vvEPA
              United States
              Environmental Protection
              Agency
              Office of Research and
              Development
              Washington, DC 20460
EPA/600/9-90/039
September 1990
The Environmental
Challenge of the 1990fs

Proceedings
              International Conference on Pollution
              Prevention: Clean Technologies and Clean
              Products

              June 10-13, 1990
                                  Printed on Recycled Paper

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                                              EPA/600/9-90/039
                                              Sept. 1990
              THE ENVIRONMENTAL CHALLENGE  OF THE 1990s
Proceedings of the International Conference on Pollution Prevention:
                Clean Technologies and Clean Products
                  Washington, DC,  June  10-13,  1990
       Sponsored by the U.S.  Environmental  Protection Agency:

                  Office of Research  & Development
                Risk Reduction Engineering Laboratory
                       Cincinnati, Ohio  45268

             Office of Policy,  Planning,  and Evaluation
                     Pollution Prevention Office
                        Washington, DC  20460
                           Co-sponsored by:

           International  Association for Clean Technology
                  1030 Wien, Fasangasse  20, Austria

                        Department of Defense
                        Washington, DC   22314

                         Department of Energy
                        Washington, DC   20585
                           Coordinated by:

           Science Applications  International  Corporation
                       McLean, Virginia  22102
                           Project Officer:

                           Kenneth R.  Stone
                Risk Reduction Engineering Laboratory
                RISK REDUCTION ENGINEERING LABORATORY
                  OFFICE OF RESEARCH AND DEVELOPMENT
                U.S.  ENVIRONMENTAL PROTECTION AGENCY
                       CINCINNATI, OHIO  45268

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                                     ;•'..'••  '•. I/*.'.   ..-.; 3t.«3t,  Rooa 1670
                                     CiUoago, IL   60604

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                                  DISCLAIMER

      The following papers have been reviewed in accordance with the U.S.
Environmental Protection Agency's peer and administrative review policies and
approved for presentation and publication:

      Waste Minimization Assessments at Selected DoD Facilities by James S.
      Bridges

      Chrome Recovery Via Adsorptive Filtration by Lisa M. Brown, M.M.
      Benjamin, and T. Bennett

      Evaluation of EPA Waste Minimization Assessment by Mary Ann Curran and
      K.R. Stone

      Waste Reduction Evaluations at the Philadelphia Naval Shipyard and Fort
      Riley, Kansas by George C. Cushnie, Jr.

      Reclaiming Fiber from Newsprint by Dry Methods by Dennis E. Gunderson,
      C.T. Scott, R.L. Gleisner, and T.M. Marten

      Managing a Hazardous Waste Minimization Investigation by Garry 0.
      Kosteck and S.P. Sobol

      Illinois/EPA WRITE Program by Dr. Gary D. Miller, W.L. Tancig,
      and P.M. Randall

      Waste Reduction at a Printed Circuit Board Manufacturing Facility Using
      Modified Rinsing Technologies by Paul Pagel

      Integrated Permits and Multi-media Pollution Prevention by Dr. Mahesh K.
      Podar

      Prototype Evaluation Initiatives in a New Jersey Vehicle Maintenance and
      Repair Facility by Paul M. Randall


      All other papers published in this Proceedings describe work that was
not funded by the U.S. Environmental Protection Agency and therefore do not
necessarily reflect the views of the Agency and no official endorsement should
be inferred.

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                                   FOREWORD

      Today's rapidly developing and changing technologies and industrial
products and practices frequently carry with them the increased generation of
materials that, if improperly dealt with, can threaten both public health and
the environment.  The U.S. Environmental Protection Agency is charged by
Congress with protecting the Nation's land, air, and water resources.  Under a
mandate of national environmental laws, the Agency strives to formulate and
implement actions leading to a compatible balance between human activities and
the ability of natural systems to support and nurture life.  These laws direct
the EPA to perform research to define our environmental problems, measure the
impacts, and search for solutions.

      The Risk Reduction Engineering Laboratory is responsible for planning,
implementing, and managing research, development, and demonstration programs.
These provide an authoritative defensible engineering basis in support of the
policies, programs, and regulations of the EPA with respect to drinking water,
wastewater, pesticides, toxic substances, solid and hazardous wastes, and
Superfund-related activities.  This publication is one of the products of that
research and provides a vital communication link between researchers and
users.

      These Proceedings from the first biennial International Conference on
Pollution Prevention; Clean Technologies and Clean Products provide the
results of projects recently completed by RREL and current information on
active projects.  These Proceedings also provide information on pollution
prevention activities currently underway in the private sector, and in nations
other than the United States.

      The Risk Reduction Engineering Laboratory and the Pollution Prevention
Office will continue to sponsor this conference in order to assure that
results of research efforts and policy decisions are rapidly transmitted
between government and industry, and between national governments, and among
those interested in the area of pollution prevention.  The 1990 Conference
attracted 1,007 attendees from industry, government, and academia, including
participants from 43 countries.


                          E.  Timothy Oppelt,  Director
                     Risk  Reduction  Engineering Laboratory
                                      m

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                                   ABSTRACT

      The International Conference on Pollution Prevention: Clean Technologies
and Clean Products, was held in Washington, DC, June 10-13, 1990.  With
support from the Department of Defense, the Department of Energy, and the
International Association for Clean Technology, this conference explored the
innovative technologies and socio-economic issues arising in the field of
pollution prevention.  These Proceedings include papers and transcripts of
most of the presentations made during the three-day conference.
                                      iv

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                               TABLE OF CONTENTS

                                                                       Page
Towards Implementation of Environmental Policies
  by Dr. Hanns A. Abele	  1-8

Systematic Process Design and Analysis for Waste Minimization
   by Dr. Robert C. Ahlert	  9-18

Cleaner Technologies in the Tanning  Industry
  by Dr. Ken Alexander and V. Donohue	  19-31

Waste Minimization - Approaches and  Techniques
  by Dr. Raymond J. Avendt	  32-40

The Army's Hazardous Waste Minimization Program
  by Robert P. Bartell. J.L. Mahannah, and M.J. Dette	  41-47

Corporate Transition to Multi-Media  Waste Reduction Measuring
Waste Reduction Progress
  by David M. Benforado	  48-56

Creating the Conditions for Sustainable Development: Programmes and
Instruments for Pollution Prevention
  by Dr. Robin Bidwell	  57-66

Technical Assistance Tools and Approaches Waste Reduction Incentives
and Barriers:  The Florida Experience
  by William W. Bilkovich	  67-72

Underground Coal Gasification:  Groundwater Contamination
Can Be Prevented
  by John E. Bovsen. J.R. Covell, J.M. Evans, and C.R. Schmit	  73-85

Business to Business Networking - A  Cycle or Short Circuit?
  by J.B. Brand. Jr	  86-88

Waste Minimization Assessments at Selected DoD Facilities
  by James S. Bridges	  89-99

Chrome Recovery Via Adsorptive Filtration
  by Lisa M. Brown. M.M.  Benjamin, and T. Bennett	100-110

The State of Ohio Pollution Prevention Technology Transfer Program
  by Orville S. Burch and P.S. Rafferty	111-117

The Use of Economic Incentives for the Introduction and Adaptation
of Clean Technologies
  by Dr. Demetrios G. Cacnis	118-129

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                                                                       Page
Pollution Prevention Through Waste Reduction  in Florida
  by Janeth A. Campbell and R. Wilkins	130-139

A Ride Through Space - With Care and Concern
  by William J. Carroll	140-143

Organizational Behavior as a Key Element  in Waste Management
Decision Making
  by Peter B. Cebon	144-153

An Approach to Hazardous Waste Reduction  and  Pollution Control  in
Thailand's Upcoming Terphthalic Acid Industry
  by Dr. Ramendra N. Chakrabartv	154-163

Address Before the EPA/IACT International Conference on
Pollution Prevention
  by Dr. Barry Commoner	164-174

Information Networking for Pollution Prevention
  by Daniel E. Cooper	175-177

Facility-Specific Waste Minimization Plans at Westinghouse
Hanford Company
  by P.A. (Penny) Craig	178-187

European Experiences in Stimulating Cleaner Technologies
  by Drs. J. Cramer and F. van den Akker	188-195

Evaluation of EPA Waste Minimization Assessment
  by Mary Ann Curran and K.R. Stone	196-203

Waste Reduction Evaluations at the Philadelphia Naval Shipyard
and Fort Riley, Kansas
  by George C. Cushnie. Jr	204-217

Securing Safe Substitutes:  Policy Measures to Promote Safe
Chemical Substitutes
  by Gary A. Davis	218-227

Open-Gradient Magnetic Separation for Physical Coal Cleaning:
Results for Pittsburgh #8 and Upper Freeport Coals
  by Richard D. Doctor and C.D. Livengood	228-235

An International  Environmental Conscience and America's Role
  by Donald J. Ehreth	236-245

Strategies for Source Reduction
  by Christine A. Ervin	246-253
                                      vi

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                                                                      Page
Multimedia Local Government Pollution Prevention Programs
  by Anthony Eulo	254-262

Materials Substitution at the Rocky Flats Plant
  by Ann C. Ficklin and G.L. Hickle	263-273

Moving Beyond the Rhetoric:  Challenges for the 1990s
  by Kathryn S. Fuller	274-283

Regulatory Impediments to the Reclamation and Reuse of Spent
Potliner from Primary Aluminum Production
  by Dr. Jack H. Goldman and J.S. Holik	284-293

Reclaiming Fiber from Newsprint by Dry Methods
  by Dennis E. Gunderson. C.T. Scott, R.L. Gleisner,
  and T.M. Harten	294-306

DoD Oil and Hazardous Substances  Pollution Prevention Program
  by Dr. Brian P.J. Hiqgins	307-312

DLA Comprehensive Hazardous Materials Management Program
  by W. Joseph Hoenscheid and W.  Beddoes	313-322

Economic Incentives for Recycling:  An Examination of U.S.
Environmental Policy for Financing Recycling Facilities
  by Scott L. Hoffman and M.H. Levin	323-331

Societal Eco-Sustainability:  The Opportunities and Responsibilities
for Colleges and Universities
  by Dr. Donald Huisingh	332-341

The Legal Basis for Waste Avoidance  and Waste Utilization  in the
Federal Republic of Germany
  by Will A. Irwin	342-345

Segregation for Recycle and Reuse of Hazardous Chemical Material
at Los Alamos National Laboratory
  by Patrick Josev	346-350

Waste Minimization Strategy Flexible Polyurethane  Foam Manufacture
  by Dr. Clifford M. Kaufman  and  M.R. Overcash	351-360

Waste Minimization Assessment Centers
  by F. William Kirsch and  G.P.  Looby	361-371

Liability and Benefit Sharing for Joint  Production Activities
Involving Risks
  by Dr. Paul R. Kleindorfer  and  A.  Watabe	372-379

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                                                                      Page
Managing a Hazardous Waste Minimization Investigation
  by Garry 0. Kosteck and S.P. Sobol	380-386

Implementing Incentives:  Experience and Expectations
  by Michael H. Levin	387-396

IGT Bioprocess Technology Development Efforts for the Production of
Clean Fuels
  by Andrea Maka and V.J. Srivastava	397-404

Energy Resource vs. Buried Waste: Spent Potliner in a Cement Kiln
  by Elbert G. Massad	405-407

The Enlarged European Environmental Market:  Impediments and
Opportunities
  by Jan C. McAloine	408-412

U.S. Air Force Hazardous Materials Management Initiatives
  by Brian D. McCartv and J.J. Short	413-422

Illinois/EPA WRITE Program
  by Dr. Gary D. Miller. W.L. Tancig, and P.M. Randall	423-433

Pollution Prevention in the Electric Utility Industry
  by Michael J. Miller	434-444

Coal Refuse To Energy
  by Dr. Ronald D. Neufeld	445-453

Sandia's Search for Environmentally Sound Cleaning Processes for the
Manufacture of Electronic Assemblies and Precision Machined Parts
  by Michael C. Obornv. M.G.  Benkovich, J.V. Dichiaro, D.R. Frear,
  E.P. Lopez, D.R. Ostheim, R.F. Salerno, and R. Waterbury, Jr	454-464

Recovering Value from Process Wastes
  by Dr. Frank T. Osborne. C.T. Chi, and J.H. Lester	465-474

Design for the Entire Life Cycle:  A New Paradigm?
  by Dr. Chuck Overbv	475-482

Waste Reduction at a Printed  Circuit Board Manufacturing Facility
Using Modified Rinsing  Technologies
  by Paul Page!	483-492

Department of Defense Pollution Prevention Initiatives
  by William H. Parker.  Ill	493-499

Crop and Pasture Land Conversion Opportunities for Mitigating
Global Warming
  by Peter J. Parks	500-509
                                      vm

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                                                                      Page
Toxic Waste Trade in Africa and the Caribbean:  From Regulation to
Pollution Prevention
  by Hugh G. Pilgrim	510-519

Integrated Permits and Multi-media Pollution Prevention
  by Dr. Mahesh K. Podar	520-527

Pollution Prevention in the 21st Century:  Lessons from Geneva
  by Dr. Arthur H. Purcell	528-534

Prototype Evaluation Initiatives in a New Jersey Vehicle Maintenance
and Repair Facility
  by Paul M. Randall	535-544

Short-Rotation Woody Crop  Opportunities to Mitigate
Carbon Dioxide Buildup
  by J. Warren Rannev (speaker), R.L. Graham, A.F. Turhollow,
  and L.L. Wright	545-557

Corporate Transition to Multimedia Waste Reduction
  by Denny B. Redington	558-562

Pesticide Application Equipment Rinse Water  Recycling
  by Darryl Rester	563-572

Pollution Prevention in Textile Wet Processing  - An Approach  and
Case Studies
  by Stephanie Richardson	573-581

The Business Council of Alabama Waste Minimization  Initiative
  by David L. Roberson	582-584

Wastewater Recycle  Facility at  IBM East  Fishkill
  by James G. Sales	585-593

State Mandated Pollution  Prevention - Legislative and  Regulatory
Initiatives to Compel Reduction of Use of Hazardous Chemicals
  by John M. Scagnelli	594-603

The Linear Tubular  Reactor -  A  New Process for  Reclaiming  Used  Oils
and Decontaminating Other Hazardous Wastes Via  Molecular Threshold
Distillation and  Molecular Condensation
  by Dr. Christian  Schoen	604-612

Approaches to Reducing  Environmental Risk Through Pollution
Prevention
  by John J. Segna  and  R.K. Raghavan	613-623
                                       ix

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                                                                      Page
Educational Aspects of Multimedia Pollution Prevention
  by Dr. Thomas T. Shen	624-632

Industrialization, Development and the Environmental Crisis in
Developing Economies of the Caribbean Basin Region
  by Dr. Winston H.E. Suite	633-642

An Innovative Graduate Thesis:  A Team Evaluation of Used Oil End Uses
  by Cynthia J. Talbot. J.P. Byrne, C.A. Cody, P.O. Doyle, A.M. Mayor,
  A.M. Reid, and S.K. Rosner	643-651

Presentation at the Opening Plenary
  By Dr. A. Tchecknavorian-Asenbauer	652-655

Clean Production:  From Concept to International Campaign
Through Networking
  by Beverley Thorpe and L.J. Bunin	656-664

Recovery of Chromium from Tannery Wastewaters
  by Dr. Dimitrios Tsotsos	665-675

Waste Prevention Strategies in the Flemish Region of Belgium
  by P. Van Acker	676-685

Water Pollution Prevention in The Netherlands
  by Dr. Frans A.N. van Baardwi.ik and H.B. Pols	686-695

New Directions in Waste Minimization Technologies:  Water
Conservation Offers Multi-Faceted Benefits
  by Amy Vickers	696-702

Process Options for Waste Minimization and Metal Recovery for the
Metal Finishing Industries
  by Dr. Clifford W. Walton. A.C. Hillier, and G.L. Poppe	703-712

CFC Pollution: Repairing the Ozone Hole Through Municipal Legislation
  by Dr. Frances E. Wins'!ow	713-719

A Novel Low-Pollution Approach for the Manufacture of Bleached
Hardwood Pulp
  by Alfred Wong and J. Tichy	720-729

Towards the Promotion and Implementation of Pollution Prevention and
Clean Technology  in Developing Countries:  The Case of Ghana
  by Dr. Gregory E. Yawson	730-737

Hazardous Waste Minimization:  Making It Happen
  by Paul J. Yaroschak	738-747

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   TOWARDS IMPLEMENTATION OF ENVIRONMENTAL POLICIES

                       HANNS A. ABELE
               WIRTSCHAFTSUNIVERSITAT WIEN
               (UNIVERSITY OF ECONOMICS AND
             BUSINESS ADMINISTRATION VIENNA)
                   VIENNA, AUSTRIA A-1090
                          ABSTRACT
     For decades it has been known that  environmental problems
constitute a distortion in the allocation of resources.  How to deal with
these distortions and to improve the working of an economy has been
controversial.  Recent developments in economic theory especially in
the  fields of  bargaining, mechanism design,  and  economics  of
information offer hope to find solution for the urgent problems which
are incentive  compatible  and rely on a sound decision theoretic
framework.
     The paper surveys recent results and discusses their chances for
policy implementation. Both views from the policymaker and from the
decision  making firm are covered.   This  allows  to  deal with the
problem of social costs and external effects using the concepts and
ideas of results on strategic behavior.
     Because of the complexity of the issues and the lack of generally
working mechanism a pragmatic approach is favoured.

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                 INTRODUCTION AND SUMMARY
      For decades it has been known that  environmental problems
constitute a distortion of the allocation of resources. That means that
the welfare of economic agents is not at  the best possible level.
Viewed from an efficiency criterion either more inputs are used than
necessary or output is not at the achievable level or both.  Economics
has  been traditionally interested  in  finding  the reasons for such
deficiencies of  economic  processes.    Basically  the  main  line of
research was to identify welfare losses and design policies to  correct
inefficiencies in allocations of resources.

      Within a Walrasian general equilibrium framework it has been
relatively easy to establish the reason for allocative distortions.  Since
the main results of general  equilibrium theory  establish  the existence
of a general equilibrium in a competitive market framework it is clear
that any failure of markets or any violation of the competitive structure
(assumptions)  may imply some suboptimality.  The competitive general
equilibrium  can be shown to be efficient or optimal with respect of the
Pare to criterion. The conclusion of the long debate has been that
market  failures and externalities give rise  to  allocative deficiencies.
Such externalities can be very general.  It suffices that consumption of
an individual is dependent  on the consumption of another individual
like behavior according to "keep up with Joneses".

      Environmental problems like pollution or hazardous waste are
therefore theoretically speaking  simple questions  of  the  effect of
externalities on the efficiency of an allocation.  They constitute no
extraordinary  difficulty at least at  first  reflection.   Since  Pigou
suggested a tax/subsidy solution to deal with such deviations from
Pareto optimality in the 1920's there has been an ongoing debate.  The
opponents  of  Pigou's  position argued that  it is impossible  for
government to design the correct intervention  mechanism because it
lacks the necessary information.   Furthermore one can construct
examples where the production functions of the firms involved  are
such that government intervention deteriorates the situation instead
of improving it.
      The other prominent strand of ideas  seeks a solution of the
problem in supplementing the seemingly not correctly functioning
market  with a negotiating  structure.   Coase1 is regarded as having
formulated  the central  ideas in his famous  paper on social cost. It
holds that  people  being unconstrained to bargain will reach an
efficient  economic solution of an externality problem.

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     However, despite this appealing result there are fundamental
doubts about its relevance.  The basic assumption of the existence of a
costless bargaining and  enforcement mechanism as  well as perfect
information of the parties involved limit the scope of the applicability
of the Coase  "theorem"...Whether it is probable that these conditions
are fulfilled is rather questionable.  Sometimes the discussion  rests
more on ideology than analytical arguments.
     Both lines of theoretical reasoning, a more centralized solution
relying on government action and a decentralized "market" oriented
bargaining approach, cannot provide solutions for  the problem of
environmental externalities in  general.  The  problem  is far  more
complex than it seemed to be some decades ago.

     On the  other hand  the pressure to provide satisfactory solutions
has  increased dramatically.   Continuous population  growth and
increased use of industrial production techniques create  enormous
amounts  of  pollution  and  environmental deterioration.   Public
awareness has responded to the  challenge.  High visibility of accidents
- Seveso,  Bhopal, Tschernobyl, Alaska - forested public understanding
of environmental hazards and their possible long run effects.  People
learned that  there are  limits of ecosystems which imply that it is
possible  to cause destabilization of the global system risking the
extinction of  mankind.
     Needless to say this situation poses a great dilemma.  While the
risks may need immediate action the theoretical foundations are in
dispute not  only  in science like  the  discussion of  the greenhouse
effect but also in social sciences and economics leading to a deadlock
as far as the design  of effective  policies is  concerned.   If the
environmental problems transgress  national borders as they  do in
most cases a global response is  necessary.  This  makes solutions not
easier.
1 RONALD CASE, The Problem of Social Cost. Journal of Law and Economics. 1960, I,
1-44

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     INSTITUTIONS AND POLICIES:  THEORETICAL REMARKS
     In order to measure the effects of externatilities and policies or
institutional settings to remedy undesirable outcomes it is necessary
to have  a benchmark  economy.   As optimality criterion  Pareto-
efficiency is  used.  That  means  it is impossible to  find another
outcome  of the system improving at least one agent without making
another one worse  off.

     If for some  reason assumptions of this  model of a market
economy  are  violated,  optimality  in  the sense of Pareto  can be
precluded. One such assumption is independence of the economic
agents.  A factory may emit smoke and thus influence the production
of a neighboring  laundry.   The  production of the latter is thus
dependent on the  output or the production  of the first.  Similarly,
interdependency may arise in consumption.  Another formulation  of
the same effect is to diagnose a discrepancy of social and private costs.
The polluting firm  does not calculate the  costs of avoiding the smoke
or additional cleaning, because there is no necessity for it. However, if
there is an agency levying a pollution tax on the emitting firm and
paying a subsidy to the laundry for the damages, it was thought to be
possible to internalize the social costs and achieve  again an optimal
outcome.  This was Pigou's approach.
     In contrast Coase argued that the laundry owns a property right
to clean  air and  therefore  can hold the  smoke  emitting factory
responsible and liable. By negotiations the agents involved will resolve
the suboptimality.  Smoke will be emitted  only if it is profitable for the
firm to do so after compensating  the  laundry for damages.  Hence
efficiency is again secured but without government intervention.
     The discussion of the two competing approaches  as well as the
analysis why they fail in certain circumstances and last not  least a
better understanding  of the  assumptions on which they  rely
contributed a lot to the knowledge of the functioning of an economy.
Despite the prominent role of markets in discussions about economics
(and ideology) a  lot of important features  of exchange, interaction and
coordination  of decisions has been left in rather vague formulations
resting on attractive but  unproven  ideas.   Research  faced  this
challenge and has  tried to remedy these deficiencies.

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DESIGNING REGULATORY POLICIES
      Critics of the Pigouvian taxes/subsidies scheme were quick to
point out that such a policy cannot solve the problem of improving the
welfare characteristics of a distorted allocation simply because the
government has  not  the necessary knowledge to  design the policy.
Even if it would be possible to collect the information it would be far
to costly to do so.  Thus the overall  result would be  an inferior
outcome.

      In response to  the critique  there are numerous studies of the
influence of limited information on the  possibility of regulation.2 To
illustrate the conceptual problems, assume that the regulator does not
know the cost function of the firm.  It can be either of two, a low cost
or a high cost function. Can the regulator decide on an optimal policy?
In general  when an  important characteristic of one party is not
observed by  the other, adverse  selection  occurs.   Informational
asymmetries and uncertainties add strategic elements  to the decisions
of the parties. It is not the same whether the  regulating agency has to
commit  itself to a  specific policy before  the  firm acts  or  only
simultaneous actions are allowed.  The firm may try to get higher
profits by misrepresenting its situation which can be countered by
providing incentives  to reveal the  true situation.   Monitoring may
improve the informational position of a regulator.  But  even monitoring
may be imperfect and for sure it is not costless.  If the firm, say, may
take  actions  which  cannot be monitored  and controlled by the
regulator, the situation is complicated again.   Moral hazard is possible
in several variants.  It may appear  as a second incentive problem in
addition to  adverse selection.  This has to  be accounted  for in the
design  of regulatory policies.  In  general a policy  which aims at
correcting one problem will not be useful in  the other situation, and
policies in the simultaneous presence  of both problems again need to
be rather different.

      Time  and dynamics  represent  another difficulty.   If certain
standards are set and the firm succeeds in  meeting  them and  as  a
consequence the standards are raised, the firm will  no longer  have
incentives to  comply with  the regulating efforts  (ratcheting).  Thus
multiperiod  regulatory policies need to be considered with respect of
commitment and credibility.
2 DAVID BESANKO, DAVID E.M. SAPPINGTON, Designing Regulatory Policy with
Limited Information. Harwood Academic Publishers:  Chury e.a. 1987.

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      Very  often multiple  regulators  as well  as  multiple firms
characterize the problem.   Sometimes  the  regulated  firms have
bargaining power to influence the goals of the regulator(s).  In any case
the complexity of the problems for the design of regulatory  policies
necessitate careful analysis and mechanism design.
DECENTRALIZED BARGAINING

      Can negotiations repair externalities?  A closer scrutiny of the
Coase "theorem"  made it  clear that  a crucial assumption for this
proposition is the absence of any private information.  Based on the
formulation of cooperative  game theory it is important for the result
that every player knows every other's payoff (utility, profit).3  In case of
private information, property rights and bargaining will not be a fully
efficient remedy.4  The distribution of property rights influences the
outcome together with the  specific bargaining  method used.  Even in
comparison to a bureaucratic institution the result may be more or less
efficient.5
      Intuitively a large number of participants that is a large number
of agents suffering from environmental damages seem to make it more
difficult to achieve an efficient outcome by negotiations.  Rob showed
in a recent contribution that it  is very  unlikely  to reach efficient
outcomes in the case  of many participants.6   Although it is socially
beneficial, a firm not knowing the true damages its  operation cause
will  abstain from operation  since the  stated  damages supersede its
profits because the participants  tend to  inflate their  compensation
demands. This adds another caveat to the general usefulness of the
properly rights and  negotiation approach.
3 KENNETH J. ARROW, The Property Rights Doctrine and Demand Revolution under
Incomplete Information. In:  M.J. BOSKIN (ed.). Economics and Human Welfare.
Essays in Honor of Tibor Scitovsky. Academic Press, New York e.a. 1979,23-39.

4 WILLIAM SAMUELSON, A Comment on the Coase Theorem. In ALVIN E. ROTH (ed.),
Game Theoretic Models of Bargaining.  Cambridge University Press:  Cambridge e.a.,
1985. 321-339.

5 JOSEPH FARRELL, Information and the Coase Theorem. Economic Perspectives,
1(2), Fall 1987, 113-129.

6  RAEFAEL ROB, Pollution Claim Settlements and Private Information.  Journal of
Economic Theory. 47 (1989), 307-333.

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     The increased effort of research on the subject of the allocation
of resources under uncertainty has led to a better understanding in
dealing with externalities.  A general picture emerges which can help
to guide decisions for environmental policies. Although it seems to be
that there is no  general solution possible, neither centralized  nor
individualistic, economic theory has  advanced a lot  and produced
suggestions for solutions in  specific circumstances. It is reasonable to
proceed by solving on a case by case approach.
    INSTITUTIONS AND POLICIES:  PRAGMATIC OBSERVATIONS
      Given the  complexities  of environmental problems and the
analog difficulties of their theoretical handling it is reasonable to try to
divide the questions in smaller parts and deal with these peces.
      With respect to  the time dimension it is possible to distinguish
(i) old problems, e.g. abandoned landfills,
(ii)  current problems, e.g. pollution and waste being created at the
moment,
(iii) future prevention of  environmental problems, e.g. shift to clean
technologies.
(i) One may feel that an environmental cleanup should be based on the
principle of strict retroactive liability.  This turns  out to  be  almost
impossible.  Very rarely all the  firms are  still in existence  having
dumped their waste on a site which is now regarded as a  dangerous
place. At the  time of the  dumping it was almost always perfectly legal
to do so.  The amounts of the claims would often force the firms into
bankruptcy. Therefore, they are ready to fight any order to pay for the
clean  up  as  long as  possible retarding  any  action  to reduce
environmental dangers.  Finally, they may argue that their  customers
profited from  their dumping activity because they  paid lower prices
than  they would  have done otherwise  in the past.7  Weighing all the
arguments and the experience of the Superfund  program in  the USA it
is clear that it is necessary in order to  improve environmental  quality
for the  public to pick up the lion's share of the costs together with
private business.
7 MAURICE R GREENBERG, Financing the Clean-up of Hazardous Waste: The National
Environmental Trust Fund. The Geneva Papers on Risk and Insurance, 14 (51, April
1989), 207-212.

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      (ii) To deal with present problems is the most difficult part of
the questions.  It is necessary  to use all the results of theoretical
research and invest in  technological developments.  A risk averting
strategy can be  to avoid hazardous waste as  much as possible.
Incentives may guide producers  to think about the life cycle of their
products and help by  shifting  to other  components  or process to
reduce environmental problems.
      (iii) For the future the core of an environmental policy has to be
to avoid known hazardous waste and pollution.  Again a shift to clean
technologies is of central strategic importance.
      In  the  international context it may be  advantageous  for  all
countries if the wealthier nations help the  developing countries to
avoid  errors they themselves made  with  respect to  a  clean
environment.   The establishment of an international fund  or in
addition an agency may  be  helpful to  stimulate efforts  to improve
environmental quality and develop policies  in an international context.
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    SYSTEMATIC PROCESS DESIGN AND ANALYSIS FOR WASTE MINIMIZATION

                   by: Robert C. Ahlert, PhD,  PE,  Dist.  Professor
                       Chemical & Biochemical  Engineering
                       Rutgers University
                       Piscataway, NJ 08855-0909
                              ABSTRACT
     The concept of 'audit' has become a cornerstone of policies and
programs dedicated to source reduction as .the primary mechanism for
hazardous waste minimization.  Audits are variously targeted at process
units, single processes or systems of processes [manufacturing plants]. In
parallel, audits have been described in terms of individual chemicals
species, process streams and overall differentials in plant inputs and
outputs [raw materials and products].  These considerations must be viewed
as environmental medium and waste state dependent, i.e., volatile matter
[air], liquid waste [water] and/or solid waste [soil]; note, these
relationships are intentionally simplistic.

     Within the intended context of an audit, it is the fundamental mass
balance of Chemical Engineering process design and analysis.  The mass
balance or audit is characterized by a point in three-dimensional process
space.  Process space, from either a design, operations or regulatory
perspective, is nearly continuous in scale and fineness of chemical
identification and relatively discrete in physical state.  Scale, chemical
detail and waste state(s) must be specified before the audit is undertaken.
If economic factors are important, an energy balance must be included, under
the same prespecified conditions.

      A hypothesis has been examined critically: waste management is a basic
element of any process design.  A process design or redesign is to
incorporate alternative materials and new technologies that permit
elimination of hazardous waste at the point of origin.  Numerous case
studies have demonstrated that this philosophy does not differ substantially
from the design goals of high yield and product purity/performance, with
maximum net profit.  The dominant conclusion from this review is that mass
balances must be carried out at appropriate scales and detail; one or more
environmental media may be involved. Whether for design, operational control
or performance monitoring, mass balances must be matched with process
characteristics.  Detailed chemical compositions are not useful or
attainable in petroleum refining or drug manufacturing.

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                           INTRODUCTION
     During the decades of the 70s and 80s, the public mounted increased
pressures to stop pollution, enact legislation and implement technologies to
achieve and maintain a clean environment.  Congress responded with a broad
array of statutes addressing clean air, soil  and water, hazardous wastes and
toxic substances.  These Acts have seemed to some to be a patch-work quilt
of regulation and a sometimes contradictory maze of voluntary compliance and
mandatory requirements with enforcement orientation.  Emotions have run
high.  Society, in general, has been outraged by environmental insults
typified by Silent Spring and Love Canal.

     Immediate expenditures were once the governing factor in selection of
treatment technology by industry, municipalities and regulatory agencies.
However, in many cases, long-term operation,  maintenance and monitoring
costs are significant in comparison with short-term costs of 'permanent'
containment, detoxification or destruction.  The concept of long-term
(perhaps perpetual) care can extend to periods of 20 to 200 years.  Total
costs are very difficult to estimate and even more difficult to put into the
context of changing national economy.  True cost must include potential
liabilities and future mandates for waste recovery and additional treatment
based on more stringent environmental standards.  National policy has
shifted cost to only one of several factors that must be considered in waste
management and site remediation assessments under the Comprehensive
Environmental Response, Compensation and Liability Act of 1980 (CERCLA).

     Land-based containment remedies have been sharply criticized.  The
United States Environmental Protection Agency (EPA) has estimated that
most land disposal sites will fail within a limited number of years of
operation.  The House Committee on Energy and Commerce published a report
in 1985 indicating that 75% of all permitted land disposal facilities are
out of compliance, have leaked or operate under undefined conditions.
USEPA land bans issued over the last two years have confronted this
problem directly.

     Avoidance or minimization of waste generation  reduces the problem  of
disposal.  A major factor  in modern process design, process and  product
acceptability, and process  economics is waste generation  and disposal.   If  a
process can be redesigned  or a new process developed to eliminate waste
sources, by selection  of alternate raw materials  and/or revised  reaction
pathways,  it gains economic and operational advantages.   Waste minimization
through operations controls, personnel training,  maintenance  scheduling  and
adjustments to process operating conditions must  be evaluated.   Recycle  and
reuse, with or without purification or complete recovery, are methods well
suited to  solvents, reaction baths, process intermediates and co-products.
If waste  isn't generated,  in an  absolute sense, there  is  no need for
waste disposal.

     The  Resource  Conservation and Recovery Act of  1976  (RCRA) states  the
national  policy  that  "generation of  hazardous waste is to be  reduced or
eliminated".   California has taken the position that  "waste reduction  as
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opposed to waste management i s the 	preferred strategy"


                        REGULATORY PHILOSOPHY
     Congress began enacting environmental legislation in the early 1950s.
The legislative history and judicial/technical interpretations have been
summarized by Majumdar [1].  Initially, the approach was single receptor
oriented, as exemplified by the Clean Air Act of 1970 (CAA) and the Clean
Water Act of 1972 (CWA).  Subsequently, the approach became multi-media and
was changed to focus on hazardous and toxic substances.  The Toxic Substance
Control Act of 1976 (TOSCA) regulated anticipated and actual manufacturing,
processing and use of certain classes of these compounds.  In parallel, RCRA
defines a solid waste to be hazardous if it has any of the following
characteristics: ignitability, corrosivity, reactivity or toxicity.  RCRA
specifies maximum concentrations for eight metals and six pesticides, in
extracts derived by the EPTOX procedure; EPTOX has been supplanted by TCLP
extraction.  Under RCRA, EPA has established three hazardous waste lists:
wastes from nonspecific sources [spent nonhalogenated solvents], wastes from
specific sources [sludge and sediment from treatment of wood preserving
process wastewaters], and discarded commercial chemical products and all
off-specification chemicals, containers and spill residues.  Facilities and
equipment for transport, storage and disposal (TSD) of hazardous wastes are
regulated under RCRA, also.

     EPA rulemaking and proposed rulemaking are published in the Federal
Register (FR); the FR is published daily.  Annually, promulgated final
regulations are codified in the Code of Federal Regulations (CFR) [2],
Periodically, changes in the Code can be checked in the Supplement to the
Register [3]; the Supplement identifies where changes are located in the FR.

     RCRA was strengthened by the Hazardous and Solid Waste Amendments of
1984 (HSWA).  Whereas TOSCA and RCRA were intended to regulate uses,
inventories and disposal of hazardous and toxic chemicals, CERCLA, otherwise
termed Superfund, was aimed at correcting poor disposal practices of the
past and the numerous unclosed or uncontained sites that resulted.  The
Superfund Amendments and Reauthorization Act of 1986 (SARA) significantly
extended the scope of CERCLA/Superfund.  Requirments for emergency planning
and a mandate for community right-to-know were added.  Title III of SARA is
tied to Hazard Communications Standards (HCSs) of the Occupational Safety
and Health Administration (OSHA).  Workers must be informed of the hazardous
properties of chemical substances, whether the employer is a manufacturing
enterprise or not.

     The Williams-Steiger Act of 1970 established OSHA [4]; the intent of
Congress was to "assure as far as possible every working man and woman in
the nation safe and healthful working conditions and to preserve our human
resources".  Under this Act, designers are responsible for inherently safe
processes and plants.  The employer is responsible for all aspects of
operational safety.  Final standards set by OSHA are given in CFR [5]. As
with EPA, proposed and interim standards appear in the FR and changes to CFR
                                     11

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are summarized in the Supplement to FR [3].  To assist the designer in
efforts to assure safe systems and operations,  a number of organizations
have developed safety guidelines and recommendations for design criteria.
These include: American Institute of Chemical Engineers (Dow Chemical
Process Safety Guide), National Fire Protection Association and the
Manufacturing Chemists Association.  Burklin lists and discusses these and
other organizations and their resources [6, 7 & 8].  The roles of OSHA and
EPA are complementary; as an example, EPA issued standards for storage of
petroleum liquids in vessels larger than 245 m3 [9].  Chemical process
safety and environmental compatibility are closely coupled.


                           DESIGN PHILOSOPHY
GOALS & IMPACTS


     The traditional goals of chemical process design are maximum net profit
and rapid return on investment.  These goals are furthered by high process
yield and production of marketable materials of appropriate quality.  Design
and operational issues that have confronted owners/managers include:

               - Labor relations & safety
               - Public image (consumer products)
               - Insurance
               - Liabilities
               - Waste disposal

Industry has been mindful of the cost of accidents and the short- and long-
term effects of poor safety and operator training.  Anetti calculated that
the cost to a chemical company (DuPont) for the loss a single work day due
to injury exceeds $16,000 [10].  With respect to waste disposal, a Report
prepared for the National Research Council by a select Committee on
Institutional Considerations in Reducing the Generation of Hazardous Waste
concludes that "waste treatment and disposal must be properly priced" [11].
This is a critical design issue.  Waste management must be allocated by
product and process, not on a plant wide basis.

     Process design in the 90s is driven by regulation.  The major goals
have been expanded to include compliance.  Community and worker right-to-
know, safety, environmental compatibility of processes and products, plans
for emergency response, source reduction, product liability and economic and
criminal penalties have significant associated costs. Thus, design factors
have changed intent and technical substance; a suitable set of design
considerations includes:

               - High yield with recycle of secondary reaction products
                 or unreacted raw materials
               - Product quality and consumer safety
               - Minimum discharge to the environment
               - Worker and community education (Right-to-Know)
                                     12

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               - Emergency planning (SARA)
               - Hazardous waste detoxification or destruction (RCRA)
               - Sins of the past to be avoided (PRPs under CERCLA-NPL)
               - NIMBY
PROCESS EVALUATION
     The fundamental reference for process design and analysis is the Basis
of the Calculation or Mass Balance(s). This basis can be a point, i.e., vent
or transfer station, a process unit, i.e., reactor or separation device, a
process train or an entire facility.  Further, a mass balance can be
developed around a single chemical species or a complex of species,  i.e.,
light naphtha cut from a petroleum crude or still bottoms.  Levels of pure
species balances can and should vary from gross to trace in sensitivity;
production of sulfuric acid differs in this regard from pharmaceutical
manufacturing.  The statement of a Basis is essential, whether the issue is
optimum process design or regulatory assessment.

     Sheevers and Muir demonstrated the use of fragmented regulatory data to
draw a nominal mass balance around an entire facility for a single,  gross
chemical constituent, i.e., toluene [12].  Their model is far too simplistic
to fulfill a need for process performance evaluation.  In addition,  this
study reflects the difficulty of using regulatory reporting as a means of
performance evaluation and source assessment.  The facility selected for the
illustration operates in the batch mode and is highly time variant;  a large
number of processes utilize many raw materials, generate many products and
numerous waste streams.  The plant has an equally large numbers of co-
products, by-products and intermediates.

     How successful was the evaluation of toluene consumption and releases
by the target facility?  Over 95% is consumed on site and none is present in
products, e.g., toluene is consumed in hydrodealkylation and none is present
in product. The authors estimated that <1% of the toluene input is released
to air and <2% is discharged directly or indirectly in wastewater.  A RCRA
Manifest indicates <0.05% of the feed is transported off-site as a hazardous
waste.  Based on a regulatory foundation, the Basis is inconsistent and the
mass balance is not complete.


                        TRADITIONAL DESIGNS
     The process for manufacture of biodegradable detergent, i.e., sodium
dodecylbenzene sulfonate (DBS), is an excellent example of opportunity for
waste reduction.  Flow diagrams, economics and nominal mass balances are
found in the popular design text of Peters and Timmerhaus [13].  Alkylation
is followed by sulfonation and neutralization.  Alkylation reactor product
is fractionated; unreacted benzene and dodecane are recycled.  Aluminum
chloride sludge is wasted from the reactor after settling and heavy ends are
wasted from a distillation sequence.  Spent acid is wasted from the
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sulfonation reactor.  Water is separated in a spray drying step.  In all,
two pounds of waste are generated for each pound of dry product.  As little
as one pound of benzene in dryer overhead would yield an aqueous waste
stream at a concentration of about 20 ppm.  This is unacceptable for direct
discharge; the pretreatment standard for benzene is 134 ppb (any one day)
[14]. Spent acid, heavy ends and sludge are suspect hazardous wastes under
RCRA.  Redesign to minimize waste is appropriate.

     Production of polystyrene (PS) is used as the basic illustration for
process design and economic evaluation by Baalsel [15].  Polymerization is
carried out in aqueous suspension, with buffer, free radical source and
surfactant.  Polymer is washed with dilute hydrochloric acid, centrifuged,
rinsed and dried.  Wastewater is generated by centrifuging; additional water
is generated in the drying step.  In total, 5.5 pounds of wastewater are
generated for each pound of polymer.  Wastewater contains about 0.6%
suspended and dissolved solids. Also, about 1.5% of the polymer stream is
off-specification. Treatment and disposal represent significant cost
factors; however, this issue is not addressed.  Process water consumption is
a major target in both the DBS and PS processes.


                 APPROACHES TO WASTE MANAGEMENT
ALTERNATIVES
     Disposal Options include:

               - On-site destruction
               - Recycle - Reuse
               - Pretreatment & discharge to a POTW
               - Pretreatment & manifest to a RCRA-TSD
               - Off-site treatment

     Source Reduction and/or Elimination can utilize:

               - Alternate process technology
               - Substitute solvent or reactant(s)

     During the decade of the 80s, disposal options were narrowed
considerably.  Under Section 308 of CWA, as modified by the Consent Decree
of 1976 (NRDC vs Train) and several subsequent court orders,  EPA
promulgated effluent limitations, guidelines and standards for several
industrial categories.  Limits on discharges to surface waters and
Publically Owned Treatment Works (POTWs) have been strictly defined.
Regulations are based on "best practicable control technology currently
available" (BPT) and "best practicable technology economically achievable"
(BAT).  Hund et al summarize pretreatment standards for new and existing
point sources in the Organic Chemicals, Plastics and Synthetic Fibers
(OCPSF) Point Source Category [14].  This report contains the data on which
48FR11828 (03/21/83), 50FR29071 (07/17/85), 50FR41528 (10/11/85) and
                                    14

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51FR44082 (12/08/86) are based.  The OCPSF industry includes nearly 1,000
plants, of which 289 discharge directly to surface waters after on-site
treatment, 393 discharge raw or partially treated wastewater to POTWs and 15
utilize both modes of discharge [16].  Over 25,000 organic chemicals,
plastics and sythetic fibers are manufactured; less than half are made in
quantities exceeding 1,000 Ibs/yr.

     In parallel, under the authority of RCRA, EPA has issued regulations
for land disposal and deep well injection; promulgation of "land bans" was
completed in May of this year.  Evanoff describes the sequence and effective
dates of these regulations [17].  He cites the effects of these limitations
on aerospace industry activities.  In addition, he discusses the roles of
solvents and waste reducing alternatives in minimizing these effects on
manufacturing processes.


SOLVENTS
     Chlorinated aliphatic and aromatic hydrocarbons have a special  niche in
the hierarchy of hazardous and toxic substances.  These species are employed
as solvents, chemical intermediates and degreasing agents.  In general,  they
are volatile, more dense than water, highly toxic to diverse organisms and
interact with soil constituents, such as natural organic matter and clay
minerals.  They react with other compounds, in air, in the presence of
ultra-violet radition.  Wolf summarized the use of chlorinated solvents  in
cold cleaning, vapor degreasing and electronics manufacturing, in 1986 [18].
Use of 1,1,1-Trichloroethane (TCA) exceeds the combined uses of all  other
major solvents for cold cleaning.  Trichloroethylene is a close second in
vapor degreasing.  Over the past two decades, industrial use of chlorinated
solvents has shifted dramatically away from TCE to TCA [19].  This is a
consequence of reduced toxic hazard and comparable solvent properties.  The
use of Perchloroethylene (PERC) has remained relatively constant at 0.6 to
0.7 billion Ibs/yr.

     Almost 0.5 billion gallons of waste solvent are disposed on land,
annually, in the United States  [20].  Of this quantity, about 97% is treated
or stored in surface impoundments.  This practice must cease under "land
ban" regulations; Reference [20] is the Background Document for Solvent
Restrictions.  Evanoff tabulates candidate substitutes for the solvents in
common use by the aerospace industry [17].  Water-based/alkaline cleaners
can replace TCE, TCA, PERC and  Freons in vapor degreasing; terpene-based
cleaners can replace TCA, naphtha and methanol in cold-immersion cleaning.
Also, Evanoff cites processes and process modifications suitable for recycle
and reuse of aerospace industry hazardous wastes.


AUDITS
     Means must be established to measure waste generation and waste
reduction.  Absolute elimination of hazardous waste can be achieved by plant
closure; partial reduction accompanies reduced operation or abandonment of a
                                     15

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waste-related product/process stream.  These actions may have a positive
environmental effect; however, they may have a very negative impact on
industrial/community economy and growth.  In short, source reduction and
waste minimization must be evaluated in the context of vigorous, potentially
expanding, industrial activity.  Also, waste reduction must be monitored.
The objective should be to sustain gains and to improve performance as
technology advances.  Appropriate mass balances, as discussed earlier, are
the means of measuring and monitoring.  Within the context of regulation,
appropriate mass balances are termed "audits".

     With the objective of establishing general guidelines for measurement
of waste reduction, EPA undertook a series of trial waste minimization
audits in 1987 and 1988, as follows:

Waste Type                           EPA Report          Reference

Corrosive and Heavy Metal Waste        87/055               21
Cyanide Electroplating Waste           87/056               22
Solvent Waste from Electronic Parts
    Cleaning and Manufacturing         87/057               23
Printed Circuit Board Sludges and
    Solvent Wastes                     88/008               24
Solvents and Electroplating Wastes
    (DOD)                              88/010               25
Mercury Cell Chi oral kali Plant Wastes  88/011               26

     Recovery and recycle of  calcium fluoride from stainless steel  pickling
liquor led to 30% reduction in waste volume and savings on raw material
purchases [21].  Audits at two electroplating facilities encountered
variability  in the quality and availability of data  [22]; the same  was true
for an audit of solvent wastes [23].  Metal-plating  rinsewater  sludges and
solvents were audited and significant reduction attained in four of six
printed circuit board facilities  [24].  Drabkin and  Sylvestri conducted
audits at a  generator of F002 and F004 wastes  (spent  solvents)  and  F006
wastes (wastewater treatment  sludges from electroplating operations)  [25].
Three source reduction options and  two  recycle/reuse  options for
cadmium/chromium waste, as well a source reduction option for chromium
waste, were  developed.  Appropriate combination of these options could lead
to delisting of the  F006 wastewater sludge.   Two  alternative source
reduction options were developed  for paint stripping  solvent.   One  source
reduction option for  a K071 waste was  identified  [26];  mercury  cells  could
be replaced  by membrane systems.  Retorting of  a  mercury-bearing wastewater
treatment sludge,  for mercury recovery  and recycle,  was technically feasible
and may  be viable  economically.   A  treatment  option  for detoxification of
K071 waste appeared  to be  feasible.

     Many States  (MN, NC,  NJ, PA, etc.)  and Universities  (CO  St.,  TN,  KY,
etc.)  have Technical  Assistance  Programs to assist small  and medium-sized
businesses with  audits  and  advise on appropriate  waste minimization
technology.   EPA has published a  Manual  for Waste Minimization  Opportunity
Assessment  in  an  effort  to  generalize the  audit process [27].  The  Manual
 illustrates  waste  minimization assessment  procedures; it  is under  evaluation
 by the  NJTAP,  a  joint venture of NJIT and  Rutgers University.
                                      16

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                          REFERENCES
 1.  Majumdar, S.B., "Regulatory Requirements and Hazardous Materials",
    Chemical Engineering Progress. Vol. 86, No. 5, Pps. 17-24, May 1990.

 2.  Code of Federal Regulations FCFR1. Title 40, Chapter 1, Part 60, "U.S.
    Environmental Protection Agency", U.S. Government Printing Office,
    Washington (DC), Annual.

 3.  Federal Register Supplement. "List of CFR Sections Affected and FR
    Citations, Periodic.

 4.  Williams-Steiger Occupational Safety and Health Act of 1970 [OSHA],
    United States Statutes at Large. Vol. 84, Part 2, P. 1590, U.S.
    Government Printing Office, Washington (DC), 1970.

 5.  Code of Federal Regulations. Title 29, Chapter 17, Part 1910,
    "Occupational Safety and Health Administration", U.S. Government
    Printing Office, Washington (DC), Annual.

 6.  Burklin, C.R., "Safety Standards, Codes and Practices for Plant
    Design", Chemical Engineering. P. 56, 2 October 1972.

 7.  Ibid, P. 113, 16 October 1972.

 8.  Ibid, P. 143, 13 November 1972.

 9.  Federal Register. "Standards of Performance for New Stationary
    Sources", Vol. 38, No. Ill, Part II, P. 15406, 11 June 1973

10.  Annetti, R., "Advice on Safety: Play it Safe with Consultants",
    Chemical Engineering. P. 25, 26 November 1984.

11.  National Research Council. Committee on Institutional Considerations
    in Reducing the Generation of Hazardous Industrial Wastes. "Reducing
    Hazardous Waste Generation: An Evaluation and a Call for Action",
    National Academy Press, Washington (DC), 1985.

12.  Sheevers, H.V. and W.R. Muir, "Review of New Jersey Hazardous Waste
    Reduction Information Resources", Hampshire Research Associates Inc.,
    Alexandria (VA), 1989.

13.  Peters, M.S. and K.D. Timmerhaus, "Process Design Development", Plant
    Design and Economics for Chemical Engineers. Third Edition, Chapter 2,
    McGraw-Hill  Book Co., New York (NY), 1980.

14.  Hund, F.H.,  H.E. Wise, J.K. Goodwin and W.D. Smith, "Development
    Document for Effluent Limitations Guidelines, New Source Performance
    Standards and Pretreatment Standards for the Organic Chemicals and
    the Plastics and the Synthetic Fibers Point Source Category, Volume
    I", Report EPA/440/1-87/009. Office of Water Regulations and
    Standards, USEPA, Cincinnati (OH), October 1987.
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15. Baasel, W.D., "Process Design and Safety", Preliminary Chemical
    Engineering Plant Design. Second Edition, Chapter 4, Van Nostrand
    Reinhold, New York (NY), 1990.

16. Clean Water Act of 1972. "Section 308 Survey", U.S. Environmental
    Protection Agency, 1983.

17. Evanoff, S.P., "Hazardous Waste Reduction in the Aerospace Industry",
    Chemical Engineering Progress. Vol. 86, No.  4, Pps. 51-61, April 1990.

18. Wolf, K., "Chlorinated Solvents: The Regulatory Dilemma", Solvent
    Waste Reduction Alternatives Symposium: Proceedings. September 1986.

