army and Air Force.
                            DoD also is implementing a program to dramatically reduce its releases of toxic chemi-
                            cals under Executive Order 12856^. For 1994, the first year mat requirements to report
                            releases of toxic chemicals applied to DoD, 131 of 425 major  DoD installations had
                            toxic releases that exceeded the threshold levels. The 1994 baseline, by which progress
                            is to be measured in future years, included both on-site releases to air, land, and water
                            as well as  off-site transfers of waste for treatment, storage, or disposal.  The total
100

-------
amount released during the baseline year was 11.46 million pounds. About two-thirds
of this total was released on-site primarily as air emissions. The remaining one-third
was waste transferred off-site. The total of all DoD reported releases was less than
one-half of one percent of the total releases.from private industry reported in 1993
(most current data available). •
In the past five years, DoD has conducted an aggressive program to eliminate the use
of ozone-depleting substances (ODSs), This effort was motivated by the production
phaseout of ODSs by the, end of 1995 in accordance with the international Montreal
Protocol Treaty. The Department must identify and validate, alternative materials
before changes can be made. Typical investments included the purchase of aqueous
washers to replace cleaning systems that used solvents containing ODSs. DoD re-
duced its procurement of ODS-based solvents and refrigerants from 14.6 million pounds
in 1990 to 313,000 pounds in 1995 — a 98 percent reduction.
DoD has not found suitable substitutes for all materials and all applications. For ex-
ample, no material has been found that will equal the performance of halon as a fire
suppressant for jet aircraft engines. As a consequence, while research continues to
seek an alternative, DoD must continue to use halon in its aircraft. Nevertheless,
. overall use of halon has been dramatically reduced, dropping from 10.3 million pounds
in 1990 to 231,000 pounds in 1995 — a 97 percent reduction. .
. To reduce landfill disposal costs and potential environmental risks, DoD established
goals to reduce the generation of nonhazardous waste and to increase recycling ac-
tivities. The goals required a 50 percent reduction in the amount of nonhazardous
waste shipped to landfills by 1999 from a 1992 baseline, and a 50 percent increase in
the amount of waste recycled by 1999 from a 1992 baseline. Significant progress
already has been made towards achieving these goals. For example, Naval Air Station
Whidbey Island, Washington, when faced with the imminent closure of its landfill,
implemented aggressive recycling and composting programs. In FY95, revenues from
recycling exceeded $285,000. In the same period, cost avoidances through reductions
in nonhazardous waste disposal totaled more than $784,000. Overall, DoD reduced
nonhazardous waste disposal 20 percent and increased recycling 45 percent.
During FY95, DoD also developed new policies and procedures to substantially change
the way in which weapon systems are developed and procured. The new policies
required that environmental life-cycle costs be understood fully in the early stages of,
the acquisition process. This policy has encouraged developers'of new weapon sys-
tems to seek alternative materials and processes that reduce future operations, mainte-
nance, and disposal costs.
In FY97, DoD will continue to invest in projects to decrease its use of hazardous
materials and its generation of pollutants. .There will, however, be fewer investments
related to ODSs since most uses already have been phased out. In FY97, DoD is
launching two new initiatives that have the potential to significantly reduce future
environmental costs. The first initiative, entitled ENVVEST, is intended to promote
more effective use of environmental investments. Installation commanders will iden-
101

