&EPA
Industrial Pollution
Prevention
Project
United States
Environmental Protection
Agency
Office of Water
Mail Code 4301
EPA.82Q-F-93-QQ1
October 1993
Industrial Pollution Prevention Project
(IP3)
Overview
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
slightly.
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.
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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.
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IP3 Demonstration
Projects
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
prevention.
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.
Nebraska
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-
sions.
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.
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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
Process."
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
4301
Office of Water
401 M Street, S.W.
Washington, DC 20460
(202) 260-7811
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