19. Hughes et al, Two-Carbon Chlorinated Solvents. Standford Research
    Institute Internation, 1983.

20. Anon., "Solvent Waste Volumes and Characteristics, Required Treatment
    and Recycling Capacity, and Available Treatment and Recycling
    Capacity", Background Document for Solvents  to Support 40 CFR Part
    268 - Land Disposal Restrictions - Volume III. Office of Solid Waste,
    USEPA, Cincinnati (OH), January 1986.

21. Drabkin, M. and E. Rissmann, "Waste Minimization Audits at Generators
    of Corrosive and Heavy Metal Wastes", Report EPA/600/S2-87/055.
    Hazardous Waste Engr. Res. Lab., USEPA, Cincinnati (OH), November 1987.

22. Versar Inc. and H.M. Freeman, "Waste Minimization Audit Report: Case
    Studies of Minimization of Cyanide Waste from Electroplating
    Operations", Report EPA/600/S2-87/056. Hazardous Waste Engineering
    Research Laboratory, USEPA, Cincinnati (OH), January 1988.

23. Jacobs Engr. and H.M. Freeman, "Waste Minimization Audit Report:
    Case Studies of Minimization of Solvent Waste from Parts Cleaning and
    from Electronic Capacitor Manuf. Operations", Rent. EPA/600/S2-87/057.
    Haz. Waste Engr. Res. Lab., USEPA, Cincinnati (OH), November 1987.

24. Nunno, T., S. Palmer, M. Arienti and M. Breton, "Waste Minimization  in
    the Printed Circuit Board Industry - Case Studies", Report EPA/600/S2-
    88/008. Haz. Waste Engr. Res. Lab., USEPA, Cincinnati (OH), Mar. 1988.

25. Drabkin, M. and P. Sylvestri, "Waste Minimization Audit Report: Case
    Studies of Minimization of Solvent Wastes and Electroplating Wastes  at
    a DOD  Installation", Report EPA/600/S2-88/010. Hazardous Waste
    Engineering Research Laboratory, USEPA, Cincinnati  (OH), March  1988.

26. Drabkin, M. and E. Rissmann,  "Waste Minimization Audit Report:  Case
    Studies of Minimization of Mercury-Bearing Wastes at a Mercury  Cell
    Chi oral kali Plant", Report EPA/600/S2-88/011. Hazardous Waste
    Engineering Research Laboratory, USEPA, Cincinnati  (OH), March  1988.

27. Lorton, G.A., C.H. Fromm and  H.M.  Freeman, "The EPA Manual for  Waste
    Minimization Opportunity Assessments", Report EPA/600/S2-88/025.
    Hazardous Waste Engr. Res. Lab., USEPA, Cincinnati  (OH), August  1988.
                                     18

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          CLEANER TECHNOLOGIES IN THE TANNING INDUSTRY
               Dr Ken Alexander (Assistant Director - Technical);
      Veronica Donohue (Assistant Information Officer - Computer Applications)
             British Leather Confederation, Northampton, England
   The British  Leather  Confederation,  which provides the Secretariat  for the
International Union of Leather Technologists and Chemists Environment and Waste
Commission, is gathering information on clean technologies of leather manufacture,
in co-operation with other leather industry associations. First results of this work will
be presented as an example of the  role that industrial associations can play in
networking and promoting cleaner production.

   Key aspects of the work are:

       .  Development of a practical database of clean technologies for the
          leather industry

       .  Development of networks of experts on clean technology for the
          leather industry
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ENVIRONMENTAL IMPACT OF LEATHER PRODUCTION

    Leather manufacture is one of the oldest established industries and has a current
annual turnover of approximately US$25 billion, providing employment for around
half a million workers on a worldwide basis('. It is essentially a by-product industry,
utilising hides and  skins from animals raised primarily for their meat.  Statistical
information from the United Nations Food and Agriculture Organisation shows that
in 1987 global leather production was nearly 14 billion square feet, produced from
over 5 million tonnes of rawstock(2). In this sense the tanning industry considerably
reduces the environmental impact of the meat industry, which would otherwise have
a major waste disposal problem.

    However, only approximately one-fifth  of the  rawstock can in  practice be
converted into saleable leather, the remainder forming wastes or by products. For
example, some of the raw material, such as hair, soluble proteins and fat has to be
removed during processing to prepare the collagen fibre structure of the hide for
tanning and some parts of the leather also have to be trimmed or shaved during the
production process.  Residual chemicals from the leather manufacturing process
contribute further to the tannery wastes. An indication of the amounts of liquid effluent
and solid wastes or by-products resulting from the processing of 1 tonne of rawhide
to leather is given in Figure  1.

    A more detailed analysis of leather processing showing the stages at which
chemical inputs are made and liquid effluent and solid wastes produced is given in
Figure 2, and discussed below. The reader is also referred to a number of excellent
reviews published in recent years that provide comprehensive  information on the
environmental impact of leather  processing  and  pollution  abatement, eg,  The
Technical Guide  to Reducing  the Environmental Impact of Tannery  Operations
(F Balkau; UNEP/IEO)*'; Pollution Abatement and  Control in the Leather Industry
(R L Sykes, D  R  Corning, British Leather Confederation; UNEP Industry  and
Environment Journal)*'; Environmental Impact Guidelines for New Source Leather
Tanning  and Finishing  Industries (Wapora; US EPA)™; Wastes from Tanning,
Leather, Dressing and Fellmongering (UK DOE)W.

LEATHER PRODUCTION AND WASTE MANAGEMENT

    It can be seen  in Figure 2 that after soaking hides to remove curing salt and
soluble, non-collagenous proteins (eg, albumins), the hair and epidermal layer of the
hide are degraded by chemical digestion of the hair/epidermal keratin with alkaline
sodium sulphide. This unhairing step accounts for  much of the BOD, COD,  and
suspended solids produced in the tannery effluent. The alkaline treatment also
removes additional interfibrillary protein to open up the collagen fibre structure of the
hide, which is essential for the production of soft leather. Although alkaline sodium
sulphide itself poses few problems, toxic hydrogen sulphide gas would be evolved if
the pH dropped in the effluent and most tanneries, at least in the developing countries,
therefore use a manganese catalysed aeration treatment originally developed by
BLMRA(' to comply with the low sulphide levels required by control authorities for
discharges. Physico-chemical treatments  are frequently employed to reduce the
organic load and COD in the effluent (by around 50%) and to reduce the suspended
matter by 80-90%. A typical tannery effluent treatment system is illustrated in Figure 3.
                                     20

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       50 m3 LIQUID EFFLUENT
           CONTAINING
    COD
    BOD
    Susp solids
    Chromium
    Sulphide
235-250 kg
  c 100 kg
  c 150 kg
    5-6 kg
   c 10kg
                                 SOLID WASTES AND
                                    BY-PRODUCTS
                             Untanned
                               Raw trimmings
                               Fleshings

                             Tanned
                               Blue sheetings
                               Trimmings
                               + shavings

                             Dyed/finished
                               Buffing dust
                               Trimmings
                             120kg
                          70-230 kg


                             115kg

                             100kg


                               2kg
                              32kg
Figure 1 Environmental inpa
-------
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Ul

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ui

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Ul
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       Figure 2 Chemical inputs and wastes produced during leather processing (source '4')
                                            22

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             Figure 3 Physico-chemical treatment of tannery effluent (source
    Physico-chemical treatment requires
initial  balancing   (homogenisation)   of
collected liquors followed by controlled
addition of flocculants and sedimentation
(or flotation) to remove sludge, which is,
in most cases, then dewatered. Biological
oxidation can provide  a more  effective
treatment system  for  tannery  effluent,
although  considerable  land space  is
required.  The oxidation ditch shown in
Figure 4 reduces BOD levels in tannery
effluent from 500-1000 mg/l down to levels
as low as  1-2 mg/l  residual BOD, with
almost    complete    elimination    of
suspended solids and of ammonia, some
of which  is  derived from  the  use  of
ammonium salts used for lowering the pH
to prepare the skins for enzyme treatment
(bating). The fatty  fleshings that have to
be removed from hides can be used as a
source of tallow,  although  profitable
disposal, of chrome  shavings produced
after chrome tanning is difficult and often
has  to be disposed to  landfill.  Excess
chromium (III) in the effluent is strictly controlled.

Clean Technology and Pollution Control
Figure 4 Oxidation ditch for biological oxidation
       treatment of tannery effluent
  (courtesy of W E & J Pebody Ltd, England)
    Despite the fact that pollution abatement is a considerable, non-productive cost
burden  on leather manufacturers,  the  industry itself has taken the initiative  in
introducing cleaner technologies and improving pollution control. At the last meeting
of the International Union of Leather Technologists and  Chemists Societies  in
Philadelphia, USA in 1989 over 60% of the scientific papers presented were concerned
with the development of cleaner technologies for leather manufacture^. In a recent
survey of research directors of leather research organisations'', clean technology
was highlighted as the  most important priority  for future research,  after cost
reductions.
                                      23

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   The key targets identified in that 1987 survey were:
       .  Replacement of chromium
       •  More effective use of chromium
       .  More efficient use of chemicals
       .  Sulphide free unhairing, possibly with hair recovery
       .  Utilisation of wastes
       .  Re-use of water
       .  Odour control
       .  Solvent free finishing
       .  N-free deliming
   In fact many of these  targets are now already being achieved and Figure 5
illustrates just a small selection of new clean technologies that are currently being
introduced by the leather industry, or are already in place. These include:
       .  Hide chilling to avoid salt in the effluent
       .  Hair recovery processes to reduce BOD/COD of the effluent
       .  Enzyme-assisted unhairing to reduce sulphide
       .  CO2 deliming to reduce ammonia in the effluent
       .  Better uptake/exhaustion of chrome or chrome recovery/recycling to
          reduce chrome in the effluent
       .  Alternative mineral tanning agents to avoid chrome in the effluent or
          solid wastes
       .  Water-based and  solvent-free top coats to avoid VOC emissions
   More detailed information on the processes are reported in the References cited
in Figure 5.
Development of a Clean Technology Database for the Leather Industry
   A lack of clear, objective and practically useful information is a major difficulty
facing the busy tanner who wishes to introduce cleaner technologies of leather
manufacture.
   This need for an easily accessible source of information on clean technologies
was the driving force behind the decision to set up a suitable database. The British
Leather Confederation, which provides the Secretariat for the International Union of
Leather Technologists and  Chemists Environment  and Waste  Commission  is
therefore  currently  gathering information  on   clean  technologies  of  leather
manufacture, in co-operation with other  leather  industry associates. The work is
dependent upon the development of a network of co-operation and support, involving
                                      24

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                POLLUTION
      PROCESS
PROCESS STAGE
                                                                                  CLEAN TECHNOLOGY
REDUCTION OF
 POLLUTION
ro
               SALT IN SOAK,
                   LIQUORS
       SALT
      CURING
                  DIGESTED
                 HAIR (HIGH  ,
                  COD/BODT~
                SULPHIDE IN
                  EFFLUENT
  HAIR DIGESTION
(WITH SODIUM SULPHIDE,
       UME)
                AMMONIA IN.	.
                  EFFLUENT"*
 USE OF AMMONIUM
       SALTS
              CHROMIUM III IN
               EFFLUENT AND^H
               SOLID WASTES
 USE OF CHROMIUM
    TO PRODUCE
 MODERN VERSATILE
     LEATHERS
            VOLATILE ORGANIC
             COMPOUND (VOCU-
                  EMISSIONS
      USE OF
  SOLVENT-BASED
     TOP COATS
                           HIDE CHILLING
                          HAIR RECOVERY
                             PROCESSES
                                       (12-15)
                                                                                  ENZYME-ASSISTED
                                                                                      UNHAIRING
                                                                                                  (16)
                           CO2 DELIMING
                                                                                                (17-19)
                         BETTER CHROMIUM
                              UPTAKE/
                             EXHAUSTION
                                       (20-25)
                                                                                         OR
                                                                                     CHROMIUM
                                                                                RECOVERY/RECYCLING
                                                                                                (26-34J
                                                                                          OR
                                                                                ALTERNATIVE TANNING
                                                                                  eg, ALUMINIUM/TITANIUM
                                                                                                (35-37]
                         WATER-BASED AND
                         SOLVENT-FREE TOP
                               COATS
                                        (38-41
                                             Figure 5 Clean technology for leather production
  NO SALT IN
  EFFLUENT
  REDUCED
  BOD OF
  EFFLUENT
                                                                              REDUCED USE
                                                                              OF SULPHIDE
  NO AMMONIA
  IN EFFLUENT
  REDUCED
  CHROMIUM IN
  EFFLUENT
                                                                              REDUCED
                                                                              CHROMIUM IN
                                                                              EFFLUENT
                                                                              NO CHROMIUM
                                                                              IN EFFLUENT,
                                                                              SOLID WASTES
  NOVOC
  EMISSIONS

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tanners, industrial research associations, industry suppliers, Government and other
agencies (e.g. the European Commission under the SPRINT programme, the United
Nations Environment Programme etc) and independent leather experts, as illustrated
in Figure 6.
                            > Tanners
                         Leather Industry clean
                          technology network
                Environmental, 	 Leather expert*
               Government and
                other agencies
                (eg, UNEP, EC, Figure 6 Network - Clean technology
                 DOE, EPAJ         information database

    The main objective is to set up a practically useful system to enable the tanner
to easily shortlist appropriate technologies for his requirements from the database.
As part of this procedure it is also essential for the tanner to be able to identify existing
users  of  the technology  and  independent  leather  experts, as  well as  the
manufacturers or inventors,  whom the tanner can then separately consult.   It is
considered most important that the database should not just be a bibliographic
source of information but should be of immediate practical use, quantifying  wherever
possible the reductions in pollution achievable by the clean technology, listing any
disadvantages and above all, giving an indication of its present level of development
and extent of use, since systems inevitably range from those just at the research and
development stage to  well-established technologies in widespread use. An outline
of the factors that have been selected for inclusion in the database is given in the
Questionnaire reproduced in Figure 7,  which in this particular example/case history
has been completed for a new tanning  product, Synektan TAL, manufactured by ICI
as a replacement for chromium.

    The leather industry has made considerable investments in time and  money in
reducing the pollution from tanneries and has achieved significant progress in
introducing cleaner technologies, in collaboration with the suppliers. Nevertheless,
because of the imposition of increasingly restrictive and sometimes unreasonable
environmental legislation, many tanners have been forced out of business in recent
years and the jobs of their workers lost because of the  non-productive costs of
improving environmental standards.  In the recent survey of research directors of
leather research organisations, one  of the problems highlighted was the need to
eliminate 'environmental hysteria'™.  It is to be hoped that in the years to  come the
legislative authorities will recognise the efforts of the tanning industry by  setting
realistic and  scientifically  based controls and avoiding,  wherever  possible,
politically-motivated or emotional responses to the environmental problems facing
all of us.
                                      26

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                 Figure  7 Clean Technology  questionnaire
          CLEAN   TECHNOLOGY  :  LEATHER   INDUSTRY
1.
2.
3.
4.
5.
                          QUESTIONNAIRE

Brief SUMMARY of clean technology  procena/nyntcn in as few words as possible:
(eg. Unhalrlng using enzymes,  chilling using ice)

Aluminium + titanium complex mineral tanning agent (non-chrome)

Is there a SPECIFIC process/trade  name?  (eg, Blair hair. Chromesaver A-31)
Synektan TAL

In which PROCESS STAGE is the  clean technology to be applied?         (Please  tick)
            O Rawstock
            O Beamhouse
            EfTanning and  pretanning for wet white
            El Dyeing and Fatliquoring and retanning

            O Other: (Please explain)
                                                      OFinishing
                                                      CD Waste Treatment
                                                      OEnergy Usage
DESCRIPTION of the key features of the clean technology process/system in not more
than 200-300 words:                         (Use No. 11 for COMMENTS on the process)
Non-chrome tanning agent,  potentially useful in' three areas:
(i)    pretanning for wet white,  to reduce production of chrome tanned solid waste
       and reduce chrome consumption in  the tannery
(ii)   total or  partial  replacement  of chrome  In main tannage,  to  reduce chrome
       offers by  aiding  chrome uptake  and  by  substituting at  least  part of  the
       normal chrome offer
(ill)  total or partial replacement of chrome in combination tannages or retanning

Where  there  is  a reduction in effluent loading, QUANTIFY  the  changes  made by  the
process or the achievable levels

Total replacement of chrome by Synektan  TAL would satisfy any requirement regarding
solid or  liquid  chrome-bearing waste.   If a  practical  chrome  offer,  eg,  1% £^03,
is  retained  (to  maintain  chrome  leather  character),  chrome  discharges  in   the
effluent  might  be approximately  10 ppm in  the  mixed waste stream.  By optimising
conditions, that level can be  significantly reduced.
6.   What ENVIRONMENTAL claims are made?
                                                          (Please tick relevant  item/s)
               Ammonia
               Chromium
               Chloride
               Nitrogen
               Sulphide
               Solvents
               Pesticides
               Blocldes
Cleaner or
less toxic
alternative

*^






Less
required

S






Recycled








Better
uptake

•s






Liquid
waste
benefits

^






Solid
waste
benefits

/






          Reductions:
               Biochemical/Chemical Oxygen Demand
               Suspended  solids
               Total  solids
               Grease

            O Odour  reduction
            D Energy saving
            D Better working conditions

            ET Other:  (Please explain)

               Chrome-free solid by-product by pretanning for wet white
                                           27

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7.   quantify ADVANTAGES itemised above:   (eg.  10Z  less  salt  In effluent)

     Prnctlcally,  chrome in spent tan  liquor  might  bo  reduced by 95%

8.   What DISADVANTAGES are there? (eg. aluminium In effluent) Please explain
                                                           (Please  tick  relevant  Item/s)

           53  Undesirable effects on the environment - Mono nt present;  loi'isluilon
                                                   may  apply Consent Limits
           O  Hi8h costs

           II  Technical problems

           [vl  Other:

     Post-tanning steps have to be modified to take account of Al  + Tl  in  the  leather

9.   How PRACTICAL IB the clean technology?  Please explain

     Very practical, no capital cost required or changes to existing  processing methods

10.  Give an estimate of the 'CLEANNESS'  of the process    (Please tick relevant  Item/s)

           CD, Very good - Best possible
           GET Good - Best available to date
           II  Reasonable - Better than other processes
           O  Not so good - No better than other available processes

11.  Give an OPINION or make COMMENTS on the 'CLEANNESS' of the  process:

     Synektan  TAL can  make real  reductions in levels of  discharged  chrome  with  no
     current  additional environmental problems. Discharges  of  aluminium  (and possibly
     titanium) may be subject to environmental pressure in the future

12.  Name of ORGANISATION/MANUFACTURER responsible for clean technology:

               Contact  name:       Ian Tate
               Company  name:       ICI Colours and Fine Chemicals
               Address:            PO Box  42, Hexagon House, Blackley, Manchester M9 30A

               Tel:  061  721 2562     Telex:  667841     Fax:  061 795 6005

13.  At  what  STAGE OF DEVELOPMENT is  the process now?      (Please tick relevant Item/s)

           D Research & Development              D/Llmlted commercial use
           D Trial/Prototype                     13  Widespread use
           CD Other:   (Please  explain)

     HOW MANY YEARS has the process/system been  In commercial use?   2  years
     WHAT YEAR was  the process/system first  developed?    1987   Product launched In 1988

 14.  TANNERY COSTS  AND PAY-BACK PERIOD

                IMPLEMENTATION  COSTS:                    PAY-BACK PERIOD:

            CD  £1 - 5000
            D  £5001 - 10,000
            tH  £10.001 - 50,000                        5-10  years
            O  £50,001 - 100,000
            d  More than £100.001

 15.   AVAILABILITY                                          (Please tick relevant Item/s)

            ET Europe                              15]  Australia & New Zealand
                Asia                                t^N America
                Africa                              El  S America

 16.   Estimated NUMBER OF TANNERIES using the technology WORLDWIDE in year 2000:

            O  1-10                  CD 101-500
            O  11-50                 ffifMore than 501
            CD  51-100
                                             28

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17.  ESTIMATED square feet of leather produced  to date using this technology:

           D.Lesa lhan 1 million square  feet
           \§S  1-5 million square feet
           d  More than 5 million square  feet

18.  Give details of TANNERIES using this  process who would be willing to be contacted:

          Coutnct name:        Dr M P Walker
          Organisation name:   The British  Leather Co Ltd
          Type of business:   Bovine tanners
          Address:            Tranraere Tannery.  New Chester Road, Birkenhead, L41 9BS

          Tel:  051 647 6252      Telex: 629570    Fax:   051 647 3573

19.  If  IT  IS NOT  POSSIBLE to  give above  contacts,  please  give details  of an
     INTERMEDIARY who could pass on any requests for information to a relevant tannery:
          See  (12)

20.  Give full details of REFERENCES in the literature  to the process:
     (Continue on a separate sheet if necessary)

     A D Covlngton     Tannages based on aluminium  (III)  and titanium (III) complexes
                       J Amer Leather Chem Assoc,  1987,  82,  (1),  1
     I Tate            The use of  aluminium,  titanium and magnesium  complexes in the
                       pretannlng, tanning and retannlng operations
                       Proceedings, IULTCS Congress,  Philadelphia,  1989

21.  Give details of any PRODUCT DATASHEET Reference  Numbers:
          Product code 36003

22.  Give details of other sources of INFORMATION:
          Company Information pack

23.  Which Individuals are considered to be THE EXPERTS in this area?

     Name              I P Tate/R M Webster
     Organisation      ICI Colours and Fine Chemicals
     Address          PO  Box  42, Hexagon House, Blackley, Manchester M9 30A

     Tel:  061 721  2562       Telex:  667841      Fax:   061 795 6005

     Name              Dr  M  P Walker
     Organisation      The British Leather Co Ltd
     Address          Tranmere Tannery, New Chester Road, Birkenhead,  L41  9BS

     Tel:  051 647  6252       Telex:  629570      Fax:   051 647 3573

24.  Where information  is  obtained  directly from the manufacturer, give details:

     Name:              I  P Tate
     Organisation:      ICI Colours  and Fine Chemicals
     Address:           PO  Box 42, Hexagon House, Blackley, Manchester M9 30A

     Tel:  061  721  2562         Telex:   667841      Fax:  061 795 6005

25.  Editor/Person completing this  form:

     Name:              Dr A  D Covlngton
     Organisation:      British Leather Confederation
     Address:           Leather Trade House, Moulton Park, Northampton  NN3 1JD

     Tel:  0604 494131          Telex:   317124      Fax:  0604 648220

26.  Any COMMENTS not covered above:

     EC  Supported Demonstration  Project (ACE/88/UK/002/A21) currently being conducted at
     The British Leather  Co  Ltd,  in collaboration with  the British Leather Confederation
                                            29

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Ind Environ (UNEP)  10 (2) 19-22
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                                 8-15
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J Amer Leather Chem Assoc    1987    82  (1) 1
Tate, I.P.    The use of aluminium, titanium and magnesium
complexes in the pretanning, tanning and retannlng operations.
(Synektan TAD
IN:  20th IULTCS Congress, Philadelphia, 1989.  Lecture no.16.
Anon.    Id's Chrome-free alternative.  (Synektan TAL)
Leather    1988   190 (4558) 59-61
Anon.  IN: Water-borne finishes start making a splash.
(Rodacryl 143 & Roda pur 309) (Rohm GmbH)
World Leather  1990   3  (1) 16-20
Gill, C.    New acrylic  technology: high performance aqueous
systems.    (Rohm & Haas)
Leather    1988    190 (4560) 23-27
Domajnko, D.H.  Advances in leather finish technology: the
aqueous poIyurethanes.      (Stahl Chemical Industries BV)
Leather   1988   190 (Jan) 19-21
Ramondetti, A.  All-aqueous finishing systems for leather:
problems and solutions under the aspects of chemistry,
technology and ecology.     (K J Qulnn GmbH)
IN: 19th IULTCS Congress, Melbourne, 1987,   132-143
Anon.    Br111sh .Leather Confederation leads clean technology
project.
World Leather    1990   3  (1) 2
                                    31

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          WASTE MINIMIZATION - APPROACHES  and TECHNIQUES
                    by:  Raymond J. Avendt Ph.D  P.E.
                         Vice President, Environmental Activities
                         The Harmon Group Inc.
                         225 West Washington Street
                         Chicago, Illinois  60606
                             ABSTRACT

     This  paper will  present a  series of  suggested  steps for
conducting  a  waste minimization  assessment,  discuss means  of
inventory management and methods for improving operations.  These
suggested methods of assessment and process  modification will be
cast in  the context of specific industrial waste  streams in the
automobile parts manufacturing and  the metal finishing operations.
The modification of any manufacturing process that has impacts on
the   receiving   facility    and/or   POTW  which  receives   the
wastestream(s) will be discussed.

                        IMPACTS ON POTW's

WASTEWATER CHARACTERISTICS
     Manufacturing  facilities are  now  more  than  ever taking  a
closer  look  at waste  streams  that are  generated   from  their
operations.   Discharges  via  smokestacks,   sewers   and   refuse
containers  are  being evaluated in an effort  to reduce operating
costs and storage requirements, improve public image and operating
efficiency  and to  manage  the  potential  risks and  liabilities
associated with waste disposal. Waste streams  can be thought of as
anything that doesn't go out the door as product. Waste can be in
the form of a solid, liquid,  gas,  or a combination  thereof and
released into all environmental media.  As materials are reused or
reclaimed, they are considered a resource and no longer a waste.
     This paper will evaluate the impact of waste minimization on
publicly owned treatment plants (POTW's), and will therefore focus
on  wastewater  discharges  from  the  industrial  facility.  The
wastewater  characteristics  should  be evaluated  to determine the
volume and rate of water and contaminants that may be subjected to
reduction and/or recycling.

SLUDGE PRODUCTION
     The POTW treatment of  industrial wastewaters will normally
increase the sludge production.  The impact of reducing the amount
of sludge will usually  result in less sludge requiring treatment
and disposal. Care  should be taken  in instances where industrial
wastewater  flows  are substantial  not to adversely affect sludge
operations at the POTW.          -,

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PRETREATMENT COMPLIANCE
     Changes  in  the wastewater  characteristics may  also  impact
compliance with industrial pretreatment  standards  imposed  by the
POTW  or  regulatory  agency.  The  most  common  impact  is  the
concentration of contaminants by reducing  wastewater flow rates;
resulting  in violations  of  concentration  based  standards.  The
higher concentration of contaminants may also  not  be amenable to
treatment.  An example would  be the  shock loading of BODS that was
usually handled at a lower concentration.

TOXICITY
     Changes in the flow rate or  concentration of contaminants may
also have an impact on the POTW.  This is  especially important when
the  treatment works  involves  biological tertiary  treatment for
nutrient removal or water reuse.


                        WASTE MINIMIZATION

REDUCTION
     Waste reduction  is reducing the volume or toxicity of waste
through source reduction and  recycling  practices. Reduction is any
in-plant  activity  that decreases the  volume or toxicity  at the
point  of generation.   Source reduction is the environmentally
preferred  approach to waste reduction and usually  provides the
greatest economic benefits.

RECYCLING
     Recycling is the use  or  reuse of a waste material in a process
without  changing  its original  form or reclamation by  recovering
secondary  materials   for  a  separate   end-use  or  by removing
impurities  so that  it may be reused.  Recycling  may  generate a
cashflow. It should not be selected  as  a  waste minimization option
solely on  economics,  since the receiving market value may vary
greatly or be eliminated.

                        SOURCE REDUCTION

PRODUCT CHANGES
     The process for identifying  options should follow a hierarchy
in which source reduction  options are explored  first, followed by
recycling options.  The reduction  of the wastewater discharge at the
generation   source  may   involve   substitution of  a  product,
conservation of a critical material  used  or a change in the product
composition.

SOURCE CONTROL
     Changes  in the  input  material  that  results in the  wastewater
discharge  is the  first point of  evaluation.   In  many instances
technology changes  have been developed by  others to reduce waste
streams. Technical  journals, trade  publications and professional
societies should be consulted. The most overlooked method of source


                                 33

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reduction in the use of good  operating  practices  to reduce waste
generation.

RESULTS
     Source reduction for waste minimization is the direct impact
on the POTW. The changes in the wastewater will result in reduced
discharge  fees  and /or pretreatment  costs.  Any  proposed source
control changes should be discussed with the operations personnel
of the POTW.
                            RECYCLING

USE AND REUSE
     Recycling via use and/or reuse  involves the return of a waste
material either to the originating process as a substitute for an
input material, or to another process as an input material.

RECLAMATION
     Reclamation is the recovery of  a material from a wastestream.
Reclamation techniques differ from use and reuse techniques in that
the recovered material is not used  in  the facility,  rather it is
sold to another company.

RESULTS
     The economic  evaluation of recycling options  should always
include  the cost  of  wastestream  management  under the  current
operation for comparison. The potential  liabilities associated with
improper  disposal  by  others  under  contract  should  also  be
addressed.
                        WASTE MINIMIZATION
                       ASSESSMENT  PROCEDURE

PLANNING AND ORGANIZATION
     Since  effective  waste minimization  ideally  involves  the
coordinated efforts of all personnel, the planning and organization
are crucial to the success of a program.  The development of a waste
reduction and/of recycling program begins with obtaining management
commitment,  organizing  a  waste  assessment  team  and  setting
realistic goals.

ASSESSMENT PHASE
     The  purpose  of  the  assessment  phase  is  to  develop  a
comprehensive  set  of  waste  minimization options,  and to identify
the  attractive options that deserve additional ,  more  detailed
analysis. In order to develop these waste minimization options, a
detailed  understanding of  the  industrial  facility's  wastes and
operations is  required. The assessment  should  begin by examining
information about  the processes,  operations  and waste management
practices at  the facility.  This  will  serve as the baseline for


                                34

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comparison of options.

FEASIBILITY AND ANALYSIS PHASE
     The remaining waste minimization options from the assessment
phase are then evaluated based on technical and economic factors.
The technical evaluation will determine whether a proposed option
will work in a specific application within the industrial facility.
Problems associated with facility building or operating constraints
should be critically evaluated.  Bench-scale or pilot testing may
be necessary. Production requirements should be  considered  in the
analysis as changes  will affect the design criteria and operating
parameters of the waste minimization option.
     An economic evaluation is conducted by comparing the operating
costs of  the existing  operation  with the  capital  and operating
costs  of  the  proposed waste  reduction option.  The  incremental
operating costs  should be determined.  Capital  costs  include the
costs   for   process  equipment,   construction   materials,  site
preparation,   installation,   utility   hook-ups,    engineering,
permitting,  training and  start-up.  Operating costs  include the
costs of raw materials,  maintenance,  supplies,  labor, utilities,
waste transportation, disposal, storage and handling. Revenues from
recycled waste can partially offset operating costs.

IMPLEMENTATION

     It is  good  practice to implement  the  options  that have low
capital costs first.  These options are usually easy  to implement
and  result   in  significant waste  reduction.   The more  capital
intensive operations will be  easier  to implement  after  a  track
record has been established.  For projects involving the purchasing
of equipment, the installation of equipment should proceed in the
same manner as other capital improvement projects.
                           WASTE STREAM
                         CHARACTERISTICS

WASTEWATER
     The critical waste minimization factor impacting POTW's is the
change in the wastewater  flowrates and contaminant concentrations.
The  discharge may  also be  intermittent  as a  result  of batch
operations  or recycling. The  impact  on normal  diurnal influent
flowrates to the POTW should also be considered.

SLUDGE
     Dissolved solids requiring further treatment at the POTW will
result in the production of sludges for treatment  and disposal.
Biological waste sludges  from the treatment of organic wastes will
also be impacted by waste minimization. The treatment capacity at
the POTW allocated to handling industrial wastewaters should also
be  evaluated for  changes  in  capital   and  operating  costs.  Any


                                 35

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reductions  in  these  expenses  may  not  be  passed  on  to  the
discharger.

                          PROBLEM AREAS

DISCHARGE RATES
     The most common problem with implementing waste minimization
programs involving wastewater discharges to POTWs alteration of the
discharge rate.  Typical programs of reducing rinse water discharges
or washdown waters may result in highly concentrated pollutants be
discharged to the POTW.

CONCENTRATION OF POLLUTANTS
     Impacts on the  unit processes at the POTW and the maintenance
of the NPDES  discharge  permit  may be affected  by  changes in the
concentration  of  pollutants.  Both the  process performance  and
reliability should be evaluated.

PRETREATMENT PROGRAM COMPLIANCE
     Penalties imposed by violations or surcharge provisions in the
industrial  pretreatment code should  be considered.  Alternative
wastewater disposal  options may not be available. On-site treatment
options rarely prove economical over the long term.
                                36

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        WASTE MINIMIZATION
     Approaches and Techniques
Slide #1.
        WASTE MINIMIZATION
            IMPACT ON POTW's

      • Wastewater Characteristics
      • Sludge Production
      • Pretreatment Compliance
      • Toxicity
Slide #2.
                  37

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         WASTE MINIMIZATION
        Reduction
        Recycling
Slide
         SOURCE REDUCTION
        Product Changes

        Source Control
          Input Materials
          Technology
          Operations
Slide #4.
                   38

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             RECYCLING
      • Use and Reuse
      • Reclamation
Slide #5.
        WASTE MINIMIZATION
     ASSESSMENT PROCEDURE

      • Planning and Organization
      • Assessment Phase
      • Feasibility and Analysis Phase
      • Implementation
Slide #6.
                   39

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           WASTE STREAM
          CHARACTERISTICS

       • Wastewater
          Liquid Fraction
          Solids Percentage

       • Sludge
          Moisture Content
          Handling and Storage
Slide #7.
           PROBLEM AREAS

       • Discharge Rates
       • Concentration of Pollutants
       • Pretreatment Compliance
Slide #8.
                   40

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       International Conference on Pollution Prevention:
             Clean Technologies and Clean Products

  Session 37:  Hazardous Waste Minimization in DoD Operations
                Washington, DC  -  June  12,  1990

        THE ARMY'S HAZARDOUS WASTE MINIMIZATION PROGRAM

                              by
    Robert P. Bartell, Janet L.  Mahannah & Michael J. Dette
          Research  and  Technology Development Branch
         U.S.  Army Toxic and Hazardous  Materials Agency
                            ABSTRACT

     The Army engages in a wide variety of activities including
manufacturing, maintenance, and testing operations.  These
operations result in the generation of a wide variety of
hazardous wastes such as solvents, sludges, acids, bases, and
heavy metal-contaminated materials.  Reducing the volume and
toxicity of these wastes presents significant challenges for
all levels of Army management.  To respond to these challenges,
the Army has developed a comprehensive hazardous waste
minimization  (HAZMIN) program.
     The following initiatives are part of the Army's program:
systems to help the potential hazardous waste generator track
hazardous material use and disposal;  a HAZMIN awards program to
stimulate waste minimization ideas; a hazardous waste source
reduction study to identify and evaluate opportunities for
HAZMIN in the material acquisition life cycle process; and
research, development, and implementation of technologies,
processes, or materials to result in HAZMIN.  Ongoing research
and development efforts are directed to accomplishing HAZMIN
through material substitution, operational changes, and by-
product recovery and reuse.
     The Army HAZMIN program has seen tremendous change and
growth in the past five years, and current goals to
dramatically reduce the generation of hazardous waste are
indicative that this change and growth will continue.  Ongoing
HAZMIN initiatives are directed toward meeting these goals.
                              41

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                          VIEWGRAPHS
        THE ARMY'S HAZARDOUS WASTE MINIMIZATION PROGRAM
                       ARMY HAZMIN GOAL

             To reduce hazardous waste generation
                   by 50% by the end of 1992
                using FY 1985 total as baseline
                      ARMY HAZMIN PROGRAM

                            STATUS
               Tracked Waste  (1000 Metric Tons)

1985    1986    1987    1988    1989    1990    1991    1992
  98     126      60      59     112*   	> 49

          * Includes 60,000 metric tons generated during
               two RCRA closures
             HAZARDOUS WASTE  GENERATION  (CY  1989)

               92%  Army Materiel Command (AMC)
                6%  Forces Command (FORSCOM)
                2%  Training & Doctrine Command (TRADOC)
                  HAZARDOUS WASTE GENERATION
       Relative generation per selected operation in AMC

     Spills
     Motor pool
     Surface treatment        	
     Ammunition disposal      	
     Energetics production    	
                                 Quantity 	>
               MAJOR HAZARDOUS WASTE  CATEGORIES

               o  PEP:    Propellants
                         Explosives
                         Pyrotechnics
               o  Organic solvents
               o  Heavy Metals
                              42

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    TACTICAL VEHICLE MAINTENANCE HAZARDOUS WASTE GENERATION

                    	>   SLUDGES
PAINTING                                Excess paint
DEPAINTING                              Stripped Paint
DECREASING                              IWTP sludge
CLEANING            	>   AIR EMISSIONS
ELECTROPLATING                          Volatile organics
                    	>   AQUEOUS/LIQUID WASTES
                                        Rinse waters
                                        Spent strippers
                                        Spent plating baths
                        HAZMIN CHALLENGE

          REDUCE OR ELIMINATE GENERATION OF HAZARDOUS WASTES
               Materials Substitution
               By-product recovery/reuse
               Operational changes
          RESULTS
               Improved production rates
               Improved product quality
               Decreased operating costs
                     ROLE OF R&D IN HAZMIN

     APPLICATION OF EXISTING TECHNOLOGIES
          To new situations
          To meet Army-specific requirements
          To fit into existing processes
            I
            |   INNOVATIVE TECHNOLOGY DEVELOPMENT
            |        New processes
            I          I
           \|/       \|/      METHODS
          IMPLEMENTATION           Material substitution
                                   Operational changes
                                   By-product recovery/reuse
                              43

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           ARMY  HAZMIN TECHNOLOGIES UNDER DEVELOPMENT

RECOVERY/REUSE
  o  Requalification/recycle of off-grade TNT during production
  o  RDX and TNT as fuel supplements for installation
          heating plants
  o  Recovery of propellants for reuse by resolvation
PROCESS CHANGE
  o  Aluminum ion deposition as an alternative to
          electroplating
  o  Plastic media blasting for paint stripping
  o  Fluidized bed paint stripping for small parts
  o  More effective paint application techniques
  o  Extension of stripping solutions by dialysis and
          filtration
MATERIALS SUBSTITUTION
  o  Alternate chemical paint stripper formulations
              PLASTIC  MEDIA  BLASTING  DEMONSTRATION

Benefits realized from replacement of obsolete equipment with
state-of-the-art plastic media blasting booth

WASTE REDUCTION
  o  High efficiency recycle system and pressure control
          reduces waste generation by 70% (annual waste
          production is reduced by 93,000 Ibs)
LABOR REDUCTION
  o  Automatic floor recovery reduces labor requirements by 25%
          (1250 manhours per year)
COST REDUCTION
  o  Estimated yearly cost savings of $63,000 - $210,000
OTHER BENEFITS
  o  Greater variety of parts processed
  o  Cleaner, healthier, and safer environment for operators


  ALTERNATIVE CHEMICAL STRIPPER IDENTIFICATION AND EVALUATION

OBJECTIVE
     Identify and evaluate commercially-available strippers to
     replace current formulations containing methylene chloride
SUCCESSFUL STRIPPER MUST:
  o  Reduce TTO contributions
  o  Effectively strip a variety of coating/substrate
          combinations within 2 hours
  o  Meet operational, health, and safety requirements
                              44

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                 ALUMINUM ION VAPOR DEPOSITION

OBJECTIVE
     Demonstrate that aluminum ion vapor deposition is a viable
     alternative to cadmium corrosion protection plating
VALUE
     Reduce generation of hazardous wastes resulting from
     cadmium plating operations
METHOD
     AIVD unit to be purchased and installed at Anniston Army
     Depot.  Testing/demonstration to determine applicability
     and operating parameters.  Implementation to be pursued
     where appropriate.


                    FLUIDIZED PAINT REMOVAL

OBJECTIVE
     Demonstrate the use of a heated bed of fluidized aluminum
     oxide to remove grease and paint from parts at Army depots
VALUE
     Reduce reliance on chemical stripping
       o  Reduce generation of hazardous waste
       o  Provide better worker environment
METHOD
     Fluidized bed unit to be purchased and installed at Red
     River AD.  Testing/demonstration to determine
     applicability and operating parameters.  Implementation
     pursued where appropriate.


              FILTRATION OF PAINT STRIPPING BATHS

OBJECTIVE
     Demonstrate the potential for extending the life span of
     paint stripping baths by filtration
VALUE
  o  Reduce generation of hazardous waste
  o  Reduce costs associated with treatment/disposal
  o  Reduce raw material costs
METHOD
     Filtration unit to be purchased and installed at
     Letterkenny AD.  Testing and demonstration will be
     conducted to determine feasibility, effectiveness, cost,
     and to develop guidelines for system implementation
     wherever appropriate.
                              45

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               HIGH EFFICIENCY PAINT APPLICATION

OBJECTIVE
     Demonstrate the use of high efficiency paint application
     systems to increase transfer efficiencies and reduce
     hazardous waste generation and VOC emissions
VALUE
  o  Reduce generation of hazardous waste
  o  Reduce VOC emissions
  o  Reduce costs associated with treatment/disposal
  o  Reduce material costs
METHOD
     Three high efficiency paint application systems will be
     purchased and tested at Sacramento AD.  Test analyses will
     include transfer efficiency, rate of application, and
     ability to meet coating specifications.  Information to
     provide for guidance for other depots.
           ELECTRODIALYSIS OF CHROMIC ACID SOLUTIONS

OBJECTIVE
     Demonstrate the potential for increasing the life span of
     chromic acid solutions
VALUE
  o  Reduce generation of hazardous waste
  o  Reduce costs associated with treatment/disposal
  o  Reduce material costs
METHOD
     Electrodialysis unit to be purchased and installed at
     Corpus Christi AD.  Testing/demonstration will be
     conducted to determine potential for waste reduction and
     to develop performance criteria for implementation.


              PROPELLANTS/EXPLOSIVES/PYROTECHNICS
                   HAZARDOUS WASTE  GENERATION

OPERATION                               WASTE FORMS
  o  Production of energetic material     o  Sludges
  o  Assembly of rounds                   o  Wastewaters
                                          o  Air emissions

                    OPPORTUNITIES FOR HAZMIN
                      o  Material substitutions?
                      o  Process changes?
                              46

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                 WHAT'S LEFT? - RECOVERY/REUSE

OPPORTUNITIES
  o  Solvation of propellants for reconfiguration
  o  Rework/recycle of off-grade TNT during production
  o  Use of waste explosives as fuel oil supplements
  o  Activated carbon regeneration
  o  Reuse of explosives in munitions
  o  Use of propellants as fuel supplements
                           KEY WORDS

               O    IMPLEMENTATION

               O    COST


        INHERENT PROBLEMS  IN IMPLEMENTING NEW TECHNOLOGY

     o    Performing accurate cost analysis
     o    User acceptance
     o    Acquisition of operating/construction funds


                            SUMMARY

     Three primary means to reduce the generation of hazardous
          wastes:
                  Recovery/Reuse
               -  Process Changes
               -  Material Substitution
     Opportunities currently exist to reduce hazardous waste
          generation in ways that will reduce operating costs
          and at least maintain, or improve, product quality
     Current emerging technologies can be adapted to
          site/application-specific operations to accomplish
          the above
     As more HAZMIN measures are implemented, more innovation
          will be required to accomplish the above
     In the absence of future innovation, more HAZMIN can be
          expected to require higher operating costs
     An interface of real substance must be established between
          user and developer in order to effectively benefit
          from new HAZMIN technology
                              END
                              47

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       CORPORATE TRANSITION TO MULTI-MEDIA WASTE REDUCTION
                MEASURING WASTE REDUCTION  PROGRESS
             by: David M. Benforado, P.E.,  DEE
                 3M Company
                 Building 21-2W-06
                 900 Bush Avenue
                 St. Paul, MN  55144
LACK OF DATA

One of the impediments identified in the NWF CCC policy statement
Dr. Bringer listed in the introduction was "Lack of Useful Data
on Progress."

In the policy statement itself it appears as "Lack of consistent
and useful data on the extent and effect of industrial source
reduction."  Source reduction here means preventing the
generation of waste.


WHAT IS NEEDED

If this is to change, two things have to happen:

1.   Companies need to do a better job of keeping track of
     projects that reduce wastes and releases.  They need to keep
     track of successes and failures for existing and new
     products.

2.   The government needs to develop a better understanding of
     how to collect good data from very varied manufacturing
     operations.

Reliable data showing where and how much waste minimization is
taking place would be helpful in furthering the cause of
pollution prevention.

1.   It would provide trend data to show the Agency where
     promotion of waste minimization is needed most.  Also, it
     would show where to focus our efforts, taking into
     consideration other factors, such as potential exposure,
     fate, and public concerns.
                                48

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2.   It would identify successful waste minimization projects
     that would be prioritized for technology transfer.


USEPA REPORT TO CONGRESS

In its report to Congress in 1986 on waste minimization, the
USEPA concluded that waste minimization is taking place, but that
it is hard to quantify.

The recommended strategy suggested was to gather detailed data
through 1989 using RCRA reports.  Based on the results, the
Agency would prepare a waste minimization report to Congress in
1990 with recommendations for legislative changes if they were
needed.
REASONS FOR LACK OF GOOD DATA

Unfortunately, there have been difficulties collecting the
detailed data.  Some of the reasons for the lack of good data
are:

1.   Generation prevention (source reduction)  is hard to
     quantify, because when you stop generating waste, it isn't
     around to measure.

2.   The ability to quantify waste minimization is simpler with a
     facility manufacturing a single product,  than with a multi-
     product facility with combined waste streams.

     Most of 30,000 large quantity generators, and more than
     100,000 small quantity generators, are multi-product
     facilities that make many products and combine the waste
     streams.

     For multi-product facilities with combined waste streams,
     waste minimization progress cannot simply be determined by
     taking the annual difference in combined waste streams
     adjusted for average production.

3.   Another reason for lack of good data is most multi-product
     companies have not kept track of completed waste
     minimization projects.

     This is because in many cases the effort is part of a larger
     project,  and after getting the job done,  the engineers have
     had other priorities.  Also, many projects are initiated and
     completed in a plant by workers, who never make a record of
     their work.
                                49

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4.   Still another reason, is that the initial format the Agency
     used to collect waste minimization data using the RCRA
     biennial report was seriously flawed for multi-product
     manufacturing facilities with combined waste streams.

     The format was changed for the 1989 reporting year; however,
     it's unclear if the change was effective.  Also, it's not
     clear if the Agency has the resources to evaluate and
     utilize the data collected in time for the 1990 report.

5.   The last reason why data collection has been difficult is
     that the forms themselves are intimidating.  They are
     complex, asking for details not needed, in industry's view,
     and they have complex instructions.  Many of the detailed
     questions ask for data not readily available and are of
     questionable value.  The forms are resource intensive for
     the companies to fill out, and also resource intensive for
     the Agency to validate and interpret the results.


MINNESOTA EXPERIENCE

Experience in Minnesota with the USEPA waste minimization forms
for 1987 showed that more than half of the persons filling out
the forms are nontechnical — accountants, personnel managers,
presidents, laborers, etc.

They are intimidated by complex, detailed technical questions and
instructions.
                                                               as
The reliability of the responses to a questionnaire decreases,
complexity increases.


EXAMPLES - PROBLEMS WITH MULTI-PRODUCT FACILITIES

With that background, here are examples comparing the problems
with data collection for multi-product manufacturing companies
with single product manufacturing:

     o    Slide 1   Single product vs. multi-product
     o    Slide 2   Single product without waste minimization
     o    Slide 3   Single product with waste minimization
     o    Slide 4   Multi-product without waste minimization
     o    Slide 5   Multi-product with waste minimization.
RECOMMENDATIONS

I have two recommendations that would improve the measurement of
waste reduction progress:
                                50

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1.   The Agency should provide an option (Slide 6), clearly
     stated, for multi-product facilities to be able to report
     estimated results of waste minimization projects that
     prevent the generation of waste.

     Here's an example (Slide 7) of how companies can collect
     data by projects and report estimated results.  This is a
     summary of how 3M keeps track of 3M Pollution Prevention
     Pays (3P) Projects.

     If data are collected in this way, it will be useful for
     showing trends of generation prevention progress (Slide 8).

2.   The RCRA waste minimization forms should be made self-
     explanatory.

     A good example would be the U.S. Census Forms that we all
     just completed.  Based on the simple census form I filled
     out, I'd say most of the people completed the form without
     needing to read the separate instructions.

     Here's an example of the USEPA RCRA waste minimization form
     made self-explanatory (Slide 9).

The best way to ensure getting good data is to keep it simple.
Don't make it a resource intensive activity for the company and
the Agency.

Plant personnel don't have a lot of spare time to fill out the
forms.  The agencies do not have the money and manpower to
analyze and to interpret resource intensive forms.  Much of the
data already collected will never be looked at.
FUTURE POSITIVE ACTION

On the positive side, industry is working with the Agency towards
improving the data collection process.

At the last meeting of the American Institute of Pollution
Prevention (AIPP), arrangements were made for the Implementation
Council to meet with Mr. Gerald Kotas, Director of the Office of
Pollution Prevention, and his staff, on the matter.

Anyone interested in waste minimization measurement is invited to
join us.
                                51

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                 SLIDE 1
       WASTE  MIN  PROGRESS
       DATA  COLLECTION


       SINGLE  PRODUCT  MFC
         Unmixed Wastes


       MULTI-PRODUCT MFC
     Combined  Waste  Streams
           Mixed  Wastes

                 SLIDE 2
 DEDICATED SINGLE PRODUCT OPERATION
 CASE I - WITHOUT WASTE MINIMIZATION PROJECT

      SIC CODE	         WASTE CODE	
        UNITS   TONS WASTE GENERATED    TONS
   YEAR   OF                     WASTE
        PRODUCT   ACTUAL   EXPECTED*   PREVENTED   INDEX '
              REPORTED


   1986   75      150                -      2
   1987   150     300       300*      ZERO      2
                      CALCULATED
EXPtCTED = 1986 TONS MULTIPLIED BY PRODUCTION RATIO
       PRODUCTION RATIO 1987/1986 = 2
INDEX = ACTUAL TONS WASTE PER UNIT PRODUCT
                  52

-------
                          SLIDE 3

     DEDICATED SINGLE PRODUCT  OPERATION
      CASE II  -  WITH  WASTE  MINIMIZATION PROJECT
          SIC CODE
                                    WASTE CODE
       YEAR
       1986
       1987
 UNITS
  OF
PRODUCT
  75
  150
TONS WASTE GENERATED

 ACTUAL     EXPECTED*
REPORTED
150
150
                                  300*
                                CALCULATED
                     TONS
                     WASTE
                    PREVENTED
                                 150
INDEX '


 2
 1
 • EXPECTED = 1986 TONS MULTIPLIED BY PRODUCTION RATIO
           PRODUCTION RATIO 1987/1986 = 2
   INDEX * ACTUAL TONS WASTE PER UNIT PRODUCT
                          SLIDE 4
1986
    MULTI PRODUCT OPERATION - COMBINED WASTE STREAMS
           CASE I - WITHOUT WASTE MINIMIZATION PROJECT
               SIC CODE	   WASTE CODE	


INDEX
ACTUAL
TONS WASTE GENERATED TONS TONS WASTE
UNITS OF PROD RATIO
PRODUCT PRODUCT 1987/1986
A 35
B SO
C 15
AGGREGATED
TOTAL 1 00
ACTUAL
REPORTED
15
10
5

30
WASTE PER UNIT
EXPECTED* PREVENTED OF PRODUCT
.43
.20
.33

.30
1987
                           TONS WASTE GENERATED

A
B
C
AGGREGATED
TOTAL

70
25
30
125

2
1/2
2
1 .25 AVG
ACTUAL
REPORTED
30
5
10
45
EXPECTED'

APPARENT
INCREASE
37.5. 7.5 TONS

.43
.20
.33
.36
               • 1986 TONS MULTIPLIED BY PRODUCTION RATIO
                               53

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                                               SLIDE  5
          1986
               MULTI PRODUCT OPERATION - COMBINED WASTE STREAMS
                          CASE II - WITH WASTE  MINIMIZATION PROJECT
                              SIC CODE	     WASTE CODE	


UNITS OF PROD RATIO
PRODUCT PRODUCT 1987/1986
A 35
B 50
C 15
AGGREGATED
TOTAL 1 00

TONS WASTE (
ACTUAL
REPORTED
15
10
5

30
INDEX
ACTUAL
5ENERATED TONS TONS WASTF
WASTE PER UNIT
EXPECTED* PREVENTED OF PRODUCT
.43
.20
.33

.30
         1987
TONS WASTE GENERATED TONS
ACTUAL WASTE

A
B
C
AGGREGATED
TOTAL

70
25
30

125

2
1/2
2

1 .25 AVG
REPORTED
22.5
5
10

37.5
EXPECTED* PREVENTED
7.5


APPARENT
37.5« NONE

.43
.20
.33

.30
                             • 1986 TONS MULTIPLIED BY PRODUCTION RATIO
                                           SLIDE  6
                                       Clearly Show Options
Sec I Results of project or activity
 ** I  Show Quantity of Waste Prevented or Newly Recycled
      Complete either Item 1 or Item 2 - Describe In Section III

  Item 1.  Single Uncomblned Waste Stream - Single Product Manufacturing
        A. 1987 Quantity Generated	  Q  Tons
                                        n Pounds
        B. 1988 Quantity Generated	  d   Gals.	 Ib/gal
        C. Production Ratio       	
        D. Calculate Quantity Prevented or NewJy Recycled in year reported
PROJECT
                                                                           Prevented Generation or
                                                                           Newly recycled
           A x c - B =
                                             Prevented
                                             Newly Recycled
                                                                 Onsite I I

                                                                 Off$"9 ^
Item 2. Combined Waste Streams - Multi-Product Manufacturing
       A. Estimate Quantity Prevented in year reported	
          Explain Estimate In Section III
       B. Quantity Newly Recycled In year reported	
                                                               Tons
                                                                 Pounds
                                                                            . Ib/gal
     A Narrative description of waste minimization project or activity and results achieved.
                                                  54

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                    SLIDE 7

  TRACKING  WASTE MINIMIZATION PROJECTS

               DATA SUMMARY
                   TABLE 1.