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       .    .
  Chapter^ i
•• ENVVEST at Vandenberg AFB           '
  In July 1996, a pilot ENVVEST project was launched at Vandenberg Air Force
1  Base m California. Vandenberg was the first DoD installation to sign up for relief
E from selected EPA regulations, and plans to redirect environmental compliance
•: fiinds mtij water cpnseryatipp^^
  Vandenberg's proposals are a reduction in NOx emissions by a minimum of 10
t tons during the five-year life of the pilot project closed-loop recycling for waste-
1 * water, and on-site batch"treatment plants at three major space launch complexes.
  DoD will conduct^an independent evaluation of the progress of the program. At
  the kick-off event, Dob Under Secretary Sherri Goodman noted, "ENVVEST opens
,  the door, to creative solutions for local problems. In twenty years, we will look
i  back at this event and wonder why we didn't do this sooner,"
                                                                             tify regulations that require
                                                                             large investments but pro-
                                                                             duce little or no environmen-
                                                                             tal improvement.   Regula-
                                                                             tors, now allowed to relax en-
                                                                             forcement of rules under spe-
                                                                             cific circumstances^ would
                                                                             enter into agreements with
                                                                             the commanders.  These
                                                                             agreements would specify
                                                                             the regulations that would be
                                                                             relaxed and an alternative en-
                                                                             vironmental approach that
                                                                      i    '   would be pursued. DoD an-
                            ticipates that most of the alternative efforts would be high payback pollution preven-
                            tion projects. The Department believes by using the flexibility permitted under this
                            initiative, the installation could achieve greater overall environmental protection and
                            reduce costs. The initiative will be tested at three to five installations.
                            The second initiative involves the use of data from the TRI to better focus pollution
                            prevention and environmental technology efforts. The DoD components operate many
                            weapon systems that were developed before there was full understanding of the liabili-
                            ties and costs associated with the handling of hazardous materials and disposal of
                            hazardous waste.  Many specifications, cited by operations and maintenance manuals
                            for these older systems, direct the use of hazardous materials.  DoD intends to change
                            these specifications to prescribe more environmentally benign substitutes. However,
                            there are thousands of specifications  to be reviewed and potentially changed.  DoD
                            must focus its efforts on those specifications that create the largest part of the problem.
                            DoD proposes to analyze the TRI data to identify those processes and associated weapon
                            systems that require priority attention.
                                                         !    '       '•                           I
                            Conservation
                            In FY95, DoD invested $152 million to support conservation activities.  In order to
                            meet its legal obligations and to properly operate and maintain operational ranges and
                            maneuver areas, DoD established goals to complete inventories of special resources,
                            such as threatened and endangered species habitat, and to prepare integrated manage-
                            ment plans for both natural and cultural resources. The goals required that most inven-
                            tories be completed by FY98 and all plans be completed by FY01.
                                                         •I                • '  '
                            DoD made significant progress towards achieving these goals.  At the end of FY95,
                            over 66 percent of the biological inventories and 68 percent of the wetlands invento-
                            ries were completed. In addition, nearly 50 percent of the historic building inventories
                          •  and 34 percent of the archaeological inventories were completed.
                            DoD also made substantial progress* in the preparation of integrated management plans.
                            Over 51 percent of the integrated natural resource plans and 36 percent of the inte-
                            grated cultural resource plans have been completed.
102

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In order to improve mission performance, DoD has made small investments in the
study, protection, and enhancement of some natural resources. For example, It has
studied the migratory patterns and nesting preferences of birds. This information
has enabled flight planners to adjust low level aircraft training routes to reduce the
potential of birdstrikes and the resulting loss of aircrews and aircraft. This infor-
mation also assisted land managers in selecting maintenance practices that dis-
courage birds from nesting near airports. In some instances, DoD has taken ac-
tions to promote plant and animal species, particularly those identified as threat-
ened or endangered. These actions have led to increased operational flexibility on
some installations.
DoD is convinced that natural resources should be managed as part of an entire eco-
system. This approach is being used in the Mojave Desert, where some of the most
important training and testing installations are located. DoD, in coordination with
other major landowners in the desert ecosystem, is collecting existing data on natural
and cultural resources to develop a desert-wide land management plan. DoD antici-
pates that the resulting plan will give installation commanders more flexibility, protect
installations from encroachment and restrictions on military operations, protect criti-
cal species, and support orderly economic development.
The Army is implementing new'land management practices at its training ranges.
Army exercises, when conducted without safeguards, can cause extensive damage
to vegetation and terrain and undermine the effectiveness of future training activi-
ties. A comprehensive training land use management approach, called Integrated
. Training Area Management (ITAM), attempts to balance training needs with the
ability of soils and vegetation to absorb and recover from training uses.
In FY97, DoD will continue to complete inventories and develop integrated man-
agement plans. In addition, in compliance with the Native American Graves Pro-
tection and Repatriation Act, DoD will continue efforts to identify human remains
and associated funerary objects of Native American origin that have been uncov-
ered on DoD lands and attempt to return them to appropriate representatives of.
Native American tribes for reburial.
Education and Training ' ".
DoD intends to educate or train all personnel, both military and civilian, to meet
the environmental responsibilities associated with'their jobs.
In FY95, DoD completed an inventory of all environmental education require-
ments and began to identify the most cost-effective means of satisfying them. When
practical, DoD has embedded environmental education into existing courses. En-
vironmental education has been incorporated into basic training and technical spe-
cialty training curricula. Environmental education also has been added to profes-
sional military education programs such as Army War College and Air Command
and Staff College. DoD began to incorporate environmental education into courses
offered by the Defense Acquisition University.
103

