Industrial   Pollution
                              United States
                              Environmental Protection
                            Office of Water
                            Mail Code 4301
October 1993
Industrial Pollution Prevention Project



In 1991, EPA initiated the Industrial Pollution Prevention Project (IP3). The IP3
is an Agency-wide project to see:
II  how pollution prevention can be incorporated into EPA's determination of
   the best available treatment technologies for particular industries; and
II  how the pollution prevention ethic can be embraced by industry, the
   public, and all levels of government.

PoEution prevention is an approach for protecting the environment that recog-
nizes that the best way to clean up the environment is to prevent pollution in
the first place.
             Background  For the most part, pollution control in the United States has been carried out by
                               governments setting limits on discharges, based on the best available treatment
                               technology for a given discharger.

                               The effectiveness of treatment technologies in controlling the discharge of
                               pollution has improved over the years. However, the 1991 Toxics Release
                               Inventory (TRI) showed that there is not a downward trend in the waste
                               generated prior to treatment, control, or disposal. Also, industry's TRI projec-
                               tions for 1992 and 1993 showed waste generation to be flat or even increase

                               According to the Science Advisory Board, EPA should emphasize pollution
                               prevention as the preferred option for reducing risk. Pollution prevention
                               reduces the transfers of pollution among air, land, and water. It also reduces
                               residual risks because the poEution is not generated in the first place.

                               PoEution prevention benefits industries and municipalities as weE as the
                               environment. Pollution prevention requires manufacturers to analyze each step
                               in their production processes and make changes in the process or materials that
                               they use. This usuaEy results in increased efficiency in the production process
                               and reductions in the amount of energy, water, raw materials, or other re-
                               sources. It also results in reduced poEution control costs. Most importantly, the
                               environment benefits as a result of reduced discharges of poEutants into
                               surface water, ground water, and air.

Key Elements   The IP3 consists of seven distinct studies, four demonstration projects, and two
                      outreach activities.

          Studies   •  Barriers and incentives
                         This study examines the most promising incentives to overcome existing
                         barriers to industrial pollution prevention.

                      •  Technology innovation waivers
                         This study examines the innovative technology waiver provisions (301(k))
                         of the Clean Water Act (CWA). This section of the Act provided an oppor-
                         tunity for permittees to request that compliance be extended for up to two
                         years if they use innovative technology to meet or exceed permit limits.
                         The study explains why the program did not work.  It presents a legislative
                         and regulatory history of the program, including a comparison to the
                         variance program under the Clean Air Act. Further, the study highlights
                         several successful programs at the national and state levels that have
                         promoted technology innovations. It also discusses the potential role of a
                         revised and redesigned program to promote technology within the CWA.

                     •  Statute analysis
                         This analysis identifies and examines the industrial pollution prevention
                         opportunities in two major environmental statutes: the Clean Water Act
                         (CWA) and the Resource Conservation and Recovery Act (RCRA).

                     •  International case studies
                         This is a series of "success stories" describing how industries throughout
                         the world including Canada, China, France, Germany, the Netherlands,
                         the former Soviet Union, the United Kingdom, Sweden, Denmark, Fin-
                         land, Spain, Greece, Italy, Belgium, India, and South Africa, successfully
                         used pollution prevention innovations. The objective of compiling these
                         case studies is to help EPA and U.S. industries learn from what is taking
                         place in other countries.

                     •  Analysis of the effluent guidelines process
                        This is an analysis of the process by which EPA determines effluent limits
                        for specific industries. The analysis shows where in the process pollution
                        prevention considerations can be incorporated.

                     •  Technologies in selected industries
                        This is a series of technical studies examining specific pollution prevention
                        technologies for the pulp and paper, pharmaceuticals, metals manufactur-
                        ing, and pesticides industries.

                    •  A retrospective on the leather tanning industry
                        This examines how four leather tanneries have used pollution prevention
                        as well as control technologies to comply with the promulgated effluent
                        guideline for leather tanneries. It also provides information on how facili-
                        ties make decisions when complying with the effluent requirements.

IP3 Demonstration

The IP3 includes Demonstration
Projects in four different geo-
graphical regions across the
nation. ^

The purpose of these regional pilot
projects is to:

(a) demonstrate different specific
   aspects of the pollution pre-
   vention approach;

(b) actually prevent pollution at
   real locations; and

(c) gain new insights from the
   demonstrations that will be
   useful to both industry and
   EPA in furthering pollution
New England
A demonstration of how two states (MA and NH) were able to cooperate
to build source reduction into pretreatment and industrial programs to
prevent discharge of toxics into the Merrimack River. The project also
demonstrates methods and incentives for preventing pollution through
process change and product alternatives in the cases of both direct dis-
chargers and indirect dischargers.

A demonstration of the implementation of pollution prevention at a
machinery manufacturing company in Columbus, Nebraska. This project
focuses on three aspects of the facility's manufacturing operations: electro-
plating, hot dip galvanizing, and painting.

Southern California
A demonstration of enhanced communication and coordination between
federal, state, and local regulatory agencies (including POTWs) to promote
industrial pollution prevention. This project will also result in a model
multi-media pollution prevention program for the industrial laundry
sector, which looks at industrial solid waste, wastewater, and air emis-

Pacific Northwest
A demonstration of pollution prevention at a pulp and paper mill in
Tacoma, Washington that developed an implementation plan for the mill
as well as a model plan and a bibliography for use by similar mills. This
project will also demonstrate how pollution prevention can be incorpo-
rated in the enforcement settlement process.

Outreach Activities
   The IP3 Focus Group
   This 23-member Group was comprised of representatives from industry,
   labor, environmental groups, academia, and all levels of government. This
   Group, for 18 months, provided a forum for constructive dialogue among
   all the groups affected by adoption of industrial pollution prevention
   measures. It also provided continuous review of and input to the project to
   ensure useful results and products, and recommended ways to improve
   pollution prevention technology transfer and information sharing. The
   Group also developed specific recommendations to EPA on "How Best to
   Promote Industrial Pollution Prevention Through the Effluent Guidelines
       A Look Ahead
                                Consumer Education
                                This outreach effort seeks to produce a prudent and effective strategy to
                                communicate with consumers —to change consumer demand away from
                                products that are a significant cause of pollution either when they are
                                being manufactured or when they are disposed. This effort is based on
                                careful research on when and how to communicate with the public on
                                environmental issues.
Pollution prevention allows the regulated community and regulators to take a
broader, more integrated look at the requirements of environmental regula-
tions and the tools available for reducing industrial discharges. It further
allows them more flexibility toward finding the most efficient and effective
ways to reduce risk and protect the environment.

The results from the IP3 studies and demonstration projects, when completed,
will provide innovative ideas and approaches for states, local government, and
industry on how to incorporate pollution prevention in pollution control
programs for industrial sources.

These documents are in various stages of completion. The drafts where avail-
able may be obtained from:

Jim Lund
U.S. Environmental Protection Agency
Office of Water
401 M Street, S.W.
Washington, DC  20460

(202) 260-7811