                       POLLUTANTS PREVENTED (TONS/YR)
PROJECT NAME
REFORMULATION
RADIATION
POLYMER.
VAPOR DEC/
SOLV. SUB.
FREON REPLACE/
IN CANS
SPRAY DRIED/
LEAD ELIM.
ALTERN.
EMULSIFIER
HIGH 'SOLID
ADHESIVE
ZINC OXIDE
REDUC.

DATE
1987
1987

1987

1987

1988

1988
1988

1988


PLANT
A
B

C

D

E

F
G

H


AIR WATER W/W SOLID HAZ.
1 1
3000

45

313 430 430

430 3.5

643 327
332

70 70

TA3UU
                    SLIDE 8

                    EXAMPLE
FIGURE 3.  SUMMARY  WASTE MINIMIZATION TRENDS
SICO CODE 000
               LARGE QUANITY GENERATOR COMPANY
               WASTE CODE F-000
240 -
1" 220 -
0 200 -
N 180 -
^ 160 -
p 140-
P
£ 120 -
R 100 -
80 -
Y
r
A 4°-
R 20-
n -
224












0



2.









1. rKLVtmtu
2. GENERATED 195
3. RECYCLED






58

3.


















. rt
4U

1.


2.























85
70


3.






1.



233




2.









218



3.






















            1986
                       1987

                   CALENDAR YEAR
                                    1988
                      55

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        FIGURE 4.  INDUSTRIES' ONE PAGE, SELF-EXPLANATORY PROPOSED FORM
      MAKE A COPY OF THIS FORM FOR EACH NEW WASTE MINIMIZATION  PROJECT
 BEFORE COPYING THIS FORM, ATTACH SITE
 IDENTIFICATION LABEL OR ENTER:
 SITE NAME
 EPA ID NO.
      I  I  I  I   I  I  1  I  I  I   I  I
                                              U.S. ENVIRONMENTAL PROTECTION AGENCY
                                                          1988  or 1989
                     FORM

                    WM
              WASTE MINIMIZATION
                   REPORT FOR
                    FJ1988
                    fj 1989
 WHO MUST COMPLETE THIS FORM?  This form must be completed by large generators that completed a new waste
                                    minimization activity, or project in 1988 or 1989.
  Waste minimization means:

  (1) Any new activity which prevents generation of Hazardous  Waste.

  (2) Any new recycling of hazardous waste - onsite or offsite.
                                                        INSTRUCTIONS:
                                                        Enter "DK" for "donl know" or "not available."
Sec.
  I
A.EPA hazardous waste code



I  I   I   I  I  I  I  I   I  I

I  I   I   I  I  I  I  I   I  I
B. Prevented
D Good Practice
D Inventory Control
D Spill Leak Prevention
O Raw Material Substitution
Q Process Modification
rj Product Modification
D Direct Recycle
C. Description of product or service
D. SIC Code
 E.Waste form code
 D Gas
 D Liquid
 D Solid
 Q Not known
            SARA 313—TRI Constituents
             D Not required for facility
             Q Required but none on list
             Q Req'd& SARA 313 chemicals are
                  fn waste
             D Don't know	
                H. Source description:
                D Cleaning and degreasing     Q One time event
                D Surface preparation         [] Treatment
                D Other than surface preparation
                                I. Origin
                                ^Generated on-site
                                QRec'd from off-site
                                DReskfue from onsite
                                 Treat or Recover
 Sec I Results of project or activity
  ** I  Show Quantity of Waste Prevented or Newly Recycled
       Complete either Item 1 or Item 2 - Describe in Section III

  Item 1. Sinole Uncombined Waste Stream - Single Product Manufacturing
         A. 1987 Quantity Generated 	  Q  Tons
                                          O Pounds
         B. 1988 Quantity Generated s        d   Gals.	 to/gal '
         C. Production Ratio       	
         D. Calculate Quantity Prevented or Newly Recycled in year reported
                                                             PROJECT CD Prevented Generation or
                                                                       n Newly recycled
            A X C - B  =
                                                Prevented
                                                Newly Recycled
                                                               Onsite
                                                               Offsite
  Item 2. Combined Waste Streams - Multi-Product Manufacturing
         A.  Estimate Quantity Prevented in year reported	
            Explain Estimate in Section III
         B.  Quantity Newly Recycled in year reported 	
                                                             Tons
                                                              Pounds
                                                             Gals. 	
                                                . Ib/gal
Sec.
  Ill
 A Narrative description of waste minimization project or activity and results achieved.
                                           SLIDE  9
                                                   56

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Creating the Conditions for Sustainable Development: Programmes and Instruments
for Pollution Prevention

Dr R Bidwell, Environmental Resources Ltd, 106 Gloucester Place, London W1H 3DB

INTRODUCTION

           There  is at present considerable  interest  worldwide  in  programmes
designed to encourage environmentally less damaging behaviour; it can be argued that
this interest has  been spurred  on  by such factors as the Brundtland Commission
Report, highlighting the need for sustainable development and concern about both
global issues (eg the Greenhouse effect) and local issues (eg Hazardous waste).

This paper examines what this might mean in practice and in particular draws on:

           the National  Environment  Policy Plan established by the Netherlands
           Government and  the concept of "integrated  life cycle  management"
           intended as a framework for  fundamentally reducing resource use and
           waste production;

           the experience in  OECD countries of employing different forms  of
           instrument that can be used to implement sustainable development policies

PROGRAMMES

Integrated Life Cycle Management

           The Netherlands National Environment Policy Plan sets out quantitative
targets for a number of pollutants and waste streams. There are targets for 2010 and
are expressed in Table  1 as a percentage reduction from 1985 (or 1980) levels. The
analysis proceeded to look at how these targets could be achieved.  Three scenarios
were examined: a continuation of current  policy (I); a  very strict emission  orientated
regime (II) and a package of emission orientated measures together with a more far-
reaching change to the pattern  of consumption, resource use and waste production.
A key element in  this more "structural" strategy was a focus on integrated life cycle
management (ILCM).

           ILCM is a strategy designed to ensure that all the "actors" involved at  all
stages in the production and consumption of goods and services shape their activities
to minimise the use of resources and production of wastes.

           To  achieve  the  aims   of  the  Netherlands  NEPP  and  to  improve
environmental quality to the defined target level of 2010, it will be necessary to meet
consumer demand for goods and services in such a way as to minimise the production
of waste at all stages of the "life cycle". While waste minimisation at each stage will
be an important component of  the strategy,  ILCM also requires that  there is some
reshaping in the way that  goods and services are supplied to the consumer;  and this
reshaping necessarily affects each stage in the production chain.

           There are two important points.  First, the aim is not to limit economic
growth. Rather, it is recognised that the cost of add-on pollution control will continue
to grow and in the long run could have a greater impact on economic prosperity than
refocussing the way that goods and services are supplied. Second, there are  numerical
                                      57

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targets.  In the past, politicians have exhorted industry and consumers to cut waste,
increase recycling etc, reduce hazards, use public transport etc; but they have failed
to support these exhortations with targets and coherent strategies let alone policies or
implementation - in other words, they have failed to create the necessary conditions.

Conditions for Sustainable Development

           Table 2 sets out some of the conditions for a concentrated reduction of
pollution levels such as those envisaged by the Dutch Plan.

           Influencing the market. The choice of resources, goods and  services by
consumers and producers depends on price, availability and information; producers
are influenced in the product design and supply of services by consumer behaviour.
Economists will argue that a key  component of the ILCM strategy must be pricing: to
ensure that the environmental costs are  fully taken  into account and to  ensure that
pricing  is  used  (through  application  of economic  instruments)  to  implement
government policy.  Improving the flow of information (from producer to consumer)
and of education  (understanding the environmental implications of certain actions)
are also important elements.

           Influencing the public sector.  It is often forgotten that government is a
major provider of goods and services and a major purchaser (consumer) and investor.
The way in which for example the public  sector establishes its procurement policies
and invests in transport infrastructure has a major impact on resource use and waste
production.   Once again, pricing  is an important  tool:   but it is  important that
information is available in the decisions that are being taken, and government can
influence the market (and pricing) by its procurement policies:  if the public sector
will only purchase cars with catalytic converters that creates a considerable "base
load" market  for manufacturers.

           "Command and  control" restrictions.   Market  mechanisms alone are
unlikely to prove  adequate; in  certain sectors actions will be required to achieve the
aims  through restricting the use  of  certain  substances, requiring that certain
information is made available, regulating the proportion of a substance in a particular
product, limiting waste discharges.

           Integration.  The conditions need to be such  that in each part of the
producer-consumer-user chain, the decisions taken are consistent with the overall aim
of  minimising  waste  and  resource use and delivering goods  and services  in an
environmentally less damaging way.

Categories of Instrument

           Based on the above,  Table 3 sets out the instruments available to bring
about ILCM.  The Table also indicates how each type of instrument may be expected
to influence each group of actors.

1.         Economic  instruments. These are primarily charges and taxes  levied on
           products or discharges (eg, taxes to make  leaded petrol  more costly, or
           charges on discharges to water or air of pollutants); subsidies to encourage
           certain  investments; and  deposit refund  schemes.   They also include
           tradeable permits.

2.         Command and control. These include product and discharge standards and
           restrictions.
                                       58

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3.          Information.  This category includes the provision of information (or the
           requirement that information is provided) about  a  particular plant,
           substance  or  product.    It  therefore   includes  labelling,  auditing,
           environmental impact assessment (EIA).

4.          Liability.  This category includes measures that require the discharger to
           bear responsibility (and costs) for any damage caused by  products or
           wastes.

5.          Education. This category is concerned with the general provision of data
           about the  environment,  a  process or a substance.  It therefore includes
           government information about clean technologies, recycling centres, state
           of the environment.

EXPERIENCE OF IMPLEMENTATION

I.          Economic  Instruments

           There has been renewed interest in  product and waste charges over the
           past two years in  OECD countries and particularly in Europe.

           Economic  instruments, charges and subsidies can be  used:

                to ensure that the full environmental cost is included in the price of
                goods or services or in cost of  waste disposal;

                or, and more pragmatically, to change behaviour by ensuring there
                is a  differential that favours the environmentally  less damaging
                option;

                or to  raise money  to  subsidise  environmentally less  damaging
                processes or services (eg transport);

           Tradeable permits that have been employed in the US have a more limited
           role in allowing dischargers adjust at least cost to  regulation

           There are at  present a range of product charges  in force in Europe
           particularly in Scandinavia. In addition there has been extensive use of
           pollution and waste disposal charges and subsidies in Europe over the past
           decade:  for example in the Netherlands, France and Germany for  waste
           water discharges  and there is increasing  interest  in extending full cost
           recovery charges for waste disposal to include even the opportunity cost
           of the facility or  wider environmental costs, (eg in California).

           There are  a number of issues:

                How practical is  it  to   introduce  a widespread   system  of
                environmental cost accounting to ensure the full costs are paid? This
                issue is on the agenda in a number of countries and companies but
                experience is fairly limited.

                In which areas would introducing economic instruments have the
                greatest effect?  How  is the level of  price  required to change
                behaviour to be determined?.  In Sweden it was found that a high
                                      59

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                 charge was required to achieve a 75% beverage container recovery
                 rate; in  the  UK a differential of around 5%  was sufficient to
                 encourage the use of lead free petrol.

                 What are the practical issues?

II         Restrictions

                 Government  can of course achieve the more fundamental pollution
           prevention  strategies  and  goals  through  regulations  restricting  or
           encouraging certain practices.  Examples include the following.

                 Recycling:   in  Denmark there is legislation requiring  that  all
           beverage containers should be returnable; this is supported by a deposit
           scheme. Government may also regulate to encourage all stages  in waste
           recycling, but in most countries, activity has been limited to exhortation.

                 Restricting substances.   Sweden  has taken  steps to restrict the
           industrial use of cadmium in order to reduce the amount that is dispersed
           in the environment.  Similar actions have taken place in  Denmark and
           there is some voluntary action by companies.

                 Product  use.  In the US,  legislation imposes strict requirements on
           vehicle  manufacturers to ensure that average fuel  consumption in their
           whole production achieves 26 miles per gallon by 1990.  Failure to achieve
           these levels will be met by fines of $50 per car.

           But again there are a number of issues:

                 Why have governments tended not to use restrictions to encourage
           recycling, limit environmentally hazardous substances from products or
           restrict  waste?  These approaches have been used  to protect consumer
           health but with a  few exceptions have had  limited application where
           environmental protection or resource use has been the goal.

                 Are they effective instruments for creating the conditions for long-
           term pollution prevention? Or are they too interventionist, potentially
           distorting the market? Are they difficult to design without protecting one
           part of the environment at the expense of the other?

                 Where are the priorities  where this form of instrument should be
           used? What are the practical issues?

Ill         Liability

                 Liability may also be seen  as  a  market mechanism insofar as it
           brings the responsibility for the damage caused by products, processes or
           waste streams into the financial calculations of the producer or consumer:
           it introduces a  need to minimise risks, wastes and discharges for financial
           reasons.

                 The Superfund legislation in the United  States imposes a strict
           liability upon firms that have deposited wastes on sites where subsequently
           clean-up is required.  An important issue is that evidence of use of the site
           imposes a liability on the firm; and that liability might be for the full
                                       60

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           clean-up  cost.   In other  words,  the  burden of proof is shifted:  the
           regulator no longer has to prove damage has occurred or the proportion of
           damage caused by the discharger; rather, there is  a strict  "joint  and
           several" liability.

                Also in the United States, the Environmental Clean-up Responsibility
           Act (ECRA) of New Jersey requires firms to notify  any event likely to
           cause contamination. Firms are also required to prove the applicability
           or non-applicability of clean-up  responsibility when they are selling a
           major portion of the company.

                The EC is also considering extending liability to waste producers so
           that they have strict liability up to the point  of final disposal.

           The key issue here is:

           How successful has imposition of  liabilities been in terms  of altering
           producer and consumer practices? Could the  schemes be better focused?
IV         Information
                Information  is in  part  a "market mechanism"  insofar as  full
           information about environmental implications of products will allow the
           consumer to make an informed choice when purchasing.  Information is
           also an  important tool  in  terms of providing members of  the  local
           community with information about the waste discharge from factories or
           the risks associated with materials stored on the premises.

                Product    information.     Environmental  labelling   is  under
           consideration in a number of EC countries, Japan,  Canada and non-EC
           Scandinavia.  For example, the German Blue Angel  eco-labelling scheme
           covers 57 product categories but is not compulsory. Government regulation
           sets a frame for the standards required to be eligible for such awards but
           application by manufacturers  for   blue  label  awards is  voluntary.
           Government procurement policies stipulate that  public authorities should
           use Blue Angel products where these are available.  Similarly the US
           Conservation Act sets energy efficiency requirements and standards for
           13 categories of major domestic appliance:  standard test procedures are
           laid down  and appliance labelling is required to show energy  efficiency
           or annual cost  of operation of the machine.

                Voluntary  auditing and  information  disclosure.   A  number of
           companies  audit their  own activities in  order  to identify  potential
           environmental risks, opportunities for  waste minimisation etc.   Such
           practices are increasingly commonplace amongst major multinationals.

                Environmental Impact Assessment. (EIA) for developments  and
           products. EIA is an information tool: it allows the planning authority and
           community to understand the environmental implications of a proposed
           new development and provides the opportunity for re-shaping at an early
           stage.   Environmental  assessments  are  also under  consideration for
           products: in Sweden an attempt is being made to develop an approach to
           examine raw materials, processing, use and waste for a range of products.
                                     61

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     Compulsory disclosure.  Organisations may be required by law to
provide information on potentially environmentally damaging substances
stored or released.  The EC Seveso Directive requires companies to make
information available about certain categories of substance stored on site.
In the US, the Toxic Release Inventory requires manufacturers to provide
the  EPA  with information on routine or chemical releases to air, water,
land or sewage for over 300 listed potentially hazardous chemicals. The
public has full access to the information.

There are a number of issues.

     Does environmental labelling work? What are the key elements in
making it work: how are criteria established? Should labels only be given
if all aspects of the product and packaging are "environmentally friendly"?
How is the scheme audited?

     How can company auditing be encouraged? Should disclosure of the
results be made compulsory? How can auditors be trained and  a code of
conduct established?

     What evidence is there that providing information about waste and
toxic releases has a feedback in terms of altering the behaviour of the
company? How can such schemes be shaped?  Should they be tied into
auditing?

     How valuable are product audits or  product assessments?  Can the
approaches  currently being considered  be linked into labelling?  How
again does one establish the criteria?  What links to  other instruments
might be required?

Education

     Education has been a major tool in terms of encouraging changes in
producer and consumer behaviour.

     To a large extent it has been government inspired.  For example a
number of OECD governments have provided  extensive information on
recycling, waste minimisation, energy conservation and on the use of
different types of resources and products with  information on  the
environmental consequences.

     Environmental pressure groups have also had an impact. The tropical
hardwoods campaign in Europe is an example.  Environmental groups
actively  lobbied  government  and  international  agencies to change
hardwood forest management practices; they also lobbied the retailers of
tropical  hardwood products  and  approached   consumers   through
publications such as the "Good Wood Guide" in the UK.  Over 200 retailers
or specifiers (eg architects) for furniture  and  wood fittings agreed to a
statement that  they would  only sell tropical  hardwood products from
sustainable sources.  A  number of  Local Authorities  made a similar
commitment.

     There  are also investor implications.   A group in  the US  has
established a set of principles called the "Valdez Principles". Companies
that wish to be considered environmentally sound (and as such  ones that
                          62

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           ethical investors would wish to support) are being asked to agree to these
           principles: they include voluntary auditing and disclosure of the results.
           The availability of such information would educate the investors.

           There are a number of relevant issues.

                How effective are government information campaigns?  Are they
           undertaken because they  are  inexpensive and give the impression that
           action is being taken?  Do they achieve results?  Should  they be tied to
           other instruments?

                Are  environmental  pressure  groups  an  important element  in
           providing  information to  shape public opinion  and  the  choice  of
           environmentally less damaging approaches?  Is there evidence for this?
           Should such campaigns receive financial support from government?

CONCLUDING COMMENTS

           Overall it can be seen  that "creating the conditions" involves a different
response by government from that which has traditionally been the pattern over the
past two decades.  In the sector of minimising waste and resource use there has been
a tendency for government action to focus  on new technologies:  providing R&D
subsidies,  information exchanges, technology transfer etc.   While  these  may  be
important elements, they should be seen as actions that will be required to relieve
particular bottlenecks rather than priorities in themselves.

           In general  there  is therefore the need  to focus  on (i)  creating the
conditions  under  which  all  the many  individual decision makers implement
environmentally less damaging initiatives; (ii)  ensuring  that  targets are  met for
particular target sectors and (iii) identifying for any one  country the international
and trade implications.

           The paper has examined those instruments that can create the necessary
conditions  within which  environmentally less damaging decisions will come to be
taken.  There is clearly a need to provide a consistent framework that allows potential
environmental damage to be taken into account and, in general, to avoid a piecemeal
approach to environmental  management planning.
                                      63

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TABLE  1
Netherlands  Plan.   Targets for 2010

S02 (1)
Nox (1)
MH3 (1)
Hydrocarbons (2)
discharges to Rhine and North Sea (2)
North Sea waste (2) to a 10X
(1) 1980 is base year
(2) 1985 is base year
(3) Scenarios
X reduction achieved by Scenarios (3)
Target 1 II
to 3 10X -50 -75
to 9 10X -10 -60
to a 10X -33 -70
to a 20X -20 -70
to a 20X -50 -75
0 -50



III
-90
-80
-80
-80
-90
•90



          I         Continue  current pollution policy control (Cost 1.9X GOP)

          II        Maximum utilisation of currently available emission orientated measures (Cost 3X GDP)

          III       A package: emission-orientated and "structural" source orientated (Cost 4X GDP net)

          Costs assume other  countries do not take the same measures as the Netherlands.


Derived from:  National Environmental Policy Plan, Netherlands Government, 1989.

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TABLE 2
Role of actors in Pollution Prevention
CONSUMERS:
PRODUCERS:
                    OBJECTIVE
                                                                                DECISION FACTORS

                                                                                          Influenced by:
                    Choice of environmentally less damaging products and services

                    Use products and services in an environmentally less damaging
                    fashion

                    Recycle more of waste stream.
                    Design and make available environmentally less damaging products
                    services.

                    Develop and install environmentally less damaging processes
                    Invest in R&D designed to identify environmentally less damaging
                    products and processes.
INVESTORS;

                    Finance available only to producers that are committed to environ-
mentally less damaging processes, products, services.
MEDIA;
                                                                                          Influenced by:
Influenced by;


information)


Influenced by:
                    Provide education on environmentally less damaging processes,
                    products, services.
                    Pricing (economic instruments)

                    Product availability (regulations).
                    Information to aid environmentally less damaging choices.
                    (regulation information and education)
                    Consumer choice.   Risks,  responsibilities  and potential claims
                    (I{abilities,information, education)

                    Availability and price of resources (regulations,  economic
                    instruments)

                    Restrictions and cost of waste discharges and attractiveness
                    of secondary materials market (regulations,  economic instruments)

                    Encouragement to install new  processes or undertake R&D,  (economic
                    instruments)
Ethical concerns (education).  Longterm profit motive (education
                    Ethical  concerns  (education).   Longterm  profit motive  (market
                    forces)

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TABLE 3
Imtnamts for lapt
                  ing  ILCM.  Examples relating to different actors.
 Instruments

 Economic  instrunents
 (Taxes, other
 subsidies)
                      Consumers

                      Influence product pricing to encourage
                      purchase charges, and use of environmentally  less
                      damaging products (eg lead in petrol).
                      Encourage recycling of beverage containers.
Producers

Encourage use of cleaner processes, (eg  German
waste water charges) or installation of  cleaner
processes (eg subsidy schemes operating  in  some
EC countries). Encourage R S D into cleaner processes.
Investors

Possibility of tax incentives
for "Green" investment funds.
and Control           Regulate type of product sold (eg hazardous
                      substances, vehicles, eg USA CAFE  or
                      require recycling (eg beverage containers)
                      or way product is used (speed limit
                      in USA).
                                                                                           Controls over discharges, wastes, environ-
                                                                                           mental standards etc.  Controls over use of
                                                                                           resources, types of process etc (eg Cadmium
                                                                                           controls).  Establish product standards
                                                                                           (length of life, recycled content etc) and
                                                                                           link these to procurement policies.
Information
                               Requirement  that  information be supplied to
                               consumer  (or encourage voluntary measures)
                               (eg  Blue  Label).
                                                                                  Requirement  that  information on all  discharges
                                                                                  released  to  public  domain (eg USA  Toxic Release
                                                                                  Inventory).
                                                             Possibi I i ty of requi rement
                                                             that coipenies should provide
                                                             envircniEntal audit infonreticn
                                                             (Valdez  Principles).
liability
                               Requirement  that consumers  (users)  should be
                               responsible  for full cost of any environmental
                               damage.
                                                                                  Requirement  that  producers  bear  full  responsibility
                                                                                  of cost of damage caused by products  or processes
                                                                                  or are fully liable  for  any incident  where they may
                                                                                  have been partly  responsible (ECRA,).
                                                             Investors  take account of
                                                             potential liabilities when
                                                             providing f trance to prcdjcers.
Education
                               Increases ability of consumers to make an  informed
                               choice  (eg Tropical Hardwood Campaign, Hewlett
                               Packard, Agfa).
                                                                                  Increases producer awareness of  risks,  liabilities and
                                                                                  and opportunities for  improvement, also
                                                                                  availability of new  technologies and need for waste
                                                                                  minimisation.
                                                                                                                                               Increases investor awareness.

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            TECHNICAL ASSISTANCE TOOLS AND APPROACHES
WASTE REDUCTION INCENTIVES AND BARRIERS: THE FLORIDA EXPERIENCE
      by:   William W. Bilkovich
            Waste Reduction Assistance Program Engineer
            Florida Department of Environmental Regulation
            Tallahassee, Florida 32399-2400

      Waste reduction is an idea whose time has come. More accurately, it is an idea
whose time has returned.  In a less profligate age it was unthinkable to waste raw
materials and energy because they were in such short supply. The discovery of the
planef s liquid fuel reserves gradually changed our attitudes toward the way we made
and used products. With very cheap energy and unregulated disposal of wastes, the
consequences of inefficient  energy  use and unsafe  waste disposal were effectively
passed on to future generations. It was as if we had found a savings account passbook,
in the form of petroleum reserves, lying on the ground.  We went to the bank and
found we could make withdrawals.  What we didn't realize then was that the function
of that savings account was  to get the human race  through a transition period during
which a self-sustaining industrial ecosystem would need to be invented.  By the 1960's
it had become evident to some that we would never  close  the loop  on this ecosystem
and quite possibly poison ourselves out of existence  if the way wastes were handled
did not  change.  The  Environmental Protection Agency and  the Department of
Environmental Regulation  were founded  to address this problem. Regulating the
treatment of specific wastes in specific media (air, land and water) and permitting their
disposal was the first step in a process of making industry and through it, society,
responsible for the consequences of the way products are designed, manufactured, used
and discarded.

      As regulations became stricter and the number of regulated  wastes expanded,
disposal costs rose and more of the costs  that had formerly been  transferred to the
future were brought back into the present.  The regulatory framework can be thought
of as functioning to simulate scarcity of energy and raw materials, thereby encouraging
waste reduction. The non-regulatory Waste Reduction Assistance Program (WRAP) in
the State of Florida's Department of Environmental  Regulation was created to assist
the regulatory side of the Agency by encouraging voluntary waste reduction. The
program's goal is to reduce the flow of all  wastes into all media by:
      1.    Changing industries' attitude toward waste
      2.    Connecting industry to waste reduction tools and
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      3.     Helping make waste reduction a permanent part of the corporate
             culture.

      For this program to be successful it became apparent early on that it would be
necessary to examine the incentives for and barriers to waste reduction. After all, if
waste reduction is such a great idea, why isn't it already happening?  Let us examine
the tasks mentioned above  in  light of the forces that assist and impede their
accomplishment.

      Program engineers try to change industries' attitude toward wastes by showing
them how to look upstream from the "end of the pipe" toward the sources of waste.
A new hierarchy of waste management is taught:
             1. Source Reduction
            2. In-plant recycling
            3. Out-of-plant recycling
            4. Treatment to detoxify waste
            5. Disposal as a last resort.

      Concentrating on treatment, the "end of the pipe", fosters the attitude  that waste
costs are merely a part of doing business. Waste costs become part of the budget and
someone is assigned to manage compliance and keep up with changes in regulations.
Once that is accomplished, the system is thought to be in control and that  is the end
of their effort.  What were supposed to be incentives for waste reduction,  increasing
disposal costs and regulations, have become barriers.  Looking upstream from the end
of the pipe on the other hand  encourages industry to take control of the source of the
waste, not merely its treatment.

      Back at the source, the nature of the true costs of waste becomes more apparent.
For example, a Florida company that paints aluminum  asked for help dealing with
their paint waste.   They electrostatically apply thermosetting  high-solids coatings
(paints that remain liquid until heated to over 300°F) with about 95% efficiency, which
is very close  to state-of-the-art.  They paint so much, however, that  they  have over
10,000 gallons of oversprayed paint and clean-up solvent per year. Disposal costs are
about $30,000/year  which was a concern of the paint manager at the company.  The
visiting Waste Reduction Assistance Program engineer pointed out that the waste they
were paying $30,000 to throw out contained over $150,000 in raw materials in the form
of paint and solvent. (Typically, 75% of the savings from waste reduction come from
raw material cost savings.)  The real cost of waste is more than $180.000 per year. It
would take an additional $3.6 million in sales to generate the same bottom-line balance-
sheet effect as eliminating this  waste cost. This potential cost savings is the single most
powerful incentive for waste reduction.  Why then wouldn't  a company leap at the
chance to save $180,000 per year?
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      Examining a list of barriers to waste reduction  will give us some possible
reasons. We've already mentioned three: there is a budget for waste, the company is
complying with all regulations and the system is working.  "If it ain't broke, don't fix
it."  We can add to those the following:
      1.     The generally short-term economic focus of American industry.
      2.     Although there is a budget for waste, there is no budget for pollution
            prevention.  (In our own lives,  for example, most of us have health
            insurance, but far fewer have a budget for the  prevention of health
            problems.)
      3.     If implementation of the waste reduction idea requires a permit,
            companies are very reluctant to pursue it.
      4.     Competition for resources within the company.
      5.     Fear of failure, especially with a new technology.
      6.     Concerns for product quality.

      Let us assume that the Waste Reduction Assistance Program has accomplished
its second task  and found  an in-plant-recycling waste reduction  solution to this
company's problem and that the permit question has been resolved to the Department
of Environmental Regulation's satisfaction.  Further assume that the  capital cost is
$25,000 and the operating costs are $0.25 per gallon recycled. The payback period for
this solution would therefore be about 7 weeks. This should overcome the short-term-
focus barrier and make it competitive for company resources.  The technology is not
very complex and in its general form has been applied elsewhere.  This leaves us with
the last barrier:  concerns about product quality.

      The long-term survival of a company depends upon producing consistently high-
quality products. Any changes that may affect that quality are examined very closely
before being implemented. The collection, filtration and reformulation of thermosetting
paints is the way some office furniture manufacturers handle  their overspray paint.
This Florida company, however, paints parts for exterior use and  will have to be
convinced by testing or example that the coating will not degrade five years from now
as a result of the recycling process.  In the final analysis someone must be willing to
take the risk of trying any new idea.  There are a number of incentives whose benefits
are not easily quantified, but which can encourage companies to take risks and try new
processes.

      If a waste reduction idea could totally eliminate a class of waste, the cradle to
grave responsibilities  for that waste  disappears with it.  Unknown, off-balance-sheet
costs such as  those associated with future Superfund cleanups  or  other long-term
liability problems associated with having produced a waste are perceived as risk by the
securities  markets. The greater the perceived risk the lower the price of a company's
stock.  This gets the attention of Chief Executive Officers and shareholders.  Another
non-quantifiable incentive is getting  off the top of the list of generators of hazardous
waste or air toxics. No one can say exactly what that is worth, but our experience
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shows it to be a powerful incentive. Being an environmentally responsible business is
becoming more important to a company's survival with each passing day.

      A waste reduction solution which lowers health risks for employees has a better
chance of being implemented than one that doesn't.  This incentive may prevail in
cases where the power of the cost savings incentive is weakened by the structure of an
industry.  For example, some regulated  industries and the defense industry have
incentives to merely pass  waste costs on  to customers and/or taxpayers.  Let us
examine the Waste Reduction Assistance Program's second task, which is to connect
companies to waste reduction tools, with an example that illustrates some of these
incentives.

      Some waste  reduction opportunities  are  easier  to implement because the
necessary equipment already exists.  A Florida chemical repackager is installing dry-
disconnect hoses and changing  a  piping manifold so that solvent cleanup between
batches becomes unnecessary. Other opportunities involve operational changes  that
make a worker's job easier and  therefore have a good chance of becoming standard
practice.  In some  cases,  however, a solution  is apparent but the  equipment to
implement that solution does not  exist.  In this case, connecting industries to waste
reduction tools means a search for  someone willing to build a new type of equipment.

      Vapor degreasing is a cleaning technique used to prepare parts for electroplating
or painting. It involves placing  a  room temperature part into hot solvent vapor.  As
the vapor condenses it washes off any contaminants. The more common solvents used
are halogenated hydrocarbons  such as  perchloroethylene,  trichloroethylene, 1,1,1-
trichloroethane, dichloromethane and Freon 113.  Research  is being done on replacing
these toxic smog-creating or ozone-depleting cleaners.  There  are,  however, a  few
intractable cleaning problems that remain, so that this cleaning method will likely be
around for at least another 5 years. Quite a few of these cleaners have been seen in the
course of the more than fifty on-site assessments Program engineers have performed.
Most of them are losing substantial amounts of solvent to the atmosphere.  Fugitive
and stack emission for 1988 of these 5 chemicals, from just those Florida companies
reporting under SARA Title III regulations, amounted to more than 8 million pounds.
The losses are a direct result of the way degreasers are designed and operated.  As
presently constructed the lids must remain open while parts  are being degreased.
Substantial air  flows are required in the  work place both  for health and comfort
reasons.  This air flow blows solvent out of the degreaser whenever it is open. In
addition to these losses, operators can cause solvent losses by moving parts in and out
of the dergreaser faster than one  foot every six seconds. Given Florida's climate, which
makes wearing a gas mask uncomfortable  and the fact that these degreasers operate
at over 170 degrees Fahrenheit, operators try to spend as little time as possible standing
over them.
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      The solution seems to be a split lid which can be closed after the part is inserted
and a programmable controller for both the lid and the parts winch. This would assure
that the lid was closed as much as possible, prevent losses due to rapid part movement
and get the operator away from the source of solvent when the lid is briefly open. The
problem is that no one seems to make such a device.  Program engineers have found
two  cases where  lids were brought under control and in both solvent losses fell
dramatically. At Lufthansa's rebuild facility in Hamburg, Germany losses to the air
went from 75 tons/year to 2 tons/year when a very elaborate degreasing facility was
constructed.  On a much smaller degreaser in America, strict manual control of a split
lid reduced  solvent losses from 48 drums/year to 1 drum/year.  The search for a
vendor of retrofit equipment of this nature is continuing. One of the program's clients,
an aircraft component rebuilder, loses $75,000 of sol vent/year from one degreaser!
This would  seem to  be  a powerful economic incentive for purchasing such waste-
reduction equipment. The rebuilding of airplane components, however, is a regulated
industry. Other rebuilders experience similar solvent losses  and costs.  The ability to
pass these costs on to the airlines (and passengers) makes the expense and effort of
implementing this waste reduction solution less attractive. Similar forces are at work
throughout the defense industry. The more powerful incentives for this company are
the fact that they are  at the top of the local polluter list and  that it offers the
opportunity  to drastically reduce worker exposure to a hazardous chemical. Being the
top polluter  in an area makes company officials very uncomfortable. The unknown
future costs of worker health problems, like the unknown future costs associated with
cradle-to-grave responsibility for wastes, subject a corporation to a risk that it cannot
predict  accurately.   Good business practice dictates that such risks should be
minimized.

      The third and final task of the program is to help make a waste reduction
program a  permanent  part  of a  corporation's  culture.   The  biggest barrier to
accomplishing this is the fact  that everyone  already has a full time job.   The
environmental manager is especially busy. Typically, this person oversees waste
disposal, worker health and safety, all waste reporting, training of workers in waste
handling and safety and frequently  also oversees quality control and instrument
calibration.  The possibility of reducing one of the company's waste streams is an
attractive incentive, but where is the time to do it going to come from?  One can
picture waste reduction opportunities as fruit on a tree.  What WRAP engineers are
trying to do is find a nice piece of low-hanging fruit, put it in the appropriate person's
hand, help them carry it to upper management  and say, "Look what we could do if
you would commit some resources to waste reduction."  The successful completion of
that project must be the stimulus for a company-wide policy of waste reduction with
top-management commitment and the involvement of every worker. Waste reduction
must become part of what a company does every day for it to be successful. When this
happens, the time and money necessary to accomplish waste reduction will become
available.
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      The Waste Reduction Assistance Program has been fully staffed for a little over
6 months. It is therefore too early to say how successful the program will be in
accomplishing this last task. Hundreds of examples from all over the country indicate
that success at waste reduction is an infective process. One Florida client, having had
success with his first waste reduction project, finds that whenever he walks though his
plant he now thinks not of how many parts are being made, but of how he could
reduce each waste stream. The benefits of waste reduction so outweigh the costs of
implementation, the incentives for it are so much more powerful than the barriers to
it mat, once begun, waste reduction becomes an integral part of a company's survival
strategy. Every time that happens, we take another step toward creating the dosed
loop industrial ecosystem necessary for our long-term survival.
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                     UNDERGROUND COAL GASIFICATION:
               GROUNDWATBR CONTAMINATION CAM BE PREVENTED

              by:  James R. Covell and
                  John E. Boysen
                  Western Research Institute
                  P.O. Box 3395, University Station
                  Laramie, WY  82071

                  James M. Evans
                  Gas Research Institute
                  8600 W. Bryn Mawr
                  Chicago, IL  60631

                  Craig R. Schmit
                  North Dakota Mining & Mineral Resources
                  Research Institute
                  Energy and Environmental Research Center
                  University of North Dakota
                  P.O. Box 8213, University Station
                  Grand Forks, ND  58202
                                ABSTRACT

    The prime  environmental  concern associated with  underground  coal
gasification  (UCG)  is the  potential  for groundwater contamination.
Previous  UCG field tests have  impacted groundwater quality.  With the
support of the Gas Research Institute  (GRI)  and the U.S. Department of
Energy (DOE), an environmental  program was  developed to  address
contamination of groundwater resulting from UCG  operations.  As a result of
this program, a clean cavity  concept was devised to reduce the generation,
deposition,  and transport of contaminants associated with UCG operations.
Restoration  procedures  and operational  constraints devised from  this
concept were  incorporated into the operational plans for the Rocky Mountain
1 (RM1) UCG  field  test.   Test  results show that the restoration procedures
and operational constraints successfully reduced impact to groundwater
quality resulting  from UCG operations at  the RM1 site.
                              INTRODUCTION

    Underground coal  gasification  (UCG) has the potential to significantly
increase the usable  energy resources of the United States by  developing
coal reserves that are too deep or too thin to be economically  mined with
conventional  techniques.   UCG recovers the  energy  of a coal seam as  a
gaseous fuel through a combination of in situ coal drying,  pyrolysis,  and
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gasification processes.  Major  constituents of the  gas  include steam,
carbon dioxide  (CO2),  carbon monoxide  (CO), hydrogen (Hg),  and methane
(CH4).   Some hydrogen sulfide (I^S)  is also  found in the gas.   This gas  can
be used as a fuel or as a feedstock  for producing liquid  (e.g. methanol)
and gas products.  Up to 90 percent  of the heating value of the coal can be
recovered as  combustible energy and  sensible heat.   Due to the in situ
nature  of the process, minimal surface disruption and reduced capital  costs
relative to  surface coal gasification are achieved.

    The UCG process  is  a relatively simple  process and, in its most  basic
configuration, consists of two  vertical  process wells  in the  coal  (Figure
1).  Most commonly,  the methods used to  create the permeability necessary
for fluid flow  between the vertical well pair are reverse  combustion,
horizontal  drilling,  or a. combination  of the two.   Reverse combustion
consists of starting a fire in the coal seam at the base  of  one well  and
injecting high pressure air in the other well.  The air permeates though
the coal and intersects  the combustion zone at the base of  the first  well.
The reverse  combustion zone follows  the oxygen source back to the  injection
well forming  a  highly  permeable charred channel  between the wells.  In
horizontal  drilling,  a horizontal well is drilled in the  coal seam to
intersect the vertical wells.   Once  conditions promoting fluid flow between
the wells have been  established,  gasification of  the coal  is  initiated by
injecting oxygen or air.

    UCG has been field tested at a number of sites in the United  States.
Most of this  testing occurred in Wyoming  during  the  1970s,  and some of
these  tests contaminated the local groundwater.   Local  groundwater
contamination  resulted  in  the perception that the UCG  process  was
inherently detrimental  to the environment,  and concern resulted about  the
environmental acceptability of  the process.   Because of the potential
benefit of the UCG process to the energy independence  of this  country,  the
Gas Research Institute  (GRI)  and the  U.S. Department of Energy  (DOE)
initiated a  program to address the environmental issues associated with  the
process as part  of the  Rocky Mountain 1  (RM1)  UCG  test  program near Hanna,
Wyoming.
                           TECHNICAL APPROACH

    The initial focus of the environmental program was to evaluate data
from previous UCG  tests  to better understand the mechanisms of  UCG-induced
groundwater contamination.   The hydrogeology of  old test  sites and
operational histories of these tests were  reviewed and evaluated.

    Subsequently,  an approach was  developed and applied  through which ths
basic mechanisms of UCG groundwater contaminant  generation,  deposition, and
transport were investigated at  a laboratory scale.   The objectives  of this
research  to evaluate the potential impact of the UCG  process on local
groundwater quality  and  to develop control technology for reducing  impacts
to groundwater from UCG operations.   A series of bench-scale UCG simulation
experiments were conducted to evaluate the interaction of the gasification
process with the  hydrogeologic environment.   The  environmental control
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technology  developed  was demonstrated  as a part of  a UCG  field
demonstration conducted near Hanna,  Wyoming.

    The field test,  designated RM1 UCG test, was conducted during the  fall
of 1987 and  the  spring of 1988.  Two different UCG configurations  were
simultaneously tested in  separate process modules.  They were the Elongated
Linked Well  (ELW) configuration and the Controlled Retracting  Injection
Point  (CRIP)  configuration.  Details of the  test  are presented in the
literature (United Engineers  and Constructors Inc., Stearns-Roger Division
1989) .  An extensive environmental program was conducted  as  part of  this
test to evaluate the effectiveness of the bench-scale-derived control
technology in a  commercial UCG  facility.  This program consisted of the
following components:

    o    Site Characterization

    o    Test Monitoring

    o    Groundwater Restoration

    o    Restoration Monitoring

    The  site  was  characterized  to evaluate  the condition  of  the
pregasification hydrogeologic environment at the test site and included an
extensive  evaluation of the baseline groundwater quality.  Groundwater
quality and physical parameters were monitored during the test to determine
changes resulting from  UCG  operations and to determine the  effectiveness of
the posttest environmental  control technology.   After the completion of UCG
operations,  the  UCG cavity was  cleaned  of  potential contaminants  and the
affected groundwater was removed, treated,  and discharged to the surface.
Long-term groundwater monitoring  continued  after UCG operations  were
completed and will continue through  1992.  This report reviews the results
of the environmental  control technology demonstrated  during the RM1 UCG
test  by summarizing  the  groundwater  quality data for  the test site.
Further details related to  changes in the hydrology and  groundwater quality
at the UCG test  site and the importance of  these changes  are reported by
Beaver et al.  (1988) and  Moody (in press).
                         RESULTS AND DISCUSSIONS

ENVIRONMENTAL EVALUATION OF PREVIOUS UCG TESTS

    A review of previous UCG  tests  conducted in  the  United States showed
that selection of  a  UCG test  site  in which the coal  seam is not severely
fractured or faulted and in which the coal  seam is hydrologically isolated
from near-by aquifiers is beneficial for  reducing potential groundwater
contamination and  associated  impacts.   Hydrologic isolation from near-by
aquifiers confines  the gasification products  within the gasification
cavity, which is important for reducing groundwater contamination from the
process.  The containment of gasification products within the gasification
cavity  depends  on  the physical properties  of  the coal seam and boundary
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strata (e.g. permeability).  Other important factors to consider in the
location  of the UCG operating facility are thick competent boundary strata
separating the coal seam and aquifiers,  the existing water quality and use
of potentially affected aquifiers, and a minimum of  structural deformations
(e.g.  faults).

    The Hoe  Creek and Rawlins  UCG field  sites are  examples of the
importance of site selection for reducing the potential for groundwater
contamination.  The Hoe Creek site is located near Gillette,  Wyoming, and
three UCG field tests were conducted at the  site  from 1976 through  1979.
The target coal seam  was at a depth ranging from 160  to  200  feet  from the
surface.   The coal seam was a relatively permeable aquifier overlain by
poorly consolidated  overburden containing  several  other water-bearing
zones.  Extensive subsurface  subsidence into the  cavity that was created
during the tests  caused as much as 20 percent  of the total produced gas to
flow from the UCG cavity into the local strata.  The gas loss contaminated
the near-by aquifiers with  benzene and phenols (Barrash et al. 1988).

    The hydrogeologic evaluation of the Rawlins UCG  test  site near Rawlins,
Wyoming,  indicated  that the  coal  seam had  low permeability  with
structurally  strong boundary strata and no overlaying aquifiers.   Two  large
UCG  field tests were  conducted  in 1979  and  1981.   Because of the
hydrogeologic conditions at the  site, little impact to the  local
groundwater systems was detected.

    All of the Hoe Creek  and Rawlins UCG  tests  were conducted  with UCG
reactor pressures higher  than the  hydrologic pressure of the coal seam
aquifier  being gasified.  In the  Hoe Creek tests, the high permeability of
the  coal seam and  unconsolidated  nature  of the  overburden created
conditions that resulted in contamination.  In the Rawlins UCG  tests, the
low permeability of the  coal seam and the  consolidated nature of the
overburden created conditions that helped prevent  contamination.   These two
test  series illustrate that selection of  a UCG site with  favorable
reservior  conditions,  similar to the Rawlins test site, can reduce the
potential for impacts from  the process on the  local  groundwater quality.

    However,  from the UCG-field test review,  we found that the groundwater
could  become significantly contaminated after  active  gasification was
completed.   After gasification operations,  a large mass of hot rubble
exists in  the gasification cavity (Figure 1).   The temperature of this
rubble can exceed 2500°F.  Heat transfer from the rubble into the adjacent
coal continues  and results in continued coal pyrolysis with corresponding
generation of pyrolysis products.  Laboratory  research confirmed that  it is
these pyro.lysis products are  the source of  potential groundwater
contaminants ("oysen et al. 1988).   If these pyrolysis products are not
removed  from the  subsurface  environment, they can contaminate the
groundwater.  The environmental evaluation of previous UCG testing led to
the development of a  theory that  addressed the fundamental causes of UCG-
related  groundwater contamination.  With  this understanding of the
mechanisms for  UCG related groundwater  contamination,  it was hypothesized
that contamination of groundwater can be minimized, even in sites with
unfavorable  hydrologic and geologic  conditions.   Two simple operational
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constraints implemented during UCG will reduce possible  contamination of
groundwater:  gas  loss from the UCG cavity to the surrounding strata must be
minimized, and pyrolysis products generated after gasification must bt,
removed  from the underground system before they can solublize in  local
groundwater.   The clean cavern  concept was developed and refined in a
laboratory program to develop control technologies  to  reduce  UCG-related
impact on local groundwater  (Boysen et al.  1988).

CONTAMINANT CONTROL METHODS DEVELOPMENT

    The clean cavern  concept for  UCG requires operators to (I)  contain UCG
products within  the  cavity  and process  piping,  (2)  evacuate
postgasification products  (pyrolysis products)  from the UCG  cavity,  (3)
cool  the rubble  in  the gasification cavity,  and  (4)  remove affected
groundwater  for  treatment, if required.   UCG operating procedures were
developed to  accomplish these objectives  and were  evaluated in a laboratory
simulation program.

    Results of the literature survey previously  discussed  illustrate the
importance of proper site selection to reduce the environmental impact of
UCG.   Further, results of  the  laboratory  simulation program show that
groundwater  contamination can be significantly reduced by applying UCG
operational constraints  and the proper gasification termination procedures
(Boysen et al.  1988).   The most important aspect of  UCG groundwater
contamination control is the constraint on  cavity  pressure during and after
UCG operations.  Cavity pressure that  is greater  than the hydrologic
pressure of the coal seam can push UCG product gases and condensibles out
into  adjacent  water-bearing strata contaminating the  aquifier.   The Hoe
Creek test is an  example of  contamination that resulted  from high operating
pressures.  However,  after gasification operations  are terminated, the high
cavity pressure also  needs to be  constrained.  The  residual heat in the UCG
cavity will convert  groundwater  flowing  into the UCG cavity into steam. If
a gasification cavity is not vented after  gasification operations,  the UCG
cavity pressure will  increase.  The pressure can eventually exceed opposing
forces  (permeability and hydrologic pressure) permitting cavity gases to
flow into the surrounding strata.

    In addition  to reducing the  potential  for gas  flow  into  surrounding
strata, cavity venting promotes water  influx into the gasification cavity.
Influxing groundwater enhances the cooling of and contaminant removal from
the cavity walls and  rubble.    Further,  the creation of conditions to
promote  water  influx into  the  UCG cavity after gasification  allows UCG-
contaminated groundwater to be removed from the underground system to the
surface where it  can  be treated for use,  disposal,  or reinjection.

    Other gasification  termination procedures can  reduce groundwater
contamination.  Flushing the cavity  with steam will accelerate  cooling
while stripping contaminants from the  cavity walls and rubble.   Monitoring
groundwater levels  in and  around a gasification cavity will provide
indications  that groundwater  is about to  flow  out of the gasification
cavity.   Any affected water in  the  cavity can be removed before  it can
impact adjacent water-bearing zones.
                                      77

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ROCKY MOUNTAIN 1  (RM1) UCG TEST

    The contaminant  control methods developed and  evaluated in the
laboratory were incorporated into  the  operation plans of the RM1  UCG test
as a  comprehensive environmental program  designed to demonstrate and
evaluate these methods.  The planned environmental program included:

    o   Maintenance  of  cavity pressure below hydrostatic pressure of the
        coal seam aquifier to reduce the potential for gas loss during
        operation

    o   Venting  and flushing of  the  UCG cavities  with steam after
        operations to maintain reduced cavity  pressures, remove potential
        groundwater  contaminants from the cavities,  ensure  the collection
        and containment of  affected  groundwater,  reduce  cavity rubble
        temperature, and  strip contaminants from  the cavity walls and
        rubble

    o   Monitoring groundwater flow gradients to assure  containment of
        affected groundwater in the gasification cavities until this water
        can be removed by pumping

    o   Removal,  treatment,  and discharge  of affected groundwater from
        gasification cavities before the  water could migrate away  from the
        cavities and impact unaffected regions of the coal  seam aquifier
RM1 Site Selection and Characterization

    The RM1 site was located adjacent to the old Hanna UCG test site near
Hanna,  Wyoming.   The RM1  site possessed good hydrogeologic characteristics
for UCG operations  based on test  data from the previous Hanna tests.  The
target  coal seam (Hanna #1) is approximately 360 feet deep  at  the RM1 site.
It is approximately 30 feet thick and is classified as a high volatile C
bituminous coal  (Mason et al. 1987).