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. _
Chapters-
' . *• . . £JHf *= ji*B
In FY97, DoD will prepare an environmental career development program. This pro-
;gram will aid the development of environmental personnel for positions of greater
responsibility. For the first time, environmental professionals will have a clear vision
of the environmental career ladder.
Environmental Technology
DoD is seeking innovative technologies to meet environmental performance standards
in an effective, cost-efficient manner.
DoD's overall strategy for environmental technology is to identify and establish pri-
orities among users' needs and match them if possible to'existing technologies. If
existing technologies, are not available, then the development of new technologies is
pursued through the environmental technology program.
1 •• • • j . • • . . • • .'(
In FY95, DoD invested over $ 164 million in environmental technology. Of this amount,
approximately $108 million was invested in direct support of the Environmental Qual-
ity Program. Over $54 million was allocated for pollution prevention, $45 million for
compliance, and over $9 million for conservation.
. In FY95, the Air Force was designated executive agent for preparing the DoD Envi-
ronmental Technology Requirements Strategy (DETRS). The first DETRS was pub-
lished in March 1995. This document contained technology goals and requirements
identified and prioritized by the users. It established the direction for future technol-
ogy investments. . ,
The Environmental Security Technology Certification Program (ESTCP) also was
launched in FY95. This program also was established to demonstrate and validate
• the most promising new technologies to meet urgent DoD needs. Successful candidate
projects were expected to achieve payback within five years.
There were a number of new technologies successfully implemented in FY95. The
Navy successfully developed and fielded the plastic waste processing system to com-
ply with the Marine Plastic Pollution Research and Control Act of 1987, as amended
by the Defense Authorization Act of 1994. The Air Force implemented the aircraft
component subsystem paint stripper. This is expected to reduce the amount of haz-
ardous waste generated during stripping operations by 94 percent and the labor hours
required to strip an aircraft by 50 percent.
In FY97, DoD will continue to invest in environmental technology projects. The ef-
fort will focus on .problems that are unique to the military or offer significant reduc-
tions in current operations and maintenance costs. Examples include the develop-
ment of an antifouling coating for ships and the development of an ultraviolet oxida-
tion process to treat air systems contaminated with nitroglycerin and solvents.
104

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Department of Energy
Program Management
In December 1995, the Department of Energy (DOE) was honored along with 20 pri-
vate sector companies with an "Environmental Champion" award.  The award, co-                     .
sponsored by EPA and McGraw-Hill Company's Chemical Engineering and Environ-
mental Engineering World Magazines, was presented to DOE for its success in EPA's
33/50 Program. DOE, the

                           ^^i^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^

                            The Kansas City Plant; a Department of Energy facility, and a major generator, of j
 only federal agency receiving
 an award, reduced its use of
 17 targeted chemicals by 95
 percent between  1988 and
 1993.
DOE has renewed its efforts
to prevent wastes wherever
possible as a way to reduce
costs,  In her May 3,  1996
memorandum and accompa-
nying 1996 Pollution Preven-
tion Program Plan, Secretary of Energy Hazel O'Leary demonstrated the Department's
commitment to pollution prevention by establishing DOE's most ambitious waste re-
duction, recycling, and affirmative procurement goals to date.  These goals, to be
achieved by the end of 1999, were developed in accordance with recent Executive
Orders and internal departmental guidance. DOE field sites are requked to set: spe-
cific goals to help achieve the overall departmental goals.
In December 1995, DOE's Office of Environmental Management released the Annual
Report on Waste Generation and Waste Minimization Progress for calendar year 1993.
This report showed two trends: (1) environmental restoration and facility stabilization
activities are the primary waste generating activities; and (2) DOE continues to re-
duce, recycle, reuse, and avoid waste generation wherever possible. The report also
concluded that between 1991 and 1993 routine operations waste generation decreased
35 percent, while sanitary waste generation increased by approximately 26 percent.
DOE has institutionalized pollution prevention in several important ways:
•  Establishing a top-level Pollution Prevention Executive Board, chaked by the
    Under Secretary, to set priorities and assist in achievement of goals;

•  Creating an Office of Pollution Prevention within the Office of Envkonmental
    Management;
5 1996 DOE Pollution Prevention Awards Program: Abstracts of Nominations Selected for National
Awards. DOE EPIC.
                                                                                                 105

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• • Appointing pollution prevention program managers in other DOE Secretarial
organizations that generate wastes, and installing pollution prevention coordina-
tors at field sites;

• Decentralizing program implementation, thereby allowing each site to develop
its own goals (designed to achieve DOE-wide goals) and to fund activities to
achieve these goals, in a manner consistent with the best practices at that site,
and;
• For FY97, elevating pollution prevention to the status of a "national program"
so that it-will no longer have to compete with mission activities in site
budgets.
. i • '
••- •••••'•. . • : .' '•"•• - [ •'..;.•• • •. In an effort to save taxpayer
An Example from DOE'S Return on Investment Pilot Program ; money while reducing waste,
[ A pollution prevention opportunity assessment was completed on machining pro- '" the Pollution Prevention Ex-
1 cesses at the IGF Kaiser Hanford Company machine shop. A hazardous waste ecutive Board initiated a high
{ stream consisting of machine coolant that contains persistent and toxic chemicals return-on-investment (ROI)
! is generated each year at a cost of $ 138,000. In' a return-on-investmeht (ROI) : P^ot program to fund specific
I project funded by the Department of Energy's Richland Operations Office, a cool- pollution prevention projects
; ant recycling system was selected and installed for;a total cost of $61,000; the ! with the greatest "payback"
i annual cost savings exceeded $121,000 for an ROI of 188 percent. . > potential. The ROI program
',", _h •, '..-. ,.._.'.,..'..:. ;.:.;.•„ ..;.•.•.,;..: _:... .••;....„,„••:. ... .,-.;.-.,,.•'. '..' was initiated to demonstrate
the economic benefit of implementing pollution prevention projects, focusing on those
with high potential for reducing operational costs. Thirteen ROI projects were initi-
ated in 1994 and an addition^ 21 were funded'in 1996. Savings over the next ten
years are projected to exceed $135 million (in 1996 dollars). Continued pollution
prevention investments will steadily reduce hazardous and radioactive waste genera-
tion and will reduce the need for unnecessary expenditures for waste treatment, stor-
age, and disposal. The ROI program is now decentralized to the field sites for imple-
mentation. •
In an effort to encourage waste generator accountability, promote waste reduction, and
: provide a source of funds for pollution prevention implementation projects, the Pollu-
tion Prevention Executive Board created a system whereby generators set aside a por-
tion of the costs related to the, management of their wastes to be used for funding
pollution prevention projects. This pilot demonstration will serve as the template for
similar set-aside programs at other sites.
Incorporating performance-based incentives for DOE contractors to minimize waste
streams has significantly energized the pollution prevention program at field sites.
For FY 1996, Savannah River Operations Office set aside nearly $1.3 million, al-
most ten percent of the total site award fee contract, to motivate its prime contractor'
to implement pollution prevention initiatives that will minimize wastes. Specific
language was negotiated in the Savannah River annual operations plan that required
achievement of source reduction through documented waste minimization initiatives
in order to qualify for fee dollars. These performance objectives were calculated on