    Preoperation site  characterization  revealed both desirable  and
undesirable features.  The  boundary strata consisted of competent  (strong)
consolidated  shales and sandstones.  In addition,  the nearest aquifier
above the coal seam  was  favorably located more  than 100 feet  above the top
of the  coal  seam.   However, hydrogeologic evaluation of the  coal seam
aquifier also revealed  that  the  coal seam contained zones of relatively
high permeability  due to  fractures and there were also indications of
structural deformities across  the site.   This  suggested that  tight
constraints on  the  cavity pressures needed to be  maintained during and
after UCG operations to  prevent gas  flow out of the UCG cavities and into
the surrounding strata.   However,  the location  of  the overlaying aquifiers
at the  site and  competent  overburden suggested that any  flow out of the
cavities would be confined in the  coal seam  (Mason et al.  1987).

    The pregasification  groundwater  quality  (baseline) and hydrology were
also evaluated to  detect  changes in characteristics during  and after
                                      78

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gasification.   Groundwater quality and hydrostatic levels  were monitored by
using a series of monitoring wells (Figure 2)  installed before gasification
operations (Mason et  al.  1987).

Test Monitoring

    Gasification operations were initiated on November 17, 1987, and were
completed on February 26, 1988.  Two cavities were created from the dual-
module operation.  The approximate locations of the cavities are shown in
Figure 2.  The monitoring wells were sampled approximately every ten days
during the gasification,  and samples were analyzed for  a number of chemical
constituents that could  be introduce  into the groundwater as a result of
UCG operations.   These included phenols, ammonia, total  organic  carbon
(TOC), total dissolved  solids  (TDS),  boron, and cyanide.

    During initial UCG  operations, some  difficulties were experienced that
raised the cavity operating pressures above the hydrostatic  pressure of the
coal  seam.   Based  on  data  collected  from the  monitor wells,  field
observations suggested that the high operating pressures caused UCG gases
to flow from the  cavities into the  surrounding coal seam.   This gas flow
was toward the southwest, toward well TW-18 (Figure 2).  As  a result of the
gas flow  from  the UCG  cavities, a number of  the monitoring wells  in the
southwest area became pressurized and could  not be monitored.   Operating
pressures were subsequently  reduced.   This  stopped the  gas migration,
recovered some portion of the gas that had migrated away from the cavity,
and depressurized the coal  seam near the  monitoring wells.  As a result of
the UCG gas flow  into the surrounding coal seam,  TOC and TDS concentrations
were elevated in the groundwater samples  from the monitoring wells to the
southwest of the test area.    In addition, the groundwater pH in this area
was reduced from approximately 8 to approximately  6 due to dissolution of
carbon dioxide from the UCG  gas.   The  increase in TOC  and TDS probably
resulted from the change in  dissolution  characteristics of  the groundwater
resulting from the pH change  (Moody et al. in  press).

    Following this short term high-pressure  event, UCG  cavity pressures
were successfully maintained  at less than the hydrostatic pressure in the
coal seam for the remainder of the test,  and gas flow out  of the  UCG cavity
and into the coal seam was stopped.
Postgasification Venting, Flushing, and Cooling of the Cavities

    After the completion of the UCG test, the cavities were  vented for over
100 days, to flush the  cavities, steam was injected into each  cavity for 10
days.  Vented cnses were monitored  for  flow volume and composition.   The
amounts of potential contaminants  produced  during  the  venting and flushing
operations are listed in  Table  1  for  both process modules.   If  these
contaminants had not been produced from the underground  system but had
instead been allowed to solublize in the local groundwater, the impact of
the RM1 test on the local groundwater quality would have been much worse
than it actually was  (Boysen et al. 1988).
                                      79

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           TABLE 1.  RM1 VENT AND FL0SH CONTAMINANT PRODUCTION
                                ELW                CRIP
Constituent                   Module              Module
Phenols, kg                     207                 328
Total Organic Carbon,  kg         974                 666
Sulfide, kg                     171                 368
Sulfate, kg                     103                 114
Ammonia, kg                     969                 1209
Arsenic, g                       14                  60
Boron, g                        356                 186
Groundwater Pumping,  Treatment, and Discharge

    A minimum of two cavity pumpouts  and associated groundwater treatments
were required to comply with RM1 state environmental permit requirements.
The amount  of  water to be removed from the cavities during  pumpout was
based on  estimated cavity volumes or  physical indications that  all the
cavity water has been removed.  The two pumpouts and treatments have been
successfully completed.

    The first pumpout and treatment  was performed  from  August 25  through
September 20,  1988.   Approximately 2,100,000 gallons of water was pumped to
the surface from the two  cavities.   This  represents  approximately 115
percent of  the calculated cavity void volume (1,800,000  gallons).   The
calculated  cavity void volume  is  based on the  coal consumed minus the
estimated ash volume.

    Table 2 lists baseline concentration  ranges of the  coal  seam
groundwater  for chemical constituents  that  are  normally associated with UCG
contaminated groundwater.  These values are compared with  values  for the
combined cavity waters  at  the  beginning and end of the pumping.  Boron and
phenols were the only constituents  that were significantly  elevated above
baseline concentration  at  the  beginning of the pumping.   However,  in these
and in all other cases,  the concentration of the constituents decreased as
the groundwater  was  removed from the cavities, indicating that the  UCG-
affected  groundwater was  successfully removed after UCG operations.  In
summary, the water quality was good  before  pumping,  relative  to baseline
conditions,  and improved during pumping. Details of the  first cavity water
pumping,  trealm^nt, and discharge are presented  by Covell and  Speight
(1989) .
                                      80

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   TABLE 2.   CHEMICAL CONSTITUENTS IN CAVITY HATER—FIRST TREATMENT


Constituent
Ammonia
Boron
Phenols
TDS
TOG
Baseline
Range,
mg/L
2.4-7.9
<0. 010-0. 037
<0.020
1,360-2,750
11-45

8/25/88,
mg/L
10.4
1.97
0.760
2,710
30

9/20/88,
mg/L
6.4
0.387
0.021
2,160
27
    The second pumping  and treatment was initiated when  groundwater
monitoring data showed that the cavities had again filled with groundwater.
This  pumping was  conducted  from July 31  through  August  15,  1989.
Approximately 1,570,000  gallons of cavity water was pumped  from the  two
cavities.  Pumping  was terminated when all water was  evacuated from  the
cavities and  both  submersible pumps lost suction.

    Table 3 lists the concentration of the monitored constituents  at  the
beginning and end  of the  second pumping.  The baseline concentration ranges
are also lists  for  comparison.   The groundwater quality in  the cavities
before the pumpout was at or near baseline quality  except  for boron.   The
second  pumpout further  reduced the concentrations of the constituents
except  for TOC,  which  increased minimally.  Subsequent  groundwater
monitoring data show that the water quality in the  cavities remained near
baseline  quality.   Further restoration efforts  probably  will not  be
necessary.
  TABLE 3.  CHEMICAL CONSTITUENTS  IN CAVITY WATER—SECOND TREATMENT
                   Baseline
                    Range,  '           7/31/89,            8/15/89,
Constituent          mg/L                mg/L                mg/L
Ammonia             2.4-7.9              9.8                 7.9
Boron             <0.010-0.037            1.30                0.64
Phenols             <0.020              <0.020              <0.020
TDS               1,360-2,750           2,890               2,280
TOC                  11-45                17                  22
                                     81

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Site Conditions as  of December 1989

    Groundwater quality across the monitoring area  (Figure 2) continues to
remain at or near baseline quality.  Well TW-18  shows higher  concentrations
of  TOC (60 mg/L)  and TDS  (3,470) than the  highest baseline values.
However,  there are  indications that these increases  result from movement of
groundwater with naturally  occurring high concentrations of  TOC and TDS
into the  well monitoring area  (#).   Some  benzene was detected  at  small
concentrations (0.005-0.040  mg/L)  in the  cavity wells before and after ths,
second pumping but  was  not detected in these same wells during the pumping.
We believe that the benzene  is associated with local deposits of coal tars
in  or  around the  well casings of the  cavity wells  which were used as
process wells  during gasification operations.

                              CONCLUSIONS

    Careful  selection of UCG sites  based   upon  detailed  site
characterization can  substantially reduce the potential for  groundwater
contamination  resulting from UCG operations.   If possible, a  site should be
selected with  the proper hydrogeologic characteristics to help prevent flow
of gases  out  of the UCG  cavities and into the surrounding  strata making
potential for communication with near-by water  bearing strata  negligible.
If conditions exist that do not tend  to  prevent the flow of gas  from the
UCG cavities into the  surrounding strata, UCG operational constraints are
critical for preventing the contamination of local groundwater.

    The potential for  groundwater  contamination associated with UCG can be
significantly reduced  through the application  of operational  constraints
and selected  gasification  termination and post-gasification operating
procedures.   Particularly  critical  is the control of cavity pressures
during and after  gasification.  Pressures in the cavities  need  to be
monitored and controlled at  or below  the hydrostatic pressure  of  the coai
seam  being gasified  to  minimize  gas  flow from the cavity into  the
surrounding strata and the  importance of this constraint depends on the
hydrogeologic  characteristics of the site.  The gasification cavities need
to be  continuously vented  to cool the cavity, evacuate post operation
products, promote  collection and treatment of affected groundwater,  and
terminate coal pyrolysis.

    These procedures were successfully demonstrated as a part of the RM1
UCG field test.  To date, environmental monitoring results of the test show
little impact to water bearing strata in the vicinity  of  the gasification
test.  This achievement is  significant considering the test site did not
possess  ideal hydrogeologic characteristics  for  preventing  groundwater
contamination.   Further, the pumping and treating of the UCG  affected
waters initially   filling  the UCG  cavities  after  gasification were
successful.

                               FINAL  NOTE

    The approach used in this program can be applied to  other thermal
recovery  processes such  as  modified  in situ oil shale retorting and oil
                                     82

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    Air and/or Steam-Oxygen
                                           Got
                                             *—
                                   Condeniolef*~
          Separator

                -250'C
                            ~—-Overburden"	
Pyroly«il_ .
Preducl»_	
  Figure  1.   Underground Coal  Gasification  Reactor
                 Schematic
         PW-I
       CPW-l
         CIW-I
                                               IW-ll
                                                     S% C.f Sic J« I
                                                            \1
              LEGEND

         4 Ovo'burdin Unit C Wtll
         T Ovtrburdtn Unil A W.ll
         • Honno No. 1 Cool Siam Well
         • Und«fburd«n Unit Wtll
         « Proms Wtlll             /

         • Cavity Cleanup Wtll (Approx lotolion)

        ^ ^) Rtgion ol Catititd Coal

        ^ Caitd Horiionlol Well

       ^^* Open Hontontol Holt
   SCALE
   s^ssss
too  100
      Figure  2.    Rocky Mountain  1  Monitor  and Process
                     Wei 1  Layout
                                   83

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combustion drives.   A similar program is being devised for Occidental  Oil
Shale Inc.'s planned modified in situ project (Boysen et al, 1990).
                              REFERENCES

1.  Barrash,  W.,  J.W. Martin,  and U.  Sharum, 1988.   Status Report of
      Groundwater  Quality at  the Hoe Creek Underground  Coal  Gasification
      Site, Powder River Basin, Wyoming.   WRI  report to U.S. DOE.

2.  Beaver,  F.W., G.H. Groenewold,  C.R.  Schmit, J.M.  Evans, and J.E.
      Boysen, 1988,   The  Role  of Hydrogeology in the  Rocky Mountain  1
      Underground Coal Gasification Test,  Carbon County,  Wyoming, in
      Bartke, T.C. and V.L.  Hill,  eds., Proceedings of the Fourteenth
      Annual  Underground Coal Gasification Symposium, DOE/METC-88/6097,
      162-174.

3.  Boysen,  J.E., J.R.  Covell, R.G. Vawter,  K.G., Kofford, and J.E.
      Marshall, 1990, Management  Program  for  Spent Modified In Situ
      Retorts.  Proceedings of the 23rd Oil  Shale Symposium, Golden,  CO, in
      press.

4.  Boysen, J.E.,  S. Sullivan, and J.R. Covell,  1989 Venting, Flushing,  and
      Cooling of the RM1 UCG  Cavities,  Bartke,  T.C.  and V.L.  Hill,  eds.,
      Proceedings  of the  Fourteenth Annual Underground  Coal  Gasification
      Symposium, DOE/METC-88/6097, 284-303.

5.  Boysen, J.E.,  C.G. Mones, J.R. Covell, S. Sullivan, and  R.R Glaser,
      1988,   Underground Coal Gasification Contaminant Control Program:
      Simulation of Postburn UCG Contaminant  Production.  Gas Research
      Institute, Chicago,  IL.  GRI-88/0170.

6.  Covell, J.R.,  and  J.G. Speight, 1989,   Rocky Mountain 1  Groundwater
      Restoration: First  Treatment.  Proceedings of the International
      Underground  Coal  Gasification  Symposium  1989, Delft, The Netherlands,
      p.  515.

7.  Mason,  J.M., R.L.  Oliver,  J.D.  Schreiber, C. Moody, P. Smith,  and M.J.
      Healy,  1987,   Volume 1:  Geohydrology of  the Proposed Rocky Mountain  1
      Underground Coal Gasification Site, Hanna, Wyoming.  Laramie, WY
      Western Research  Institute  report.

8.  Moody,  C.G., in press.  Changes in Groundwater Quality and Subsurface
      Hydrology During the  Rocky Mountain 1 Underground  Coal  Gasification
      Test,  Hanna, Wyoming.   Laramie,  WY, Western  Research Institute,
      report  WRI-88-R041 for the  Gas Research  Institute and the U.S.  DOE.

9.  United Engineers and  Constructors Inc., Stearns-Roger Division,  1986.
      In-situ Research and  Development Testing License Application.
      Submitted to the Wyoming Department of  Environmental Quality,
      Cheyenne, WY.
                                   84

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10. United Engineers and Constructors Inc., Stearns-Roger Division,  1989.
      Rocky Mountain 1  Underground Coal  Gasification  Test, Hanna, Wyoming,
      Summary Report.   U.S. DOE and GRI combined report.

11. Western Research Institute.   Annual  Technical  Progress Report,  October
      1988-September 1989.  Laramie,  WY report to DOE WRI-89-R036 pp 3-3
      through 3-19.
                                     85

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   BUSINESS TO BUSINESS NETWORKING - A CYCLE OR SHORT CIRCUIT?

             by:  J. B. Brand, Jr.
                  Business Council of Alabama
                  Birmingham, Alabama 35232-0619
     The Business  Council  of Alabama is a 501.C(6) non-profit
member supported business association.  It represents  some  2200
member companies in Alabama.  The membership is  divided into more
than 60 industrial classifications - from a single entrepreneur
to a 20,000-employee textile  plant.

     The Business Council networks within itself and  its member-
ship concerning waste minimization, waste exchange and  recycling
programs through  its Environmental Resources  Committee.   This
volunteer committee is comprised of experts from the  major  manu-
facturing classifications in Alabama.   Included  are mining,
chemicals, paper  industries,  contracting, hospitals, nursing
homes and other companies who either produce or  use products that
add to the hazardous waste  problem.

     The Business Council,  in turn, networks with the  more than
80 other business associations  in the state to  supply  expertise
to their association members.

     The Council sponsors workshops and shares  information with
the Automobile Dealers  Association, Retailers Association,
Service  Station Operators,  Textile Association, The Chemical
Manufacturers Association,  Cast Metals Association  and  other
business organizations.  Committee members appear on the agenda
for regional, statewide and local seminars and before  civic
groups.

     As Executive Vice  President  of  the Business  Council  of
Alabama, I operate as the  coordinator for EPA Region IV  waste
minimization  exchange for  the COSMA group - The Conference  of
State  Manufacturers Asssociation.  This organization is the
counterpart of the Business Council of Alabama.  Within its mem-
bership are 43 states and Puerto Rico.  The organization meets  on
                               86

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an annual  basis and the environment  is one of the prime subjects
on the agenda.  COSMA is primarily political  in nature and it
concentrates  on political solutions  to the environmental problem
and protecting business from punitive environmental legislation.
The other  part of our discussion centers on  ideas for changing
the image  of  business in relationship to the environment and dis-
cussing programs that enhance the environment in which business
operates in each of the individual represented states.

     No business wants to establish an operation in any state
that does  not have a strong environmental law and does not seek
to protect its citizens from hazards of  air,  water  and land
pollution.

     Not  a single one  of  the 44 COSMA members  operates in an
ecological vacuum.  To my knowledge, all are committed to struc-
tured economic growth in their state and at the same time provide
a clean working and playing environment for its employees.

     The  business community has received negative  publicity.
It's the job  of our  associations',  through  networking, to make
sure the story is clear and  that the other  segments of society
accept their  responsiblity for environmental degradation along
with manufacturing.  The business community recognizes that with-
out healthy,  productive workers,  who are also consumers, that it
cannot exist. No  business  prospers in the  long run in an un-
healthy environment.

     The exchanges between the business communities through net-
working between  the  states is extremely  important as  new
innovative ideas are developed.  That information can be system-
atically  replicated  in other states.  The  exchange  of ideas
allows quick  response to new  ideas  so that  each state does not
have to start from ground zero on each waste minimization idea or
recycle idea. What may be a waste product in Alabama could very
easily be  a raw material for production in Mississippi.

     I am  currently working as the coordinator for the EPA Region
IV states  in  developing a COMPACT within the  eight southeastern
states.   At  present  four southeastern states are committed.
Alabama has four  states with which we have  capacity assurance
agreements -  Tennessee, South Carolina, Kentucky and Alabama.

     There are two states who are specifically banned from
depositing hazardous wastes within the state.  This ban is based
upon legislation passed in Alabama in 1989.   Within the COSMA
group we are  attempting to develop  a COMPACT between the eight
states to  assure that we can accommodate hazardous wastes pro-
duction within the  region.  The COMPACT,  if  reached will, of
course, have  to be approved by Congress.
                               87

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     In the meantime, as we work  with the COMPACT concept we are
in constant exchange of ideas dealing with  recycling and waste
minimization,  and are currently exchanging ideas and information
as to regulatory changes and state laws  and  regulations dealing
with the disposal, creation and recycling of hazardous wastes.

     The original question in the title  of my text - "A Cycle or
Short Circuit?" -  at the current  time,  the  hazardous  waste
exchange is working in full cycle,  but as  far  as the COMPACT is
concerned,  it  has now been short  circuited.

     We hope to clear up the short circuit and see the electrical
circuit flowing again.

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         WASTE MINIMIZATION ASSESSMENTS AT SELECTED POD FACILITIES

           by:    James S.  Bridges
                 RREL, U.  S.  Environmental  Protection  Agency
                 Cincinnati,  Ohio 45268
                                  ABSTRACT
     The Waste Reduction Evaluations at Federal  Sites (WREAFS) Program
consists of a series of evaluations and demonstrations for pollution
prevention and waste reduction conducted cooperatively by the Environmental
Protection Agency (EPA) and other Federal agencies.  The objectives of the
WREAFS Program include: (1) performing waste minimization opportunity
assessments, (2) demonstrating waste minimization techniques or
technologies at Federal facilities, (3) conducting waste minimization
workshops, and (4) enhancing waste minimization benefits within the Federal
community.

     This paper describes the WREAFS Program support of DOD activities in
the pollution prevention area, and provides an overview of current projects
being conducted at the Philadelphia Naval Shipyard, Fort Riley (Kansas)
Army"Forces Command, and the Naval Undersea Warfare Engineering Station in
Keyport, Washington.  Also described is a waste minimization research
project with the Air Force.  These DOD waste minimization opportunity
assessments have identified waste minimization opportunities for a range of
industrial and military operations including:  metal cleaning, solvent
degreasing, spray painting, vehicle and battery repair, ship bilge
cleaning, and torpedo overhaul.  The resultant waste minimization
recommendations are source reduction methods including technology, process,
and procedural changes and recycling methods, which focus on reuse or
recycling.

     This paper has been reviewed in accordance with the U.S. Environmental
Protection Agency's peer and administrative review policies and approved
for presentation and publication.
                                    89

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                                INTRODUCTION
     The purposes of the WREAFS Program are to Identify new technologies
and techniques for reducing wastes from industrial processes used by
federal agencies and to enhance the adoption of pollution prevention/waste
minimization (WM) through technology transfer.  New techniques and
technologies for reducing waste generation are identified through WM
opportunity assessments and are evaluated through joint research,
development, and demonstration (RD&D) projects.  The information and data
from these projects are then provided to both the public and private
sectors through various technology transfer mechanisms, including project
reports, project summaries, conference presentations, and workshops.

     The waste minimization opportunity assessments are conducted by an
assessment team that is composed of personnel from EPA, staff from the
Federal facility that is cooperating in the program, and EPA's contractors.
The assessments follow the procedures described in the EPA report Waste
Minimization Opportunity Assessment Manual.  This manual provides a
systematic planned procedure for identifying ways to reduce or eliminate
waste.  The development of this procedure was supported by the Risk
Reduction Engineering Laboratory, U.S. Environmental Protection Agency,
Cincinnati, Ohio.

     As a result of joint waste minimization opportunity assessments
(WMOA's), RD&D projects are identified with recommendations for pollution
prevention.  The demonstration projects are conducted under inter-agency
agreements with joint funding by EPA and the cooperating Federal agency.
Waste minimization workshops and other technology transfer methods are
being used to communicate the results of these projects to the Federal
community and the private sector.

WREAFS  PROGRAM PROCEDURES

     The WREAFS Program procedures used for conducting the waste
minimization assessments are closely related to the WM procedures presented
in the  Manual.  Figure 1 describes the course  followed by a typical WREAFS
project.  The asseessments consist of four major  phases:

(1)  Planning and Organization - organization  and goal setting;

(2)  Assessment - careful review of  a facility's  operations and
     wastestreams and the identification and screening of potential options
     to minimize waste;

(3)  Feasibility Analysis - evaluation of  the  technical and economic
     feasibility of the options selected and  subsequent ranking  of options;

(4)   Implementation - procurement, installation,  implementation, and
     evaluation.
                                     90

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  PLANNING AND ORGANIZATION
• AssemHe Team consisting of facility staff,
 EPA personnel. and EPA contactor's daft.
• Conduct Intel meeting at the federal site
 to Minify overal assessment goals.

• Identify tia rolaa of Via Team members.

• Develop assignments for Taam members for
 each major operating unit or facility am.

• Ravlaw lha Inbrmaton and dam requirements
 ol the Worksheets and make revisioni to
 tailor tha forms to (ha currant project
• Complete fia Worksheets related to planning
 and organization.
* AQuira; background
                             ASSESSMENT  PHASE
      ASSESSMENT  SURVEY
• Inspect tha equipment used In the assessment
 area.
• Conduct interviews with operators, shift
 supervisor* and foremen.

• Collect and review available Information and
 data related to process input materials, waste-
 stream characterization, generation rates,
 waste management techniques, etc.
• Conduct a Taam meeting to review Information
 and data. Identify addional needs, and refine
 project objectives.

• Complete data collection efforts.
                                               DATA  UTILIZATION
• Complete the worksheets related to site data
 and prepare a waste stream summary.

• Conduct a brainstorming session with Team
 members to Identify waste minimization options

• Develop descripDons of the WM options.

• Evaluate the options using weighted criteria
 that are specific to tie needs of the facility.

• Select the options that favor the needs of the
 faclily for he feasibility analysis phase.
               FESIBILITY ANALYSIS PHASE
          • Determine the technical feasibility of the selected options

          • Determine tha economic feasibility of the selected options

          > Determine and compare tie return on investment of the
           various options.
           IDENTIFICATION OF  RESEARCH  OPTIONS
          • Review the optons and identity specific research
           opportiralies.
         PREPARATION OF WM ASSESSMENT REPORT
                         DEMONSTRATION  AND  EVALUATION  PROJECTS
                             • Develop Interagency agreement with Joint funding

                             • Prepare design of selected WM option and procure
                               needed equipment and supplies

                             • Implement demonstration of WM option and monitor
                               performance
                                                                                • Evaluate tie results of the demonstration
                                                                                     PREPARATION OF  TECHNOLOGY
                                                                                         TRANSFER MECHANISMS
                                                                                •Reports
                                                                                • Conference and seminar papers
                                       Figure 1.  An Overview of the WREAFS Program

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     Many of the WM opportunities identified during WREAFS projects involve
low-cost changes to equipment and procedures that may be presently employed
at other Federal facilities or within private industry.   These WM
opportunities can often be implemented by the facility without extensive
engineering evaluations.  Some other WM opportunities identified during
these projects will require further study before full implementation can be
realized.  Typically, opportunities requiring further evaluation are those
that have the potential for affecting the process and/or require the use of
new procedures or equipment.  In such cases it may be necessary to conduct
demonstration projects.

Demonstration and Evaluation Projects

     The types of research projects that can be pursued under the WREAFS
Program are those that are expected to advance the knowledge and practice
of waste minimization technologies and methods, and have broad
applicability to Federal facilities and private industry.  Depending on the
nature and state of development of the WM option selected for demonstration
and evaluation, these projects may include:  (1) process design, (2)
detailed design and specification, (3) system procurement, (4) installation
and start-up, (5) monitoring, and (6) reporting.  Some projects may require
bench-scale and/or pilot testing prior to or as a part of the demonstration
project.  Other projects may utilize full-scale equipment directly on the
production line.

                              CURRENT PROJECTS
     Four WREAFS projects are being performed at DOD facilities.  These
projects are in various stages of completion.  The assessment survey has
been completed for several projects and the waste minimization options and
research opportunities have been identified.  Other projects are just
underway.  The following is a description of each project.

PHILADELPHIA NAVAL SHIPYARD

     This project is being conducted in cooperation with the Environment,
Safety and Health Office of the Philadelphia Naval Shipyard (PNSY).  The
shipyard has an ongoing program for waste minimization.  With their
guidance, several industrial operations were selected for application of
the new waste minimization procedures.  The shipyard plans to utilize the
results from this project as a guidance tool for evaluating waste
minimization opportunities at other industrial activities at the PNSY.  The
results of this project will be particularly applicable to facilities that
operate aqueous cleaning and spray painting processes.  However, the
procedures employed to identify and evaluate minimization alternatives are
applicable to most industrial operations.

Facility Description

     The Philadelphia Naval Shipyard is the nation's oldest continuously
operating naval shipyard.  The shipyard now specializes in revitalizing and
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repairing ships already in fleet.  The Service Life Extension Program
(SLEP) is the shipyard's largest program.  It is a comprehensive,  keel-up
restoration and modernization overhaul intended to extend the life of
aircraft carriers by half, at about one third of the cost of a new carrier.

Selected Areas and the WM Options Evaluations

     The procedure used for conducting the WM evaluation followed the EPA
Waste Minimization Assessment Manual.  The industrial activities selected
for this project include areas used for the fabrication and surface coating
of aluminum products, spray painting operations for steel parts, and a
citric acid derusting operation, which is located at the drydocks.

     The aluminum cleaning operation is performed to remove oil and other
materials from the surfaces of aluminum sheets prior to welding.  The
cleaning line consists of four tanks:  two process tanks, and two rinse
tanks.  The cleaning procedure consists of loading aluminum sheets into a
metal basket, hoisting the basket into a process tank, and rinsing in one
of the rinse tanks.  The process water becomes diluted after repeated
operation due to dragout losses and tap water replenishment.  These tanks
also collect floating oil, and the solution becomes contaminated with
suspended solids.  After approximately three months of operation, the
process tanks are pumped to a tank truck and hauled by the contractor for
disposal.  The rinse tanks are operated as non-flowing rinses because of
the low pH of the rinse water and the lack of facilities for
neutralization.  The rinse tanks are disposed of in the same manner as the
process tanks but on a more frequent schedule, usually every two weeks

     Two WM options were evaluated for the aluminum cleaning operation.
First, a dragout reduction and bath maintenance system was proposed.  This
system will include a hand-held spray rinse that will be applied over the
process tanks.  After affecting the parts, the rinse water will drip into
the process tank.  The spray rinse is expected to return 90 percent of the
dragout back to the process tank.  And 2, the acid baths accumulate oil and
solids from the parts, and therefore, returning dragout losses may cause
the process tanks to accumulate contaminants at a faster pace.  These
contaminants may interfere with the cleaning process; thus a bath
maintenance system was recommended.  This system would include an oil
skimmer for floating oil removal and a cartridge filter for suspended
solids removal.  The dragout reduction and bath maintenance systems are
expected to extend the usable life of the baths to one year.

     A 2-stage rinse was proposed as an  alternative to the existing rinse
arrangement, where only one rinse tank is used after cleaning.  The 2-stage
rinse would make use of the existing tanks; however, some rearrangement was
proposed to improve the layout of equipment and the efficiency of the
operation.  Using a 2-stage rinse would  reduce the frequency of discarding
the rinse water by allowing the  first rinse to become more heavily
contaminated.  Then, after the first  rinse is discarded and refilled with
fresh water, the sequence of rinsing  is  changed  (i.e., the cleanest rinse
would always be the second rinse).
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     The spray painting processes are used for small  and medium-sized
aluminum parts, steel parts, and columns.  Aluminum parts are degreased by
wiping with rags that have been dipped into xylene.  The parts are then
spray painted in a water curtain booth.  The painting process typically
consists of a zinc chromate primer, air drying,  a final  enamel paint
coating, and air drying.  A new booth water chemical  system was recently
implemented.  Spray painting of steel parts and columns  is performed at
various locations.

     Several WM options were evaluated for the two spray painting
operations.  First, an operator training and awareness program option was
evaluated that could reduce the amount of waste paint by controlling the
amount of paint overspray, the amount of unused paint left in the can, and
the amount of paint that is unusable due to partial solidification prior to
use.  Second, equipment changes were evaluated for the current compressed
air paint spraying systems.  Under consideration is the  high-volume,
low-pressure (HVLP) method.  The transfer efficiency of  HVLP is reportedly
in the range of 65 to 90 percent.  Compressed air equipment typically
provides a 40 percent or lower transfer efficiency.  Other WM options
evaluated during the assessment included expanding use of a new paint booth
chemical system and use of sludge dewatering equipment that would reduce
the volume of paint sludge and recycle booth water.

     PNSY employs a chemical cleaning process for ships' tanks, bilges, and
void spaces termed the citric acid process.  It is generally performed
while ships are in drydock.  This process is relatively  new and it replaces
the mechanical methods of cleaning and derusting metal surfaces.  The
process generates a spent citric acid/triethanolamine (TEA) solution.
Owing to the significant material input costs and the high disposal costs,
a recovery option was considered during the project.

Results at PNSY

     The results of the assessment, which are presented  in Table 1,
indicated that the best options in terms of cost savings are the awareness
and training program for paint waste reduction and the changes to the
aluminum cleaning line including dragout reduction, bath maintenance, and
improved rinsing.  These three options offer a combined  net savings in
operating costs of $158,680 per year.

     The citric acid/TEA recovery option was identified  as a potential
research project.  A preliminary process design was prepared for the
recovery process that included an electrodialytic membrane unit for
separation and removal of dissolved metals.  This type of technology has
been applied to similar chemical solutions; however,  its application to
this waste has not been previously demonstrated.

FORT RILEY, KANSAS

     Fort Riley is a permanent U.S. Army Forces Command  (FORSCOM)
installation that provides support and training facilities for the 1st
Infantry Division (Mechanized), Non-Divisional Units, and tenant
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                              TABLE 1.  PHILADELPHIA NAVAL SHIPYARD SUMMARY
                                    OF  WM FEASIBILITY  ANALYSIS PHASE
Location Process & Waste
Building 990
Aluminum Cleaning
Spent KRC-7X
Spray Painting of Aluminum
Paint Sludge

Used Paint Thinner
Unused Paint
Building 1028
Spray Painting of Steel
Paint Sludge

WM Options

Bath Maintenance
Two Stage Rinse
Booth Chemicals
Paint Sludge Dewat.
Awareness & Train.
Awareness & Train.

Booth Chemicals
Paint Sludge Dewat.
Nature
of
WM Option

Equipment
Equipment
Materials
Equipment
Personnel/
proced.
Personnel/
proced.

Materials
Equipment
Net Op. Projected
Total Cap. Cost Payback Waste
Investment Savings Period Reduction
$ $/yr yr Ib/yr

$12,200 $44,190
3,116 34,590
12,190 5,430
9,550 3,840
24,266 79,900
See used
paint thinner

3,300 5,460
see bldg 990

0.3 $ 44,035
0.1 190,590
2.3
2.5 15,012
0.3 unknown
-

0.6 27,022
-
Drydocks

Citric Acid Derusting
Cone. Citric Acid/TEA
ED Recovery System   Equipment
76,050
60,720
1.3
124,241

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activities.  It is a U.S. Government-owned, U.S.  Government-operated
facility.  Fort Riley provides the U.S. Army with the capability to house
and train an Army division and associated land combat forces as well as to
service Army functions in an assigned Midwest support area.

Selected Areas and the WM Options Evaluated

     The areas selected for assessment at Fort Riley were the Division
motor pools located in various areas on the post.  Routine mechanical
maintenance is performed in these areas for trucks, tanks, armored
personnel carriers, and other vehicles.  Results of the Fort Riley, Kansas
waste minimization assessment identified two waste reduction opportunities
in a multipurpose building used for automotive subassembly rebuilding, lead
acid battery repair, and other Army maintenance operations.
     Battery acid (32-37 percent sulfuric acid) containing trace
concentrations of lead and cadmium is currently drained from both dead
batteries and batteries requiring repairs, e.g.,  replacement of battery
terminals, and shipped in 15-gallon drums to a hazardous storage facility
at the installation for ultimate disposal as a hazardous waste.  It is
proposed instead that the waste acid be gathered in a holding tank,
filtered to remove any particulates, and adjusted in concentration to 37
percent sulfuric acid (using 60° Baume commercial sulfuric acid) as needed
for reuse in reconditioned or new batteries.  The buildup of dissolved
metal impurities in this recycling system is prevented by purging part of
the acid from the system.  It is assumed in this assessment that 25 percent
of the acid is purged and 75 percent is reused.

     The dirty aqueous alkaline detergent solution for automotive parts
cleaning, which contains trace concentrations of lead, chromium, and
cadmium at a pH >12 as well as the oils, grease, and dirt removed from the
automotive parts, is currently drained to an onsite nonhazardous waste
evaporation pond.  This waste, heretofore regarded as nonhazardous waste,
is currently being reclassified as a RCRA hazardous waste due to its
characteristics (D002, D006, D007, D008) and will have to be disposed of as
a hazardous waste.  The proposed waste minimization option for this waste
stream involves emulsion breaking to remove the tramp oils, filtration to
remove particulates, and addition of fresh alkaline detergent as necessary,
followed by reuse for automotive parts cleaning.  The buildup of impurities
would be prevented by purging 25 percent of the used alkaline detergent and
recycling 75 percent.

Results at Fort Rilev

     The waste reduction options identified in this study are recycle/reuse
options.  Presented in Table 2 are the results of the cost analysis phase.
A net savings in operating costs is anticipated to be $149,400 per year.
The expected payback periods for the two waste reduction options identified
are very short.  Successful application of these options at Fort Riley
would create the potential for similar waste minimization options  in  at
least 10 other U.S. Army FORSCOM installations.
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           TABLE 2.  SUMMARY OF WASTE MINIMIZATION OPTIONS COST
                    ANALYSIS DATA AT FORT RILEY, KANSAS
Operation
Waste Stream
     Waste
 Minimization
    Options
 Total     Net                Projected
Capital  Operating   Payback    Waste
Invest.    Cost      Period,  Reduction
   $     Savings, $    yr        Ib/yr
Battery Repair
Shop/Waste
Battery Acid

Automotive
Subassembly
Rebuild/Tornado
Parts Washer
Wastewater
Recycle of
waste battery
acid

Recycle of
Tornado washer
wastewater
15,200    37,400
19,800   112,000
0.41
51,291
0.18     181,395
NAVAL UNDERSEA WARFARE ENGINEERING STATION, KEYPORT, WASHINGTON

     This project is being conducted in cooperation with the Naval Energy
and Environmental Support Activity (NEESA) of Port Hueneme, California, in
coordination with the Environmental Protection Division (Code 075) of the
Naval Undersea Warfare Engineering Station (NUWES) Staff Civil Engineering
Department.  Several departments at NUWES Keyport are involved in an
ongoing program to further the process of waste minimization on the
Station.  The draft version of this waste minimization assessment is
currently under review by the Naval Undersea Warfare Station and detailed
results of the study are not available.

     NUWES Keyport is located within the central Puget Sound area of
Northwestern Washington State.  In 1978, the facility changed names from
Naval Torpedo Station Keyport to NUWES Keyport recognizing that the
functions of the Station had broadened to include various undersea warfare
weapons and systems engineering and development activities.  The principal
activities currently conducted at NUWES Keyport are the design and testing
of torpedoes.

Selected Areas and the WM Options Evaluated

     Potential sources for waste materials include torpedo as well as other
ordnance handling and related activities.  Specific activities on the
Station include welding, plating, machining, and sheet metal work; painting
and stripping; electrical work; carpentry; fuel storage and use; power
production; pest control; sanitary and industrial wastewater treatment; and
associated storm sewer runoff.  These activities generate a variety of
potentially hazardous wastes, including fuel, oil, coolant, hydraulic
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fluid, and grease; various metals and plating bath liquids;  paint and
thinner; Freon, alcohol, mineral spirits, and other solvents;  resin; acids
and caustics; chromate and cyanide salts; wastewater treatment sludge; and
detergent.

     Two areas at the Station were examined in detail during the
assessment.  Both areas are used for the maintenance of torpedoes and have
similar operations, processes, and waste streams.  The major waste
generating activities consist of defueling, disassembling, cleaning,
reassembling, and refueling of torpedoes.  The waste materials at these
areas include:  solids, liquids, sludges, solvents, and oils that are
contaminated with Otto fuel, as well as diethylene glycol (DEC), mineral
spirits (Agitene), and cyanide compounds.  Waste minimization options were
recommended for contaminated solids, contaminated liquids, and waste
mineral spirits.

     The waste minimization option for contaminated solids addresses all
clothing that becomes soiled with Otto fuel (OF).  Recommendations for the
reduction of this waste are to segregate contaminated from non-contaminated
clothing, and only dispose of the contaminated portion of a garment.

     Automated parts cleaning is another waste minimization option
recommended to reduce soiled clothing.  In addition, the increased
efficiency of an automated system will serve to reduce the amount of waste
mineral spirits.

     Contaminated liquids can be reduced in the Otto fuel tank draining
area by installing another automated system that increases efficiency and
decreases spills and contaminated solids.

     At one site location, waste mineral spirits are currently pumped on a
regular schedule from deep sink parts cleaners.  This schedule is followed
whether or not the solvents have become fouled.  By monitoring the solvents
and disposing only when fouled, the amount of waste cleaner will be
reduced.

Preliminary Results at Kevport. Washington

     The waste minimization options under consideration for NUWES Keyport
are being evaluated for technical and economic feasibility.  Projected
waste reductions and costs are not available at this time.

U.S. AIR FORCE

     In support of the Department of Defense's waste minimization program,
the Air Force is seeking to obtain information for its chlorinated solvents
recycling program.  Air Force facilities are high-volume consumers of
industrial solvents.  Applications for solvents range from degreasing
aircraft parts and missile guidance systems to cleaning small bearings and
armament material.  The major chlorinated degreasing solvent currently used
by the Air Force is 1,1,1-trichloroethane.  Due to toxicity and inherent
health effects, the use of all chlorinated solvents may be curtailed unless
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effective waste reduction and recycling programs are developed.  In this
effort, an assessment will be performed for the recycling program at a
selected Air Force base.  The project is being performed in cooperation
with Auburn University.  Objectives for the study include developing
mitigation technology for minimizing the accumulation of toxic contaminants
1n the recycled product and addressing concerns regarding solvent
Inhibitors and additives.  The results of the study will be used to
formulate a model program and establish protocols for operating solvent
recycling technology service programs.

                          SUMMARY AND CONCLUSIONS


     Waste minimization opportunity assessments conducted under EPA's
WREAFS program are an excellent mechanism for promoting pollution
prevention research at DOD facilities.  At the three DOD sites audited,
waste minimization opportunities have been identified for the following
hazardous waste streams:  aluminum cleaning solutions, paint sludge, paint
thinner, unused paint, citric acid derusting solutions, waste battery acid,
parts washer wastewaters, contaminated clothing, parts cleaning solutions,
waste Otto fuel, and waste mineral spirits.

     Pollution prevention recommendations have been made for the
Philadelphia Naval Shipyard and Fort Riley that will reduce hazardous waste
generation by a minimum of more than 630,000 pounds per year, with an
annual savings of $383,530 at the two sites.  In addition, a number of
these opportunities will make excellent demonstration and evaluation
projects.

     The WREAFS program can be used as a catalyst to implement pollution
prevention strategies and to identify research opportunities that would not
be otherwise identified.  Through this program EPA can assist DOD in
transmitting new technical information to all of its facilities through
project reports, workshops, seminars, and conferences.
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            CHROME RECOVERY VIA ADSORPTIVE FILTRATION


                          Lisa M. Brown
               U.S.  Environmental Protection Agency
              Risk Reduction Engineering Laboratory
                     26  W. Martin Luther  King
                     Cincinnati, Ohio  45268

               Mark M. Benjamin and Thomas Bennett
                 Department of Civil Engineering
                              FX-10
                     University  of Washington
                    Seattle, Washington   98195


                            ABSTRACT

     Metal-bearing wastewaters are generated in large quantities
at thousands of industrial sites in the U.S.   The concentrations
of metals in these waters may range from less than 1 to several
hundred mg/L.  The vast majority of these waste streams are
treated by processes which generate a large amount of metal-
containing sludge which then must be de-watered, transported, and
buried in a controlled landfill.

     The U.S. Environmental Protection Agency (USEPA),  through
the Office of Research and Development,  has a national research
program designed to support the intent of the 1984 Amendments to
the Resource Conservation and Recovery Act of reducing the amount
of hazardous and non-hazardous waste produced in the United
States.  This research program focuses on generation of data to
allow the development of emerging new pollution prevention
techniques.

     The University of Washington, under a thirty-one month
cooperative agreement with the USEPA,  is evaluating the
performance of packed beds of granular media coated with iron
oxide and other adsorbents for recovering chromate from
industrial waste solutions.   The initial tests are being
conducted using synthetic wastes.  Following that, tests will be
conducted using batches of real waste.  A small recovery unit
will be installed on-site at an industry near the University at
the culmination of the project for pilot-scale evaluation.

     This paper has been reviewed in accordance with the U.S.
Environmental Protection Agency's peer and administrative review
policies and approved for presentation and publication.

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                           INTRODUCTION

     Recent work at the University of Washington has led to the
development of a new material which may allow metals to be
efficiently and cost-effectively recovered from metal-bearing
wastewater.  The material consists of either ordinary filter sand
or activated carbon which has been coated with a thin layer of an
adsorbent mineral such as iron oxide.  When wastewater is
adjusted to an appropriate pH and passed through a column packed
with this material, the oxide coating adsorbs the soluble metals
and filters out the particulate matter.  Once the column's
capacity has been exceeded, the material can be regenerated
simply by passing another solution through at a different pH.
The regenerant solution typically contains the metal at a
concentration about 100 or more times that of the water which was
treated.  This process eliminates a major constituent which is
generated during conventional treatment of metal-bearing
wastewaters (iron or aluminum hydroxide) and generates a product
stream from which the waste metals may be recycled or recovered,
thereby avoiding both the cost and risks associated with
disposal.

     In October of 1989 the U.S. Environmental Protection Agency
(EPA), Risk Reduction Engineering Laboratory began a thirty-one
month cooperative agreement with the University of Washington to
develop this technology as a recycling option for use at metal
finishing facilities.  Chrome containing wastewaters were
selected as the target streams due to the toxicity and the volume
generated.

     The objective of this project is to evaluate the performance
of packed beds of granular media coated with iron oxide and other
adsorbents for recovering chromate from industrial waste
solutions.  The initial tests are being conducted using synthetic
wastes.  Following that, tests will be conducted using batches of
real waste.  A small recovery unit will be installed on-site at
an industry near the University at the culmination of the project
for pilot-scale evaluation.

     The experimental tasks have been divided into three phases:
(1) optimization of the process for coating the media with an
adsorbent surface examining a) coating efficiency and b)
dissolution of coating;  (2) optimizing collection and recovery of
chromate from relatively dilute synthetic waste solutions; and,
(3) testing the process with real industrial wastes both at
bench-scale and on-line at an industrial site.
                  DESCRIPTION OF THE TECHNOLOGY

     Conventional technology for removing metals from solution
involves precipitation of cationic metals as oxides, hydroxides,
or sulfides, and then separating the particulate metals by
settling, usually in conjunction with a coagulant such as iron


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hydroxide.  This approach has several practical limitations, some
of which are exacerbated when the metals are present in complex
matrices such as many industrial wastewaters.  Among these are
that precipitation is ineffective for most anionic metals (e.g.
Cr04/  Se03, V04)  and for metals which are present as inorganic or
organic complexes, and that those metals which do precipitate
usually form small particles which do not settle readily.  This
means that large settling basins are typically required to
collect the metals, usually followed by a sludge thickening
operation.  To ensure good treatment efficiency and good
coagulation, massive amounts of iron salts are often added,
significantly increasing the sludge generated in the process.

     When ferrihydrite coated sand is placed in a column and a
solution containing metals is passed through it, the coating can
adsorb the dissolved metals rapidly and efficiently.  At the same
time, the column acts as a normal granular media sand filter to
remove precipitated metals and other particulate matter.  After
some period of time, either the coating reaches its maximum
capacity to remove metals or the filter requires backwashing.  At
this time, a pH-adjusted backwashing solution can be applied to
recover the metals and regenerate the column for further use.
Because the ferrihydrite is trapped on the sand particles, only
the contaminant metals, not the ferrihydrite, are released.
Since the sand and the associated ferrihydrite are retained in
the column at all times a settling step is not required.  This
means the technology requires relatively small amounts of space
and treatment chemicals.

     The adsorptive filtration process generates a concentrated
regenerant solution.  This regenerant may be recyclable in the
production process or have economic value to other users.  In an
industrial waste stream dominated by one metal, e.g. a segregated
Cr(VI) waste stream in a plating shop, it may be possible to
simply recycle the regenerant solution to the process.


    INVESTIGATION OF THE COATING EFFICIENCY OF IRON ONTO SAND

     Initial experiments were conducted to characterize the media
prior to its exposure to any waste solutions.  During work on
optimizing the coating process, the amount of iron coated onto
the sand, the efficiency of the coating process and the
durability of the coating when the media is exposed to various
physical and chemical stresses were evaluated.  To determine the
amount of iron which is typically coated onto the sand from
various solutions, the sand was subjected to 10 coating cycles
with each solution tested, and the concentration of Fe on the
sand was analyzed after each cycle.

     Briefly, a cycle consisted of pouring the solution over the
sand and heating the mixture at IICTC overnight, at which time
the sand appeared to be completely dry.  At this point, the sand
was weakly  "cemented" together.  The  individual grains were

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separated by gentle grinding using a mortar and pestle.  The
grains were then rinsed for 15 minutes by placing them in a 200-
mL graduated cylinder and flushing de-ionized water through the
cylinder from the bottom at a rate sufficient to expand the media
by approximately 25%.  After 15 minutes, the flow rate was
briefly increased to expand the bed to between 75 and 100% of its
packed volume to rinse out any small particles which remained.
The water flow was then stopped, a small sample of sand was
taken, and new Fe-containing solution was added to start the next
coating cycle.  Sub-samples of coated sand from each cycle were
placed in hot, concentrated nitric acid to dissolve the iron
coating, and the resulting solutions were analyzed to determine
the amount of attached iron.

     The iron-containing solutions used in the coating
experiments varied in terms of the associated anion (nitrate or
chloride) and the amount of base added prior to the heating step.
The concentration of iron in the coating solution was 1.45 H for
the solutions made with iron chloride, and 1.30 M in those made
with iron nitrate.  Forty mL of iron-containing solution was
applied to 150 grams of sand in each cycle, unless otherwise
indicated.  This amount of solution was just enough to cover the
sand.

     Figures 1 through 3 show the amounts of Fe attached to the
sand after each coating cycle.  Figure 1 shows the Fe attachment
trend for two duplicate batches of sand coated using a solution
of iron nitrate containing no added base, and for one sample
using twice the volume of coating solution (80 mL of 1.30 M Fe
per 150 g sand) per cycle as in the others.  The results show
good reproducibility with respect to coating efficiency.  The
amount of iron attached increases after most cycles.  Although
there are occasional cycles where the increment in attached Fe is
zero or even negative, the overall trend is toward steadily
increasing attached Fe concentrations, reaching 6.3% and 6.4% Fe
by weight, respectively in the duplicate samples, and 11.1% in
the sample using a double dose of coating solution.  There was no
indication that these values were approaching a plateau.

     Figures 2 and 3 show the comparable data for coating
solutions prepared with iron (III) chloride,  rather than iron
nitrate.  In this case, when no base was added, some iron
attached for a few cycles, but then was released from the surface
in subsequent cycles.  The amount of iron on the surface never
exceeded 5% by weight of the sand, and at the end of 10 cycles
the attached Fe was 3.0% and 3.7% by weight in duplicate samples.

     Next, samples were prepared in which various amounts of
based (10 M NaOH) were added to the coating solution prior to the
heating step.  The amount of base to add was chosen as follows.
Base was added to the coating solution until a precipitate formed
which did not dissolve when the solution was stirred and heated
slightly.  This occurred when the base addition was 0.38 mol NaOH
per L of solution.  The coating solution contained 1.45 mol Fe/L,


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so the base addition when the non-dissolving precipitate formed
was equivalent to 0.206 mol OH/mol Fe.  This was chosen as the
maximum amount of base to add to any solution, and solutions were
also prepared containing 25, 50, and 75% of this amount of base.

     As Figures 2 and 3 indicate, the amount of Fe attaching to
the sand was not increased significantly by the addition of 0.05
or 0.10 mol OH/mol Fe.  As occurred when no base was added, the
amount of Fe attached increased and decreased in an apparently
random fashion, never exceeding a few weight percent.  When the
base addition was increased to 0.15 mol OH/mol Fe, the amount of
Fe attached still fluctuated somewhat, but reached higher levels
than in the samples with less base addition.  However, when the
full 0.21 mol OH/mol Fe was added, the amount of Fe coated
increased quite steadily, reaching a value of 8.1% Fe by weight
after 10 cycles.  As with the coating cycles using an Fe(NO,)3
salt, there was no indication that the amount of Fe coated had
reached a plateau.


                 ACID DISSOLUTION OF COATED IRON

     The next set of experiments investigated the stability of
the coating when exposed to acid solutions.  In a full-scale
operation, such exposure would occur either during acid
regeneration of columns used to remove cationic contaminants
(e.g. most metals) or during the treatment cycle of anions (e.g.
chromate).  In the former case, the pH of the acid solution would
probably be around 2.0, with exposure periods of less than 1 up
to about 2 hours per regeneration cycle.  In the latter case, the
exposure period would be much longer but the pH would probably
not be as low.  A pH value of 2.5 to 3.0 would probably be used
in these cases.

     For the acid exposure tests, a worst-case scenario was
simulated, representing treatment to remove chromate at pH 2.0.
The test protocol involved exposure of the media to a pH 2.0
solution for 20 hours, followed by 2 hours of exposure to a
solution containing 1 M NaOH (approximately pH 14), followed by 2
hours without flow, in contact with the 1 M NaOH.  During the
periods with water flow, the flow rate was 10.9 mL per minute
through a column packed with 21.8 mL of media, corresponding to
an empty bed hydraulic detention time of 2 minutes.  During each
daily test, some fine particles appeared to settle atop the
media.  These were washed out by a very brief (<1 minute)
backwashing step using the 1 M NaOH prior to returning to the pH
2 flow tests.

     Two acid dissolution tests under these conditions have been
completed.  In these tests, the media used were those prepared
with FeCl3 and either the maximum base addition or 50% of this
amount of base.  Both sets of media had been coated in 10 coating
cycles.  The tests lasted 14 days, with samples collected every 2
hours.  After 7 days and again at the end of the 14-day test, a


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sub-sample of the media was collected, and all the iron was
dissolved off the grains.  Analysis of the resulting solution
provided a check on the estimates of Fe lost during the test up
to that point.  The results from these tests are presented in
Figures 4 and 5.

     The amount of iron released from the surface into the acidic
water was typically between 0 and 1 mg Fe/L.  The release pattern
during a 24-hour period usually included a spike immediately
after acid flushing began, followed by a gradual decline in Fe
released for the remainder of the 22-hour exposure period.  The
amount of Fe released was consistently less in the sample which
had been coated with the more neutralized (greater base addition)
solution, particularly with respect to the spike at the beginning
of each acid exposure period.  Both because of the higher release
rate and the lower initial coverage, the media prepared using the
less-neutralized solution lost a significantly larger fraction of
the total attached Fe than did the more highly-neutralized media
(Figure 6).  In this test using more highly-neutralized media, '
the daily Fe loss was limited to a few tenths of 1% of the
attached Fe during the first 12 days of the test and decreased to
only 0.1% during the last 2 days.

     The amount of Fe detected in the acid dissolution effluents
was considerably less than the total loss of iron from the media
during the 2-week test period.  The additional losses were
apparently due to the backwashing of the fines during the brief
backwashing step each day.  These losses were significant during
the first week, but appeared to be less or negligible during the
latter parts of the test.  For instance, although the total Fe
loss during the 2-week period for the more- and less-neutralized
samples was about 33% and 50%, respectively, in both cases over
90% of the 2-week Fe loss occurred during the first week.  This
suggests that even if a  sample loses a good deal of its attached
Fe in the early stages of its use, the remaining Fe is firmly
attached and will not be easily lost.  Similar tests with the
media prepared using an  iron nitrate solution are currently being
conducted.
                    CHROMATE ADSORPTION TESTS

     In the actual adsorption/recovery tests, waste solutions
will be passed through columns packed with the coated media.  A
typical column will contain about 90 mL of bulk media.  In order
to characterize adsorption of Cr(VI) on to the coated media,
Cr(VI) concentration, solution pH, and residence time in the
columns will be measured.  Three Cr(VI) concentrations will be
tested: 10, 75, and 500 mg/L.

     In the initial tests, the solutions will contain only
deionized water and sodium chromate at the appropriate
concentration.  It is anticipated that tests will be conducted
with each solution at 3 influent pH values.  At each pH value

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tested, the test run will continue until the ratio of effluent to
influent Cr(VI) concentration is at least 0.5.  At this point the
columns will be regenerated by exposure to a high-pH solution, as
described below.  At each pH value, at least one run will be
conducted at each of 3 flow rates, yielding empty-bed hydraulic
residence times of approximately 2, 5, and 15 minutes.  If the
capacity of the column for adsorbing Cr(VI) appears to be
sensitive to flow rate in these tests, additional tests at other
flow rates will be conducted.  Based on the results of these
tests with Cr(VI) only, operational parameters will be chosen for
subsequent tests in which competing ionic adsorbates are present.

     Tests will also be conducted using sulfate and Cr(III) as
competing adsorbates.  For these tests, only the pH and flow
determined as optimal from the tests containing only Cr(VI) will
be used initially.  If the capacity of the media to collect
CR(VI) from the solutions is significantly diminished in these
tests compared to those with no competing ions, lower flow rates
and different pH values will be tested in an attempt to improve
performance.

     The maximum chromate concentration attainable in the
regenerant solution is important because it may ultimately
control whether the regenerant solution has economic value (can
be recycled).  Based on results from previous tests, a single
regeneration procedure will be chosen and used for the runs
containing competing ions.  If the regeneration efficiency in
these runs is substantially worse than in those with no competing
ions, the regeneration pH and/or flow rate will be changed in an
effort to improve regeneration performance.


             TESTS USING REAL INDUSTRIAL WASTEWATER

     Chromate-containing wastewater from a local industry will be
identified and treated using adsorptive filtration.  The initial
test runs will use operating parameters identified in the
previous tests.  Modifications will be made as appropriate to
improve process performance,  particularly if the process does
not perform as efficiently as it did in the tests with synthetic
wastes.  Once the process has been operated successfully with the
industrial wastewater at bench-scale, a pilot unit capable of
treating approximately 1 gpm of the wastewater will be
constructed and tested on-site.  This unit will be subject to any
changes in waste composition which occur in the real system, and
therefore will provide valuable information about the stability
of the system under transient loading conditions.
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                       GENERAL REFERENCES

1.   Benjamin, M.M., "Adsorption and Surface Precipitation of
     Metals on Amorphous Iron Oxyhydroxide," Environmental
     Science Technology,  17, 686 (1983).

2.   Edwards, M.,  and Benjamin,  M.M.,  "Regeneration and Reuse of
     Iron Hydroxide Adsorbents in the Treatment of Metal-Bearing
     Wastes."  J.  Water Pollution Control Federation, 61, 481
     (1989).

3.   Edwards, M.,  and Benjamin,  M.M.,  "Adsorptive Filtration
     Using Coated Sand:  A New Approach for Treatment of Metal-
     Bearing Wastes."  J. Water Pollution Control Federation, 61,
     1523 (1989).
                                107

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F
e

b
y

w
E
I
Q
H
T
           Figure 1.  Weight fraction of  attached
             iron using a ferric nitrate solution.
                       4567

                         COATING CYCLE
           8
          80 ml coating soln

          40 ml coating soln
 40 ml coating soln
          Figure 2.  Weight fraction  of attached
            iron  using a ferric chloride solution.
 10
                      4567

                        COATING CYCLE
           8
        40 ml un-neutralized

        40 ml & 0.05 M NaOH
40 ml un-neutralized
10
                           108

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           Figure 3.  Weight fraction  of attached
            iron using a ferric chloride solution
 F
 e

 b
 y

 W
 E
 I
 G
 H
 T
             0.10 M NaOH
4567

  COATING CYCLE


  -+- + 0.15 M NaOH  —•
                                            8
0.21 M NaOH
         Figure 4.  Iron Concentration in Effluent
         1.45 M ferric chloride + 0.21 M NaOH
2.5
   EFFLUENT Fe (ppm)
            10
1.5
0.5
               16   21   26  31   36   41
                      SAMPLE NUMBER
                   46   51   56
                           109

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       Figure 5. Iron Concentration in Effluent
        1.30 M ferric chloride + 0.10 M NaOH
 EFFLUENT Fe(ppm)
                             Illlinlllllliii
                                         111,
 1   6
F
e

L
O
S
T

F
R
O
M

A
C
I
D

W
A
S
H
I
N
G
2.5
      11   16   21   26  31  36   41   46   51   56
                SAMPLE NUMBER

      Figure 6.  Loss of attached iron due to
        exposure to acid (pH 2.0) solution.
                                 10  11   12  13   14
            0.10 M NaOH coating
                             0.21 M NaOH coating
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      THE STATE OF OHIO POLLUTION PREVENTION TECHNOLOGY TRANSFER PROGRAM

O. S.  Burch and P.  S.  Rafferty.  W.S.O.S. Community Action Commission,  Inc.,
P.O. Box  590,  Fremont, OH 43420

BACKGROUND

     The  Ohio  Pollution  Prevention Technology Transfer Program is the result
of a collaboration  of  several agencies interested in providing assistance  to
business  with  hazardous  waste problems.   These  agencies include  the Ohio
Environmental  Protection Agency  (EPA),  The  Department of Development's Ohio
Technology  Transfer  Organization   (OTTO),  and  W.S.O.S.  Community  Action
Commission  (WSOS).  These agencies have  taken a lead role  in  leveraging  funds
to be used  to  support a business  assistance program.  Program supporters have
included  the  U.S. EPA  (Washington,  Chicago,  and Cincinnati),  The George Gund
Foundation  and the Cleveland  Foundati'on.

     The  initiation  of the Ohio  Program began with  a cooperative agreement
between W.S.O.S. and OTTO in  April of  1987.  The purpose of the agreement was
to form a working relationship to be better able to compete for federal  funds
in  waste minimization.   OTTO was  working under  the Governors  mandate   to
provide  such  technical  assistance  along with the  technical  assistance that
they  normally provided  to  businesses.    W.S.O.S.   was  just  finishing  a
successful  demonstration program  of  waste minimization in six northwest Ohio
counties.     The  combining   of  these   two   agencies   created   a  unique
private/public  partnership  with access  to:   32 outreach  agents  at colleges
and  universities;   state   and  federal  research  laboratories;   and   waste
minimization experts.

     Thus far,  this  partnership has been  very  lucrative.   In 1988 WSOS/OTTO
wrote  an application  on behalf  of  the  Ohio  EPA.   The  application  was   in
response  to a solicitation  from the U.S.  EPA  announcing the availability  of
ten  grants   to conduct  RCRA  Integrated  Training  and  Technical  Assistance
(RITTA).  The Ohio proposal  outlined  a coopertive approach  among Ohio EPA,
WSOS,  and OTTO staff  in designing  and delivering an  innovative  one-on-one
technical assistance program for businesses.   Ohio's proposal  was  ranked
second in the  nation.

AGENCIES INVOLVED

     WSOS is  a community action agency  operating  in  the  four  northwestern
Ohio counties  of Wood,  Sandusky, Ottawa,  and  Seneca.   In  addition  to the
various  human  service  activities  conducted by WSOS,  they also  are Central
Office  and  administrating  agency  for  the  Great  Lakes  Rural  Community
Assistance  Program  (GLRCAP).   The GLRCAP program is  a seven-state training
and technical assistance center operating in Illinois, Indiana, Kentucky,
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 Michigan, Ohio, Wisconsin, and West Virginia.   GLRACP was formed in 1980 to
assist rural  communities attain  and  maintain sanitary water  and wastewater
systems.    Our efforts in this  field  has  lead  us  into other  areas  of water
management with GLRCAP serving as  the  environmental  component  of WSOS.  This
has proven  to be an  ideal  position from  where  we have been  able to affect
positive changes in the environmental  condition of rural areas.

     OTTO  is  Ohio's  official waste minimization  information system, charged
by  Governor  Richard  F.  Celeste  with  providing  training  and  technical
assistance  to  Ohio's  industrial  and  business   communities.    As  a  non-
regulatory  body,  OTTO  can  deliver technology,  materials, and information
about waste  issues  to any  Ohio  company.  OTTO  has  a network  of 32 trained
agents housed at 23 two-year  colleges  and  five  major universities throughout
the state.  Each agent offers timely,  direct, and local access to definitive
resources,  including  commercial  databases,  federal  laboratories,   and  the
faculties  to  member institutions.   OTTO also provides  those agents with the
expertise  of   an   engineering   specialist   and  two   business  management
specialists,  as well  as  the Waste  Information  Network  (WIN)  library  of
resources at its Ohio  State University Research/Resource Center.  Since 1979,
OTTO  has  promoted   Ohio's  economic   development  by  brokering  technical
information  and  expertise  from  the  higher   education  system,   federal
laboratories, and  other  sources  of Ohio's  business  and  industry.   OTTO's
objective  in  waste  management, as  in  all  other activities, is  to help Ohio
companies  become more productive and competitive  through  the  application of
modern methods and techniques.

OHIO'S BUSINESS ENVIRONMENTAL TECHNOLOGY TRANSFER PROGRAM

     Currently  the  Ohio  program  is completing  the  RCRA  Integrated Training
and  Technical  Assistance   grant,  which has  three  major  objectives:    the
development of  a State  Training  Action  Plan, the  implementation of training
for  state   environmental   personnel,    and   the   conductance   of  technical
assistance.  Ohio's plan differs from most other  States  by incorporating an
innovative technical assistance approach.  This approach is the basis for the
Ohio Business Environmental Technology  Transfer program  as well  as  most of
the  report.   The  other  elements  of   the  program and  additional activities
mobilized as a result  of the receipt of U.S.  EPA funds, however, will provide
many opportunities  for Ohio businesses.

                      STATE  TRAINING ACTION PLAN  (STAP):

     The STAP  is  basically an outline  detailing long-term  plans to achieve
RCRA program  goals  using training and technical assistance techniques.   The
STAP will  set  forth  plans  for both  training directed  toward environmental
industrial/regulated  community,   outline a  focused  pilot  project  in  waste
minimization as  well  as establish  plans for developing and implementing an
Integrated Compliance  Strategy (ICS).   The  Ohio  EPA has  organized a Waste
Minimization Task Force  (WMTF), which reports directly to the Director of the
Ohio EPA.  The WMTF has been charged with the responsibility of assessing the
Ohio's needs relative to  hazardous  waste minimization.   The WMTF has been of
individuals representing the following ten agencies or groups:
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     o    Ohio General Assembly
     o    Ohio Manufacturers Association
     o    Attorneys
     o    Ohio Environmental Council
     o    Ohio Public Interest Council
     o    Battelle Institute
     o    Ohio Chamber of Commerce
     o    Ohio Technology Transfer Organization
     o    Environmental Activities
     o    Engineering Department, Ohio State University

     The WMTF will serve as the team that will work with OTTO staff to design
and develop the STAP.  Such a team effort will ensure that the Ohio STAP is
responsive to the needs of the EPA and the regulated community.

     The Lead agency for the development of the STAP is OTTO.  A full-time
environmental specialist will be assigned to work with the Waste Minimization
Task Force (WMTF) to oversee, and develop the STAP, in conjunction with
assistance from the Ohio EPA, the National Environmental Training Association
(NETA) and the Center for Hazardous Materials Research.  The OTTO staff
person will be responsible for assessing Ohio EPA needs and working closely
with external agencies.

     All existing state training programs will be evaluated to assess the
total system performance.  The evaluation will help determine successful
elements that could be incorporated into the STAP, as well as to identify
gaps in the present state training programs that need to be supplemented in
the STAP.  Based upon input from the Ohio EPA, WMTF, WSOS, and the
business/industrial community, a five year projection of training and
technical assistance goals will be established.  Some of the factors that
will be taken into consideration will include data on Ohio's waste generation
community, and trends in the political arena that will effect both the
regulator and the regulated.  Realizing that it is impossible to predict the
type of training and technical asistance that will be needed in the future we
can only assume from previous experience that there will be an overall
decrease in the need for initial training relative to procedure and waste
minimization technical assistance; and an increase in advanced training,
relative to specjufig j-ssues as welj... as for orientation training of new
staff.

     Perhaps the most significant section within the STAP will be the outline
relative to  future funding of the  Ohio  program.   The plan will identify and
evaluate  potential  sources  such  as:     state   support;  disposal  fees/tax
support; fee  for service programs;  subscription newsletters; self sufficient
or profit  making conferences;  workshops and  trade  fairs;  and private sector
involvement.  Ohio  is  already  investing funds by annually supporting OTTO at
$1,600,000.    In  addition,  in-kind  support  from  technical  schools  and
universities, contribute to the Ohio Pollution Prevention Program.
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     Strong  public   and  corporate/industrial  awareness   and  support  is
essential to develop a State Training Action Plan and State program that will
effectively  minimize  hazardous   wastes   in   the   State.     Because  the
industrial/corporate  community will  be involved  in the development  of the
STAP, as well as  the  waste minimization project, Ohio's program will be at a
distinct advantage from the beginning in building awareness and support among
the  industrial  sector.   To gain additional support  from this group,  we plan
to increase their awareness of our program.

                  TRAINING FOR  STATE ENVIRONMENTAL  PERSONNEL

     The State  Environmental  Personnel  will be  some  of  the same individuals
and  agencies  that will  be   responsible  for  designing  the  STAP  and  for
conducting the  demonstration  program.  Specifically  this  will involve staff
at the  Ohio  EPA,  OTTO,  and WSOS.   The  training of these State Environmental
Personnel will  involve  three  specific  aspects:   interagency,  outreach, and
one-on-one.     Each  type  of  training  will  target  a  specific  technical
assistance provider   and  will be  integrated  into  the  complete Ohio  waste
minimization program.

INTERAGENCY  TRAINING;   Interagency  training  will   involve  working out  an
efficient working relationship among all  agencies involved  in training and
technical assistance.   All three agencies  involved  are  independent agencies
that are working on waste management and minimization issues.  Each brings to
the team unique expertise  and  capability.   This training element will be the
initial  training   required to  implement  the  program.   Continued  training
activities will be identified and will evolve over the course of the program.
Some of the training activities/issues will include:

     o    Ohio EPA internal staff training,
     o    State environmental personnel cooperative training,
     o    RCRA compliance training,
     o    Waste minimization techniques, and
     o    Resource utilization and availability.

OUTREACH TRAINING;   The  outreach  element of  our  program will serve  as the
initial  contact  between  the  business  community   and  our  program.    The
objective of the  outreach  element is  to determine  the assistance required by
the  owner/operator  for  the   business   to implement  a  waste  minimization
program.  The training  will involve increasing  the  awareness and capability
of outreach staff.  This may  involve developing manuals  and/or survey forms
that  will  allow  the  outreach staff to  effectively  assess  the  businesses
needs.

ONE-ON-ONE TRAINING;   The  one-on-one  element of  our program  represents  an
innovative method to insure that businesses receive the information that they
need to specifically implement waste minimization.   Many technical assistance
programs fall short of being able to  quantifiably  reduce wastes because they
do not  follow through and address the  specific  needs  of  the business.   This
training element will  involve increasing specific technical knowledge and
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 establishing  a   working   relationship  between  the  one-on-one  technical
assistance  providers and  the Ohio  EPA and the  USEPA.    Training  will also
involve a cross training element between the outreach and  one-on-one staff to
increase the flow  of information and the exchange of ideas between these two
components.

     Initially,  only general  orientation  training will be  conducted.   This
training will  bring all Ohio  EPA  staff and state environmental personnel up
to  date  relative   to  regulations   and new  legislation.     The  orientation
training will  also  outline  goals and  objectives  of the  Ohio  Program.   The
orientation  training will also  serve  as an  initial  coordination  program
between Ohio EPA staff  and OTTO/WSOS outreach and  technical assistance staff.

     In addition to the orientation  training,  the following type of training
will be conducted:   (1) Training  State technical  assistance specialists and
inspectors   to  provide   assistance   to   generators  in  identifying  and
implementing waste  minimization  project  opportunities  and  activities;  (2)
Training a  technical assistance  team  to  provide  waste  minimizaiton support
and to  identify  management coordination needs;  (3)  A joint training session
for RCRA, Water  Quality, and  Air Quality waste minimization assessments; (4)
On-site facility training;  and (5) Training of the media and general public.

                      TECHNICAL ASSISTANCE  PILOT  PROJECT

     The primary emphasis  of  the Ohio  Program utilizes  the successful model
designed and implemented by  WSOS  and the  existing  outreach  capabilities of
OTTO.   The  model is a  one-on-one  training and technical  assistance program,
conducted  by  a  nonenforcement  entity, using the technical  experience  and
cooperation of the Ohio EPA  as  a support  agency.   With  this  model,  we are
able to  gain  the  trust of businesses  and, therefore, provide  them with the
specific  assistance  that   they   require  to   achieve waste  compliance  and
minimization.

     With a  pilot  program initiated by WSOS,  we  have already  been able to:
increase the number of businesses complying to the RCRA regulations, increase
awareness  for   the  necessity of  compliance  to  RCRA,  and  assist  several
businesses to  quantifiably minimize the amount  of hazardous  wste generated.
More importantly,  we have been  able to gain the  confidence  of the business
community,   thereby,  increasing   their  willingness  to  contemplate  waste
minization.  In  the process,  we  have demonstrated that proper management and
minimization of wastes  is not so much a business  expense as it is a long term
economic savings.

     The goal  of the Ohio program is  to  establish  a  training  and technical
assistance program within the State that will successfully assist business on
environmental  issues.   To   achieve  this goal,  an  innovative  state-wide
outreach model was established.    The  model involves the  linkage of  various
agencies to conduct training,  technical assistance, information exchange,  and
one-on-one  assistance.     In   addition  to  the  agencies   that  have  primary
responsibility  for  business   technical  assistance,   the   model  incorporates
other agencies such as:   Private  Industry Councils  (PIC),  Community  Action
Agencies (CAA),  the Ohio  Chamber of  Commerce and local  chambers,  and Ohio
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colleges, Universities, and  technical  schools.   The actual services delivered
at planned for delivery are elaborated on below*
     TRAINING:  The first element of our program involves detailed training
of the individuals and agencies that will be involved in the waste
minimization program in Ohio.  Most of the elements of this training have
been detailed earlier.  We propse an innovative training component to
increase awareness for waste minimization by segments of the Ohio business
community other than and in addition to the generators.

     ONE-ON-ONE:  Our one-on-one approach is the cornerstone of the program.
Because of the success that has been demonstrated with this approach, we are
confident that other methods used to achieve reduction of wastes will
directly and indirectly benefit.  All direct technical assistance involves an
OTTO/WSOS staff member working with the business in a one-on-one capacity.
In this manner we can provide the information and assistance required to
minimize waste at that facility.  We believe that a successful one-on-one
program will allow us to effectively conduct need surveys, sponsor well
attended workshops, etc.

     OUTREACH:  Our primary outreach will be via the thirty-two OTTO agents
located in community colleges throughout Ohio.  As these agents assist
businesses they will also  assess hazardous waste management and minimization
practices, and provide assistance and referrals as required.

     SURVEYS:  A survey form will be designed that can be used to assess
business needs relative to waste minimization and other environmentally
related issues.  The survey form will also be made available to other
agencies that routinely work with businesses such as:  economic development
centers, chamber of commerce, community action agencies, small business
centers, etc.

     MANUALS:  We have already produced a guidebook for small businesses.
Based on the needs identified, we plan to produce additional manuals targeted
towards waste minimization in various industries.

     ARTICLES:  Perhaps one of the best ways to reach owners/operators is to
publish information in trade magazines.  As case histories become available,
articles will be written relative to effective examples of waste minimization
and pollution prevention.

     NEWSLETTERS:   The newsletter prepared by OTTO now contains information
on environmental issues.  This is provided gratis to Ohio business.   The
newsletter describes, in layman terms,  the new environmental regulations as
they pertain to Ohio businesses and provides a forum for brief case
histories.  Other features that may be added include:  a question and answer
section, a material trade/exchange section, an analysis of waste minimization
products, etc.

     LECTURES:  We will accept invitations to talk about waste minimization
at local conferences.  We also plan to approach trade and vocational schools
to talk to students who plan to open their own businesses about waste
minimization.
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SUMMATION:

     The first  year  of the project can  only  be rated as a huge success even
though we have  in  no  way achieved all that we  still  want to accomplish.  The
merger of OTTO  and WSOS  hazardous waste programs was done  "on-the-run" as we
implemented the program.   Often this  caused delays when we wanted  to proceed
at a more  rapid rate.   The results,  however,  speak for themselves.  A total
of  437  hazardous  waste  generators,  representing  an  average  of  1.2  per
calendar day,  received direct  one-on-one  technical assistance with specific
waste minimization problems.   Newspaper  articles describing the merit of the
program  and  the merit of  waste reduction  appeared in 35  papers.   Over 370
generators and  over   400  representatives of other  associations attended the
various  workshops  and conferences  sponsored  or co-sponsored  by OTTO and/or
WSOS.  Over 3400 items of  information were distributed in  the  form of flyers
and newsletters to an average of  850 generators per quarter.

     For year  two  of  the  program, our  plan  is  to continue at  the  same or
higher level of service  delivery.   In addition, we will begin  to quantify in
terms of volume and  impact the amount  of  hazardous  waste  diverted from the
environment.
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           THE USE OF ECONOMIC INCENTIVES FOR THE INTRODUCTION AND
                       ADAPTATION OF CLEAN TECHNOLOGIES
               by:  Dr.  Demetrios G.  Caenis
                   UNIDO Consultant
INTRODUCTION*

      The adjustment pressures on the economies of developing countries to
pursue their industrialization have increased drastically and so has the
damage caused to the environment and natural  resource base on which economic
growth depends.  It is evident that damage is being caused to the natural
environment by the technologies and practices employed in industrial
development and less harmful alternatives must be discovered and applied.   For
both developed and developing countries, the challenge to face is to continue
their economic and social development in a sustainable way.  That is, to
ensure that they meet the needs of the present without compromising the
ability of future generations to meet their own needs.

      Technological innovations have the potential of achieving this
objective.  How to use technology is not always a simple decision, but above
all is an important one, upon which our survival depends.  Technology
constitutes one of the most important factors of the industrialization
process, which is a necessary condition for economic development.

      A significant outcome of technological progress is the development of
clean methods of production which not only have major economic and technical,
but ecological implications as well.  Clean technologies reduce production
cost through savings in raw materials and energy and increase productivity,
which in turn leads to increased profitability and competitiveness.  On the
other hand, clean technologies limit discharge, avoid the production of by-
products and reduce the risks of accidental pollution and transfer of
pollution between physical environments.
* My appreciation to Dr. S.P. Maltezou, Scientific Advisor and Coordinator,
Environment Programme,  IPCT/TP/OD/EEP, UNIDO, for her valuable comments and
suggestions.
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      Nevertheless, new and clean technologies are mostly developed by
industrial countries, and in one way or another, developing nations are highly
affected by technological developments abroad since for the majority of these
countries new technologies have to be acquired from abroad rather than
developed domestically.  Moreover, the technological feasibility, the
complexity of economic and environmental problems and the financial
implications of solutions are different in industrial nations and developing
countries.  Namely, it is economically more difficult for developing countries
to promote economic development and protect the environment at the same time.

      However, measures to assist developing countries to review both economic
development and environmental quality are now needed more urgently than ever.
In addition, developing countries should be assisted in establishing the
conditions for developing clean technologies themselves or in building their
capabilities for technology acquisition.

      The main objective of the present study is to promote economic
mechanisms that could induce developing countries in transferring and applying
clean technologies.  In pursuing this objective, we consider and analyze the
implications of two policies.  The Polluter Pays Principle which focuses on
the identification of pollution generating sources and penalizing the
polluter, and the use of subsidies in order to assist enterprises or
industries to transfer, introduce, and adapt clean technologies.

      The paper is divided into three sections.  Section 1.0, defines the
Polluter Pays Principle and analyzes the implications of its implementation
through direct controls and taxes.  Section 2.0, examines the effectiveness of
subsidies as an alternative policy measure and describes the various types of
subsidies.  Finally, a summary of the main conclusions of the paper are
discussed along with their implications for future policy decisions.


1.0  THE POLLUTER PAYS PRINCIPLE AND ITS IMPLEMENTATION

1.1  Environmental Resources and Market Prices

      In a market system, consumers express their preferences for commodities
by their willingness to pay the price attached to them.  But payment of the
price is not always a necessary condition for obtaining commodities (Mayer,
1975).  Namely, some commodities that serve economic functions, are not
represented in the price mechanism and can be obtained without paying a price,
such as public goods and environmental resources.  When an environmental
effect is not automatically taken into account by the price mechanism, it is
considered an external effect.  In other words, the environmental impact of
economic activities by one or more economic unit(s) on the welfare of others
are treated as externalities.

      Environmental externalities result from both production and consumption
activities and develop rapidly as an economy grows with a substantial impact
on the society at large.  They are generally considered as the major reason
for the discrepancy between private and social cost and result in
misallocation of economic resources (Pearce, Markadya and Barbier, 1989).
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      Environmental externalities and the resulting mi sal location of resources
can be corrected, partially or wholly, through the price mechanism if a price
is placed on environmental resources so as to narrow the gap between private
and social cost.  That is, free market prices must be determined in such a way
as to reflect the true cost of production including the value of environmental
damaged caused by any economic activity.  The correct prices then should be:

            P = MC + MEC = MSC            (1)

Where, MEC is the marginal environmental or marginal external cost expressed
in money terms.  For a non-polluting product there is no difference between
private and social costs of production and therefore the marginal external
cost is zero and the proper price becomes:

            P = MC = MSC                  (2)

On the other hand, the proper price for a polluting product or service should
reflect the environmental damage as it has been expressed in formula (1).
Thus, there is a need to correct the market prices of polluting products by
making the polluter pay the differential amount.  This is the process of
internalization of externalities which we discuss in the following section.


1.2  Definition of the Polluter Pays Principle

      The central theme of any environmental policy is the internalization of
externalities that can be resolved through effective policy instruments aimed
at allocating the most relevant costs and benefits to society.  To this end, a
common environmental policy on pollution prevention has been accepted and
implemented by many nations and in particular among the members of the
Organization for Economic Cooperation and Development (OECD).

      The objective of this policy is to allocate the pollution control cost
to polluters, and  it is called the Polluter  Pays Principle (PPP).  The
Polluter  Pays Principle implies that  it  is the responsibility of the polluter
to meet the costs  of pollution control  and prevention measures, irrespective
of whether these costs are incurred as  the result of the imposition of some
charge on pollution or in response to some direct regulation.   It  is also
irrelevant whether the polluter passes  on some or all of the costs to
consumers in the form of  higher prices  or absorbs them  (OECD, 1975).

      There are  various mechanisms making the polluter pay for  the pollution
control costs.   In this paper  I consider  and analyze the implications of  two
such mechanisms,  i.e., direct  controls  and taxes or changes.  According to
Baumol and Dates  (1975),  the difference  between direct controls and taxes or
fees  is that direct controls are enforced through fines or other penalties  and
involve a directive to individual producers  requiring them to satisfy some
predetermined environmental quality standards.  If  their activity  satisfies
these requirements, they  are legal and  no penalty is imposed, but  if the
standards are violated they are subject  to punishment.  With taxes or fees  on
the  other hand,  even  if they are based  on standards, the producer  is not  told
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what level of economic activity to select.  The amount of payment will vary
with his activity level, with no imputation of illegality to the activity
level he chooses.


1.3  Direct Controls

      One mechanism through which the polluter pays principle can be
implemented is direct controls aimed at forcing the polluter to pay the cost
of cleaning the environment of his generated pollution or to order him to
utilize a clean technology for producing his output.  In order to comply with
predetermined standards set up by public authorities, the polluter must pay a
lump-sum equal to the clean-up cost or pay the cost of pollution prevention
equipment.

      The impact of the above policy is an increase in the total cost of
production borne by the polluting firm.  But as with any increased cost, the
producer may be able to pass some or all of the pollution control cost on to
consumers (through higher prices) depending on the elasticity of the demand
and supply curves.  Namely, the more elastic the demand curve is (the higher
is the competition) the more the increased costs will be borne by the producer
and less will be passed on to consumers.  In reality, the environmental
control cost is shared between the firm through reduced profits and the
consumers through higher commodity prices (Pearce, Markadya and Barbier,
1989).

      Direct controls are the safest means of preventing irreversible effects
or unacceptable pollution levels and their effectiveness depends mainly on
good administrative organization, on which efficient environmental management
also depends (OECD, 1975).  It should also be noted that direct controls are
mainly preferred by industrialists, because controls are open to bargaining
and compromising over the fixing of the standards and once the polluter has
complied with the regulations, he has no further charges to pay.  In addition,
direct controls are flexible since they can induce changes in polluting
activities and this is another reason for their popularity among regulators
(Baumol and Dates, 1975).  Moreover, direct controls are consistent with the
PPP if each polluter affected by the controls has to bear the cost necessary
for complying with the standards (OECD, 1976).


1.4  Pollution Charges or Taxes

      Another mechanism through which the polluter pays principle can be
implemented is by imposing a per unit tax or charge on the product itself,
resulting in raising the cost of producing the product.  The effect of a tax
is that it adjusts market prices to reflect the use of environmental
resources, which otherwise would be treated as being free.  The amount of the
tax must be equal to the marginal external cost so that private and social
costs become equal (Formula 2).  More specifically, the tax must be equal to
the amount at which the marginal social costs of pollution abatement equal to
the marginal social damage from pollution.  If this tax is imposed, the
polluter will reduce the polluting input up to the point where a further
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reduction in this input (further reduction in pollution)  will  cost him more
per unit than paying the tax, because he would prefer to  pay the tax beyond
this point (OECD, 1976).

      The amount of the tax should also have some relationship to the value of
environmental resources used in the production of a given product.  For
example, soft coal with high sulfur content should be charged a higher tax
than hard coal with low sulfur content.  A higher tax on  leaded than unleaded
gasoline may induce consumers to use unleaded gasoline so that to improve air
quality standards.

      Pollution charges or taxes, on the other hand, play an important role in
the process of internalizing environmental externalities.  First, unit taxes
represent a very attractive method for achieving specific standards of
environmental quality, and they automatically lead to the least-cost pattern
of modification of externality-generating activities (Baumol and Dates, 1975).
Second, pollution charges or taxes oblige the polluter to include in his
production cost the pollution control cost and by doing so he re-establishes
correct pricing, so that the gap is bridged between private and social cost
(OECD, 1975).  Third, a charging policy may achieve the objective of abating
pollution at least cost to society and it can provide a continuing incentive
for improved pollution abatement (OECD, 1976).  Finally,  the application of
charges in promoting clean technologies make the cost of pollution visible to
manufacturers, and the revenues from the charges can be used for environmental
investments  (Economic Commission for Europe, 1989).

      The two policies we have discussed so far have different effects on
product prices.  With direct controls, the first is forced to pay a lump-sum
environmental control cost which does not alter the initial prices created by
the market.  This implies that the polluter will pay the same cost regardless
of what amount of the polluting input is employed in the production process,
unless environmental quality standards change.  On the other hand, imposing
taxes on polluting inputs or products raises the prices of these products and
makes them less attractive to consumers.  Market prices determined that way
reflect both the use of economic resources as well as of environmental goods
and achieve  a more efficient allocation of scarce resources.

      Pollution charges or taxes, however, are generally considered more
effective and should be used to internalize abating pollution costs.  The
basic reason why pollution charges are likely to be better than forcing the
pollutant to bear the pollution cost is that: "charges enable a polluter to
choose how to adjust to the environmental quality standard.  Polluters with
high costs of abating pollution will prefer to pay the charge.  Polluters with
low cost of  abatement will prefer to install abatement equipment.  By making
abatement something that low cost polluters do rather than high cost ones,
charges tend to cut down the total cost of compliance" (Pearce, Markadya and
Barbier, 1989).
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2.0  FISCAL INCENTIVES

2.1  Subsidies

      As national environmental policies are applied, it seems that strict
enforcement of the Polluter Pays Principle may create economic difficulties
for certain enterprises, industrial sectors, regions or countries.  In such
cases making the polluter pay is not practical, and a transitional policy can
be adopted to facilitate adjustment.  This being so, exceptions can be made to
the PPP when there are special circumstances which the authorities regard as
justifying them.  Such situations could arise when application of the PPP
would hinder the achievement of one or more regional or national economic
objectives.

      This would be the case, for example, when the additional environmental
control cost incurred by polluting industries in developing countries would
result in holding back regional development or adversely affecting the labor
market.  In addition, to abate pollution, changes in production technology are
required in many cases, which may cause distortions in the operations of an
enterprise or industry.  Production lines may have to shut down, economies or
scale may have to be sacrificed temporarily, and workers may have to be laid
off.  Another situation may arise when an enterprise or industry in a
developing country, in order to abate pollution, must apply a new cleaner
technology which has not yet been introduced in the country in question.  Then
this technology must be transferred from abroad which in many cases is very
costly.

      Under these circumstances, a case can be made for public assistance to
help a firm or an industry to meet transitional adaptation costs, so that the
public as a whole will benefit from the process of maintaining a viable
balance between environmental and other economic or social goals.  Although
the sharing of transitional adjustment costs, through public or international
assistance constitutes a departure from the spirit of the PPP, it seems that
the general problems of adjustment and policy implementation require
exceptions to be made in the aforementioned special cases.  Furthermore,
exceptions to the PPP have been widely accepted in the form of "adjustment
assistance" under a wide variety of circumstance, ranging from import
competition to the effects of rapid technological change  (Walter, 1978).

      The major goal of implementing efficient environmental policy then
should be to minimize adjustment costs, and nationally or internationally
financed programmes should be provided aimed at reducing the overall
adaptation cost  to society.  This  is possible through the use of  subsidies
which eventually allow  adjustment to occur with reduced cost to the firm or
the  industry.  A subsidy is an aid to a polluter of  all or part of the cost of
the  antipollution measures with which he  is obliged  to comply.  In fact,
subsidies may be of advantage  in facilitating  and speeding up the
implementation of an environmental policy during a transitional period of
adaptation.
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      A comparison between subsidies and the enforcement of the PPP policies
reveal that the two policies have different distributional  effects.  In the
case of the PPP the cost is borne by the producer and the consumer of the
commodity in question, while in the case of subsidies,  the cost is paid either
by public authorities or it is shared by the polluter and the authorities.   In
the latter case, however, the cost of abating pollution is subsidized by a
public body from revenue drawn not only from the consumers of the commodity in
question, but from all taxpayers.  In this respect,  the subsidies policy may
be preferred to the PPP because its indirect influence makes it difficult to
determine who is paying and how much (Mayer, 1976).


2.2  Types of Subsidies

      In this paper, we define subsidies as the various instruments or
techniques actually employed in order to make a public body or international
organization (or in general somebody else) bear wholly or partially the
environmental-control costs rather than the polluter himself.  That is, the
polluter pays nothing or a part of the total pollution abatement costs.  All
these instruments are considered departures from the polluter pays principle,
but some have less distortive impact on international competitiveness than
others.  The following section describes these economic instruments available
for pollution control and reduction.

a.    Government Capital Grants.  They represent the most important and most
      effective form of subsidisation by the governments of productive
      enterprises and consist of direct financial assistance to the firm in
      order to reduce the capital cost required for pollution control
      facilities.  As a result, the firm's average cost per unit of output  is
      lower than would otherwise be the case, and its national and
      international competitiveness is raised.

      In terms of international competitive implications, government grants
      are the most objectionable since they reduce the firm's per unit cost
      and lead to unfair competition.  They are also prohibited by the General
      Agreement of Trade and Tariffs (GATT) in international trade relations.

      Regardless of the objections, capital grants should be provided to
      individual firms or industries of developing countries to induce them to
      introduce clean and low-waste technologies in the process of
      implementing their environmental policy without sacrificing economic
      growth or other social or commercial priorities.

b.    Tax Abatement.  Tax relief of any kind constitutes an implicit
      subsidisation by governments of capital or operating expenditures
      related to pollution control, reduces the firm's overall tax liability,
      and affects positively its profitability.  Tax concessions may be
      granted either in the form of lower corporate tax-rate or as a credit
      against tax liability of a certain percentage or of the entire capital
      investment associated with pollution control.   Lower profit tax-rates
      should be granted for a limited time period.  Usually it may not exceed
      the number of years required to recover the original cost of the capital
      investment.
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      Taxes employed under these two schemes may be direct (lower profit tax-
      rate) or indirect (i.e., tax credit against property taxes).  In either
      case, tax abatement affects fixed costs, variable costs or the profits
      of the enterprise and strengthens its competitiveness in domestic as
      well as in international markets.

      In addition, tax concessions are granted as economic incentives by all
      developing and many developed countries in order to attract foreign
      direct investment.  If this is the case then taxes should also be used
      for pollution control investment as well.

c.    Accelerated Depreciation.  By writing off capital investment for
      environmental purposes more rapidly than otherwise, the firm effectively
      reduces its current tax liability and can employ the resultant savings
      for other productive purposes.  This method is different from tax
      abatement because it influences the firm's fixed costs with long-term
      competitive implications.

      On the other hand, accelerated depreciation raises the firm's
      profitability - at least for the depreciation period - by allowing the
      firm to recover the capital investment costs faster.  For this reason,
      accelerated depreciation is one of the many economic incentives offered
      by developing nations to multinational corporations to increase the
      inflow of foreign investment in their economies.  It is also used as a
      fiscal instrument to stimulate investments and economic growth in
      periods of recession.

d.    Concessionary Loans.  This is another way of reducing capital costs
      associated with pollution control.  Loans may be provided to a firm
      either directly by public authorities or indirectly by international
      institutions, at rates of interest and amortisation terms more favorable
      than those available from financial institutions.  Alternatively,
      government credit guarantees may be extended to the firm allowing it to
      borrow from other financial institutions at more favorable rates.

      Both such methods lower the cost of capital to the firm and increase its
      profitability.  Concessionary loans have long-term rather than short-
      term competitive implications since they influence the firm's average
      fixed cost.  Because many developing and developed countries provide
      concessionary loans as incentives to attract foreign investment, they
      should also be provided for pollution control  purposes.

e.    Research and Development Expenditures.  Government-sponsored research
      and development activity associated with environmental  control may
      generate the necessary technical advances more rapidly and more
      effectively than research undertaken by individual enterprises.  Once
      innovations have been generated, they are diffused very quickly
      nationally and internationally.  That is, research and development
      benefit both domestic and foreign enterprises  in meeting environmental
      objectives with relatively low cost especially when they are tax-
      financed.
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As a departure from the PPP, tax-financed research and development has
been recognized as an exemption and appears to be non-controversial in
nature, since governments have implicitly concluded that its benefits
outweigh its costs.  Therefore, international  competitive distortions
may be minimal, because government-sponsored research and development
generates innovations which become available abroad and lead to the
development of industries producing pollution  control products for
exports (Walter, 1978).

Tariff and Non-Tariff Restrictions.  These instruments may be employed
in the case where an industry is highly trade-oriented and its
competitiveness is threatened by capital investment costs for
environmental purposes.  Then a case can be made for the government to
protect the industry in question through raising tariffs or other trade
barriers for a certain time period.

Although such restrictions are inconsistent with existing GATT rules,
exceptions should be made to facilitate the implementation of efficient
environmental policies by the industry and secure at the same time its
competitive position.  In this case the full cost of capital investment
is paid by the industry, but the restrictions  imposed may offset the
negative impact on its profitability and do not affect its pricing and
output decisions.  It is therefore necessary that a comparative study
should be conducted to assess the benefits and costs (to the industry
and to society at large) associated with trade restrictions imposed for
pollution control purposes.

Export Premiums.  Levying trade restrictions for environmental purposes,
we just discussed, concerned a whole industry.  On other hand, export
premiums should be granted to an export-oriented individual firm who
competitiveness may be jeopardized by the incremental cost of capital
investment for implementing specific environmental policies.

In this specific case, the governments may provide export premiums or
increase the ones already in existence to the affected firm in order to
subsidize, partially or wholly, its resultant cost increase from its
capital investment.  The size of the premium must be equal to or a
certain percentage of the incremental cost so as to minimize the
negative impact of the firm's international competitive position.

Concessionary  Leasing.  This is another method of reducing capital costs
related to pollution control investment.  The required equipment may be
purchased by public authorities and then leased to individual firms on
more favorable terms than they would obtain if the firm had to acquire
them itself.   This is an implicit subsidisation which reduces the  firm's
capital investment costs due to cheaper credit available to government
agencies.  Leasing of capital equipment is growing rapidly in importance
and may grow in significance in the future, as well.
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CONCLUSIONS

      At present, developing countries are confronted with two important
issues.  Deterioration of their environment and natural resource base and
achieving sustainable economic growth.  The two are totally interdependent and
policies to promote both are urgently needed.  These policies should be
designed in such a way as to provide better linkage between economy and
environment and between government and industry in reaching the goals of
sustainable development.

      The above problems faced by developing countries can be solved through
maximum utilization of existing clean technologies which increase both
economic efficiency and environmental quality.  But these technologies are
usually developed in industrialized countries and affordable instruments and
measures should be provided to enterprises or industries in developing
countries in order to be able to transfer and apply these technologies.

      In spite of the difficulties encountered in estimating appropriate fee
levels and administering the system, direct controls and taxes, implemented in
conjunction with other policy instruments including legal requirements, can be
effective in promoting the use of clean technologies, if technology options
are available.  It seems, however, that in most developing countries not only
are there no technology options, but the existing clean technologies have not
yet been introduced in these countries.  What is needed, therefore, is a
system of such instruments which will assist individual firms or industries in
developing countries in transferring these technologies from abroad.

      It is suggested that the various subsidies we have discussed in this
paper are relevant and appropriate instruments to fulfill this objective.
Besides, most of these subsidies - including tax concessions, accelerated
depreciation, concessionary loans, and trade restrictions - are part of the
package offered to TNCs by the governments of developing countries in order to
attract foreign direct investment, which is the most important form of
technology transfer.  The same instruments must become available to individual
enterprises or industries in order to assist them in the process of
transferring and adopting these technologies.  Despite their drawbacks,
subsidies must be employed in environmental policy for reasons of social
policy or regional development.

      Among the various types of subsidies, capital grants for pollution
control investment must be provided in cases where enterprises cannot
otherwise make the necessary investment themselves without financial support.
Investment grants do not simply lower investment costs, but also reduce
production costs, and for that reason they should be granted to overcome
temporary uncertainties and disadvantages of integrating clean technologies
within enterprises.   In general, grants may have a stimulating effect on the
development and application of clean technologies, if the conditions in which
they are to be applied are known and taken into account (ECE Seminar, 1989).

      Research and development funds stimulate innovations and diffusion of
clean technologies and should be directed towards long-term,  internationally
coordinated programmes.  In this respect, many developing countries have
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expressed the need for improving the utilization of existing R&D centers by
allocating more funds into their research and development activities.  For
example, Thailand has provided tax incentives for small  and medium sized
enterprises for the acquisition of new technologies and  the establishment of
science-based Parks (Expert Group Meeting, 1989).

      Furthermore, many industrialized countries have set up two types of
financial aid mechanisms for pollution control:  direct aid for investment
expenditure and antipollution operation and aid for research and development
expenditure (OECD, 1985).  Direct aid is granted subject to conditions which
encourage the introduction of new and clean technologies.  This policy, for
instance, has been applied in Norway in the paper and pulp industry and in
Germany in the metal-plating industry.  In relation to the second category,
the government finances programmes for research and development on new
processes either by funding research institutes or by assisting given
industrial projects.  In France, for example, the Ministry of the Environment
provides financial aid to industries for research and development in non-
polluting, more efficient, and energy and raw-material-saving technologies.
The Netherlands set up a special aid programme for clean technologies in 1975.
In France and Germany, the government provides 50 percent or more of the
financing for research programmes on pollution control and energy
conservation.

      In conclusion, developing countries should reassess, upgrade, and make
more efficient the existing research and development facilities in order to
strengthen their capabilities for developing, acquiring  and absorbing new and
clean technologies and analyzing their impact on their industrialization
process.  To obtain access to information and know-how in new technologies,
international collaboration is required more than ever before.  To this end,
UNIDO's role and potential contribution becomes even more crucial and
significant.  It should intensify its efforts to establish information centers
for the production, availability, and export of clean technologies.  In
addition, it should initiate the development of programmes which would assist
developing countries in their efforts to develop new and clean technologies
(Biswas, 1989).  Such programmes would include assistance in promoting
research and development activities, training of human resources, and creation
of appropriate institutional infrastructure.  The implementation of these
programmes would strengthen the position of developing countries in
negotiating, acquiring, and transferring clean technologies from international
sources.
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                               REFERENCES
1.   Baumol  W,   and  Gates  W,  The  Theory   of   Environmental  Policy:
     Externalities.  Public  Outlays and  the  Quality of  Life,  Printice  -
     Hall, Inc., Englewood Cliff, New Jersey 1975.

2.   Biswas A,  "Environmental Aspects of  Hazardous Waste  Management for
     Developing  Countries:Problems and  Prospects",  in  Hazardous  Waste
     Management,  Edited  by  S.P.  Maltezou,  A.  Biswas  and  H.  Sutter,
     Tycooly Publishing, London, 1989.

3.   Mayer R., Microeconomic Decisions, Houghton Mlfflin  Company,  Boston,
     Mass., 1976.

4.   Economic Commission  for Europe,  Seminar  on Economic Implications of
     Low-waste Technology, Report of the Seminar, the  Hague,  Netherlands,
     October, 1989.

5.   OECD, Development Co-operation in the 1990s,  Paris,  1989.

6.   OECD, Environmental Policy and Technological Change,.  Paris,  1985.

7.   OECD, Polluting Charges; An assessment,  Paris,  1976.

8.   OECD,   The	Polluter    Pays    Principle;   Definition.    Analysis.
     Implementation,  Paris,  1975.

9.   Pearce, D.,  Markardya,  A.  and  E.  Barbier,  Blueprint for a  Green
     Economy, Earthscan Publications Ltd. London 1989.

10.  UNIDO, Regional and  Country Studies Branch, Expert  Group  Meeting for
     Industrialization  Policies  in Developing Countries,  Vienna,  April
     1989.

11.  Walter  I.,   International  Economics  of  Pollution,  John Wiley  and
     Sons, New York,  1978.
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           POLLUTION PREVENTION THROUGH WASTE REDUCTION IN FLORIDA

                     by:    Rick Wilkins, Director
                            Division of Waste Management

                            Janeth A. Campbell, Environmental Supervisor II
                            Waste Reduction Assistance Program

                            Department of Environmental Regulation (DER)
                            Tallahassee, Florida 32399-2400

                                        ABSTRACT
       The 1988 Florida Legislature initiated many new and innovative waste reduction programs,
which are designed to prevent pollution and to endorse the use of clean technologies and clean products.
The State mandated recycling programs for paper, aluminum, plastics and glass; and set a goal of at least
30% waste reduction by the end of 1994.  The State also created incentive programs to encourage the
recycling of used oil, waste tires, and hazardous waste. Florida invested over $48 million in grants to
local governments to initiate recycling and source reduction programs.  Florida created educational
programs designed to increase public awareness of the need for pollution prevention methods which
achieve environmental results, which would prevent future environmental degradation, while lowering
the cost of pollution control and pollution clean-up.

       The Waste Reduction Assistance Program (WRAP) was created to provide a new multi-media,
non-regulatory, technical assistance approach to preventing pollution. It incorporated the successful
elements of the North Carolina Pollution Prevention Pays Program1, the best components from other
state programs, as well as recommendations from the U.S. Congress Office of Technology  Assessment's
publication, Serious  Reduction of Hazardous Waste.2

       The WRAP staff have developed a computerized Waste Reduction Information Clearinghouse
to facilitate  information networking  between businesses  needing source reduction and recycling
information with vendors and possible providers of those services or equipment. Training curricula is
under  development at universities and community colleges to  train  business managers, engineers,
technicians, accountants, financial analysts, insurance analysts, and clean-up crews in the incentives and
opportunities for waste reduction.  On-site and telephone technical assistance is available from WRAP
staff, as well as the Retired Engineers Waste  Reduction Assessment Partners (REWRAP). Technology
transfer, promoting clean technologies and products, is achieved through industry specific fact sheets,
handbooks, computer linkage, and presentations to trade  and industry associations.  Research and
demonstration needs are being identified.

       Incentives for pollution prevention are a primary focus of the DER WRAP. As a non-regulatory
assistance program, we identify incentives to motivate businesses to follow. Of prime importance to the
Chief Executive Officer (CEO), is the incentive to avoid becoming a JCO (Jailable Corporate Officer).
Employees may mix a hazardous waste with a non-hazardous waste, such as used oil, and subsequently
dispose of it improperly. A CEO can be held liable for illegal waste disposal, and perhaps lose  his or
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her freedom as a JCO, for the actions of a company clean-up crew. This potential risk is a major
incentive for the CEO to strenuously pursue waste reduction investments while providing leadership
to motivate employees.

       By recognizing the successes and waste reduction achievements of businesses that practice the
new environmental ethic of pollution prevention, we provide positive reinforcements for excellent
corporate behavior in Florida. Through Awards for Excellence, we plan to recognize good corporate
citizens so others in industry can be motivated to focus on the many  opportunities  to  meet the
environmental challenge of the 1990's — pollution prevention through waste reduction.