106

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the basis of levels of waste forecast to be generated and disposed of during the
upcoming year. .
Likewise, the Oakland Operations Office has succeeded in encouraging pollution pre-
vention activities in non-profit research laboratories operated by the University of
California. The Lawrence Berkeley and Lawrence Livermore National Laboratories
have achieved a far greater waste reduction in the past two years than those Oakland
sites that'did not have pollution prevention performance measures in their contracts.
••' By incorporating specific pollution prevention expectations hi the laboratory perfor-
mance plans, these two sites have reduced waste nearly 25 percent compared to 1993.
Information/Technology Transfer •
The DOE Pollution Prevention Information Clearinghouse (EPIC) was developed un-
.der a joint effort with the DOE and EPA to enhance the exchange of pollution preven-
tion information among federal, state, and local government agencies, as well as with
industries, academic institutions and the general public. The EPIC system, previously
a'bulletin board system, became a Web site in February of 1995. The system provides
access to federal and state pollution prevention regulations, DOE pollution prevention
policy and guidance, special DOE reports and memos, site project summaries, Pollu-
tion Prevention Opportunity Assessments, newsletters, pollution prevention contacts,
and other periodic reports. .
DOE sponsors an annual Pol-
lution Prevention Confer-
ence; in 1996 it was attended
by over 400 DOE and con-
tractor personnel. This three-
day conference included ses-
sions on the following topics:
MoH^Sfefe^
DOE honored winners of eleven national'pollution prevention awards,in;a cer-r
emony on July 10,1996, in Chicago. Associate Deputy Secretary for Field Man-
' agement Donald W. Pearman, Jr., presented awards to DOE employees and conr
tractors as part of the 12th DOE Pollution Prevention Conference, the special
plaques designed for the awards program were fabricated from recycled computer,
. • . * . t_ J _ 1_'__' j.1__ T^—.~_nnn /"!!*«» Til—i»•.'+• £'« «« •J»-iV»j-vtro+'Ix7
-------
;, -s^-iT^, £^.^1«fSV *"Vfc ^V::?
ample, stainless and carbon steel can be-melted and refabricated into standard-sized
disposal containers that can replace virgin metal containers currently used. Similar
research on the viability of other materials,(e.g., concrete, depleted uranium) for reuse
as aggregate or as shielding material is proceeding..
.. • .•.. • I ; , "1.," ' •
' A cost-effective program for integrated planning, hazard assessments, waste manage-
ment, and use of an innovative technology was implemented at the Formerly Utilized
Sites Remedial Action Program General Motors site resulting in savings of over $1.6
million. By aggressively looking for opportunities in a number of key areas in the
remediation process, waste volumes were reduced from 1,500 cubic yards to 175 cu-
bic yards, wastewater was disposed of at a savings of over $20 per gallon, and the
' , • impact of the cleanup on ongoing plant operations at the site was minimized.
S. , • . i- ;•,••' , ; . | .. .
"Source reduction of waste streams is performed wherever feasible. DOE sites use a
number of techniques to reduce landfill usage. The Oak Ridge Y-I2 site has estab-
lished a goal to achieve total recycling of waste streams such as paper, aluminum,
and scrap wood. The DOE recycling program was designed to 1) increase the longev-
ity of the landfill disposal sites, 2) reduce costs, 3) conserve energy and natural re-
sources, and 4) comply with federal waste minimization regulations. Due to the suc-
cess of the site-wide paper and aluminum recycling program, some .sites have identi-
fied additional waste streams for recycling. These streams include coal ash, automo-
tive wastes from vehicle maintenance, fluorescent bulbs, and toner cartridges as well
as surplus materials re-routed from disposal to the materials exchange.
u ,' . ' v -. ^ - > i The 242-A Evaporator facil-
EAJternative Solvent Developed
ni j^ *JH '„! *\ j£j-f n * ** i c
I Synergy CCS™ is an environmentally derived, surfactant-free, recyclable-Critical
KJeanlng lolvent. %Tlie Kansas*Qty Plant,1a Department of Ener|y facility, formu-
• lated the solvent in response to aproblem of a small manufacturer! The solvent was
Ifurtiier developed* and adopted by Hewlett Packard, and then licensed to a world
Reader m'alternaflve^solyent technology, Petroferm, Inc.''Synergy ctS™1 provides
f a ^iderange of cleaning capabilities for electrical and mechanical components Its
i ingredients are liste'd by the EPA as "approved" and biodegradable. It is derived
naturally and annually renewable sources, can be distilled after use, and is
atible with most existing cleaning equipment ' * ~
compatibe with most existing cleaning equipment
- -*4'* - <
ity is part of the Tank Waste
Remediation System used at
the Hanf ord site to reduce the
volume of radioactive waste
stored in double-shell tanks.
Filtered raw water was used
in the evaporator process,
contributing to condensate
eventually requiring treat-
ment. A modification to the
evaporator replaced the use
of filtered raw water by recycling a portion of the process condensate effluent^ reduc-
ing both raw water usage and process condensate requiring further treatment. Cumu-
lative savings over the projected operating life of the 242-A Evaporator should
exceed $10 million, greatly exceeding the original $230,000 cost of the modifica-
tion.
[ ; •' ' • '' '
The pollution prevention/waste minimization program at the DOE Pantex Plant in
Texas and the Savannah River Site in South Carolina received White House Closing
the Circle Awards in 1996 for achievements in recycling and waste prevention. The
awards recognized the plants' outstanding pollution prevention programs, which con-
tain 16 elements ranging from establishment of a plant-wide pollution prevention
108
-------
philosophy and enhanced communication to the creation of employee incentives
and goal setting.
Research and Development
A recent agreement between DOE's Lawrence Livermore National Laboratory (LLNL)
and EPA will encourage the development and commercialization of new environ-
mental technology by scientists and engineers. The agreement provides California
with the services of skilled lab personnel and unique lab facilities to evaluate new
environmental technologies in hazardous waste management, site cleanup, waste mini-
mization and pollution prevention for certification by California's landmark Environ-
mental Technology Certification Program. The program provides one-stop scientific
and engineering evaluation of new technologies to encourage development and speed
their acceptance.
Cooperative Agreements/Partnerships
The Department of Energy's Office of Industrial Technologies (OIT) continued to
implement its Industries of the Future strategy. OIT's strategy is to facilitate'partner-
ships with seven materials and process industries — steel, aluminum, metalcasting,
forest products, glass, chemicals, and refineries. Collectively, these industries use
over 80 percent of the energy and generate over 80 percent of the waste in U.S.
manufacturing. Industry will lead the creation of long-term visions and develop
associated "roadmaps" of technologies needed to get-there. The government plays a
supportive role by facilitating meetings, providing information and planning sup-
port, and coordinating with government agencies, DOE labs and other partners. The
technologies which OIT supports are also priorities for industrial customers who
share in the development cost. This assures not only relevance to industry needs
but rapid commercial introduction following technical success..
Acquisition Programs , .
The Department's affirmative procurement efforts are well underway and are bear-
ing fruit. In the 1996 Pollution Prevention Program Plan, the Secretary set a goal to
increase the procurement of EPA-designated recycled items to 100 percent by the end
of 1999. In 1994, DOE sites reached a 46 percent affirmative procurement level.
Guidance to field sites will help, to increase affirmative procurement by providing
useful information, such as a list of sources of recycled items, the relevant Federal
Acquisition Regulation information, the pertinent DOE Acquisition Regulation infor-
mation, and the latest EPA documents such as Recovered Materials Advisory Notices
and Comprehensive Procurement Guidelines.
DOE also maintains recycling programs at Headquarters and at most field sites. In
1993, the Department recycled approximately one-third of the total sanitary waste it
generated. DOE developed the Recycled Materials Affirmative Procurement Track-
ing System (ReMAPTS) to track its progress in buying recycled products and to track
the recycled content in items purchased. It was developed in response to a request by
the Deputy Secretary as a way for DOE to show its commitment to Executive Order
109
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.
Chapters7 Other
12870 (superseded by EO 12873).. The benefits of using ReMAPTS are that it sum-
marizes data for the Affirmative Procurement Reporting System (APRS), thus provid-
ing greater detail and improved accuracy while requiring less time for compiling year- •
end reports.
The APRS is a DOE-wide
electronic data call for those
required to report on affirma-
tive procurement. The sys-
tem is in the form of diskettes
(DOS and Windows ver-
sions) or on the Internet
through the EPIC home page.
The Internet site is a new de-
velopment for FY 1996 re-
porting and is available to
DOE sites. Benefits of the
Internet site include eliminat-
Product Energy Efficiency Recommendations
j In an effort to increase energy-efficient procurement, the Federal Energy Manage-
! nient Program (FEMP) released the first seven of its Product Energy Efficiency
i Recommendations, a series of user-friendly, one-page guidelines designed for fed-
1 era! users. Each recommendation covers, one type of equipment and provides the
| reader with an efficiency range representing the upper quartile (25 percent) of the
I market for comparable products, as well as a life-cycle cost analysis example which
', can help the-user estimate cost-effectiveness. Relevant conservation tips regarding
j such issues as proper sizing and compatibility issues are also included, as is a refer-
• ence section listing contact information for relevant organizations. In addition,
i some of the guidelines make environmental suggestions, such as responsible refrig-
! erant policy. An additional .10 recommendations are due out in late fall 1996.
! Brochures are ayatiab'ie'by calling; 1-800 tiOE-EREC.", ' " ! 'ing the need to mail computer
t< ..I—,.„„.:..,._.:. ,....;._•—.<:.•„-,,...,:-;:.-; „— L_^-.r'-- ,',:.,..,-.-";--"— '-—rr-,[ ^.-~-~,^ ., --, -•< : djsks back and forth between
sites and Headquarters, allowing sites to respond to the data call regardless of the type
of computer systems they are using.
DOE's Office of Defense Programs and the General Services Administration have
developed a procurement process for replacing chlorofluorocarbon refrigerants. Sig-
nificant benefits gained by replacing chillers under this Basic Ordering Agreement
(BOA) include: reducing the use of ozone depleting substances; reducing energy us-
age by replacing older, inefficient chillers with highly efficient chillers as recommended
by the Federal Energy Management Program; reducing emissions from the generation
of electricity; and expediting cost-effective procurements for federal agencies. Use of
the BOA will potentially lead to reductions of 24 million tons of power plant emis-
sions through improved chiller efficiency, and will avoid the use of 6 million tons of
chlorofluorocarbons.
Reuse of materials saves money. DOE, like many federal agencies, has an abundant
supply of formerly used or stored materials that are no longer needed. Reducing the
inventory can free up warehouse space and help reduce the associated costs of sur-
veillance arid maintenance. Some of these materials have considerable value and
can be reused by other DOE organizations or by others outside DOE. In the past,
knowledge of the whereabouts and status of potentially useful equipment, clean scrap
or chemicals has been the biggest obstacle to the transfer of these materials. The
Department is improving its method of tracking and advertising its assets and mate-
rials through connections to individual sites through the Internet.
Recognizing that the materials exchange process is a critical step towards pollution
prevention, the Office of Energy Research is developing a manual for use by pollu-
tion prevention/waste minimization personnel to help select, design, implement, and