                    PREFERRED STRATEGY OF POLLUTION PREVENTION


       There are basically 3 ways to deal with the problem of pollution.

               1.      avoid it     =  prevention of pollution
               2.      control it   =  strong regulations and enforcement
               3.      fix it later   =  clean-up of polluted sites.

       EPA Administrator William  K. Reilly has  been quoted in a  number of public forums as
supporting strong enforcement of increasingly stringent  sets of environmental regulations, as well as
preventing the production of pollutants that need to be rigorously regulated.  "We need to supplement
our efforts with a new strategy—one that couples conventional controls and vigorous enforcement of our
current laws, with pollution prevention so we can cut  down on the actual amount of toxics being
generated as by-products. This is one of my primary goals at EPA."3

       Secretary Dale Twachtmann, head of the Florida Department of Environmental Regulation, has
demonstrated his support of this strategy by creating what the Wall Street Journal has called "the most
ambitious assault on solid waste yet attempted in any state."4 He has endorsed waste recycling and
waste reduction of all types by creating and funding innovative technical assistance and recycling grant
awards.  Water use reduction and water reuse programs  have also been implemented. He encourages
staff to "rethink old ideas and try to  prevent new environmental problems from occurring. We can
become part of the solution, rather than part of the problem by recycling our waste, reusing our water,
and restoring damaged ecostructure."  "The best strategy for protecting our environment is to prevent
damage.  By increasing emphasis on prevention, more air, water and land resources can be saved from
degradation; and the environmental, economic, and political costs of regulation, restoration, and
mitigation can be avoided."  (PER Mission and Philosophy).5

       Preventing waste often has a payback of investment of less than 6 months.  Waste reduction of
air toxics and RCRA regulated hazardous wastes of 50 to 90% have been achieved in several companies
with top level management commitment to pollution prevention. In-plant recycling and reuse of water
has lead  to significant reductions in wasted water for rinsing and cooling operations. By reducing the
volume of discharge  to wastewater treatment plants, waste reduction can in effect "add capacity."

       If business dollars and human  resources are invested in a comprehensive multi-media air, water,
land approach to reduction of water wastes, air toxics, solid wastes, RCRA regulated hazardous wastes,
non-regulated potentially hazardous wastes, and energy wastes-then less taxpayer dollars are necessary
over time for the cleanup of contaminated sites.  As more wastes are reduced, the allocation of the
essential  state regulatory resources can be focused on the  "bad guys" that have no interest in protecting
our environment. When pollution is prevented there will be an extension of the life of very hard to site
waste treatment and  disposal facilities.
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       Our 20 years of end-of-pipe regulation of pollutants has created an enormous economic burden
which still does not achieve  the  environmental results intended by our various pollution control
regulations. Industry and government spend at least $70 billion per year on regulatory compliance and
enforcement, with each new page of regulations costing an estimated $1,000,000 per page to implement.
We must continue to have strong regulations and enforcement, but we should go back upstream to the
"beginning-of-the pipe" and reexamine what pollutants we are using at the source of operation. We need
to rethink our inputs and outputs of manufacturing processes or repair operations.  We need to reduce
waste at the source by modifying processes, using less toxic input materials, improving our operating
practices, and managing our inventory so that we don't have to discard unused toxic materials.  We
should aim to recycle anything and everything possible by segregating waste streams to allow recycling,
while making it easy for individuals to make the personal decision to reuse it and recycle it.

       Concerning efficiency of allocation of limited public tax dollars as well as business investment
dollars, there is no doubt  that preventing a problem is preferable in the short term and long term.

       In terms of effectiveness of these three approaches, pollution prevention is of strategic advantage
also. The issue of "How clean is clean?" pervades clean-up actions as well as regulatory enforcement
issues. Once a pollutant is released into the environment, it is typically dispersed, at some rate, so total
capture of all of it is practically impossible and/or extremely expensive.  If you prevent the pollution,
it doesn't have to be  regulated or cleaned up later,  because the problem is simply, effectively and
efficiently avoided from causing any environmental degradation.

       We as individuals are responsible for generating the mountains of garbage, millions of gallons
of wasted water, tons of hazardous wastes, hundreds of pounds of air toxics and other air emissions.
We use the products of commerce and discard a huge waste stream every year.  Business, industry,
government, educational institutions, and we the public are part of the waste management problem and
we all need to become part of the solution to pollution. We can do this by emphasizing the prevention
of pollution through waste reduction.

       We support the preferred waste management hierarchy of:

       First -         Reduce it at the source of generation
       Second -       Reuse it as long as possible
       Third  -        Recycle everything you can
       Fourth -       Treatment  to detoxify or recover energy
       Fifth  -        Disposal as the last resort.

       Through pollution prevention strategies, we can increase the efficiency of actions of our human
resources in preventing the degradation of our environment.  We can enhance the effectiveness of our
environmental protection efforts.  We will enhance the economic savings  of  taxpayer dollars  and
business investments.  We will achieve the environmental results we are all working toward. An ounce
of pollution prevention is truly worth a pound of clean-up "cure".

                THE MAGNITUDE OF THE POLLUTION PROBLEM IN FLORIDA
        Florida has 13 million residents and over 26 million visitors each year.  An estimated 900 new
residents move to Florida each day. Over the course of the year, this is equivalent to adding a city the
size of Tampa each year.  Almost 16 million tons of municipal solid waste were generated in Florida in
1988, and less than 4% of that waste was recycled.  The highest points in Florida are mountains of
garbage, sometimes referred to locally as "Mount Trashmore."
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       Paper is the majority of the solid waste created, estimated at around 40%. Food composes 10%,
wood wastes are 6% and yard wastes are around 15% of the waste amounts. Metals are 6%, glass is
around 5%, and plastics compose about 9% of the waste. All of these wastes have a huge potential for
recycling.6

       Other special wastes that need special handling, but until recently may have been disposed in
solid waste landfills each year around Florida include:

       .  Millions of tons of construction and demolition debris
       .  200 to 400,000 tons of biohazardous wastes
       .  120,000 tons of household hazardous wastes
       .  150,000 tons of small quantity generator hazardous wastes
       .  4 million used lead-acid batteries
       .  Unknown amounts of small batteries containing Mercury, Lead, Cadmium,
              Nickel and Lithium
       .  600,000 tons of ash from the waste-to-energy plants that combust 21% of the waste stream
       .  15 million  used tires (2% of all solid waste)
       .  7 million gallons of used oil from Do-it-Yourself auto mechanics
       .  3 million appliances (white goods)
       .  10 to 14 million pieces of discarded furniture.

       Most of the old solid waste landfills in Florida are unlined. Many are located in sandy soil in
in area with a high water table. The Department's Solid Waste Section has created rigorous new landfill
liner and leachate control system requirements that have increased the cost of new permitted landfill
space to $175,000 per acre or higher. However, at least 41 old leaking landfills are targeted for clean-up.
More than 1,000 sites in Florida have been identified for an analysis of contamination.

       As many as 80,000 small businesses may be conditionally exempt or small quantity generators
of regulated hazardous wastes and potentially hazardous wastes (used oil and lead-acid batteries).  An
estimated 550,000 tons of oils, solvents, heavy metals, paints and batteries are created by these businesses
each year. Large quantity generators of hazardous wastes create around 500,000 tons per year. Around
24 million gallons of used oils and lubricants are created by businessmen each year, with  at least 70%
of that oil being burned as a fuel substitute for virgin oil.

         According to the Toxics Release Inventory data7 required by SARA Title III, at least 53.2 million
pounds of fugitive and stack emission air toxics are released in Florida by the businesses required to
report this data.  Vapor degreasers are used in many businesses and industries for parts cleaning prior
to electroplating or painting, printed circuit board manufacture, parts repair, and other operations. Our
observations from on-site technical assistance indicate that many of these large heated vats of hazardous
solvents are left open continuously and  are wasting 30 to 50% of the solvents to the air. Many of these
are in ozone non-attainment areas for air quality in the lower east coast metropolitan area as well as
other large cities with air quality non-attainment areas.

       The  condenser coils on these vapor degreasers are often not operating correctly so millions of
gallons of fresh water are dumped needlessly into wastewater treatment facilities.  This  inefficiently
wastes fresh water and  capacity from much needed Publicly Owned Treatment Works (POTWs).
Reusing this fresh water from the condenser coils for makeup water in electroplating rinsing baths prior
to discharge could "add capacity" to POTWs and reduce overall water use.  Reuse of reclaimed water
for industrial operations can help reduce the use of potable fresh water needed for drinking water
supplies.  Water reuse at over 200 projects in Florida now saves 320 million gallons per day.8 In an era
of growth management controls and concurrency requirements in Florida for economic development and
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infrastructure needs, the multi-media approach to reducing wastes of all types could help provide waste
management, fresh water supply, and wastewater treatment capacity efficiency gains to respond to the
needs of new growth caused by Florida's 900 new residents each day.

                        THE 1988 SOLID WASTE MANAGEMENT ACT
       The 188 pages of legislation contained in this Act' are very comprehensive and far reaching in
scope.  This aggressive attack at preventing more of Florida's huge mountains of garbage and rapidly
filling landfills has made a difference in its two years of enactment. Over $48 million in recycling grants
have been provided to all 67 counties in Florida, as well as many cities.  The first year of funding
included $18.5 million in Oil Overcharge Funds, provided by the Governor's Energy Office.  The
remainder came from new fees on tires ($l/tire), newspaper ($.10/ton), sales tax registration fees and
changes in the sales tax collection allowance procedure.

       The primary goal of this ambitious assault on solid waste is to achieve an overall recycling rate
of 30% by the end of 1994. Almost 75% of Florida's 16 million tons of solid waste was disposed in 170
permitted landfills. Many of these landfills will be closed over the next 3 years since they do not meet
new stringent landfill liner requirements.  Florida's nine waste-to-energy facilities combusted 21% of the
total waste stream in 1988, and only 4% was recycled.

       A "three thirds" strategy is endorsed to increase recycling to a third, add waste-to-energy
capacity  to manage a third (and provide needed new electrical capacity to substitute for coal fired
plants), and reduce the amount landfilled from 75% down to a third or less.

       Recycling grants have been awarded to all 67 counties and many cities initiating solid waste
recycling programs.  First year funding included $4 million for educational programs, $1 million for
waste tire recycling and management, $1  million for used oil recycling, and $750,000 to reward 40 local
governments who had recycling programs in place before it was required by law.  "Truth-in-garbage"
now requires  full cost accounting to reflect all costs of waste management.  Recycling  education
guidelines and programs are required.

       While  providing  the funding for these innovative recycling and  education programs, the
Department also prohibited landfill disposal of used oil, lead-acid batteries, white goods, used tires, and
construction and demolition debris at a variety of deadlines before 1995.

       Recycling incentives were established to encourage the use of clean products and technologies.
The Florida Department of Commerce  is charged with  assisting  recycling business  startups and
expansion.  A sales tax exemption is available for the purchase of recycling equipment and machinery,
if it consumes not less than 10 percent of Florida-source recyclable materials.  The Act also established
roles for various state agencies to encourage recycling and  use recycled goods in their operations.  A
10% bid preference is to be provided for the purchase of recycled paper and other products by state or
local governments. A 5% bid preference for the use of used oil is also provided to stimulate the market
development for purchase of products made from recycled  goods.

       There are many other Act  requirements of far reaching consequences for the treatment and
disposal of wastes in Florida. However, our purpose is to focus on pollution prevention through waste
reduction; which includes source reduction, reuse, and recycling.  Further  details of the excellent
progress on the requirements of the comprehensive Solid Waste Management Act, the associated rules
and innovative programs, can be provided by the DER Solid Waste Environmental Administrator, Bill
Hinkley.
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                           SOLID WASTE RECYCLING ACTIVITIES
       As of March, 1990 at least 20 of 67 counties had implemented a Residential Curbside Pickup of
recyclables.  These counties contain 82% of Florida's population. Residential drop-off programs were
in 17 counties. The "minimum four" recyclables are defined as newspaper, aluminum cans, glass, and
plastic bottles. At least 50% of these  wastes must be recycled by the end of 1992, or a one cent per
container "advanced disposal fee" is imposed. If this goal is not achieved by 1995, the fee increases to
two cents per container. Only seven cities and 10 counties were recycling all of these by  the end of the
first year of the grant program.  Newspaper was collected for recycling by 46 cities and 26 counties.
Aluminum cans are recycled at a rate of almost 50%, with programs in 28 cities and 25 counties. Plastic
bottles are collected at only 6 cities and 11 counties. Yard trash is collected at least in five cities and five
counties. At least 42 counties have achieved a positive recycling rate. Participation rates  for the second
year will surely increase as recycling education expands in local and state government agencies.

       Recycling in apartments, condominiums, and commercial establishments has only just begun,
but is a source of huge potential for recycling in Florida.  State agencies are now initiating recycling
programs  for aluminum cans, newspaper, office paper and computer paper.  For two years DER
employees have collected these recyclables,  saving 142.75 tons of paper, which represents an estimated
2368 trees, as well as 3251 pounds of aluminum.

       Recycling markets are very important to  the long term success of any waste collection program.
DER conducted a survey of 242 potential dealers and processors of wastes to be recycled.  Industrial and
commercial sources accounted for 58% of the 1.6 million  tons of recyclable materials collected in 1986.
Private  individual non-profit groups collected 29% of this tonnage.   Municipal  programs only
contributed 3% in 1986, prior to the new initiation by the  1988 Solid Waste Management  Act. If we are
to make significant recycling progress, governments must become a steady market for recycled goods.
DER now uses copy machine paper and writing paper with recycled paper content. If we are to prevent
pollution,  we must individually and  collectively choose to reduce, reuse, and  recycle  anything and
everything we can.

          THE MULTI-MEDIA WASTE REDUCTION ASSISTANCE PROGRAM (WRAP)
       The Waste Reduction Assistance Program is a cooperative NON-REGULATORY, multi-media,
technical assistance approach to helping businesses, industry, local governments and educators
prevent pollution in Florida. We provide a set of "fresh eyes" to help a business person identify all types
of waste reduction opportunities  in their facility.  The value of creating a multi-media air, land, and
water approach is that pollution  is not just controlled, concentrated, and moved from one media to
another.  Examples of multi-media transfer of regulated concentrated pollutants include: heavy metals
in wastewater sludges moved from water to land disposal; or removing air pollutants from combustion
and disposing on land; or burning petroleum or solvent contaminated soil and exhausting air pollutants.
If you go back to the source of the pollution, you prevent the problems of the "end-of-pipe" regulations.
Since regulatory requirements are a moving target, becoming steadily more stringent we must aim to
optimize the use of business dollars to comply with environmental regulations, but reduce all wastes
to the extent possible, whether they are regulated today or not. The economic competitiveness of our
businesses and the economic survival of our democratic governments depends on efficiency gains and
effective use of diminishing financial resources.

       Waste reduction can save millions of dollars in pollution control expenditures and millions more
in subsequent pollution clean-up costs.  By not generating a particular hazardous waste, a business can
avoid the cradle-to-grave liability that results from the generation of hazardous waste.  Reducing waste
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prevents pollution, it increases efficiency of a business's operations, and results in lower raw material
and labor costs.  Waste reduction achieves positive environmental results.

       The Waste Reduction Assistance Program emphasizes efforts to reduce waste at the source,
followed by environmentally sound on-site and off-site recycling.  Assistance in reducing hazardous
wastes,  solid  wastes, air toxics, wasted fresh  water, waste water discharges, and energy  wastes is
provided.  For the remaining wastes, there will be a need for proper waste management. But even then,
there are opportunities for reducing the volume or toxicity of wastes, depending on the methods of
treatment chosen. As a last resort, the remaining hazardous wastes should be disposed of properly.

       The Waste Reduction Assistance Program consists of seven components:

1.      Information Clearinghouse
2.      Training Curriculum
3.      Technical Assistance
4.      Research and Demonstration
5.      Technology Transfer
6.      Incentives for Pollution Prevention
7.      Awards for Excellence
THE WASTE REDUCTION INFORMATION CLEARINGHOUSE

       The Waste Reduction Information Clearinghouse is a computerized information clearinghouse
which is designed to include:  contact  persons in local, state and federal government; trade  and
professional associations; schedules for technology transfer workshops and conferences; information on
waste reduction technologies; recyclers, equipment vendors and pollution prevention service companies.
The information clearinghouse also will provide case studies of successful waste reduction efforts of
Florida businesses as examples of the benefits of  waste reduction.  Free copies  of waste  reduction
publications are provided to educate all sectors of society.

TRAINING AND TECHNICAL ASSISTANCE

       The Waste Reduction Assistance Program is currently managing a U.S. Environmental Protection
Agency grant through the University of Florida's Training, Research, and Education for Environmental
Occupations Center.  The purpose of the  grant is to determine Florida's training needs in the areas of
waste reduction and  waste management  for the next 5 years.  Once this is completed, the Center will
develop the actual curricula for waste reduction and waste management courses for engineers  and
technicians. Business managers, accountants, financial and insurance analysts and clean-up crews are
future targets for training curricula.  The Used Oil Recycling Education and Incentives Contract with
Valencia Community College has produced curricula aimed at educating science teachers, kindergarten
and first grade students, middle and high  school students, and community college students on the value
of recycling used oil to prevent pollution of Florida's water supply.  A contract for general and industry
specific Pollution Prevention Education modules is under development.

       Presently, the Waste  Reduction  Assistance Program is conducting an aggressive technical
assistance and training program. Program staff have provided on-site technical assistance to at least 64
waste  generators and to thousands of businesses  over the telephone.  Waste reduction assessment
training has been provided to environmental inspectors in Dade and Broward counties. The county
employees who received this  training will provide waste reduction information and assistance to an
estimated 6,000 Dade and Broward businesses annually. Other county staff have also received training,
and future training opportunities will be  available.
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TECHNOLOGY TRANSFER AND INCENTIVES

       The Waste Reduction Assistance Program is also spreading the message of pollution prevention
through waste reduction at meetings of industrial and professional groups, such as the Florida Chamber
of Commerce Solid and Hazardous Waste Management Short Course and Trade Show.10 Following
these meetings, those who attend are able to bring home the message through a series of industry and
waste specific fact sheets and handbooks that the WRAP distributes free of charge.

       Environmental Education to all  segments of Florida's population is a goal of the WRAP. We
aim to publicize the incentives to motivate people to prevent pollution.  People create hazardous wastes
through their purchase, use and discard of hazardous substances.  By purchasing less toxic products,
or choosing not to purchase services that  create hazardous or solid wastes, individual consumers can
prevent pollution and protect our water supply.

       One of the incentives for a Chief Executive Official (CEO), such as a company who generates
hazardous wastes or used oil, is to avoid becoming a Jailed Corporate Official (JCO).  In Florida, a large
network of different types of law enforcement officers are intensifying enforcement of environmental
laws. If the person who takes out the garbage illegally disposes of a hazardous waste, the CEO can
become a JCO.  By publicizing the economic and good publicity incentives to business managers, we
plan to motivate CEOs and environmental managers to volunteer to receive on-site  assistance.  When
they make a personal commitment to waste reduction it will happen.

AWARDS PROGRAMS

       The WRAP wants to recognize  successes through the Awards for Excellence. In 1989,  DER's
Southeast District conducted an award program in conjunction with The Southeast Florida Industrial-
Environmental Association in  which Secretary Dale Twachtmann presented the Hazardous  Waste
Management Awards.  In 1990, the Secretary presented the Environmental Awards to five outstanding
projects.

TARGETS FOR WASTE REDUCTION

        More than 75% of the hazardous waste produced in Florida is from these types of small and
medium sized businesses, which are WRAP'S primary technical assistance targets.

*      Automobile repair and transportation services,
*      Construction and building repair,
*      Medical and other laboratory  services,
*      Printing and communications activities,
*      Metals manufacturing and finishing,
*      Dry cleaning and cleaning services, and
*      Boat building and repair.


USED OIL RECYCLING  ACTIONS

       Florida's Solid Waste Management Act created many new initiatives for used oil collection,
management, transportation and recycling.  The Waste Reduction Assistance Program staff promote
increased recycling through grants to  local governments and recycling education actions.
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Used Oil Collection Center Grants

       The Legislature provided $1 million in grants to local governments to establish public used oil
collection centers. By June 30,1989, fifty-four counties, six cities, and the Miccosukee Indian Tribe were
awarded between $4,000 and $25,000 in grant funds to  provide over 200 public used oil collection
centers, and public awareness programs to encourage recycling of used oil.  Private petroleum retail
operations have volunteered to accept used oil from the public at over 370 Florida locations. The law
requires a prohibition on land and water disposal of used oil, as well as establishment of a 5% price
preference for purchase of recycled used oil by state and local governments.

Used Oil Recycling Education

       A $1.5 million contract with Valencia Community College will deliver:

  *     A report on Used Oil Recycling Data.
  *     Educational materials for Petroleum Product Retailers of Used Oil.
  *     A Local Government Used Oil Recycling Program Guidebook.
  *     A Retail Outlet Used Oil Collection and Recycling Center Booklet.
  *     Used Oil Recycling  Awareness and Incentives Promotional Materials.
  *     A Used Oil Recycling Education Teacher Training Curriculum Package.
  *     Used Oil Procurement Guidance for State and Local Governments.

POLLUTION PREVENTION PARTNERS

       The Waste Reduction Assistance Program has  implemented an activity called the Retired
Engineers Waste Reduction  Assessment Partners (REWRAP).  These Pollution Prevention Partners have
provided waste reduction technical assistance for many Florida businesses.   The part-time retired
engineers and two more than full-time waste reduction engineers have initiated help to over 64 Florida
businesses.  They have already assisted businesses such as electroplaters,  painting operations, boat
builders, automotive repair, jet turbine repair, printed circuit board manufacturers, and local government
facilities  reduce their generation of wastes. The types of wastes identified as candidates for reduction
include hazardous wastes, solid wastes, used oil, air toxics, wasted water, and energy wastes. This free
non-regulatory help is available by calling any WRAP staff member.

CONCLUSION

       Significant waste reduction can be achieved by rethinking industrial process designs and
retraining governmental and business waste managers to focus on pollution prevention opportunities.
Many of these opportunities are low or no-cost alternatives to increasingly expensive pollution control
methods. When pollution  is prevented, long term liability exposure is reduced, worker exposure to
toxins are reduced, taxpayer expenses for clean-up are avoided, and Florida's environment is protected.

       The Florida Waste Reduction Assistance Program was created to provide  non-regulatory
information transfer and technical assistance to help people make a choice concerning waste reduction
opportunities. The future choices are ours. We can prevent the problem of pollution. If we prevent
it, there is  less control and  treat to detoxify.  The probability of future clean-up costs  is dramatically
reduced with waste reduction. You and I can make a difference in saving our planet.  Use it again!
Reduce — Reuse - Recycle!
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                                      REFERENCES

1.      Schecter, Roger and Hunt, Gary.  Pollution Prevention Pays Program.
       North Carolina Department of Natural Resources and Community Development, 1987.

2.      Hirschhorn, Joel S. and Oldenburg, Kirsten. Serious Reduction of Hazardous Waste.
       OTA-ITE-318. U.S. Congress, Office of Technology Assessment, Washington, D.C., 1986.254 pp.

3.      The Hazardous & Solid Waste Minimization & Recycling Report.  Government Institutes, Inc.,
       Rockville, MD. May, 1989. p. 1.

4.      Carlson, Eugene. Florida Readies Broad Assault on Garbage. Wall Street Journal. July 20,1988.

5.      Twachtmann, Dale. Department Mission and Philosophy. Florida Department of Environmental
       Regulation. November, 1989.

6.      Hinkley, Bill. Implementing the 1988 Florida Solid Waste Management Act: A Progress Report.
       Florida Department of Environmental Regulation. December, 1989.  19 pp.

7.      Toxics Release Inventory. U.S. Environmental Protection Agency, 1989.

8.      York, David.  Water Reuse in  Florida -  Use It Again,  Florida.  Florida  Department of
       Environmental Regulation.  1990.

9.      Solid Waste Management Act, Chapter 88-130, Laws of Florida. 1988.

10.     Campbell, Janeth A. and Bilkovich, Bill.  Pollution Prevention through Waste Reduction.  Solid
       and  Hazardous Waste Management  Short Course and Trade Show.  Florida Chamber of
       Commerce, November 15-17,1989.
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                A RIDE THROUGH SPACE - WITH CARE AND CONCERN

                      by:  William J. Carroll
                           Chairman of the Board
                           James M. Montgomery, Consulting Engineers,Inc.
                           Pasadena, California  91109-7009
     Most  of us  forget,  as  we  sit  in this  room that we  are traveling
through  space  at a  speed  of  approximately  67,000 mph.   This  is  just
the  speed  of our orbital  velocity around the sun.   We  are also spinning
on  our own  axis,  and then  in  addition we  have our own  galactic motion
as  our  universe  expands.   When  you realize  that we  have  billions  of
stars  like our  sun  in our galaxy  and then  there are probably  billons
of  galaxies, you reach  the conclusion  that  planet earth  is a  pretty
small  spaceship gliding  through the  dimensions of  both  space and  time
and we are merely passengers.

      We,  of course,  do  not know whether  we are  unique or  not,  which
is  something we  are  continuously striving  to  find  out.  However,  the
things we  do know are that we  exist,  that  this is our planet and solar
system,  and  that if  we  want to continue on  this grand  ride thru space
and time, we have to make sure that our spaceship is kept in good shape.

      This is probably not the  best of examples, but I bring space  into
it, because  of  the importance that  space,  and  especially the space  that
is  within  the gravitational  field of  our  earth,  is to  us.   It  is  part
of the earth system.

      My major  area  of discussion,  today,   is  the Engineers  concern  for
the  environment,  and  the  responsibility that  Engineers have  to  society
to  ensure  that  our planet  earth,  our spaceship, remains  in such  a shape
that  not only  we,  but  future  generations  can enjoy  the  ride.   Unless
we  somehow blow it up, our planet is going to  continue  spinning  through
space  for  several billions of  years.   What mankind will look like  and
act  like at  that time is  difficult  to  predict,  but  what is important
to  us here  today is  that  we exercise  the care  and concern  needed  now
that  will  protect  our planet   so that mankind can continue to  evolve
and revolve.

      "Care   and  concern"  are    beautiful   words.    They   connotate
responsibility.    They  imply  a  compassionate nature.   I  hope  they  imply
that  the  Engineering  profession  recognizes  a  primary   responsibility
to the welfare,  health and safety of the community.
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      As  we approach  the  21st  century,  we  are  increasingly  aware  of
the tremendous complexity of the interaction among development, technology
and   social   forces.    There   have   been  tremendous   achievements  and
advancements  in  our  development of  technology; yet  the application  of
this  technology  requires  us  to also  recognize  the  destructive  nature
of  some  of  this  technology,  if  not applied  with  care and  concern  for
the downstream consequences.

      I am  a believer in  development.   I see most  of  the infrastructure
on  this  planet  as a  positive  force  in  our  everyday  lives.   I  am  not
a believer that man should exist  on  this  planet and leave no foot prints.
However,  care and  concern  should  be  exercised  so that  they are good
foot  prints.  Proper  development,  or possibly sustainable  development
are better  words,  requires that  we  Engineers adhere to an  Environmental
Code   of    Practice   that   sets    forth   guidelines   that   promotes
"sustainability".   Codes   of  practice,   are  at  best,   fraught  with
difficulty.  There  are both national and  regional  differences in methods
of  the  practice  of   engineering,  and particularly business  practices.
But from moral and ethical points of view, when environment is the basic
subject,  there  should be  and  can- be  only  one approach.   This  approach
has to be  based  on personal values that  govern decision making and these
personal values have to be universally shared.

      An  approach  to  such  a code  has  been  undertaken  by the  World
Federation  of  Engineering  Organizations   (WFEO).   This  is  a  global-wide
umbrella  organization  for  the leading engineering organization  in each
of  85 countries.  It  represents millions  of  engineers around  the globe
and  one  of  its  basic  objectives  is  to encourage  the application  of
technical progress for the economic  and social advancement of the peoples
of the world.

      One of its committees,  the Committee on Engineering and Environment
developed a  Code of Environmental Ethics  for  Engineers during 1983-1985.
It was mainly the  brain child  of Engineers  from Argentina and Venezuela,
but it  was  reviewed by  members of the committee  from  about 20 countries
and then inturn adopted by the  entire WFEO in  1985.

      It  states  that  man's enjoyment  and permanence on this  planet will
depend  on the care and  protection  he provides to the environment,  and
lists  seven major  principles  which  all  Engineers  should  follow.   These
are:

      "When  you develop any professional activity:

  1.  Try   with  the   best  of  your  ability,  courage,  enthusiasm  and
      dedication to obtain a  superior technical  achievement,  which will
      contribute  to  and  promote  a  healthy  and   agreeable  surrounding
      for all men, in  open  spaces as well  as indoors.
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  2.  Strive  to  accomplish  the  beneficial objectives  of your  work  with
      the  lowest  possible  consumption of  raw materials  and energy  and
      the lowest production of wastes and any kind of pollution.

  3.  Discuss  in  particular  the  consequences  of  your  proposals  and
      actions,  direct  or   indirect,  immediate  or  long  term,  upon  the
      health of people, social equity and the local system of values.

  4.  Study  thoroughly  the environment  that  will  be affected,  assess
      all  the  impacts  that  might  arise  in  the  state,  dynamics  and
      aesthetics  of  the  ecosystems involved,  urbanized  or natural,  as
      well  as in  the  pertinent  socio-economic  systems,  and select  the
      best  alternative  for  an  environmentally  sound  and  sustainable
      development.

  5.  Promote  a  clear  understanding  cf the  actions required to  restore
      and, if possible, to  improve the  environment that may be disturbed,
      and include them in your proposals.

  6.  Reject  any  kind  of  commitment   that  involves  unfair damages  for
      human  surroundings and  nature,  and  negotiate  the best  possible
      social and political solution.

  7.  Be  aware that   the   principles   of   eeosytemic   interdependence,
      diversity maintenance, resource recovery and interrelational harmony
      form  the  bases of our continued existence  and that each  of  those
      bases  poses  a  threshold   of  sustainability  that  should  not  be
      exceeded.

      Always remember that  war, greed,  misery  and ignorance,  plus natural
disasters  and  human  induced  pollution  and  destruction of  resources,
are  the main  causes of  the  progressive  impairment  of  the  environment
and that  you,  as  an  active member of  the engineering  profession,  deeply
involved in the promotion of development, must  use your talent,  knowledge
and imagination to  assist  society in  removing those evils  and  improving
the quality of life for all people."

      These  are  grand  principles.   You  may word them differently,  but
they can be practiced universally.

      And, of  course,  this  is  not the  only  "Code of Ethics"  that exists.
As  an   example,  the  Institution  of Engineers,  Australia, has  developed
an  "Environmental  Code  of  Practice" which  embodies many of these  same
principles.   New  Zealand  has  done  the  same.   And  in discussions  with
the  Engineering  Directorate  of   UNESCO,  they are working diligently  to
develop an  Environmental Code  to  which they hope  the  Universities  around
the globe  would  require their engineering graduates  to subscribe.   They,
UNESCO, would  like  to develop  an Oath  of Practice similar to the medical
profession, for environmental engineers.
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      In  concluding  my  remarks,  today,  I  would like  to quote  from the
Introduction to  a pamphlet entitled  "A Study of Global  Change"  prepared
by the International Council of Scientific Unions.

      "Mankind today  is  in  an unprecedented position.   In  the  span  of
a  single human  generation,  the  Earth's  life-sustaining environment  is
expected  to  change more  rapidly  than  it  has over  any comparable period
of  human history.   Much of  this  change  will  be  of  our  own  making.
Worldwide  economic  and  technological  activities  are  contributing  to
rapid  and potentially  stressful  changes  in our  global environment  in
ways that we  are only now beginning  to understand.   The effects of these
changes may profoundly impact generations to come."

      How  effectively   the   engineering   profession,   along  with  the
scientific community and the public at large, respond to the environmental
care and  concern challenge, will govern the quality of  our  ride through
space.
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 ORGANIZATIONAL BEHAVIOR AS  A KEY ELEMENT  IN WASTE MANAGEMENT DECISION MAKING1

               by:   Peter Cebon

                     Sloan School of Management and
                     Center for Technology Policy and Industrial Development
                     Massachusetts Institute of Technology
                     Cambridge Ma 02139

ABSTRACT

      Given that pollution prevention often benefits both the firm and the
public, we might expect rapid and complete implementation of waste reducing
technologies and work place practices.  However, implementation levels are
lower than is economically rational.  Energy management,  like pollution
prevention, is a process waste management problem with both technological and
behavioral elements which organizations generally accord relatively low
priority.  To explore why the same apparent irrationality occurs there,  I
conducted interviews and used archival records to compare four universities'
energy management and organizational histories.

      The options the universities pursued differed surprisingly in their
form, extent, and timing.  While the schools'  size and relative emphasis on
science accounted for some of the variation,  two key variables, the ability of
specialist managers to acquire and analyze information and the distribution of
power and incentives, appear to constrain institutions' capacities to identify
and implement solutions.  With objectives accorded low priority, these seem to
be very sensitive to variations in organizational structure.  For example, the
most decentralized university very successfully implemented behavioral
solutions, which require high incentives and low technical information
processing capacity, but had less success with complex technical ones.

      Ongoing work and discussions with regulators and litigants of polluters
indicate that this model applies well for pollution control.

      The results suggest that effective pollution prevention policy modifies
either technology or organizations.  In particular,  three classes of policy
are envisioned.  One encourages development of more adoptable technology, the
second aims to eliminate constraints within organizations, and the third seeks
to change the priority organizations accord the problem.
    I am indebted to Bob Thomas  and Kathy Porter  for  their  assistance with the
    argument and structuring of  the discussion respectively.   Andy King,
    Yiorgos Mylonadis,  and Chris Schabacker provided  valuable  comments.   This
    research was sponsored by the MIT Physical Plant  Department.
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                                 INTRODUCTION
      The Bush administration's commitment to market-based pollution policy
assumes that abatement is inhibited principally by the lack of a clear market
signal.  Economic signals will foster far greater implementation levels than
command and control regulations.  This assumes that firms' internal dynamics
are a relatively minor obstacle to pollution prevention.  In this paper, I
will argue that, on the contrary, in many firms, especially those which accord
pollution control a relatively low priority, internal obstacles overwhelm
decision-making, to favor end-of-pipe solutions.  Consequently, correct
external incentives are a necessary, but grossly insufficient condition for
effective policy.

      Many waste reduction projects benefit both the firm and the public.  The
firm can increase its efficiency of operation and save money without increases
in management complexity (1).  The public is exposed to a smaller, less
hazardous, waste stream.  Therefore, a smoothly operating market would provide
rapid implementation of waste reducing technologies and work place practices
which are currently profitable.  However, levels of implementation are much
lower than is economically rational (1).

      Institutional energy conservation provides an excellent laboratory to
explore the market's ability to produce waste reduction behavior.  Energy
conservation is a form of waste reduction, but, has several advantages over
pollution prevention as an object of study.  First, the consumer faces a clear
price signal.  The market is much closer to perfect than we could ever expect
in pollution control.  Thus, we get a good opportunity to see the market in
action.  There is significant evidence that implementation levels of energy
conservation technologies are much lower than is economically rational (e.g.
(2),(3)).  Second, energy conservation is a problem of relatively long
duration.  The first "energy crisis" was in 1973, followed by a second price
shock in 1979.  By the time the study presented here was carried out (1987-
'88), people had been pursuing conservation for fourteen years.  Therefore, we
can eliminate startup effects.  Third, many options are relatively standard.
This facilitates inter-organizational comparisons.

      Given that rational choice models do not appear to explain institutional
behavior, alternative explanations of decision making are needed.  In this
paper, I will draw from organizational theory to present and discuss data from
an exploratory study into institutional obstacles to energy management in four
universities.  I made no prior hypotheses as to why universities might be poor
decision makers,  other than that it may be related to organizational factors.
This very open-ended approach was selected because, at the time,  virtually no
obviously relevant literature was available.

      The findings which emerged can be understood on two levels.  At the
first, two variables appear to be critical to understanding organizational
decision making.   They are 1) the information gathering and analysis capacity
of the people charged with formal responsibility for energy conservation,  vis
a vis the information gathering and analysis requirements implicit in a given
solution,  and 2)  the power these people have,  through coercion or incentives,
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over the people whose cooperation or support is necessary for successful
implementation of a given technology, versus the amount needed for that
technology.  At the second level, the structure of the organization and its
institutional environment very strongly prejudices managers' abilities to
command all the information and power needed for a given solution.  When
energy conservation or pollution prevention is accorded a relatively low
priority, specialist managers are, in general, relatively peripheral.  The
solutions they develop map onto the rest of the organization's technology as
the specialist managers map onto the rest of the organization.  That is, they
favor the solutions which are least constrained by power and information.
These are generally add-ons to the organizations' core technology, for
pollution control, this often means end of pipe technologies.
                                    METHOD
      The research was guided by a recognition that organizations have a
multitude of options available for the management of energy.  The key question
was whether the nature of the organization told us anything about the choices
that were made once people chose to act.  That is, in what way does the nature
of the organization delimit the smorgasbord of economically feasible options
to the small subset from which the organization actually selects?

      Data was collected primarily through seventy-five interviews of 60 to 90
minutes duration and from archival records at four sites;  the two universities
discussed here, a major state school, and a medium sized private one.  Key
interviews were transcribed.  I aimed to obtain histories of the organization,
energy management, and relevant events outside the university.  I also sought
to understand current practices, including equipment maintenance and
replacement procedures,  the way energy conservation was incorporated into new
buildings, and the way energy managers interacted with both users and various
people responsible for physical facilities.2  Where these  practices had
changed over time, I also examined their evolution.  I solicited information
and opinions from all management levels from first level supervisors through
to, generally, the vice presidential level, or equivalent.  Where possible, I
interviewed users.  I also interviewed architects, shared savings contractors,
HVAC engineers, and union officials, in person or by telephone.

      For brevity I will focus on two representative examples of energy
management decisions - computer controllers and light bulbs - from two sites.
Although many more decisions were studied,* these two are  particularly
appropriate for several reasons.  First, these technologies are considered the
    By energy manager,  I  mean members  of  the organization who make  energy
    conservation decisions  as economic agents.
    Once  it was  developed,  I  tested  the model's validity by presenting  it to
    activists and government  agencies  who study pollution behavior  to help,
    regulate, or sue  organizations.  No one disagreed with the model.
    These include motor and fan retrofits, computer control operations,
    building envelope retrofits,  rationing, fume hood controllers,  and
    preventative maintenance.   The data is presented in full in  (5).
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linchpin of effective conservation.  That is, they are particularly cost
effective.  Second, they are polar opposite approaches: compact fluorescent
bulbs are very cheap, simple, and present in the work-place; computer
controllers have historically been very expensive, complex, and hidden in the
university's infrastructure.  Third, neither impedes, to any significant
extent, the quality of the academic environment.  (In fact, computer control
tends to make it more comfortable.)  Therefore,  implementation buffers the
organization's core from the, potentially disruptive, environment (4).
Fourth, both the light bulbs and the controllers are cheaper and easier to
manage, once installed, than their predecessors.  Hence, virtually always,
they are an unambiguously good idea.  Finally, these solutions are not
mutually exclusive.  Installing one does not affect the other's feasibility.

      In the following sections, I will compare and contrast decision making
in the two cases at the two sites and attempt to explain each university's
decisions.  After contending that the explanation can be generalized beyond
energy management in universities,  I will discuss some policy implications.
                         TWO SITES: TECH-U AND PROF-U
      The first site, Tech-U, has built its reputation through its strength in
the applied physical, biological and social sciences.  The other, Prof-U, also
a private university, is famous for its professional faculties.  They are
matched in every respect except student type and organizational structure.
They have virtually identical weather, investment criteria, and ready capital
availability.  Both have multiple, virtually independent, campuses.  I
examined only the main one, which was about the same size in each case.
Energy conservation was considered important by those responsible for it,
though only in one case did senior management make it a faculty priority.
Both universities have been reasonably successful energy conservers.   Tech-U
was a successful early implementer of direct digital control, and one faculty
at Prof-U halved energy use between 1980 and 1985.

      Their organizational structures differ.5  Tech-U is administratively
uniform with its different schools using centralized administrative resources.
Facilities services are provided by a centralized Physical Facilities
Department (P.F.D.).  As would be predicted by organizational theory (4)
energy management is the responsibility a specialist office separate from the
organization's core, the operations division of the P.F.D.

      Prof-U, on the other hand, is comprised of ten autonomous faculties.
Each manages its own endowment, tuition, and expenditures.  Each faculty's
facilities office purchases services from either the university's Buildings
Maintenance Department (B.M.D.) or outside vendors.  In the study, I examined
the major School for Arts and Sciences (S.A.S.) and a Small Professional
School (S.P.S.).  The S.A.S. had about fifteen people overseeing a part-time
    Centralization differentiates these  two sites.   Using different pairs  of
    universities,  I could make the same  argument around other structural
    variations such as delegation, external contracting,  etc.
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army of superintendents (who liaised with the B.M.D.  mechanics) and energy
monitors6 (who dealt with users).   The S.P.S.  had a facilities  office of three
people devoting up to three half-days a week each to  facilities.  This
splitting of responsibility necessitated splitting the energy management task
between appropriate people in the facilities offices  and in the B.M.D.7
                                     DATA
      The obvious way to examine the research question is by studying which
solutions the given organizations did or did not implement.  However, this
approach would miss two very important elements of the data: the timing of
decisions and extent of implementation of solutions.  In some cases,
implementation was virtually simultaneous with introduction of a technology to
the market.  In others, there were lags of up to twelve years.  If lags
occurred, action was generally precipitated by a (generally external) event.
Hence, timing is best understood using a binary variable: the existence, or
not, of a significant lag.8  Second,  all sites attempted virtually all options
at one time or another.  However, their success varied.  Therefore the other
indicator of performance became extent of implementation (proportion of
climate controlled buildings retrofitted).   (Table 1)

      As Table 1 shows, implementation of these two technologies was far from
uniform.  Tech-U was a very rapid implementer of the centralized direct
digital control computer control systems (DDC) which came to market in 1976
(it was actually a prototype site) and it upgraded the system in a timely
manner as new technology became available.   For compact fluorescent light-
bulbs, however, which are much simpler and cheaper, the lag was relatively
long, three years.  In contrast, while the B.M.D. at Prof-U had installed a
simple supervisory computer control system in the early 1970s to turn systems
on and off daily, it failed to consider the next generation of the technology
when making system upgrades.  Furthermore,  the two faculties did not actually
use the supervisory computer for energy conservation until 1980 and 1986
respectively.  Finally, only after the faculties started installing cheap and
powerful microcomputer-based DDC systems did the B.M.D. consider how it would
accommodate them.
6   A position held by an administrator in the  relevant building.
7   At various times,  this responsibility was shifted around in the S.A.S.  at
    Prof-U.   From 1973-'79,  the Dean took principal  responsibility and two
    people in the facilities office worked on selected problems.   From 1980-
    '85,  when energy use was cut 50%,  he and the  engineering professor who
    catalyzed the initiative co-chaired an energy management oversight
    committee.  He also expanded the facilities office's  energy management
    staff.  At the initiative's end, in 1985, the facilities office assumed
    responsibility and used an incentive program  to  move  some of the onus to
    individual buildings.
8   Whether or not a lag is  significant depends on the nature of the solution.
    Longer delays can be expected for expensive and  complex solutions.
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  TABLE 1.  EXTENT AND LAG OF  IMPLEMENTATION FOR COMPUTER CONTROL AND
                          COMPACT FLUORESCENT LIGHTS




Centralized D.D.C.

Microcomputer based D.D.C.
Scheduled control systems


Compact fluor. lightbulbs
First Mkted

Yr

1976

1984
N/A


1984
Tech-U
P.F.D.
Yr Lag Bldgs
(Yrs) (115)
1976 0 34
1978 # 50
1987 # A/A
1976 3 34
1978 # 50
1987 # A/A
1987 3 A/A
Prof-U
B.M.D.
Yr Lag Bldgs
(Yrs) (Ho)
*

N/A
N/A


N/A
S.A.S.
Yr Lag Bldgs
(Yrs) (175)
N/A

1984 0 4
1980 7 A/A


1984 0 A/A
S.P.S.
Yr Lag Bldgs
(Yrs) (6)
N/A

1986 2 1+
1986 13 6


1986 2 1+
  *  Action not taken by 1987/88
  #  Lag not relevant once other actions are considered
  N/A Action not appropriate for this organization or part thereof
  A/A All appropriate buildings.  At Tech-U, for computer control, this was
      about 65 (excludes dormitories, unconditioned buildings, and those a
      great distance from the campus).  For compact fluorescent bulbs, about
      100 buildings.  In the S.A.S. at Prof-U, for computer scheduling, about
      100 buildings, and for lights, extensive changes in 15 buildings and
      minor changes in many others.
      Services purchased through shared-savings contract

      This pattern was repeated throughout.  Tech-U was a much better
implementer of complex, expensive, technical solutions which did not require
interactions with users (e.g. preventative maintenance, building maintenance,
steam pipe management, chilled water production, etc.).  Prof-U, on the other
hand, was much better at implementing cheap simple technologies or those which
involved users.  These included putting controllers on fume-hoods, dealing
with users,- limiting times and temperatures, simple retrofits, and so forth.9
         EXPLAINING THE DATA:  ORGANIZATIONAL LEVEL LOCAL RATIONALITY
      Given that these organizations are identical in every other respect, I
concluded that differences in structure and events in the institutional
environment could explain almost all differences in decision making (i.e.
decisions with virtually no lag, and the nature of the events which
interrupted the long lags).10  Allocation of responsibilities, which reflected
prior choices of centralized versus decentralized structures, dramatically
affected the universities' decision making capacities.  The organization  acted
as a set of filters which sieved the set of feasible (in an engineering and
economic sense) options (and problem definitions which led to feasible
options) to a much smaller sub-set from which it selected.  As a result,  the
    See  (5)  for an extensive  presentation of  the  data.
10   The  finding was supported by the  other two  cases  in  the  study.
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sub-units exhibit what Cyert and March (6) termed local rationality (i.e.
consideration of a reduced sub-set of options because of organizational level
constraints).  The institutional environment, at key junctures,  facilitated
decisions by providing inputs which compensated for the organizations'
deficiencies.  However, I extend Cyert and March's argument to suggest that
for problems accorded low priority, as is often the case for energy
conservation and waste reduction, the filter is very systematic and has a very
fine mesh.  To understand why that should be, it is essential to consider what
it takes to make a decision.

INFORMATION ACQUISITION AND ANALYSIS:

      Every decision requires the bringing together of three distinct classes
of information; technical information, contextual information, and connected
information.  Technical information is the most obvious.  It generally comes
from outside the organization, with potential solutions.  Decentralization
reduces an organization's ability to collect and analyze technical information
in three ways.11   First,  decentralized organizations must reproduce  their
decision making apparatus  for  each  sub-unit  (e.g.  faculty), making the
gathering of technical information inefficient.  Second, decentralization
reduces the skills each sub-unit can aggregate, making information gathering
incompetent.  We see this played out in the technical capacities of the
universities.  Tech-U had 13 facilities engineers, Prof-U had two for the
B.M.D. and faculties on the campus.  Third, decentralization is not the norm
for universities and so external vendors often cannot identify key people to
approach at Prof-U (see (7)).  For example, the smaller faculties at Prof-U
stood to benefit enormously from the utility-sponsored retrofit program Tech-U
used to replace its lighting.  However,  the utility took a year to find them
(i.e. until after the program was initially scheduled to finish).  Similarly,
only one faculty at Prof-U installed compact fluorescent lights.  Possibly,
the vendor assumed that because one unit in the organization had purchased the
technology, all had considered it.

      Given its low information acquisition capacity, it should be no surprise
that the B.M.D. at Prof-U did not even know about D.D.C. technology until the
faculties purchased small systems in 1984, eight years after it came to
market.  Further, some lag-ending key decisions in the faculties at Prof-U
were precipitated by exogenous inputs of technical skills and information.
Most important, the move to scheduling the computer system, the five-year 50%
reduction in energy consumption, and the purchase of micro-computer based
controllers in the S.A.S can all be traced to a lunch a professor with an
expertise and interest in energy conservation had with the dean in 1979.
Prior to that, the faculty's energy conservation attempts had been disastrous.
Similarly, the S.P.S.'s decision to schedule energy use was precipitated by
its entering into a shared savings contract for one of its buildings.12

      Technical information, however, is insufficient.  Every energy
conservation and waste reduction solution is implemented in a real location
11   Excludes very large organizations  (which have  different  constraints).
12   In a shared savings contract,  an external  party manages  an aspect of an
    organization's operations in return for some the  savings it realizes.
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which carries contextual information about the space, its use, the intricacies
of people's work lives and the idiosyncrasies of the equipment.  To implement
effective solutions, the specialist manager needs this contextual information.
Decentralization increases a specialist manager's access to contextual
information within the unit and decreases it across organizational partitions.
We expect the manager to have much more information about the spaces and
people with whom she deals regularly.  Therefore, the energy managers at Prof-
U are likely to know more about what is going on in academic domains than
their counterparts at Tech-U, and the energy managers at Tech-U are likely to
know more about what is going on in the university's infrastructure than those
at Prof-U.  This is reflected in the solutions.  For example, when Tech-U
finally installed compact fluorescent light bulbs, many were installed in
inappropriate locations and manners.  The nature of the program under which
they were installed made poor solutions more politically acceptable, and
therefore reduced the need for contextual information.  Similar conclusions
can be drawn for computer control scheduling and motion sensor installation.

      Finally, a host of people connected institutionally or geographically to
the site of projects (e.g. allocators of resources, safety professionals)
carry important information.  With decentralization, we expect organizations
to have more trouble implementing solutions which span between units.  The
fact that the first two generations of computer control spanned the faculties
at Prof-U diminished implementation incentives (8).

RESOURCES, INCENTIVES AND POWER:

      Every change in technology, no matter how simple, prevents alternative
projects and changes the social relations between people, (e.g. (9)) and
therefore potentially threatens everyone affected.  For example, compact
fluorescent light bulbs make 90% of bulb changers redundant.  To implement any
solution, unless the technology is very robust, the specialist manager must
bring on-side every person who can possibly obstruct implementation, either
aligning a project with their interest (e.g.  through incentives or simplifying
their job task) or through coercion.   This includes workers, users,  suppliers
of resources, and other people in the organization (e.g.  the safety office).

      Decentralization, by definition,  increases people's incentives to manage
an objective.  Similarly, if responsible groups are sicall,  people are less
likely to behave selfishly.   This is why the facilities office in the S.A.S.
set up a shared savings program of sorts with the individual buildings after
the formal energy conservation program finished.   The net result of relative
decentralization on resource allocation at the two sites  bears mentioning.
Despite their apparently identical capital allocation criteria, at Tech-U,  it
is easier for people to raise $1 000 000 than $50 000.  Large capital
decisions are made by senior management.   Capital beyond annual allocations
needs to be large to attract attention.   Hence, the event which enabled it to
install compact fluorescent bulbs was a utility program which let it package
$10.00 bulbs in multi-million dollar contracts.  Prof-U facilities managers,
in contrast, have reasonably easy access to capital within their faculty's
   Once  the  control  systems  are  in place,  a  lot of contextual  information  is
   needed  to efficiently match the HVAC  schedules to  space usage.
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jurisdiction.  Beyond that, requests must go to the central university with
the dean's support.  This is problematic for the smaller and poorer faculties.
Hence, the micro-computer based direct digital control systems, which are less
than the $50 000 cut-off, are easy to acquire.  A large direct digital control
system, in contrast, would have required extensive negotiation between the
B.M.D. and the faculties

      Finally, let us briefly consider power; making people do what you wish.
Decentralization increases the specialist manager's power relative to people
in the same sub-unit.  Hence, at Tech-U the energy managers have low power
over users, which is reflected in the dearth of successful projects within
academic spaces.  Projects whose costs are borne by maintenance workers,
however, are common.  In contrast, at Prof-U the faculties traditionally had
little power over the B.M.D.  In order to achieve its 50% energy use
reduction, the S.A.S. had to force a renegotiation of the contract joining it
to the B.M.D., and increased its power considerably.14
                                  DISCUSSION
      I have argued, from rational choice assumptions, that organizations'
structures dramatically constrain their decision making.  If we consider their
information acquisition and analysis ability and their power distributions and
compare them to the information and power requirements of a given solution,
then organizations will be unable to select solutions for which they have
insufficient capacity.15   End-of-pipe solutions are generally very accessible
because they need large amounts of technical information but small amounts of
contextual information and power.  These requirements parallel the capacity of
many environmental departments.  Events outside the organization can change
the balance of attributes and therefore make more solutions accessible.