110
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conduct an internal program
for excess materials exchange
at a DOE site. Examples of
materials exchange programs
for laboratories, pilot plants,
and production operations are
included to identify specific
features unique to each pro-
gram.
Pollution Prevention Assess-,
ments
i Waste Minimization afad Reuse at DOE Facilities
When the Bevalac facility at the Lawrence Berkeley National Laboratory closed
in 1993, the radiation shielding blocks at the site were no longer needed. These
<; huge, concrete, shield blocks of various shapes and sizes have extremely'low-
levels of activation and comprise a total of 19,000 metric tons with a volume of
13,600 cubic meters. Because of the large volume of these blocks, if would be
very costly to characterize, transport and dispose of these materials in a DOE burial
. site. Continued use for about 35% of the blocks was located at another DOE site at
\ ,%B™9^n ^ ••
! posal costs and trie need to construct new shielding was averted.'"-Savings-are .esn-f;
j matai at close to $40 million. The remaining blqeks are being eyaluatecl for ben-
Sandia National Laboratories ; eficiaireuse-atckherlocations.' •.'•' '••'*••• rr. '.';"• ••^•^/•'•'^•'"^~''^'^;^^.^^^-
and its 'partners have devel- •, ' , . . •> c
Waste minimization, risk reduction, and mortgage reduction are primary goals or
the Plutonium Uranium Extraction facility (PIJREX) deactivation project at the
DOE Hanford site. Suceesses^fo^^^
radioactive nitric acid for reuse as a product; elimination of approximately 200,000
gallons of radioactive rinsate through reuse of tank flush waters; elimination of
approximately 60,000 gallons of radioactive waste water through concentration;
re-deployment of approximately 3,000 cubic 'feet of laboratory equipment, and 2.5
million pounds of chemicals, batteries, oil, and office supplies; strict inventory
and project management controls to minimize .wastes; and disassembly and re-
moval from use of 12 HEPA filters, thereby reducing the total amount of mixed
waste generated by 169 cubic feet. , . .
oped a software program,
EcbSys™, which applies com-
puter science and artificial in-
telligence toward environ-
mentally conscious manufac-
turing (ECM) design and pol-
lution prevention. EcoSys™
provides users with a uniform
method of analyzing the en-
vironmental impact of manu-
facturing based on product
design, quantities of materials
used in processes, and,the environmental attributes of material constituents. With the
software package, a user may input a question regarding a manufacturing process, and
EcoSys™ provides reasonable choices on how to minimize pollution.
The Pacific Northwest National Laboratory has developed a framework and tools for
conducting pollution prevention design assessments. Tools include a guidebook, soft-
: ware installation disks, and a user manual. The package will help facilities integrate
pollution prevention concepts into the underlying principles and procedures of engi-
neering design.

General Services Administration
; The General Services Administration's (GSA) pollution prevention strategy focuses
on purchasing alternative products that do not contain or have reduced amounts of
hazardous chemicals and educating other federal agencies on purchasing decisions.
Although GSA does not manufacture or process toxic chemicals, it does use and trans-
fer toxic chemicals tiffsite; therefore, GSA is committed to achieving a 50 percent
toxic chemical reduction goal by December 31,1999, by decreasing the agency's total
releases and offsite transfers of toxic chemicals.
Ill
-------

GSA is working with EPA to incorporate environmental and recycling provisions into
the proposed new EPA Regional Headquarters building in Kansas City, Kansas. In the
' requested building design, a "green rider" specified such features as: high-efficiency
heating and air conditioning equipment with automated controls; energy conserving
'.'• lighting; endorsement of day lighting; and low-flow plumbing fixtures. Many of these
items are featured in the proposed Federal Aviation Administration building in the
Kansas City metropolitan area as well.6
GSA uses hazardous substances in facility management applications (e.g., operation
of storage tanks, cleaning operations, renovation), during new construction, and for
vehicle maintenance. However, GSA also is using several technologies that eliminate
or reduce pollution in its operational activities (e.g., reformulated paints, preserva-
tives and cleaning agents, refrigerant recoveiy units, parts cleaner recovery units, and
closed loop vehicle wash systems that recycle remaining water, after it is separated
from the wash solution).7
GSA has established the New Item Program (NIP) to provide a means to introduce
.new and improved products and services. GSA uses the NIP to promote awareness of
pollution prevention technologies and to maximize opportunities for customers to
• choose environmentally beneficial products and services.8
. '„...,, ,„„,.,„.. J ,...,....,,,,, ..=.,.;,.......,: GSA, in partnership with
! Buying Green • . '•.•-'' ,'. . '. ' '; • ;., .. • .• . ' . \
GSA has rapidly expanded the scope of environmental products included in the
Hifational supplysystem. lii addition to office supplies containing recycled content
l materials, a few examples of these products available through GSA are-
1 • recycled latex paint
( • low VOC paints
alternative fuel vehicles
, •,* jecyclable^softballs and baseballs,

' • ('.automotive refrigerant recycling equipment
V-HV*.. —«*• a •*( ~l -tn^- -* ... i -Jt '
EPA, has launched pilot
programs — including the
Cleaning Products Program
and the Latex Paints Pilot
Program — to test the prin-
ciples outlined in the envi-
ronmentally-preferable
products draft guidance.
The Cleaning Products Pro-
gram collected and pub-
lished in the GSA cleaning
products catalog, informa-
tion on the performance,
cost, and environmental impacts of various cleaning products. The Latex Paints
Pilot Program will further promote the purchase of environmentally-preferable
products.9
6 Office of the Federal Environmental Executive. Greening the Government: A Guide to Implementing
Executive Order 12873. (Washington, DC; 1996) p 45.
7 General Services Administration, Executive Order 12856 Pollution Prevention Strategy.
- . , , ••, . |
"Ibid.
9 U.S. EPA, Office of the Administrator. EPA Pollution Prevention Accomplishments: 1994 - Incorporat-
ing Pollution Prevention Into Business decisions. (EPA 100-R-95-001, Spring 1995.) !
112
-------
GSA also is committed to reducing or eliminating products it purchases for other agen-
cies or uses itself that contain hazardous chemicals by reviewing and updating its speci-
fications and by using new technologies that promote pollution prevention. GSA's
commodity centers develop specifications for products under their management re-
sponsibility. Each commodity center currently is reviewing its specifications to deter-
mine if hazardous substances can be eliminated from products and/or replaced with
industry recognized chemical alternatives. In addition, GSA is evaluating the inven-
tory of products that contain hazardous chemicals stocked at each supply distibution
center. If this evaluation reveals that significant quantities of hazardous chemicals are
stored onsite, GSA will work with commodity centers to reduce inventories.!0