      If we assume that this argument extends beyond universities,  we must
conclude that organizational models offer much better predictions of waste
reduction behavior than their economic counterparts.   Institutional
constraints, derived principally from the organization's structure and the
institutional environment, almost invariably render market forces
insignificant.  The policy conclusion I draw from this is that ensuring that
firms have a marginal incentive to reduce waste is a necessary, but grossly
insufficient, condition for effective waste reduction.

      Effective policies can do three things.  First, they can change waste
reduction technologies to be less dependent on power and the three types of
information.  For example, improved valves, control systems, etc. have this
characteristic.  Second,  policies can change the external environment of the
organization to make up for deficiencies within the organization.  For
example, technical assistance programs compensate for skills deficits.
Subsidy programs overcome internal constraints caused by resource allocation
1A  A subsequent,  detailed examination  of waste reduction at a major  chemical
   manufacturer (Dow Chemical)  supports the  findings.
15
    This  neglects  risk taking  -  selection of  solutions outside  the bounds.
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procedures and increase managers' power.  Citizen suits often force
environmental and production managers into a dialogue and bring different
types of information together.  Finally, policies can aim to bring about
permanent changes in the management of the organization to eliminate
permanently some of the institutional barriers.  Such policies might aim to
persuade top management to treat environment as more important, encourage
small waste reduction projects, innovation, and so forth.  For example, an
organization which raises waste reduction's importance is likely to increase
the power of the waste manager, and hence improve her access to resources and
technical information.  Simultaneously, responsibility is likely to move
further into line management, increasing the flow of contextual information.
In this last domain, there is a possibility for a strategic link between EPA,
OSHA, and the Commerce Department, since the organizational characteristics
which lead to high quality in manufacturing are very similar to those which
lead to safe and clean production processes.
                                  REFERENCES
1.  U.S.  Congress,  Office of Technology Assessment.  Serious  Reduction of
    Hazardous Waste:  For Pollution Prevention and Industrial Efficiency.   OTA-
    ITE-317.  Washington D.C.:  U.S.  Government Printing Office.  1986.  254 pp.

2.  Ross,  M.   Capital Budgeting Practices of Twelve  Large Manufacturers.
    Financial Management  pp.  15-22.  Winter 1986

3.  Miller,  P. M.,  Eto, J. H.  and Geller, H.  The Potential for  Electricity
    Conservation in New York State.  Washington D.C.:   American  Council for and
    Energy Efficient Economy.  1990.

4.  Thompson, J. D. Organizations in Action.  New York:  McGraw-Hill Book
    Company,  1967.

5.  Cebon, P. B. "The Missing Link:  Organizational Behavior  as  a Key Element
    in Energy/Environment Regulation and University  Energy Management."
    Master's thesis in Technology and Policy, M.I.T.,  1990.  524 pp.

6.  Cyert, R. M. and March, J. G. A Behavioral Theory of the Firm.  Englewood
    Cliffs NJ: Prentice Hall,  1963.

7.  DiMaggio, P. J. and Powell, W.  W.  The Iron Cage Revisited:   Institutional
    Isomorphism and Collective Rationality in Organizational Fields.  American
    SocioloEical Review 48: 147-160.  April 1983

8.  Lawrence, P. R. and Lorsch, J.  W. Organization and Environment:  Managing
    Differentiation and Integration.  Boston:  Graduate School of Business
    Administration, Harvard University, 1967.

9.  Winner,  L.  The Whale and the Reactor:  A Search for Limits in an Age of
    High Technology.   Chicago: U. of Chicago Press,  1986.
                                      153

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    AN APPROACH TO HAZARDOUS WASTE REDUCTION AND POLLUTION CONTROL
           IN THAILAND'S UPCOMING TERPHTHALIC ACID INDUSTRY
                           R.  N.  Chakrabarty
              Senior  Expert  (Industrial  Pollution  Control)
    Economic and Social Commission for Asia and the Pacific (ESCAP)
                     UN Building,  Rajdamnern Avenue
                          Bangkok.  Thailand.
                                ABSTRACT

     One of  the  major petrochemical  industries  that are currently be-
ing established  at  Map Ta Phut  industrial  complex on Thailand's east-
ern seaboard  is  a large Purified Terephthalic Acid (PTA) plant. Tere-
phthalic acid  is  the key intermediate in the manufacture of polyester
fibers and  films,  and  is  produced  by the  oxidation of para-xylene in
acetic  acid  medium  in  the  presence of  a  suitable  catalyst  in  an
autoclave.   The anticipated  undesirable  side-products  of oxidation of
commercial para-xylene proposed to be used by the plant in Thailand, as
they are in most  such plants elsewhere,  are isophthalie acid, mellitic
acid,   trimellitic  anhydride,  para-toluic  acid^  para-toluic ester and
other straight-chain  organic chemicals which would represent the prin-
cipal hazardous  pollutants in  the  plant  wastewaters.  Commercial para-
xylene always contains certain  amounts  of  ortho-  and meta-xylenes as
impurities; and  isophthalic acid, mellitic  acid and trimellitic anhy-
dride which are produced solely from the oxidation of meta-xylene, con-
stitute  the bulk of the  hazardous pollutants  present  in  the waste-
waters of  a PTA  or  dimethyl terephthalate  (DMT)  plant.  Almost all the
aromatics  and  methanol  released from a  PTA or DMT  plant are toxic in
nature,  but  are  biodegradable,  however.  Hence  the  wastewaters from
such plants  exert a very  high  oxygen demand with  COD of the order of
6,000 mg/1 and BOD of 750-2,000 mg/1.

     On a  request from the Government of Thailand,  the United Nations
Economic  and  Social  Commission  for Asia  and  the  Pacific  (ESCAP)
recently prepared technical  guidelines for  the mitigation of pollution
of coastal  waters of Southeast Asia  from  hazardous industrial wastes
from  a number of petrochemical  and  non-ferrous  industries including
PTA-DMT  plants.   In  the   guidelines prepared   for  PTA-DMT  plants,
the two  important recommendations  that have been made are:  (i) explor-
ing the  use of pure  para-xylene as the  raw material  so  as to prevent
or reduce  significantly  the generation of most of the hazardous pollu-
tants,  and  (ii)  installation  of a two-stage  activated  sludge plant
with  its   first  stage  unit  having  complete-mixed  and   the  second
stage  unit  with  plug-flow  hydraulic  configurations   and featuring
extended aeration system  for  effective  treatment  of  the wastewaters.
These proposed measures are discussed in this paper.

                                   154

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                              INTRODUCTION
     One  of  the major  petrochemical  industries  that  are  currently
being established at  the  Map Ta Phut industrial complex on the eastern
seaboard  of  Thailand  is  a  purified  terephthalic  acid  (PTA)  plant
of  Thai  PTA  Company  Limited,  a  subsidiary  of   Imperial  Chemical
Industries  (ICI) Ltd  of  U.K.  Two  polyester  making plants  are also
being  established  as  the  PTA  plant's  downstream units.  Although
PTA  is  now  used as the  key  intermediate  for  the  manufacture  of
polyester fibers and films and has largely replaced dimethyl terephtha-
late (DMT) which was  used earlier,  many DMT plants are still operating
in some countries in Asia.

     Of all the petrochemical industries, PTA or DMT  industry probably
generates  the   strongest   wastewaters   containing  a  large  variety
of pollutants, many  of which are also  hazardous  in nature. In view of
this,  the  treatment  of  wastewaters  from  this  industry  is  usually
carried out  jointly  with  other petrochemical industry wastewaters in a
common  facility  as  far as  practicable.  But  in some  countries as in
Thailand,  individual  ownerships  of such  industries may  often compel
them to  install  and  operate their  own waste  treatment plants. Treat-
ment of such  hazardous wastes at individual plant level often requires
the  application  of advanced  technology.  Therefore,  on a request from
the  Government   of  Thailand, the  United Nations  Economic  and Social
Commission for Asia and the Pacific (ESCAP) recently  prepared pollution
control guidelines for a number of petrochemical and  non-ferrous indus-
tries  including  the  PTA industry presently  being established at Thai-
land's eastern seaboard.  The findings and recommendations contained in
the  guidelines  on  PTA-DMT  industry  (1),   which  are  summarized  in
this report,  also  include the  strategy  for minimizing  waste genera-
tion in this industry.

                         MANUFACTURING PROCESS
     To facilitate an  understanding  of the sources and types of pollu-
tants  generated  in  a  PTA industry,  the  ICI  Pure  Terephthalic  Acid
Process (Figure  1)  which has been proposed  for the plant in Thailand,
is  briefly described  here.  This process involves oxidation  of para-
xylene (p-xylene), C6H4(CH3)2, with  air in the presence of acetic acid
and a  suitable  catalyst (such as cobult, manganese, or bromine) and at
a  controlled temperature  and pressure  when  terephthalic acid (TA),
C6H4(COOH)2,  is  produced.  TA, being  insoluble  in acetic acid, crysta-
llizes  and  is   separated  from  the  acid by  filtration.  It  is  then
dried  to  give crude TA. A part  of  the acetic solvent, including cata-
lyst,  is   recirculated  to the  reactor.  The remaining  acetic acid is
concentrated  by evaporation  before  recycle to  the oxidation  reactor.
The organic residues are disposed of by incineration.
                                   155

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                          Hot vapours
            Autoclave
            reactor
   I paraxylene
   •(Acetic  acid
   (_ Catalyst
      Air
Silo
                                                                                        Catalyst recovery &
                                                                                         by-product removal
                                                                                                unit
 By-product residues (to incinerator)
Filter
                               Waste
                               water
                                                                                                                     Distillation
                                                                                                                     column
                                                                                                                        Acetic acid
                                                                                                                        Impure
                                                                                                                        terephtnallc
                                                                                                                        acid Silo
                                                                                                                       Water
       Figure 1.   Simplified Flow Diagram for the Manufacture of Purified Terephthalic Acid

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     p-xylene used  in  a PTA plant usually  contains certain amounts of
ortho-  and  meta-xylenes  as impurities  which also  participate in the
oxidation  reaction  to produce  side-products  such  as phthalic  acid
(ortho-acid) and  isophthalic acid (meta-acid).  In the quantities pro-
duced, none  of  these chemicals can  be  recovered economically, so they
are extracted as  a molten residue and  incinerated.  Also,  due to part-
ial oxidation of  p-xylene,  4-carboxybenzaldehyde (4-CBA),  C6H4CHOCOOH,
and  other by-products  like benzoic  acid,  C6H5.COOH,  and trimellitic
acid, C6H3(COOH)3,  are formed.  These by-product acids are largely re-
moved as  molten  residue  during the  soiId-liquid separation stage and
incinerated.  4-CBA remains  as  an  impurity  in  the crude  TA crystals
which are purified by  dissolution  in hot  water followed  by selective
catalytic  hydrogenation when  the 4-CBA is  converted  to para-toluic
acid, C6H4.CH3.COOH. Purified  terephthalic acid (PTA)  is  then crysta-
llized  from the  aqueous  phase,  centrifuged  and dried  for  its direct
esterification with  ethylene glycol  to  produce  polyethylene terephtha-
late in a polyester plant.

              SOURCES  AND CHARACTERISTICS OF  WASTEWATERS
     p-toluic  acid  produced  from  4-CBA,  and  other  organics including
isophthalic and  trimellitic acids  (or  anhydride),  acetic acid, methyl
acetate,  methyl  alcohol,  formic acid,  formaldehyde and  also a small
amount  of unrecoverable  TA are purged from  different  process units.
The  concentrations  of  the  abovementioned  chemicals  in the  process
effluents  are   appreciable.   It is  reported  (2)  that  the  process
wastewaters  of  a  DMT  plant  in India,  which  constituted  less  than
4  per  cent  of  the  daily volumes of flow of  the  plant wastewaters
(including  cooling tower  blowdown), accounted  for  over 95  per  cent
of  the total  BOD.  Table  I  shows  the composition of  this undiluted
effluent  stream.  BOD   values   of   the  wastewaters  varied  from  750
mg/1 to 2,000 mg/1.

     TABLE I. COMPOSITION OF  PROCESS WASTEWATERS FROM A DMT PLANT
     Compounds               Concentration        Cone.in composite
                             in process           wastewaters,mg/1
                             wastewaters (% w/w)
     Acetic acid                  2.4                   935
     Formic acid                  1.3                   506

     Formaldehyde                 0.26                   97.5

     p-toluic ester and
     methyl benzoate              0.27                  101
     Soluble organics
     including methanol           1.5                   700
                                   157

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      Lau (3)  reported that the normal concentrations of different orga-
 nic  components  present  in  the  process  wastewaters  of  TA  plants
 in the United  States are  as shown  in Table  II.  Typical  COD of  the
 process wastewaters  was 6,000  mg/1.  The strength  of process  waste-
 waters from a TA/PTA plant varies widely from plant to plant,  depending
 upon the purity  of p-xylene  used,  the process operated,  the  extent
 of recovery and  recycle of by-products  and  the  water  usage in  the
 plant.  Some operating plants  in  India,  U.K. and U.S.A.,  have reported
 BOD  values of  their  wastewaters  ranging  from  2,000  mg/1  (2)   to
 3,650  mg/1  (4)  and  the  COD  values  around  6,000  mg/1  (3),   while
 a   new plant   proposed  to be  established   in  the  Republic  of  Korea
 has  estimated  the  BOD  and  COD  of  its  potential  wastewaters  to  be
 about 8,000 mg/1  and 9,800 mg/1,  respectively (5).

    TABLE II.  TYPICAL COMPOSITION  OF PROCESS EFFLUENTS OF A PTA PLANT

              Components                      Concentration,  mg/1

              Terephthalic acid                   600

              Isophthalic acid                     600
              Trimellitic anhydride               600
              Acetic acid                         2000
          CURRENTLY PRACTICED POLLUTION ABATEMENT TECHNOLOGIES
     A  few  case studies  are  briefly described  here to illustrate the
successes and  constraints of  treatment of  DMT- and  PTA  plant waste-
waters .

                              CASE STUDY I

     Possibly the  first extensive study on the  treatment  of high BOD
wastewaters  of  a  DMT  plant  in  multi-stage bioreactors   was carried
out  by  Chakrabarty   (2)   at  the  Indian  Petrochemicals Corporation
Ltd (IPCL) at Baroda,  India,  in 1973.  The plant  included a neutraliza-
tion  tank,   a  two-stage   oxidation  ditch  (the  first  stage having
a volume of  880 cu.m  and  the  second  stage of 2,250 cu.m) with nutrient
dosing  arrangement,   a  final   clarifier  with  sludge  recirculation
system and a sludge dewatering bed  (Figure  2).  The plant  was operated
with wastewater  flows  varying  from 1,020  cu.m/day to  2,340 cu.m/day
and having  BOD  values  ranging  from  750 mg/1  to 2,000  mg/1  and at an
MLVSS concentration of  1,968  mg/1 to 3,050 mg/1. The first-stage aera-
tion tank was operated at an overall F/M  of 0.874 kg BOD/kg MLVSS-day
and the  second  stage  at  0.092 kg BOD/kg MLVSS-day. A  summary of the
results of performance  of this plant is shown  in Table III.  The aver-
age BOD reduction in this plant was greater than 99 per cent.
                                  158

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                                                1st Stage
                                                  llnd Stage
(71
VO
                           Raw

                       wastewater
                               Neutralization
                                     tank
                                     Nutrients
                                                                                    D
                                                                      Clarlfler
                                                      I
Splitter
 box
                             •-J	**J      U
                        •*	*	*	1
Treated effluent for disposal


Stabilized sludge to dewaterlng beds
                                                               Excess sludge

                         Figure 2.   Flow Diagram for Treatment of DMT Wastewaters in Two-Stage Oxidation Ditches

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           TABLE III. SUMMARY OF THE RESULTS OF PERFORMANCE OF
           TWO-STAGE OXIDATION DITCH TREATING DMT WASTEWATERS

Date
(1973)

July
26
27
28
30
31
August
2
3
8
11

Flow
m3/d


1,165
1,960
1,630
1,280
2,340

1,500
1,470
1,790
1,870
FIRST STAGE
Det.
time
hr.

18.0
10.8
13.0
16.5
9.0

14.0
14.4
11.8
11.3
F1LVSS
mg/1


2,400
2,300
2,180
2,140
1,968

2,650
3,050
2,875
2,460
Inf.
BOD
mg/1

1,400
750
1,200
1,000
1,675

2,000
1,200
900
850
Eff .
BOD
mg/1

155
145
115
115
120

180
-
125
110

Det.
time
hr.

26.5
15.8
18.9
24.0
15.3

20.6
21.6
18.7
18.1
SECOND
MLVSS
mg/1


2,460
2,345
2,248
2,200
2,140

2,720
3,040
2,880
2,470
STAGE
Inf.
BOD
mg/1

155
145
115
115
120

180
_
125
110

Eff.
BOD
mg/1

10.5
2
5
4.5
10

11
8.5
12.8
14.4
                             CASE STUDY II
     A similar study on bio-oxidation of TA plant wastewaters in multi-
stage aeration tanks was performed by Lau (3) of Amoco Chemicals Corpo-
ration, Naperville, Illinois, U.S.A. The investigator used three bench-
scale activated  sludge  units:  a single-stage  reactor,  a two-tanks-in-
series  reactor,   and  a  three-tanks-in-series  reactor,  each  equipped
with  an external  clarifier.  A  synthetic feed  of  the  composition as
shown in Table II  was used.  An MLSS concentration of 6,000 mg/1 and an
overall feed  to  microorganisms ratio  (F/M)  of 0.5  kg  COD/kg MLSS-day
were  maintained  in the bio-reactors.  The results of  operation of the
three bench-scale  units showed  that under oxygen  non-limiting condi-
tions (100% air supply,  above 3 mg/1 DO in the first tank of the tanks-
in-series  unit),  the average  COD  reduction was  greater  than 98 per
cent  in a  three-tanks-in-series  system and over 96  per  cent in a two-
tanks-in-series  system.  The effluent COD  values of these  two systems
were at or below 100 mg/1 and 175 mg/1,  respectively.

                             CASE STUDY  III
     Terephthalic  acid plant  wastewaters have  also  been effectively
treated by the Deep Shaft process developed by Imperial Chemical Indus-
tries  (ICI)  Ltd,  U.K.  Although this process  has so  far  been used in
more than  50 sewage  and  industrial waste treatment  plants,  mostly in
Japan  and  U.K.,  there  is presently  one such installation  at Wilton,
U.K., where, since 1981 a TA plant has been treating its wastewaters by
                                  160

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this  process.  The  plant   wastewaters   (2,650  cu.ra/day)  having  an
average BOD of  3,650 mg/1 are treated in a single-stage deep shaft to
produce an effluent with an average BOD of 300 mg/1 (4).

                   AN  APPRAISAL  OF THE CASE STUDIES
     There appears  to be  a  similarity of  approaches and observations
made in the Case Studies I and II, although in Case Study I, full-scale
two-stage combined    complete-mixed-plug-flow    reactors    (oxidation
ditches) were used and  in Case Study  II,  bench-scale two-  and three-
stage complete-mixed reactors (CFSTR) were used.  By using a multi-stage
configuration   of  the  reactors,   both  the   investigators  obtained
98  to 99  per  cent  BOD reduction.  In contrast, a  single-stage unit
used  in Case  Study  III  could  achieve a  BOD  reduction  of  a   little
more than 90 per cent.  These observations indicate that a single-stage
reactor, even featuring an extended aeration system,  would be  incapable
of producing the low effluent BOD achievable in a multi-stage reactor.

             SCOPE OF WASTE  REDUCTION IN  THE  PTA INDUSTRY
     Terephthalic acid  industry  is one of the petrochemical industries
that  has  not yet  been  able  to  resolve  the  problem  of  generation
of highly  polluting  wastes in  spite of developing  and using improved
manufacturing  technology  for  more  than  a  decade   now.  The  major
steps  that have  been  taken  by  this  industry  in achieving economy
in  its  manufacturing  processes,  and  at  the  same  time  in  reducing
the  generation  of  wastes to a  certain  extent,  is   the abandonment
of  production  of  DMT  as  the second  intermediate  and  of  the  use
of  nitric acid  as a  solvent for  p-xylene in the  oxidation reactor.
This  resulted  in  the  elimination  of  methyl alcohol  and   a  number
of other toxic and hazardous  pollutants associated with the manufacture
of  DHT.   Even  with  this  improvement,  the  magnitude   of   pollution
potential  of  this  industry  has  not diminished   to any significant
extent. This  is because of the fact  that the basic process of  oxidation
of  p-xylene  in  acetic acid  medium  to manufacture  terephthalic acid
has  remained practically  unchanged  in modern  PTA plants.   As a sig-
nificant amount of the  by-product  chemicals (as pollutants) are genera-
ted  in  the p-xylene oxidation process itself,  the  PTA plants generate
almost as  strong a wastewater as do  the DHT plants (Figure 3).

     The organic pollutants that are generated in the PTA industry are
primarily  the oxidation products of o-xylene and m-xylene which remain
as  impurities in the feedstock  (p-xylene)  supplied to the industry by
p-xylene   producers.  Although   the  oxidation  of  pure  p-xylene  is
also likely   to  produce   some   amounts  of  benzoic   and trimellitic
acids  as  by-products,  the  quantum  of  these  pollutants should  be
much  less than  that  produced from the oxidation  of   impure  p-xylene.
Therefore,  by  using  pure p-xylene  as  the  feedstock,  a number  of
currently  practiced  operations  in  the  industry   can  be  reduced,
thereby  bringing  about further  economy  in the  manufacturing process
and also minimizing the costs of pollution  control in  this industry.
                                   161

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ro
                            FEEDSTOCK


                               CH3
                                     Oxidation
                               CH3

                         PARA-XYLENE
                          Impurities  In
                            p-xylene
                                     Oxidation
                         META-XYLEIME
                                         Oxidation
                         ORTHO-XYLENE
  Main
product

  Side
products
                                                           Main
                                                          products

                                                        Ma.n
                                                                                             To Polyester Plant
     Terephthalic Acid (purified)
                  COOH
                                                                        o
                       Catalytic hydrogenation
     4-carboxybenzaldehyde
COOH
COOH
                                                                                Benzole Acid
                  COOH
                         Trimellitic Acid
                      COOH
                      COOH

                  COOH
                                                                                   isophthal ic Acid
                                                                                 OOH
                                                                           COOH
                                                                                   Phthalic Acid
       To wastewater
                Plant
       COOH
para-toluic Acid
                                   Figure 3. Major Pollutants Generated in the Oxidation of Commercial grade p-xylene in PTA Plants

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                               REFERENCES
1.   Guidelines for the Mitigation of Pollution of Coastal Maters
     from Hazardous Industrial Wastes - III. PTA-DMT-Polyester
     Industry. United Nations Economic and Social Commission for
     Asia and the Pacific, Bangkok. 1990.

2.   Chakrabarty,  R.N.   Design  and  Operation  of  a Multi-stage  Bio-
     oxidation Plant for DMT Wastewaters.  Jour. Inst. Pub.
     Health Engrs, India. Vol. 4,  No. 3 and 4, 1975. p.  111-122.

3.   Lau, C.M. Staging Aeration for High-Efficiency Treatment
     of Aromatic Acid Plant Wastewater. In: Proceedings of 32nd
     Industrial Waste Conference.  Purdue University, U.S.A. 1977

4.   Personal communication with Dr. Harvey Lancaster, ICI Engineering
     Division, Billingham, Cleveland, U.K. December 1989.

5.   Personal communication with Mr. Lars-Erik Ohlsson,  PURAC AB,
     Lund, Sweden. March 1990.
                            ACKNOWLEDGEMENTS
     The  author wishes  to thank  Dr.  K.F.  Jalal,  Chief,  Division of
Industry,  Human Settlements  and Environment  of United  Nations ESCAP
for  his  valuable  advice during the  preparation of  pollution control
guidelines  for  various  industries  including  the  PTA-DMT  industry
by the  ESCAP secretariat under  the supervision of  the author.  Thanks
are  also due  to  Dr.  Harvey  Lancaster  of  ICI Engineering  Division,
U.K., for  providing valuable information on  the ICI Pure Terephthalic
Acid process and other helpful suggestions.

     The  Government   of  The  Netherlands   deserves  special  thanks
for  providing  extrabudgetary  funds  for organizing  this study under
the  ESCAP  project  titled  "Environmental  Assessment  of  Industrial
and  Urban Development  in Coastal  Areas of  Southeast  Asia -  A Pilot
Study at Thailand's Eastern Seaboard".
                                  163

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             ADDRESS BEFORE THE EPA/IACT INTERNATIONAL CONFERENCE
                            ON POLLUTION PREVENTION
               by: Dr. Barry Commoner
                   Center for the Biology of Natural Systems
                   Queens College, CUNY
                   Flushing, New York
      This conference comes at a crucial moment in the history of
environmental ism.  Two months ago, millions of people in dozens of countries
bore witness to the elevation of the environmental crisis to the top of the
global agenda.  Even more than the first Earth Day 20 years earlier, Earth Day
1990 confirmed the nearly universal commitment to restoring the quality of the
environment.

      But the two Earth Days differ sharply in their results.  In 1970, Earth
Day was the signal for action: a series of far-reaching environmental laws
were passed; the U.S. Environmental Protection Agency (EPA) and state
environmental agencies were established; local clean-up campaigns were
organized; schools adopted new environmental courses.  In 1990, Earth Day has
come — and gone — leaving scarcely a trace in the country's life.  No new
remedial programs have been proposed; the Congress is still debating a Clean
Air Bill that — failing to recognize what we have learned over the last 20
years — was obsolete on the day it was written; a curious silence has
descended on the airwaves and editorial pages.

      The chief message about how to clean up the environment that emerged
from the recent festivities is: do it yourself.  Some examples, gleaned from
one of the numerous published lists: "live within walking distance of your
job; carry your own shopping bag; keep the lint screen in the clothes dryer
clean; be creative with leftovers; go barefoot."  Virtuous as they are, these
measures are hardly adequate to a world confronted with the massive task of
preventing global warming and ozone depletion, of eliminating smog and acid
rain, of sharply reducing exposure to toxic chemicals.

      I have been particularly concerned about this discrepancy because early
on I called for a new understanding of the environmental  crisis:  to explain
why, despite the huge and costly effort, the environmental problem persists;
to prevent pollution instead of trying to control  it; and to achieve that
through a massive, world-wide transformation of our systems of agriculture,
manufacturing, energy production, and transportation.
                                     164

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      This urgent message, I regretfully report, was lost in the glamorous din
of the recent Earth Day.  In the quiet aftermath we are obliged, I believe, to
speak out and, as clearly and as forcefully as we can, awaken the world, not
simply to the size and urgency of the problem — that is well known — but to
the monumental scope and radical impact of the necessary remedy.  We need to
fill the vacuum left by the trivialization of Earth Day and ~ as I shall show
~ by the failure of this Administration to provide leadership in the new,
more meaningful direction.

      To appreciate the sweeping significance of pollution prevention as the
guiding strategy for resolving the environmental crisis, we need to go back 20
years, to the law that defined U.S. environmental policy — the National
Environmental Policy Act  (NEPA).  The stated purpose of that Act is:

         "To declare a national policy which will encourage productive and
      enjoyable harmony between man and his environment; to promote efforts
      which will prevent or eliminate damage to the environment and biosphere
      and stimulate the health and welfare of man."   [emphasis added]

      What is most significant about this clear-cut statement of U.S.
environmental policy is that for 20 years it was ignored.  The simplest
evidence is that 20 years after NEPA, in the Federal  Register of January 19,
1989, EPA found it necessary to announce pollution prevention — as a new
policy.  In the Pollution Prevention Policy Statement signed by the former
Administrator, Lee M. Thomas on that date, the  novelty of this position  is
made quite clear.  The statement acknowledges that EPA's past effort "had  been
on pollution control rather than pollution prevention" and asserts that
"...today's notice commits EPA to a preventive  program to reduce or eliminate
the generation of potentially harmful pollutants."

      I have emphasized the word "generation,"  because it sharply
distinguishes the new policy from the old one.  The earlier, control strategy
accepts the existence of  the facilities that generate the pollutants —  the
automobile or the power plant — and then prescribes  appended control devices
~ catalytic converters or scrubbers -- to trap the pollutants before they can
enter the environment.  Prevention, instead, calls for replacing the present
facilities themselves with new  kinds of cars and power plants that do not
generate the pollution, obviating the need for  a control device.

      In the 20-year period between NEPA's pronouncement that pollution
prevention is national policy and  its adoption  by  EPA, the United States has
made  a massive effort to  restore the quality of the environment.  More  the $1
trillion of public and private money has been spent to control rather than
prevent pollution; impressive bureaucracies have been created; numerous
regulations have been enacted.  But with what results?  Mr.  Thomas' policy
statement answers this question diplomatically:  "...EPA realizes that  there
are limits as to how much environmental improvement can be achieved under
these [i.e., control] programs."   I can be less diplomatic,  and  assert  as  I
did in an earlier address to the EPA staff (in  January  1988) that  "...the
massive effort that began in 1970  has failed to restore the  quality of  the
environment."
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      At that time, and more recently in my book,  Making Peace with the
Planet. I reviewed the available numerical  data regarding emissions and
environmental concentrations of pollutants  that lead to this conclusion,  it
is useful to summarize these data here,  for they show not only that the
controls strategy has failed, but more important,  that — in the very few
instances in which, more or less by accident, it has been applied — the
prevention strategy has succeeded.

      The data show that, with very few exceptions,  the effort to reduce the
emissions and environmental concentrations  of pollutants has failed.
Improvement in annual emissions of the standard air pollutants —
particulates, sulfur dioxide, carbon monoxide, nitrogen oxides, and volatile
organic compounds — has been modest at best.  Between 1975, when the
acquisition of uniform annual data began, and 1987,  the average reduction in
these emissions was only 18%, including a 2% increase in nitrogen oxide
emissions.  Similarly, a U.S. Geological Survey study of the levels of
standard water quality factors ~ fecal  coliform bacteria, dissolved oxygen,
nitrate, phosphate, and suspended sediment  — at several hundred river sites
throughout the country shows that between 1975 and 1983 the average levels
improved at 13.2% of the sites; they deteriorated at 14.7%; and remained
unchanged at 72.1%.

      Qualitative improvement of the order  envisaged in the environmental
legislation of the 19703 — 70% to 90% ~ has occurred only in the case of a
handful of pollutants: airborne lead emissions, which have declined by 94%
between 1975 and 1987; DDT and PCB concentrations, which have declined in
human body fat by 70-80% in the decade following 1970; mercury concentrations
in Great Lakes sediments, down by 80% between 1970 and 1979; strontium 90
concentrations in milk, which have declined by 92% between 1964-1984; and, in
a few local sites such as the Detroit River, a 70% reduction in phosphate
concentrations between 1971 and 1981.  The  numerous failures and the rare
successes tell the same story: pollution prevention works; control devices do
not.  Environmental pollution is an incurable disease; it can only be
prevented.

      Every pollutant on this very short list of successes reflects the same
remedial action: production of the pollutant has been prevented.  Lead has
been almost entirely removed from gasoline; DDT and PCB have been banned;
mercury has been removed from chloral kali production; where phosphate has been
eliminated from detergents, concentrations  in surface waters have declined;
the atmospheric nuclear bomb tests that produced strontium 90 have been
halted.

      In each case the production process that originally generated the
pollutant has been changed.  In gasoline production, lead has been replaced by
organic octane boosters; in cotton production, DDT has been replaced by other
insecticides; in transformer production, PCBs have been replaced by other
dielectric fluids; in chloralkali plants, semipermeable membranes are now used
in the electrolytic cells  instead of mercury.  In sum, the strategy of
pollution prevention requires an appropriate change in the technology of
production; the change entirely eliminates the pollutant, reducing emissions
to zero.  In contrast, the strategy of control attempts only to reduce the
amount emitted — and fails to do so appreciably.


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      One of the rules of environmental ism is "There is no free lunch," a
reminder that there is a cost associated with every environmental mistake.
The mistaken strategy of control is no exception,  it has not only rendered
futile the huge 20-year effort to clean up the environment, but has also
created new problems that could have been avoided had the strategy of
pollution been implemented instead of being entombed in NEPA.

      A major consequence of the effort to combat pollution by applying
control devices to the otherwise unchanged facilities that generate it is the
much-lamented — but spurious — conflict between environmental quality and
economic development.  This conflict has led to the claim that since economic
development depends on increased use of the same technologies that generate
pollutants — modern automobiles and trucks, fossil fuel and nuclear power
plants, or chemical agriculture — then it follows that environmental quality
demands limits on economic growth.  This claim has a chilling effect on
communities and countries that are struggling to overcome the most serious
assault on the quality of life — poverty.

      Experience with the strategy of control appears to confirm the reality
of this conflict.  Thus, one reason why emissions from motor vehicles and
power plants have decreased only slightly since 1975 is that vehicular fuel
consumption has increased by 11.3% and electric power production by 9.8% in
that period of time.  Since they are never perfect, the increment in overall
activity counteracts the modest reduction in emissions that the control
devices can achieve.  On the other hand, when a preventive measure is employed
-- for example, removing lead from gasoline — emissions are reduced to zero
regardless of the level of activity.  After all, any number multiplied by zero
remains zero.

      Thus, if we rely on control devices that only partially reduce
emissions, then increased activity will counteract their effect — and there
is, indeed, a conflict between environmental quality and economic development.
Nor can this conflict be relieved by raising the efficiency of the control
device to 100%, for this inevitably involves exponential increases in their
costs — adding to the cost of production and, again, generating a conflict
between environmental quality and the economy.

      In fact, changes in production technology motivated by pollution
prevention will often themselves improve economic productivity.  For example,
in the United States, the economic productivity of agricultural chemicals —
i.e., the dollar return on the investment in them — has decreased by some 70%
since they were introduced in 1950.  There is now a good deal of evidence that
the prevention-motivated alternative — organic agriculture — is economically
successful compared with conventional agriculture.  Similarly, with the cost
of producing fossil fuels inevitably escalating as supplies are depleted,
solar alternatives that are renewable and therefore stable in cost become
economically advantageous.  Indeed, it is safe to say that if American
industry would gear up to produce smogless cars and trucks, low-cost sources
of solar energy, and processes that sharply reduce the environmental burden of
toxic chemicals, it could recover a good deal of the vitality that it has lost
to other, more innovative, national economies.
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      This conference testifies to the fact that the principles of pollution
prevention have been widely appreciated and are beginning to be applied.
Efforts are being made to reduce the amounts and toxicity of the wastes that
are generated, and where possible to recycle them.   Pollution prevention is
beginning to move from policy to practice.

      But there are serious obstacles which, unless they are confronted and
resolved, will, I believe, hold back the full-scale development of the
strategy of prevention and ~ once again — frustrate our effort to restore
the quality of the environment.  In order to identify these obstacles and come
to grips with the task of overcoming them,  we need  to look at some of the
larger implications of implementing the strategy of prevention.  For this
purpose it is useful to examine a specific — and large-scale ~ source of
environmental pollution: the automobile.

      In the 1970s the automobile was recognized as the source of at least
several major environmental pollutants: carbon monoxide, photochemical smog,
and lead.  Guided by the strategy of control, EPA tackled the problem by
prescribing a control system to reduce emissions of carbon monoxide and
nitrogen oxides.  In a detailed rule-making document, EPA prescribed specified
control devices and predicted that they would reduce national carbon monoxide
emissions by 80% and nitrogen oxide emissions by 70% between 1975 and 1985.
This prediction turned out to be far off the mark;  in fact, carbon monoxide
emissions declined by only 19%, and nitrogen oxide  emissions increased by 2%
in that period.  And since nitrogen oxides trigger  smog production and
contribute significantly to acid rain, there has been little improvement in
these important environmental problems.

      The original estimates took into account the  several relevant factors,
including the efficiency of the control system (chiefly the catalytic
converter) and the expected increase in traffic.  The failure to achieve the
predicted reductions revealed that the efficiency of the control system was
insufficient to overcome the approximately 11% increase in automotive fuel
consumption over that period.  Meanwhile, it was discovered that lead, then
widely used in gasoline as an octane-booster, poisoned the catalytic
converter's platinum catalyst, and EPA moved to rapidly eliminate lead from
gasoline production.  As a result, national lead emissions (from all sources)
has declined by 94% since  1975.  This is one of the few real environmental
successes; it has reduced  the toxic effects of lead emissions, for example in
inner-city children where  it had been sufficient to account for symptoms of
mental retardation.

      The sharp reduction  in lead emissions shows that pollution prevention
works; the failure to significantly reduce carbon monoxide and nitrogen oxide
emissions shows that the control strategy does not.

      How could the principles of pollution prevention be applied to carbon
monoxide and nitrogen oxides?  The basic principle is clear from the example
of lead: change the technology of production so as to eliminate the pollutant
at its point of origin.  The generation of both carbon monoxide and nitrogen
oxides is inherent  in the  operation of the automobile engine — in one case,
because of incomplete combustion, and in the other because of the elevated
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temperature of high-compression engines.  The principle, then, is to change
the engine so as to eliminate its propensity for producing these pollutants.
The generation of nitrogen oxides can be eliminated by reducing the engine's
compression ratio or by redesigning it to localize the high temperature (as is
done in the stratified charge engine.)  But carbon monoxide production can be
eliminated only by doing away with the internal combustion engine itself, for
example by using an electric motor instead.

      For the sake of this example, let us agree that both carbon monoxide
emissions and the generation of nitrogen oxides and the resultant
photochemical smog should be eliminated by replacing the present automobiles
with electrically driven ones.  The first fact to take note of is that this
clean automotive technology exists.  It was widely used in the 1920s when, as
I recall, the trucks operated by the Railway Express Company (the predecessor
of American Express) in New York City were driven by electric battery-powered
motors.  Indeed, General Motors has recently exhibited a prototype electric
car that they state will be produced for sale at some unspecified date.  Thus,
there is at present no technological barrier to replacing the present cars, at
least in urban areas, with electric ones, thereby eliminating most urban air
pollution — a notorious, unsolved environmental problem.

      Why, then, has this urgently needed example of pollution prevention not
been adopted?  There are, of course, numerous obstacles to this much-to-be-
desired eventuality.  The most important one is that General Motors is
understandably reluctant to invest in the necessary new production facilities
until a sufficiently large demand for the car is established.  Unlike
conventional cars, there is at present no existing market for electric cars.
And so we are frozen into inaction.

      Yet there is a way to break out of this paralysis and begin the large-
scale introduction of electric cars, at least in urban areas.  The federal
government buys about $7 billion of cars and trucks annually, many of which
could be suitably replaced by electric vehicles.  Many such vehicles are also
purchased by state and city governments.  Taxis, which make up a considerable
part of the traffic in cities like New York, although privately owned, are
subject to municipal regulations regarding their design.  Surely this
represents a demand for electric cars sufficient to enable General Motors to
invest in producing them — creating at once a market that will facilitate
private purchases as well.  In sum, federal and other government orders for
the purchase of electric cars -- or, for highway travel, cars with stratified
charge engines — is a practical way of generating the transformation in
transportation technology that is the only effective means of lifting the
heavy burden of vehicular air pollution.

      What can be done in the area of electric power production — another
major, persistent source of environmental pollution?  The environmental
consequences of our present technologies are well known: power plants that
burn coal, oil or natural gas afflict the environment with emissions of sulfur
dioxide, nitrogen oxides, dust, and a noxious mixture of organic compounds.
They generate a great deal of carbon dioxide that contributes to global
warming.  Nuclear power plants eliminate the carbon dioxide problem — but
only through a Faustian exchange with the intractable problems of radioactive
contamination.
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      Pollution prevention calls for a transformation in the technology of
power production.  It leads us, for example, to a source of electricity that
generates neither carbon dioxide, noxious air pollutants, nor radioactivity--
photovoltaic cells.  What stands in the way of adopting this ecologically
sound, clean technology is its price.  Photovoltaic cells and their auxiliary
equipment, such as batteries, are still too costly to compete in the major
market for utility electricity.  Photovoltaic cell production is already well
developed, and the small industry that now exists, chiefly in the United
States and Japan, is reliably supplying photovoltaic cells for portable
electronic appliances and remote installations — applications that do not
compete with electric utilities.

      Yet there is little motion toward large-scale application of
photovoltaic cells as a means of reducing the severe environmental impact of
the present, massive production of power from fossil fuels and nuclear
reactors.  Sharp price reductions could be achieved, and the market increased,
by greatly expanding production facilities, with the resultant economies of
scale.  But at the present price, the demand is small and insufficient to
justify the investments needed to expand production.

      Here, too, a government procurement program would solve the problem.
This is not a new idea.  Just such a program was proposed during the Carter
Administration, in the form of a bill — passed by Congress but vetoed by Mr.
Carter ~ for a $400 million purchase of photovoltaic cells for use in federal
installations.  (This proposal was based on earlier experience with the impact
of large-scale federal procurement of integrated circuit computer chips in the
1950s ~ which sharply expanded production and reduced their price by some 95%
over a five-year period and thereby created the present computer industry.)
It was estimated that a procurement program representing 150 megawatts of
power would reduce the then-current price of $20 per peak watt to $0.50 over a
five-year period.  As the price drops, the market for photovoltaic electricity
expands enormously.  At $1 per watt, photovoltaic cells become economically
feasible for roadside lighting, representing a demand of about 50,000
megawatts.  At $0.50 per peak watt, photovoltaic cells were expected to
complete with utility power in many parts of the country.  Once again, a
federal procurement plan, which could readily be augmented by state and
municipal purchases, would generate the demand needed to bring this pollution-
preventing, environmentally clean production technology into the market.

      Recycling is a major feature of pollution prevention, for by keeping
materials in their separate, useful state, it prevents the generation of
trash.  A major obstacle to large-scale recycling, which, as a recent CBNS
test has demonstrated, can dispose of as much as 84% of household trash, is
the lack of markets.  This difficulty in turn is largely due to the potential
users' reluctance to make the necessary investments in process modifications.
All this could change almost overnight if the federal (and other) governments
would simply decide to buy only recycled paper.

      How could the strategy of pollution prevention be applied to the
pervasive environmental problems generated by the heavy use of synthetic
pesticides and chemical nitrogen fertilizers in agriculture?  To prevent the
resultant environmental impact, which leads to pollution of groundwater and
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water supplies ~ and, all too frequently, to food unacceptably contaminated
with toxic pesticide residues — the technology of agricultural production
must be changed.  The heavy application of chemical nitrogen fertilizer must
give way to natural sources -- nitrogen-fixing plants and organic forms of
soil nitrogen — and pests must be controlled by their natural predators
instead of by synthetic chemicals.  We now know from a recent National
Research Council/National Academy of Sciences report that this is both
technically and economically feasible.  This confirms a much earlier CBNS
study that showed from a detailed comparison of a group of large-scale
Midwestern farms with otherwise similar, conventional ones that organic farms
produce only 8.5% less output but achieve exactly the same income per acre.

      What stands in the way of transforming U.S. agriculture — wholesale —
from its present chemically based technology to organic farming?  In fact,
this transformation is already under way, albeit slowly, for organically grown
fruits and vegetables are now in the market, appearing regularly, for example,
on the shelves of New York City supermarkets.  However, organic food sells at
a price premium of as much as 50%.  This effectively limits the market to
affluent people, separating the food supply into two streams, one free of
chemical contamination but available only to the rich, and the other, often
contaminated by pesticide residues, but available to the poor.

      Apart from the untoward moral consequences of this situation, the small
market for organic food prevents economies of scale and perpetuates the high
prices that stand in the way of large-scale expansion.  A major obstacle is
that it may take five years or more after chemical agriculture is stopped for
the natural fertility of the soil and the natural balance between pests and
predators to be restored — a period in which the farmer may need federal
support.  Again, these difficulties could be readily overcome by procuring
organic produce for cafeterias and restaurants that serve federal
establishments.  Imagine the impact of a White House state dinner free of
agricultural chemicals and a menu printed on recycled paper.

      Thus, we are at a crucial point in the 20-year effort to clean up the
environment.  We have made a massive attempt to significantly reduce pollution
levels with control devices ~ and have failed.  But we have learned what
works: preventing pollution by transforming the production technology that
generates the pollutant, to eliminate it.  We also know that the necessary
clean technologies are largely in hand.  Yet this is the only workable way of
responding to the insistent public demand for environmental action.  We are
confronted, therefore, by the intimidating prospect of a radical
transformation of the national system of product — in agriculture,
transportation, energy, and manufacturing.

      Nevertheless, I have demonstrated, I believe — here, in an earlier
account in the EPA Journal, and in more detail in my recent book, Making Peace
with the Planet — that there is a powerful tool, in the hands of federal and
state governments and even some municipalities, that can break us out of this
impasse:  government procurement of the clean technologies.
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      That we are at a momentous, historic juncture has been recognized by
William K. Reilly, the EPA Administrator, who recently said:

      "...The dawning of the third environmental decade finds us at a historic
      turning-point ~ a time when we must find a new approach to meeting our
      needs...a new approach to managing waste: pollution prevention."

Moreover, in testimony to Congress, Mr. Reilly has cited the importance of
using federal procurement programs to develop markets for recycled materials
and other products of clean pollution prevention-guided technologies.
Finally, principles of pollution prevention have been embraced by President
Bush himself when, last June, in an address to a Washington environmental
group, he declared himself not only an environmentalist but a preventionist as
well.  And, given the fortuitous timing of Earth Day 1990 — when the whole
world was engrossed with environmental concerns ~ there was a marvelous
opportunity for Mr. Bush to respond by taking the one step that would begin to
put pollution prevention into action: government procurement.

      I say all this to explain my enthusiastic reaction to the discovery,
shortly before Earth Day, that the EPA had, in fact, moved to turn that event
into a truly historic one.  EPA had prepared, for Mr. Bush's approval, a
Presidential Executive Order, to be announced on Earth Day, that would set in
motion a comprehensive federal procurement program, soundly derived from the
principles of pollution prevention.  The objectives of the proposed order are
worth quoting in  full, for they reflect a deep understanding of the nature and
significance of the new policy:

      WHEREAS, traditional environmental protection approaches which stress
      treatment and disposal after pollutants have been generated will not be
      adequate to assure protection of human health and the environment.
      Pollution prevention and recycling must become the focus of our long-
      term strategy for environmental protection, and

      WHEREAS, the Federal government can no longer view energy,
      transportation, agriculture, and natural resource policies as discrete
      from the Nation's long term environmental protection objectives.  These
      policies must become instruments to achieve the protection of human
      health and  the sustainable development of our resources in an
      ecologically safe manner,  and

      WHEREAS, the Federal government  should become a leader  in the area of
      pollution prevention,  recycling, and procurement.  The  Federal
      government  should function as a  proving ground for innovative pollution
      prevention  programs and technologies,  should build markets for clean
      products, and should incorporate pollution prevention  into the basic
      daily  choices of Federal employees, and

      WHEREAS, as the single largest  consumer  in the Nation,  the Federal
      government  has the opportunity  and the responsibility  to move  into the
      forefront of pollution prevention  and  solid waste management by both
      reducing the amount of waste that  the  government produces  in the first
      place,  and  by recycling as much  of the remaining waste  as  possible.
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      The executive order calls on "...all Federal Agencies, and Government-
owned, contractor operated facilities (GOCOs) [to] reduce the generation of
pollutants and waste...and set an example for the rest of society through the
development of pollution prevention, recycling, and procurement programs...
[to] stimulate demand and markets for clean, recyclable and recycled materials
by revising procurement policies and specifications."

      Section 506(c) of the proposed Executive Order gives the EPA
Administrator the authority to take actions that would put the Federal
procurement program that I have outlined in place:

         "The Administrator of the Environmental Protection Agency
      shall...'provide guidance to assist procuring agencies in promoting the
      purchase of recycled products, clean technologies and products, and
      products that maximize energy or water efficiency and conservation."1

      Under these terms, "clean technologies and products" would include
electric cars and organic foods, and "products that maximize energy or water
efficiency and conservation" would include photovoltaic cells.

      So, I am happy to report that under Mr. Reilly's leadership, EPA has
devised a program that would put pollution prevention into practice — an
action that could have turned Earth Day 1990 into a truly historic event.
Unhappily, I must also report that the proposed Executive Order was killed by
the President's Domestic Policy Council.

      That President Bush failed to seize this opportunity to endow Earth Day
1990 with the momentous content that it merited —• he went fishing instead ~
can be traced, I believe, to his Chief of Staff, Mr. Sununu.  In his powerful
position, which includes a guiding role in the Domestic Policy Council, Mr.
Sununu, often abetted by Richard Darman, Director of the Office of Management
and Budget, has a record of environmental obstructionism.  Mr. Sununu
intervened to overrule EPA and seriously weaken the Administration's position
on remedying global warming and ozone depletion, on wetlands protection, and
on air pollution legislation.  We are told by the White House that Mr. Sununu
simply prepares options for the President's consideration and "insures that
all points of view are heard."  But to my knowledge there is no evidence that
the EPA's historic Executive Order ever escaped from the deadly confines of
the Domestic Policy Council and reached the President.  Perhaps it did, but
got lost in his tackle box.

      Had Mr. Bush in fact issued the Executive Order proposed by EPA, the
country and the world would have been galvanized  into action — but this time,
unlike 1970, guided by the only workable environmental strategy: pollution
prevention.  This would have been a magnificent act of leadership, converting
the despair and anguish over the fate of the Earth often voiced by Earth Day
participants into a meaningful movement to restore the natural environment.
Earth Day cried out for leadership, and EPA's courageous, far-sighted proposal
provided the necessary vehicle.  In blocking the  EPA proposal, Mr. Sununu
deprived Mr. Bush of a historic opportunity to lead.  And Earth Day, thereby
drained of significant content, became only a brief, if noisy — but
unanswered — outcry for help.
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      The obstruction of EPA's Executive Order is not only a blow to the
Nation's environmental future; it also diminishes the power of American
democracy.  The demand for real environmental  improvement is a national
commitment which, as we know, can be realized  only by changing the pattern of
industrial investment.  But these decisions are in private, largely corporate
hands, and inaccessible — thus far — to the  American people.  Democracy
stops at the door to the corporate boardroom.

      The government's massive purchasing power is the only means, at present,
of influencing the pervasive corporate decisions that now govern our system of
production.  This power is an important instrument of American democracy.  For
the sake of the environment and of democracy itself,  it is time that we used
it.
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               INFORMATION NETWORKING FOR POLLUTION PREVENTION

                 by:  Daniel E. Cooper
                      Chief, Special Projects
                      Alabama Department of Environmental Management (ADEM)
                      1751 Cong. W. L. Dickinson Drive
                      Montgomery, AL    36130

    The  networking  of "pollution prevention"  information  extends  beyond the
normally  accepted  definitions  of  "business".   The  need  for  educational
materials and  technical   assistance  is present  in  governmental  agencies,  as
well  as  associations and private  citizen groups.  The concept  of expanding
the  "business  to business"  idea  to other  affected  parties gave  way  to the
May 31,  1989  formation  of The Alabama Waste  Minimization  Advisory Committee
(WMAC).  A  brief history of the Committee  development was provided  in Mr.
David Roberson's presentation.