Department of the Interior
The Department of the Interior's (DOI) Pollution Prevention Strategy commits the
Department to pursuing a hierarchical approach to pollution prevention, beginning
with source reduction. DOI's
Departmental Manual Part
518, Comprehensive Waste
Management, also identifies
pollution prevention as the
primary approach to manag-
ing waste activities on all In-
terior-managed lands and fa-
cilities. Under the
Department's Pollution Prevention Strategy, each Bureau is responsible for compli-
ance with the requirements of EO 12856, including developing a baseline for measur-
ing reductions in toxic chemicals (using baseline data no later than 1994), developing
facility plans by December 31, 1995, complying with EO 12856 reporting require-
ments, reviewing and revising specifications, acquisition procedures, and other stan-
dardized documents to reduce the purchase and use of toxic materials, and disseminat-
ing information about pollution prevention techniques and approaches. The strategy
directs each covered DOI facility to report releases and offsite transfers to TRI by July
1,1995, and commits DOI to voluntarily reduce releases and transfers of toxic chemi-
cals by 1999 as specified in Section 313 of EPCRA."
DOI issued General Guidance on Pollution Prevention and Right-to-Know in response
to Executive Orders 12856 and 12969.12 This guidance represents DOI's commitment
to the sound management and treatment of solid and hazardous waste and other pollut-
ants on DOI managed lands and facilities. It is embodied in DOI's hierarchical ap-
proach to waste management (pollution prevention, waste reduction, waste manage-
ment and cleanup, and restoration). Additionally, this commitment is also reflected in
2*!W-y;¥-i;~-:«:>KK««^S"5^«'p:y
The Okefenokee National WiM
vides habitats for a variety of wildlife and recreational opportunities for visitors,.;
Since 1995, the Refuge has eliminated the storage and utilization of over 400
hazardous substances and has decreased its solvent usage by '60 percent through
modification of its parts and paint cleaning operations.. '•..
10 General Services Administration, Executive Order 12856 Pollution Prevention Strategy.
11 U.S. Department of the Interior, Executive Order 12856 Pollution Prevention Strategy.
12 DOI General Guidance on Pollution and Right-to-Know (September 1995).
113
-------
source reduction strategies in facility management and the acquisition of environmen-
tally-preferable products and services.
The National Park Service (NFS) has developed its own pollution prevention strategy
for achieving the requirements of Executive Order 12856. The strategy involves pre-
paring pollution prevention plans for each NFS facility and providing public access to
information on the presence of hazardous and toxic materials used and stored. To
facilitate compliance with the strategy, NFS sponsored the development of a training
course to help NFS employees develop pollution prevention plans, conduct opportu-
nity assessments, and comply with EPCRA requirements.'13
In addition, DOI implemented an Environmental Achievement Award, which recog-
nizes winners at three levels: Bureaus with outstanding performance, employees with
outstanding performance at each Bureau, and contractors with outstanding performance.
Examples of DOI's information transfer initiatives include a series of 30 pollution
prevention fact sheets to educate DOI facility managers about pollution prevention
opportunities available for certain activities, such as vehicle maintenance, metal
working, pest management, building maintenance, concession stands, and others.
Some DOI Bureaus have developed their own pollution prevention programs and ini-
tiatives. For example, the former Bureau of Mines developed a publication to Help
hardrock and industrial minerals mining and milling facilities reduce or eliminate
environmental pollution. The report includes worksheets designed to help mining
facility operators to establish their own pollution prevention programs.14
i'1 " •'• , i ... •, • i • . .•• i' .: : •
Some parts of DOI are using pollution prevention approaches to their own wastes.
U.S. Geological Survey (USGS) laboratories generate various waste streams contain-
ing phosphoric, sulfuric, boric, and hydrofluoric acids, potassium dichromate and
sodium diphenylamine. These chemical uses and wastes have been targeted for a 50
percent reduction by 1999. The USdS labs have already reduced these wastes through
process modifications. Prior hazardous waste annual disposal costs averaged ap-
proximately $400,000. To date, reductions have resulted in reduced annual waste man-
agement costs to approximately $225,000.
•'!.••
n. I .
National Aeronautics and Space Administration
t' '
In 1994, the National Aeronautics and Space Administration (NASA) developed a
Pollution Prevention Strategy in compliance with the requirements of Executive Order
12856. As part of this strategy, NASA committed to prevent or reduce pollution at the
source whenever possible. Specific activities described in the strategy include com-
mitments to: . "
13 IKS. National Park Service, Pollution Prevention and Community Right-to-Know Training Manual.
Prepared by EA Engineering, Science, and Technology, Inc., under Indefinite Quantities Contract No.
1443-CX-2000-95-006, Task Order No. 1, for the National Park Service Hazardous Waste Program.
I
14 Witkowsky, D.S. Pollution Prevention in Mining and Mineral Processing - Waste Assessments for
Mines andMills. U.S. Bureau of Mines.
114
-------
f; ;•

• Review and revise NASA specifications and standards to reduce the use of
products containing extremely hazardous substances and toxic, chemicals;

• Use life-cycle cost analysis and source reduction potential as criteria in setting
project priorities; • •

• Prepare ;and begin to implement a written pollution prevention plan at all
major field installations and facilities by December 31, 199515; and

• Strive for a minimum of 50 percent reduction (from a 1994 baseline) for toxic
chemicals by the turn of the century.