    I will  focus my  comments  on the  Goals and  Objectives  of the  WMAC and
particularly emphasize  the committee  structure  and activities which enhance
information transfer.  The  purpose  statement of the committee is to "develop
voluntary programs  for  the  minimization  of wastes generated  in Alabama and
disseminate   appropriate    information  to   affected   groups".    Committee
objectives under development are listed below:

        Waste Reduction  Opportunity Assessments
        Pilot Projects for Waste Reduction
        Technical Assistance Program
        Pure Prevention  Strategy
        Small  Business Assistance
        Public Awareness Strategy
        Success Recognition Program
        Long Range Program Support

    The WMAC structure was established by soliciting committee members  from
affected  groups,  agencies  and departments.   The   Director  of  ADEM  then
appointed the  members to serve on  the Committee which meets on a quarterly
basis.  The Committee structure is  as follows:

        Department of Education - 1  member
        Department of Economic and  Community Affairs  - 1 member
        Association  of County Commissioners  - 1  member
        League  of Municipalities -  1  member
        Business Council of Alabama  - 1 member
        Alabama Chemical Association -  1 member
        Public  at Large  -  2 members
        ADEM -  Support Staff
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    Time does  not  permit for a full discussion of  the committee activities,
so I  will  use  my time to  highlight  committee  objectives  which are extremely
visible and positive.


                   Waste Reduction Opportunity  Assessments

    The  Waste  Reduction  Opportunity Assessment  program also  known as  The
Waste Reduction  and  Technology  Transfer program is  rapidly  emerging from the
development  phase   to   the   implementation  phase.   On May  30,  1990,  a
Memorandum  of  Understanding  (MOU) was  executed with the  Tennessee  Valley
Authority   (TVA),   ADEM,  and  Shoals,   Incorporated,  a  not   for  profit
organization  chartered  in  the  State  of  Alabama.   This  MOU  defines  the
working relationship among the  parties  as we develop and implement the Waste
Reduction  Opportunity  Assessment  program.   More  specific  information  is
provided in the following text.

    Waste  assessments,  sometimes  called  waste  audits,  are  an  essential
component  of  a  waste  reduction  program.  Such   audits  show  where  waste
reduction methods can  be most effective; where they can be  used for planning
and  allocating  resources;  and  where  they can  be  used  to measure  waste
reduction progress.

    Utilizing  retired  engineers  and scientists with  supplemental  assistance
and  training,  provided  by  the  University of  Alabama  Hazardous  Material
Management  and  Resource  Recovery Program (HAMMARR),  the  Tennessee  Valley
Authority  and  the  State  of  Alabama are  implementing the  program  elements
listed below:

        a.  recruiting  and   training  retired  engineers  to   conduct  waste
           assessments;
        b.  conducting on-site waste assessments on a request basis to:
           1. identifing  the types  and amounts of waste  generated in  all
              media by the various processes in the  plant;
           2. identifing the  major material losses and their causes;
           3. identifing and  evaluate potential waste reduction  methods;
           4. itemizing current waste management  costs;
           5. estimating the  cost  of different  waste reduction practices;  and
           6. presenting findings  and recommendations to management.

        c.  identifing needs  for  technical  assistance  in  basic  research  for
           new  and  improved  technology,   and  applied  research  to  meet
           pressing  and  specific  needs  in   industrial  by-products and/or
           hazardous materials management.   The needs  identified  will  serve
           as suggestions for research projects to the HAMMARR program,  the
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           Gulf  Coast   Hazardous  Substance  Research   Center,   and  other
           research organizations.

                       Education  and Public Awareness

    Recognizing  the  need for  educational  materials, for  k through  12,  and
post  secondary education,  and the  need  to  educate  the general  public  to
Increase   the   overall   awareness   and    understanding   of    pollution
prevention/waste reduction,  the  State  of  Alabama utilizes  the resources  of
the Waste Minimization Advisory Committee to:

           a. develop a speakers bureau;
           b. develop   educational/instructional   materials  for   use   by
              speakers;
           c. develop and  implement procedures to facilitate  the  sharing  of
              Information  among  organizations   represented  on   the  Waste
              Minimization Advisory Committee;
           d. develop   and   implement  .procedures   to   identify   existing
              educational  and technical assistance  resources, and  to  make
              those resources accessible to the member organizations;
           e. Identify needs  for  curricula development 1n k through  12,  and
              post secondary education;  and
           f. identify and develop strategies  for increasing public
              awareness of pollution prevention/waste reduction.

    In summary,  I  would  say  that programs for waste reduction or pollution
prevention  can  be   developed to   fit  a wide  variety  of   institutional
arrangements.   The  central   theme  however  should   be   that  tasks  can  be
tailored to each state's specific needs utilizing the resources  of both the
public sector  as well  as private  enterprise to form  a partnership which will
lead to a successful  program.
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          FACILITY-SPECIFIC WASTE MINIMIZATION PLANS AT
                  WESTIN6HOUSE HANFORD COMPANY

             by:  P.A. Craig
                 Westinghouse Hanford Company
                 Richland,  WA  99532
                            ABSTRACT

     A waste minimization program is required by public law and
Federal and State regulations for hazardous waste generators and
treatment, storage, and disposal facilities.  The U.S. Department
of Energy (DOE) has directed its contractors to develop an
effective strategy to minimize the generation of hazardous,
radioactive, and mixed wastes at the Hanford Site in compliance
with State and Federal regulations.

     Since Westinghouse Hanford Company (Westinghouse Hanford)
has a large and diversified operation, a key component of the
Westinghouse Hanford waste minimization program is facility-
specific waste minimization plans that document present and
future activities to reduce the volume and toxicity of waste
generated.  Preparation and implementation of these plans will
demonstrate facility compliance to Westinghouse Hanford and DOE
requirements, as well as State and Federal regulations.  The
plans include both the goals and the activities for their
achievement and provide a basis for evaluation.

     Preparation of the plans is divided into two phases.  The
first phase involves writing the "general" plan that describes
the facility operations, the types of waste produced, and the
administrative controls used by the facility to ensure waste
minimization.  The second phase involves a detailed
characterization of each waste stream.  This characterization
includes baselining the quantity of waste generated,
brainstorming possible options to minimize waste, and documenting
other factors, such as cost and environmental and safety issues,
involved with the generation of the waste.  This section is ever-
changing as more information is obtained and as the waste
minimization program evolves.
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     The general section of the facility-specific plans was
prepared by most facilities by December 30, 1989.  Phase two, the
detailed characterization of each individual waste stream and the
setting of goals, has just begun.

INTRODUCTION
     A waste minimization program is required by public law and
by Federal and State regulations for hazardous waste generators
and treatment, storage, and disposal facilities.  The DOE has
directed its contractors to develop an effective strategy to
minimize the generation of hazardous, radioactive, and mixed
wastes at the Hanford Site in order to achieve compliance with
State and Federal regulations.
     The Department of Energy-Richland Operations Office (DOE-
RL) manages the activities at the Hanford Site located in
southeastern Washington State.  Westinghouse Hanford is one of
four contractors that currently operate the Hanford Site for DOE-
RL.  Westinghouse Hanford employs approximately 9,000 people and
manages a number of diversified operations:

     o    Advanced reactor development
     o    Chemical processing
     o    Waste management
     o    Environmental restoration
     o    Site support services
     o    Computer and data management.

WASTE MINIMIZATION PROGRAM
     Each DOE-RL contractor has designed and is implementing its
own waste minimization program within the structure of DOE-RL's
Hanford Site Waste Minimization and Pollution Prevention
Awareness Plan.  As shown in Figure 1, Westinghouse Hanford's
Waste Minimization Program requires support from the
Environmental Division, Waste Management Division, Communications
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Department, and each facility that generates waste.   The
Environmental Division, which provides oversight  for  the Waste
Minimization Program,  ensures that the program complies with all
applicable regulations and DOE orders; verifies that  waste
minimization is considered in all planning documents,  activities,
and new projects; and oversees preparation of progress reports as
required by the DOE, as well as other Federal and State
regulatory agencies.
     A Waste Minimization Team has been formed within the Defense
Waste Management Division and is chartered to develop,
coordinate, and implement a company waste minimization program.
The Waste Minimization Team provides guidance to  individual
generating facilities and develops and implements waste
minimization programs that have company-wide applicability and
benefits.

      Figure 1. Westragbouse Hanferd Company Waste Minimization Program
                       Implementation Hierarchy

J
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Operation
1
BMpWPttHMlQU mSt/0
(ftiitelaAataimnt


Environments'
Division


1^^^^^ COfiMinllMttMOflft

Defense Waate
Management Otvtoon


Dip«imant

1 1 1
Engineering and
DeveMpment
OpMattom Safety. Quality
Support Aaeureme anil
••Mill •aourtty

1
Information
RMOurc*
Management
                                                    SMMM1.1IM
     The Communications  Department is responsible for
coordinating  the  Environmental  Awareness Program which includes
the training  and  awareness  aspects of waste minimization and
pollution prevention,  as well  as the development of employee
incentives  and  rewards to encourage participation.
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     Each waste-generating facility is required to incorporate a
waste minimization philosophy into its operations.  Assessments,
priorities, goals, and implementation of waste minimization
opportunities are the responsibility of each waste-generation
organization.  Documentation of these efforts is provided through
facility-specific waste minimization plans.

FACILITY-SPECIFIC WASTE MINIMIZATION PLANS
     The large and diversified nature of operations within
Westinghouse Hanford requires that detailed plans be developed at
each waste-generating facility.  These plans, entitled Facility-
Specific Waste Minimization Plans, document the present and
future activities to reduce the quantity and toxicity of waste
generated.  The facility-specific waste minimization plans are
considered "living documents," meaning they are periodically
updated to reflect the current status of the facility's waste
minimization program.  These plans will, therefore, remain in the
system as long as the facility continues to generate waste.
     To ensure consistency in content and format throughout all
facilities, a guidance document for writing waste minimization
plans was developed.  This guidance document divided the
preparation of facility plans into two stages:  (1) the program
development phase, and (2) the implementation phase.  Figure 2
shows an outline of the facility-specific waste minimization
plans.

PROGRAM DEVELOPMENT
     The body of each facility-specific waste minimization plan
is essentially composed of (1) a facility description, and (2) a
definition of the facility's waste minimization program
structure.
     The description of the facility's operations provides
background information on the purpose, scope, and scale of work
routinely conducted at the facility.  The major chemicals and
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              Figure 2. Facility-Specific Waste Minimization Plan Outline.
                                 1.0 INTRODUCTION
         1.1 PURPOSE AND SCOPE OF PLAN
         1.2 FACILITY BACKGROUND
           1.2.1 Facility Description
           1.2.2 Material Use
           1.2.3 Major Categories of Waste Streams

                          2.0 WASTE MINIMIZATION PROGRAM

         2.1 Waste Minimization Organization
         2.2 Responsibilities
         2.3 Training Program
         2 4 Employee Participation and Incentive Program
         2.5 Waste Minimization for New Projects and Designs

                                   APPENDICES

         Appendix A Waste Stream Identification and
         Minimization Potential
           A.1 Origin
           A.2 Regulatory Status
           A.3 Quantity Generated
           A.4 Costs
           A.5 Environmental and Safety Impacts
           A.6 Waste Minimization Potential
         Appendix B Goals and Progress Reports
           B.I Goals
           B.2 Waste Minimization Accomplishments
materials  used  by the facility are also  described here,  as well
as  the types and approximate quantities  of waste generated.
      The plan defines the  structure of the facility's waste
minimization program  and describes the steps  being  taken to
develop and maintain  an effective  waste  minimization program
within the facility.   Here,  the plan describes the
responsibilities of each facility  employee with respect  to waste
minimization and identifies  the members  of the facility's waste
minimization team.  Additional topics described in  this  section
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of the plan include the facility's training on waste minimization

and the use of an incentive program to encourage employee

participation.  Also discussed are the methods used at the

facility to ensure that all new projects and facility upgrades

are reviewed with respect to the minimization of waste.


IMPLEMENTATION
     Documentation of waste minimization implementation

activities consists of two appendices that are updated as

information changes to keep the facility-specific plans current.

Appendix A of the facility-specific plans provides detailed

characterization of each waste stream.  The following elements

are provided for each waste stre.am:


     o    Origin - The process that generates the waste is
          described.

     o    Regulatory Status - The waste stream is characterized
          with respect to hazardous and radiological constituents
          according to State and Federal regulations and DOE
          orders.  Applicable waste codes are identified.

     o    Quantity Generated - This difficult but necessary
          section requires a quantifiable baseline of the
          quantity of waste generated.  Depending on the origin
          of the waste (e.g., routine operations, equipment
          decommissioning and replacement, materials and product
          disposal, or cleanup activities), the method of
          baselining is different.  Waste generated from routine
          operations may or may not be directly dependent on the
          production rate.  For waste that is related to
          production, it is important to make this relationship
          part of the measurement device  (e.g., gallons of
          waste/widget) so that a change in product will not
          cause a distortion of the measurement.  Waste generated
          from equipment decommissioning and replacement,
          material and product disposal, or cleanup activities is
          dependent on the time and funding devoted to perform
          those activities and, therefore, it is very difficult
          to determine a meaningful baseline.  However, some
          quantitative measurement is requirement to show the
          effects, if any, that waste minimization techniques
          have had on the quantity of waste generated.
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          Costs - The costs for managing,  storing,  and disposing
          of each waste stream are discussed.   This generally
          includes an estimate of the long-term storage and
          disposal costs for mixed waste.
          Environmental and Safety Impacts - The potential
          environmental and safety impacts associated with the
          generation of each waste stream are identified.
          Waste Minimization Potential - All possible waste
          minimization opportunities are listed.  The U.S.
          Environmental Protection Agency (EPA) chart on waste
          minimization techniques is used as a brainstorming
          tool.  Opportunities are investigated for feasibility
          at a later date.
     This characterization procedure is intended to prioritize
the waste streams for which the facility should concentrate its
efforts.  A likely candidate would be a large stream that has
several regulated characteristics, may have significant
environmental and/or safety impacts, and appears to have several
opportunities for minimization.
     Appendix B of the facility-specific waste minimization plan
is entitled "Goals and Progress Reports."  Each facility is
required to set annual goals toward waste minimization.  The
goals may address specific waste minimization implementation
ideas or include studies to obtain information for characterizing
an individual stream.
     Each quarter, the facility representatives report their
progress made toward achieving its goals.  Annually, at the end
of December, the quarterly report also includes an accomplishment
report that details the results of waste streams that were
successfully minimized.  These accomplishment reports are used to
prepare reports for the DOE, as well as other State and Federal
agencies.
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RESULTS
     Twenty-nine facility-specific waste minimization plans have
been identified to cover all hazardous, radioactive, and mixed
waste generated by Westinghouse Hanford.  These plans range in
complexity from the Hanford Patrol, which generates small volumes
of gun-cleaning solvent and rags, to the major chemical
processing plants that generate millions of gallons of liquid
waste and thousands of pounds of solid waste.  The recently
strengthened emphasis on environmental cleanup at the Hanford
Site is expected to have a major impact on waste management
activities.  While these cleanup and closure activities will be
generating large quantities of liquid, solid, and sludge waste,
the potential for minimizing this waste is still present and is
being addressed in facility-specific waste minimization plans.
     Employee awareness of waste minimization and facility-
specific plans varies across the company.  Upper management is
very supportive of the waste minimization program.  Most
facilities have jumped into the program eagerly, while some have
been slower in responding because of other regulatory
requirements and shortage of personnel.  Waste minimization teams
have been established at many facilities and are meeting on a
regular basis.  The current emphasis at most facilities is on
stream characterization, the development of waste minimization
goals, and employee awareness projects.
     In one instance, a facility has banned a particularly
hazardous product used for radioactive decontamination purposes,
because of the inevitable generation of mixed waste.  The
facility management has offered several nonregulated substitutes
to its operators for this task.  This banned product is currently
used extensively across the company, and other facilities are
awaiting the results of the experimentation with the new
substitutes so that they can substitute nonregulated products
into their processes.
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     Facilities are active in cleaning out their old products and
unknown chemicals.  While this is generating large quantities of
waste at the present, better inventory practices and management
procedures will hopefully prevent the situation in the future.  A
sitewide chemical exchange has been initiated to assist
facilities in finding users for chemicals they no longer need.
This is intended to save on purchase costs, as well as to provide
a significant savings in waste disposal.
     Several facility representatives have joined together to
work on common problems.  The first task team is investigating
degreasing agents in search of an effective substitute for
hazardous products currently being used.
     Westinghouse Hanford is assisting facility efforts by
providing forums for facility representatives to exchange ideas.
Informational mailings are also used to communicate activities
and successes of other organizations both onsite and offsite.
Facilities are being encouraged to show company-owned commercial
videos on waste minimization to their employees in an effort to
educate and spark interest in their facility-specific programs.
     One major element missing from the facility-specific plans
is a method to evaluate potential waste minimization
opportunities.  It is important that each potential solution be
fully evaluated and tested before implementation.  This has not
posed a problem yet, but is an area that will need to be
addressed in the near future.

CONCLUSION
     Facility-specific plans provide a method for bringing the
responsibility of waste minimization to those best suited to
produce results.  However, the process takes time.  Employee
awareness and education play a key role in the success of a waste
minimization program.  This awareness and education must be
directed to each  employee, from the company president to the
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personnel who work with budgets, procurement, who work in
offices, and who directly generate waste.  Few can argue the
benefits of minimizing waste when they understand the process and
why it is necessary.
     A major concern at Westinghouse Hanford continues to be the
development of effective baseline generation values with which to
measure waste minimization or reduction successes.  Regulatory
reports require quantitative results for waste that has been
minimized, and the future hints at required percentage reductions
through State or Federal avenues.  Without an effective baseline
for the waste that is currently being generated, it is impossible
to prove that minimization has occurred.  The tie to production
is necessary whenever possible, and Westinghouse Hanford is
finding that the majority of the waste generated cannot be tied
to a production ratio.
     Although no waste minimization program can be effective
without involvement by the people working directly in processes
that generate the waste, strong company-wide programs, such as
employee incentives and rewards, chemical exchange, recycling,
and procurement control, are also necessary to support the
detailed facility-specific efforts.  Westinghouse Hanford
recognizes the long-term benefits from minimizing the waste we
generate, and we believe we have a strong program that will lead
to success.
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          EUROPEAN EXPERIENCES IN STIMULATING CLEANER TECHNOLOGIES

                 by:   Dr. J. Cramer
                       TNO Center for Technology and Policy Studies
                       P.O. Box 541
                       7300 AM  APELDOORN
                 and:  Drs. F. van den Akker
                       Ministry of Housing, Physical Planning and
                       Environment
                       P.O. Box 450
                       2260 MB  LEIDSCHENDAM
                                INTRODUCTION
     Growing  awareness  of  environmental  degradation  has  led  to  many
European  countries  placing  increased  emphasis  on  the  development  and
implementation  of  cleaner technologies. Leading countries  in this respect
are  particularly  the  Scandinavian  countries,  the  Netherlands and  West-
Germany.  By  'cleaner technologies'  we  mean the whole  spectrum of add-on,
pollution abatement technologies versus integrated,  low-emission production
technologies,  designed  to  avoid  most  of the  pollutants  at the  source
(including changes in both process technology and product substitution).
The direct,  more structural government  interference  with  cleaner  technol-
ogies started  in various European countries in the mid 1970s.  A series  of
specific  measures  were  introduced to  encourage industry to  adopt cleaner
technologies:  financial  assistance,   research  and development programmes,
dissemination  of  technical  information,  adapting  regulations to  favour
cleaner  technologies,  etc.  This  paper aims to summarize  the experiences
gained  particularly  in  the various  Northern-European  countries in  stimu-
lating  cleaner  technologies  and discuss the  possible ways to proceed.  An
important element in promoting cleaner technology is the focus on the whole
product's life-cycle and the measures which could be  taken to increase the
awareness of  the environmental  aspects of the  product's  history and the
environmental  consequences  of  its use.  In this context special  attention
will be paid to  'Environmental Product Information-Exchange'  (EPIE) and the
'Environmental  Product  Profile'  (EPP).  It  will be discussed whether such
information  could be  used  as a  policy tool.  In  evaluating  the  European
experiences  use will  be made  of various reports  on this  topic and  in
particular of the  conclusions drawn  at  the recent  ECE seminar on 'Economic
Implications of  Low-Waste Technology',  held in  The  Hague (the Netherlands)
in October 1989.
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          PRACTICAL  EXPERIENCES WITH CLEANER TECHNOLOGY POLICIES
     In promoting  the development and implementation of  cleaner technolo-
gies most  European countries  have traditionally devoted  a great  deal  of
attention  to  the use  of legislated, regulatory  measures,  coupled  with  a
system  of  monitoring  and  sanctioning  non-compliance.   Although  direct
regulations have enabled government authorities to control the behaviour of
industries to a large extent, this form of regulation does have a number of
limitations.  The  costs  of  developing and enforcing  regulatory programmes
are high and it takes a long time before new regulations can be implemented
in  practice.  In  addition,  many  countries lack  a  sufficiently developed
infrastructure  to control  the implementation  of  appropriate  legislative
provisions  and  related regulations. Moreover,  the  prevailing single-media
oriented environmental  legislation inhibits the integration of legislation
directed  towards pollution  prevention.   Finally,  the  kind  of  mechanical
command-control relationship, in which the government tries to force indus-
tries to meet certain emission standards,  often restrains industry to play
an active  role in developing and implementing preventive technologies. As a
result  regulatory measures have  mainly  led  to the application  of add-on
pollution  control equipment and far less to process-integrated technologies
and product-substitutions.

     In order to overcome the limitations of regulatory programmes, several
European  countries  have developed additional measures, especially  in the
form of economic incentives or disincentives.  These  include incentives in
the form  of loans, subsidies,  tax relief and  exemptions,  grants,  etc.  or
disincentives in the form of taxes, fines, charges, performance bonds, etc.
In  contrast  to  the United  States  European countries did  not intervene in
the market structure  by allowing  a trade in pollution  rights  (bubbles,
offsets, netting  and  banking).  Only minor applications  are seen in Germany
(1) .
Generally  speaking, until now only limited use has been made of the various
economic  instruments.  Given that  charges and  subsidy  funds are  the most
often implemented economic instruments to stimulate cleaner technologies we
will dwell below  in some detail upon the experiences gained in Europe with
these particular instruments.

     Charges, particularly  effluent  and  user  charges,  have been introduced
in various West-European countries but often without much incentive  impact.
These charges were often too low and mainly directed at raising  revenues to
cover the  costs of the  services  involved.  Effluent charges were generally
introduced in  connection  with  issues  of  water- and  air-pollution. User
charges are more  common as regards the collection and treatment of  munici-
pal solid  waste and waste water discharged into sewers.
More and more attention is being given to product charges, for  instance on
fuel  (e.g.,  the Netherlands),  packaging (e.g., Denmark),  certain batteries
(e.g., Sweden), waste  oil  (e.g., Finland), non-refillable containers (e.g.,
Norway)  and  carbon   dioxyde   (e.g.,  the  Netherlands).   Some  countries,
including  the Netherlands,  are considering the extension of the number of
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years thereafter.

     Experiences have learned that the application of economic instruments,
in particular  charges  and financial aid programmes, may  have an incentive
impact  on  the promotion  of  cleaner technologies,  if properly  applied and
used  in  combination  with  other  instruments.  However,  similar  to  the
experiences  with legal  instruments both  charges  and  financial aid  pro-
grammes  have also led mainly  to the development of  end-of-pipe,  curative
technologies,  while  investments in preventive technologies  lagged  behind.
Due to  the government's  focus  on a short term  environmental policy,  most
attention  has  been  paid to the  solution of  acute,  environmental problems.
This has led to a reactive, effect-oriented policy  aiming  at the elimina-
tion  of the environmental  effects mainly  through  the establishment  of
technical  standards.  In  order  to  meet  these  standards  industry  could
suffice by implementing additional end-of-pipe technologies.
            ADJUSTMENT OF PRESENT LEGAL AND  ECONOMIC  INSTRUMENTS
     To  facilitate the promotion  of cleaner technologies  various sugges-
tions have been made to adjust the legal and economic instruments presently
used.  Most  of  these  suggestions, however,  have often  not been  put into
practice yet. Let us give some examples.
ADJUSTMENT OF LEGAL INSTRUMENTS
     With  respect to  legal regulations  it  is  proposed to  modify,  where
necessary, the implementation of legal regulations through improvements and
greater  flexibility giving industry  more  latitude  in  its  technological
policies  (4) . Experiences have  learned that  strict regulation coupled with
a flexible implementation can lead to the desired changes. If, for example,
it is unclear whether and how the government will adjust its regulations in
the near future, industry will tend to react rather conservatively and will
postpone major investments  in production  modifications.  On the other hand,
a timetable  for alterations in  rates  covering a  sufficiently  long period
would enable  industry  to take appropriate action  in  full knowledge of the
facts. In this way the government  can,  so to  say,  'force' the introduction
of  cleaner  technologies.  Independent  research-institutes  can  play  an
important mediating role in this process.
One of  the major obstacles in  realizing this  suggestion is  the enormous
differences  in  environmental standards  and  the  respective  environmental
administration systems in the various European countries. Thereby the force
of introducing  or implementing  cleaner technologies  differs considerably
too.  Countries  with strict environmental standards  tend to  take the lead
concerning the development  of cleaner  technologies (5).  How this situation
will  change  after  the  establishment  of  the  Internal  EC  Market  in 1992
cannot be predicted. Fear exists that  the EC  environmental policy tends to
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water down legislation to  the  lowest  common  denominator of the policies of
the EC  Member States. Under the present  structure of  EC decision-making
only a greater overall commitment to EC environmental policy on the part of
all Member States could lead to stronger legislation (Bartle, 1990).

     Beside  the  greater flexibility,  existing legislation  and regulation
practices should  also be  examined  and modified,  aiming at  ensuring inte-
grated pollution  control based on the concept of  low-waste  technology. To
this effect,  the  following legal  and  administrative measures were proposed
at the recent ECE Seminar  on Economic Implications of Low-waste Technology
(16-19 October 1989, The Hague, the Netherlands).  These measures should:
a)   contain  provisions to promote the application of the low-waste concept
     at the earliest phase of production/consumption processes, e.g.  at all
     planning and  design   stages  in  the  product's  life-cycle,  namely
     manufacturing  processes,  use  and  disposal,   in   order   to  minimize
     waste/pollution  generation and its environmental  impacts. An example
     of  such provisions is  the obligation  to carry out  properly defined
     environmental  audits  which  should  be  included  in  plant   licenses,
     regulations  or other  appropriate  legal instruments.
b)   provide  for  the analysis  and  evaluation  of  possible environmental
     impacts  of  activities  and related technological  options  in the  con-
     struction,  operation  and abandonment  phases. This  may  involve re-
     thinking a  process to  seek  an alternative method of operation  using
     environmentally  sound technologies with due consideration being  given
     to the  need  for  mitigation and compensation for environmental damage.
c)   tighten responsibility  and  liability  regulations  for  all societal
     actors   to  play a  forceful  anticipatory role,  including  preventive
     duties,  through wider  implementation of low-waste technology.  Espe-
     cially  industry could use such  a concept as  a tool to predict  future
     expenditures related  to responsibility and liability questions.  There
     is  no  doubt  that  the risk of having to pay  could be  reduced by the
     progressive  adoption  of low-waste technology.
ADJUSTMENT  OF  ECONOMIC INSTRUMENTS
      Governments  can also  improve  the  use  of  economic  instruments  (particu-
 larly charges  and  financial  aid programmes)  to promote  cleaner  techno-
 logies.  At the ECE seminar on 'Economic Implications  of  Low-Waste  Technol-
 ogy'   it   was   recommended  that  charges  (on  e.g.  polluting  techniques,
 products,  raw materials or social activities) should  meet  certain  require-
 ments in order to be effective. They  should  be reasonably high, set  for  a
 considerable  period  of  time  and  aimed  at specific environmental  objectives.
 The  role of subsidy programmes  in stimulating cleaner technologies can be
 reinforced as well.  At  the ECE seminar mentioned above it was, for  example,
 concluded that financial  aid programmes  for R&D  in  cleaner technologies
 must  be  efficiently administrated  and co-ordinated  with other  forms of
 financial assistance and  the main components  of environmental policy. At
 present  R&D  funds  are often  insufficiently directed  towards long-term,
 internationally co-ordinated programmes focusing on  cleaner  technologies.
                                  191

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Moreover, efforts must be  made  to improve the access to aid  for  small  and
medium-sized firms, which  at present receive only a  very minor part  of  the
aid.
In principle,  aid  for pollution control may also have  an  incentive  impact
on the  promotion of  cleaner technologies.  However,  doubts were  raised at
the  ECE  seminar  about  the  effectiveness  of  providing  such  investment
grants. As  long  as firms are not interested in applying low  and  non-waste
technologies,  grants  often seem to be  a  waste  of money,  whereas, if they
are willing to make use  of such technologies, they will usually do so even
without  financial  aid.  Despite  this  general  scepticism  some exceptions
should  be mentioned.  In the case  of  urgent  environmental  problems,  for
example,  financial  aid or  cost-sharing  arrangements can  be  effective,  in
particular  for smaller firms.  It is also  true  that subsidies reduce  the
economic  risks inherent  in developing process-integrated  technologies  and
product-substitutions. They can therefore  be beneficial if granted subject
to stringent conditions  (7).

     To  sum up,  it  can  be  stated  that one of  the major  problems  facing
European governments  at present is to find out how they can best induce  the
industrial  sector  to change over  to  preventive  technologies instead of
favouring add-on technologies.  In order to use  governmental policy instru-
ments more efficiently in developing cleaner technologies the necessity was
stressed at the  ECE seminar on  'Economic Implications of Low-waste Technol-
ogy' to  broaden  the  present regulatory perspective and reorient it towards
an  environmentally sound  business  strategy for enterprises.  The need  was
expressed  of  integrating  environmental policy  with economic  policies in
general  and industrial policies in particular.
The  starting-point of this  broader technology  policy  should no  longer be
solely  the  Government,  who  must work  for a  cleaner environment  mainly
through  regulation. Governments should also promote  a greater environmental
responsibility on  the part of producers and consumers. Therefore pollution
prevention  does  not  exclude   the  application  of  other  policy  measures,
mainly  of an educational nature, for promoting new  life-styles,  changes of
patterns  of consumption and production  and alternative forms of  organiza-
tion of social life.  For the purpose of illustration we will  present below
two  examples  of  new policy measures European governments are developing to
enhance the environmental  responsibility  among producers.
        THE  PROMOTION OF ENVIRONMENTAL  RESPONSIBILITY  AMONG PRODUCERS
      In Europe there is a growing tendency to  extend the producers'  respon-
 sibility from the manufacture  of products to  the  whole life-cycle of  the
 product,  including recycling, recovery, re-utilization  and disposal of  the
 product and related  materials  (e.g. packaging). In order to promote this
 responsibility several measures  are  being  proposed.  At the  recent  ECE
 seminar on 'Economic Implications of Low-Waste Technology' major  attention
 was paid to:  a)the institutionalization within enterprises of environmental
 care;  b)the development  of  guidelines  for 'Environmental Product  Informa-
 tion-Exchange' and 'Environmental Product  Profiles'.
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inform  each  other  about  the  environmental  aspects of  their  products.
Certification-systems  do exist  with  respect  to  products and  production
processes  within  the  framework  of  quality  care  (including health  and
safety). Moreover,  various  countries  (following in  the  footsteps of West-
Germany) are engaged in developing product-information for consumers (envi-
ronmental  labelling)   (8)  (9).  These  forms  of  information-exchange about
environmental  aspects  of  (half)products have  hardly got  off the ground
among producers.

     In order  to  improve this  situation, information about the environmen-
tal aspects of the whole product's life-cycle, including the environmental
consequences of its use- should be communicated among manufacturers by means
of  an  'Environmental  Product  Information-Exchange'  (EPIE)   or  sometimes
called  'Environmental  Product  Declaration'  (EPD).  At  the ECE  seminar on
'Economic  Implications  of  Low-Waste  Technology'  it was  recommended that
such an  information flow needs to be  set up in a  systematic way following
harmonized procedures  which are based  on compatible  criteria and principles
to establish  an environmental  product  profile (EPP)  as well as an  environ-
mental technology  profile  (ETP).
The  Environmental  Product  Information-Exchange should  be  preventive and
stimulate the  manufacturers to develop products with improved  environmental
properties. The mere fact that environmental product information should be
presented  by   all  manufacturers  of all  products  would be  an  incentive to
avoid  unnecessary  negative  qualities being associated with  the  product.
The EPIE should also  guide importers,  wholesalers  and retailers and in this
way  help to   secure  good marketing  of  the products.  Products  with good
environmental  standards could certainly  be a way to  strengthen the  goodwill
of the company and thus help ensure  long-term  corporate profitability  (10).

In  principle,   a  complete 'Environmental Product  Information-Exchange' or
'Environmental Product Declaration' may  contain the  following  parts (11):
1)   a  list   of  all  environmentally  relevant substances  (elements  and
     compounds), which are present in  the product;
2)   an  account  of all  stages in  the  production  process,   which are of
     importance to the environmental properties of the product;
3)   an account of the final treatment of the  product;
     More complex  products may be  supplemented with
4)   a dismantling/scrap declaration;
5)   a repair  declaration.

     However,  it may  be questioned  whether the exchange  of such  detailed
information  will  always be  useful.  Whether,  and  if  so,  which  kind of
product  information-exchange among producers is worthwhile, will depend on
a variety of factors,  such as:
     the kind of  relationship/cooperation between the particular  customer
     and subcontractor (in the case  of a close cooperation  and professional
     negotiation-structure  EPIE  may  be a  rather  crude  instrument  in  a
     delicate  process);
     the chain in  the particular production-column  where  the exchange of
     information between customers and subcontractors occurs;
     the available environmental expertise among those concerned;
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     the availability of an elaborated  environmental  product profile (EPP)
     and environmental technology profile (EPT);
     the diversity of (half)products with which customers have to deal;
     the  interactions  within  the particular  firm   (e.g.,  the  relation
     between the  buying department and the environmental  care department;
     the management and the employees, etc).

     Governmental  authorities  who will play  an  important role  in issuing
guidelines  for  the  EPIE  should  take into  account  the  considerations
mentioned above.  They need to  differentiate  the requirements for an EPIE
according to  the  needs of the  manufacturers involved.  It  will,  for  in-
stance, not always be necessary  to make it obligatory to print in full the
complete EPIE on the product or even on the packaging. Which combination of
information exchange will be the most useful is still an open question.  One
could  think of a  combination  of some form of environmental labelling  and
certification-system  with  a  fairly  complex  and  elaborate  EPIE. Further
details should, however, still be worked out.
In order to avoid the uncontrolled spreading  of  environmental messages and
logos,  the  requirements of EPIEs should be well  regulated  by governments
and internationally harmonized. To that effect, the ECE has  recently  set up
a  Task Force,  in  which the Netherlands will  play an  initiating role. If
this Task F.orce is successful EPIEs can form an important additional  policy
instrument to  stimulate the development and marketing of cleaner products
and in  this way broaden the set  of  instruments used at present.
                                 REFERENCES
 1.  Opschoor,  J.B.  and Vos, H.B.,  Economic Instruments for Environmental
     Protection. OECD,  Paris, 1989.

 2.  Ibid, note 1

 3.  OECD,  The Promotion and Diffusion  of Clean Technologies in  Industry.
     Environment Monographs  No.9,  Paris, June  1987.

 4.  Ibid, note 3

 5.  Miiller,  K.  International  Cooperation  -  Status  arid Demands for  the
     Future.  Paper presented at the VTT Symposium on Non-Waste  Technology.
     Espoo, Finland,  June 20-23,  1988.

 6.  Bartle,  C.  The Green Light  for  Change,  New  Initiatives  in the Environ-
     mental  Policy of  the  European Community.  Centre  for European  Policy
     Studies.  Brussels,  1990.
                                  194

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 7.  Cramer, J. Measures  to  Render Economic Instruments More Efficient and
     to Reduce  Barriers  to  Low-Waste Technology,  Introductory  Report for
     the ECE Seminar on Economic Implications of Low-Waste Technology. The
     Hague, the Netherlands,  16-19 October 1989.

 8.  Lindhqvist, T. The Environmental Product Declaration, EDP, Discussion-
     paper  for  the ECE  seminar  on  Economic  Implications  of  Low-Waste
     Technology. The Hague,  the Netherlands, 16-19 October 1989.

 9.  Soest, J.P.  van  (ed.),  Milieu en  Marketing  (Environment  and Marke-
     ting)  . Samson H.D. Tjeenk Willink, Alphen aan den Rijn, 1990.

10.  Ibid,  note 8.

11.  Ibid,  note 8.
                                    195

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              EVALUATION OF EPA WASTE MINIMIZATION ASSESSMENT

              by:  Mary Ann Curran
                   Kenneth R.  Stone
                   RREL, U.S.  Environmental Protection Agency
                   Cincinnati, Ohio  45268
                                  ABSTRACT
     EPA's research efforts to encourage the use of waste minimization
opportunity assessments is presented in this paper.  The early stages of
EPA research centered on the development of the EPA-recommended procedure
for conducting an assessment, and its use at a number of facilities.  This
paper will demonstrate the value of the waste minimization assessment for
discovering and developing opportunities to minimize wastes by presenting
briefs on assessments recently conducted at several private concerns.

     These private concerns include a photo lab, a truck manufacturer, a
large church facility, a nuclear power generation facility, and a graphic
controls manufacturer.  These assessments are at various stages of
completion.  The status and results of each assessment are presented.

     Based on completed assessments and discussions with company
representatives, the EPA-recommended procedure as described in the "EPA
Waste Minimization Opportunity Assessment Manual" is evaluated for its
usefulness.  Reluctance in initiating an assessment has been encountered,
but when technical support was provided to conduct an assessment, company
representatives expressed strong satisfaction with the results.

     This paper has been reviewed in accordance with the U.S.  Environmental
Protection Agency's peer and administrative review policies and approved
for presentation and publication.  Mention of trade names or commercial
products does not constitute endorsement or recommendation for use.
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                                INTRODUCTION
     While the word "assessment" often raises the fear that what is being
talked about is an environmental audit, the assessment team is not looking
for incidences of facility non-compliance.  Their purpose is to examine a
process and its components for inspiration to develop techniques that would
enhance the cleanliness of a particular process or operation.  To
accomplish this goal, certain team members must have technical background
appropriate to the type of process they are assessing.  Therefore, a
knowledge of RCRA compliance and SARA Community Right-to-Know regulations
is not required of the assessment team.

     Conducted by an in-house team or with an independent outside
consultant, a waste minimization opportunity assessment (WMOA) is simply a
structured review of a process or operation to lead to identified opportun-
ities for waste reduction or recycling.  Its focus can be broad or narrow.
Often, it is more effective to select a few areas for intensive assessment
than to attempt to cover all waste streams and processes at once.

     The EPA has published "The Waste Minimization Opportunity Assessment
Manual" (EPA/625/7-88/003) for conducting a waste minimization assessment.
This manual is available at no cost from the EPA's Pollution Prevention
Research Branch, Cincinnati, Ohio 45268.  The procedure recommended in the
manual is outlined in Figure 1.  WMOA's are an extremely effective way to
improve a facility's operations, from both an economic and environmental
standpoint.

     The following sections on industry assessments,  "church assessments",
and New Jersey assessments represent descriptives of some of the assessment
efforts currently being conducted by the EPA.

                            INDUSTRY ASSESSMENTS
     The focus of the industrial assessments effort has been on locating
small and medium-sized facilities which may not have the immediate
resources or expertise to do what is necessary to reduce their waste, and
would benefit significantly from Agency support.  Toward this goal,
assessments have been conducted at a mini-photo lab and a truck
manufacturing facility.  Both hazardous and non-hazardous wastes are
included in the assessments.

     Details on the mini-photo lab and the truck manufacturer assessments
are provided below.

MINI-PHOTO LAB

     After an assessment  in August 1989,  the assessment team identified
five waste minimization options they considered applicable to the waste-
streams of interest.  Following is a brief description of these options.
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    Option  1  - Wash Water Control - Wash water is used for color film
    development and the B&W paper process.  The wash water is turned
    on each production day at approximately 7:00 a.m. and shut off at
    7:00 p.m.  Water use is therefore continuous during the day,
    however,  production is not.  The waste minimization option
    consists  of a simple timer control system consisting of a switch,
    timer and solenoid valve.  The operator would punch a button on
    the switch to activate the timer.  In turn, the activated solenoid
    would allow water to flow for a preset time period.

    Option  2  - Silver Recovery/Metal Replacement Cartridges - Silver
    is found  (as light-sensitive silver halide) in spent photographic
    chemicals and wash waters as a result of removing the emulsion on
    films and papers.  A metal replacement cartridge is a widely-used
    device  for silver recovery.  It can be used alone or in
    conjunction with other recovery technologies.  In this case, the
    spent process solutions which contain significant amounts of
    silver  would be plumbed to a single pipe.  Two cartridges would be
    used to allow for high capacity while maintaining a high recovery
    rate.

    Option  3  - Silver Recovery/Electrowinning - An electrowinning unit
    passes  a  direct current through a concentrated silver solution
    from anode to cathode causing the silver to plate out onto the
    cathode in nearly pure metallic form.  A wide range of equipment
    is commercially available for electrowinning.  Using
    manufacturer's literature as a basis, it is expected that up to
    two batches  (4 gallons each) can be treated each day.  During the
    average batch, 1.13 troy oz. of silver would be recovered within
    4.5 hours.

    Option  4  - Silver Recovery - This option is based on using the
    electrowinning device in Option 3, with metal replacement
    cartridges used to polish the effluent.  The average effluent will
    be desilvered from 500 mg/1 to approximately 10 mg/1, using only
    one cartridge.

    Option  5  - Bleach Fix Recovery - The recommended method for bleach
    fix recovery  is desilvering with two metal replacement cartridges.
    This requires three steps: 1) silver recovery, 2) restoring
    bleaching ability by aerating ferrous-EDTA complex to oxidize back
    to ferric-EDTA, and 3) replenishment of chemicals lost through
    carry-over with the film or paper.  Approximately 75% of the
    recovered bleach  fix solution can be reused while 25% should be
    discarded to  prevent contaminant build-up.

    Total capital investment, net operating cost, and payback period  for
each option  are  shown  in  Table  1.  The  owner  of the  lab  has  received a copy
of the final assessment  report  and  is  taking  the  recommended  options under
advisement.
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       TABLE 1.   SUMMARY OF MINI-PHOTO LAB WASTE MINIMIZATION OPTIONS
                                 TOTAL CAP.       NET OP. COST    PAYBACK
WASTE MINIMIZATION OPTION	INVESTMENT. $    SAVINGS. S/YR   PERIOD. YR
Wash Water Control               $  675            $ 1,436        0.47

Silver Recovery Using             1,071              1,325        0.81
Metal Replacement Cartridges

Silver Recovery Using             3,510              1,414        2.48
Electrowinning

Silver Recovery Using             3,667              1,757        2.08
Electrowinning with MRC
Tailing

Recycle of Bleach Fix and         1,571              2,508        0.63
Silver Using MRCs


TRUCK MANUFACTURER

     This truck manufacturing facility produces 34 trucks (tractor-trailer)
per day.  The production processes are primarily assembly and painting.
The current quantities of generated wastes and the associated disposal
costs for the first three quarters of 1989 are given below:

                                         Amount        Cost of
                                          Mb)         Disposal

     Waste Paint                        184,860        $12,957
     Pretreatment Sludge                 71,020        $ 9,134
     Undercoating                         3,375        $ 2,560
     Oegreasing Solvent (Chlorinated)     13,060        $ 5,431
     Used Oil                             28,275        $   105
     Paint Sludge                       474,960        $15,132
     Housekeeping                         3,800        $ 1,428


     The above figures represent a sharp decrease from recent years.   The
facility has instituted a number of waste minimization measures and cost
reduction methods related to good waste management practices.

     A site visit was conducted in January 1990 to begin the assessment.
Although this facility has made major strides in waste minimization,  the
assessment team feels there are additional opportunities which may have
significant impact.  The following are targeted areas which will be
investigated further throughout the assessment and feasibility phases.
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     Spray  Painting  - Air-assisted  airless  spray equipment  is  used  for  most
     spray  painting.  This method  is  a distinct improvement  over
     conventional  compressed  air spray painting, however, alternatives
     exist  which may improve  transfer efficiency.   Increasing  the transfer
     efficiency reduces  the volume  of paint used and  reduces volatile
     organic  carbon  (VOC) emissions.

     Phosphating - An automated phosphating (conversion  coating) process
     and  electro-coat (E-coat) is  used for  small and  medium-sized parts.
     This line consists  of several  processing  and  rinsing steps.  The rinse
     water  is piped  to a chemical  treatment plant  where  it  is  combined  with
     paint  booth wastewater.  The  resultant sludge is disposed as a
     hazardous waste.

     It may be possible  to avoid waste treatment of the  phosphating rinse
     water  by using  an ion exchange recycle system, thereby  also reducing
     water  usage.  Furthermore, the current wastewater treatment process,
     which  uses large amounts of ferric  chloride,  may be altered, resulting
     in reduced sludge generation.

     Decreasing of Rail  Frames - The  rail frame, or chassis, is degreased
     prior  to spray  painting  using  a  chlorinated solvent (90%  1,1,1,-
     trichloroethane/10% methylene  chloride).  The spent solvent is
     distilled  (350-400  gallons per day)  and reused.   Waste  minimization
     options  may  include chemical  substitution, procedural  changes, or
     improvements  to the recycle process.

     The  assessment  team is completing the  feasibility phase and a  draft
report is expected in May  1990.

                             CHURCH  ASSESSMENT


     This study of a church facility  looked at daily  office operations,
special  functions, general  maintenance and  an on-site pre-school.  As would
be expected, churches are  not normally large waste sources, however, they
are a tremendous  source of social  awareness.  It  is anticipated that this
assessment and  suggestions for waste minimization  will result in  wide-
spread distribution  through the church's governing bodies  and congregation.
This information  will  impact  not  only other churches, but  also people's
activities at home and at work.

     The  location  of the church assessment  was the Mt. Washington
Presbyterian Church  (MWPC) which  is about fifteen  miles  east of downtown
Cincinnati.  With a  1990 budget of $615,000 and  a  $3,000,000 renovation  and
expansion project, this 2,000 member church represents a substantial insti-
tutional  facility.  The church has a very aggressive Recycling Committee
which has been active in collecting recyclable material  for the community.

      The site  visit was made in  December 1989.  The  specific areas of
concern  included building and grounds maintenance, pre-school, social
activities,  kitchens, administrative offices, and new building expansion.
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     Predictably,  the largest waste generated by the church is white paper.
However, there are numerous other cleaners, paints, lawn materials (e.g.,
weed killer), etc., that are used in significant quantities.  The final
report describing waste minimization options is expected to be available by
the summer of 1990.

                           NEW JERSEY ASSESSMENTS


     A pilot project with the New Jersey Department of Environmental
Protection (NJDEP), entitled "Assessment of Reduction and Recycling
Opportunities for Hazardous Waste (ARROW)," will allow the State to
evaluate waste minimization techniques and conduct assessments at
approximately thirty facilities within New Jersey.  The objective of the
site selection is to cover ten industries  (three sites in each) to develop
industry-specific information through the assessment activities.

     Through a subcontract with NJDEP, the New Jersey Institute of
Technology (NJIT) is locating sites and performing the assessments by
following the EPA-recommended procedure outlined in the EPA manual.
Participation in the program by facilities is on a voluntary basis.  To
date, response to the program has been enthusiastic and 14 companies are
lined up for assessment work.  Four site visits have been completed and the
assessment reports are being prepared.  Brief descriptions of two of the
companies visited and potential waste minimization options follow below.

NUCLEAR POWER GENERATION FACILITY

     Interestingly, the bulk of the wastes from this electrical power
generation facility  is from construction and maintenance activities when
power generation is  shut down.  Three major sources of waste streams were
identified by the assessment team: operations, maintenance, and site
services.  After analysis of costs and waste generation quantities, the
assessment team targeted opportunities for reduction in the levels of  off-
spec materials and containers of partially used materials which go to  waste
treatment and disposal.  Several waste reduction options were identified,
such as improved project estimation and planning of material procurement,
dispensing,  and stocking; incentives  to contractors for waste reduction;
and improved security to protect against wastes imported to the site.

GRAPHIC CONTROLS MANUFACTURER

     This facility manufactures pens and markers for automatic recording
devices and  inks for use in these devices.  The waste generation data
indicate that the operation for ink formulation and preparation contribute
to the  bulk  of the hazardous waste generation.  Some options leading to
reduced waste generation include reduction in quantities of rinse water
used in the  cleaning of equipment; improved scheduling of colors and types
of batches of inks to reduce cleaning between batches; increased use of
mechanical cleaning  of tanks to supplement water cleaning; and changes in
ink preparation procedure such as the utilization  of a large ink base  which
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could be tinted to the appropriate color in smaller batches as the need
arose using small amounts of tinting color.

     NJIT continues to work with facilities who show a strong interest in
waste minimization and have volunteered to participate in the ARROW
program.  This effort will continue through August 1991.

                      ASSESSMENT  PROCEDURE  EVALUATION
     The EPA's assessment procedure itself is of interest regarding its
usefulness in identifying waste minimization opportunities.  As expected,
this issue is difficult to quantify, however, some general comments on the
effectiveness of the manual can be made from the assessments that have been
completed within the EPA's waste minimization opportunity assessment
program.

     Discussions between EPA contractors performing waste minimization
opportunity assessments and company representatives led to identifying
three issues on how a company may be delayed in initiating an assessment
effort.  These three issues are as follows:

     1)   Implementation of the Manual's procedure is based on the
          establishment of firm corporate commitment.  This commitment is
          needed in order to devote necessary time and resources.
          Management may not be approachable if specific information is not
          available to them on what the company can expect in return for
          their investment.

     2)   To someone who is not familiar with the manual, it appears
          cumbersome and lengthy and looks like a lot of work in filling
          out the forms.  This impression may cause users to lay the Manual
          aside until a later time.  The user may or may not return to the
          Manual.

     3)   Occasionally there is the fear that the completed manual forms
          would become available to the regulatory agencies and become
          incriminating information.  This unfounded fear prevents people
          from filling out the forms which is a critical step in
          understanding a facility's waste generation and management
          practices.

     In situations where outside assistance was received in performing
assessments, company representatives expressed strong satisfaction with the
results.  They perceived the amount of time involved in the exercise to be
appropriate.  The most valuable result was the identification of ways to
lower costs, which  in turn helped convince management of the profitability
to be incurred in an effective waste minimization program.

     It is reasonable to conclude that many manufacturers recognize their
waste generation problems and have undertaken actions to address and
improve them.  Toward this end, they are very receptive to any method such
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as the one presented in the Manual which will assist them in meeting their
waste management objectives.

                                 CONCLUSION
     This paper describes several  waste minimization success stories
arising from the EPA's Pollution Prevention Research Branch in Cincinnati,
Ohio.  The programmatic approach has been to go to industry to determine
the manual's implementation and to transfer technical pollution prevention
impacts throughout the community, especially to small and medium-sized
businesses which may not otherwise have the resources to pursue pollution
prevention initiatives on their own.  Furthermore, it is clear that EPA's
program has focused on practical approaches to already existing processes
and facilities.  Such an approach begs the question: What about the future?

     EPA's assessment program will continue to aid in the establishment of
a knowledge pool of individuals technically-oriented to pollution
prevention.  The assessment process is becoming an integral part of
business management practices, much as safety concerns have become routine-
Beyond these assessments, the Agency's pollution prevention research
programs must turn to identifying clean practices, clean products and
processes.  With the cooperation of representatives from private concerns,
EPA anticipates broad potential for research in alternative technologies
and products that lower risks to the environment and our future heritage.
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       WASTE REDUCTION EVALUATIONS AT THE PHILADELPHIA NAVAL
                 SHIPYARD AND FORT RILEY. KANSAS
             by:   George C.  Cushnie, Jr.
                   Science Applications International Corporation
                   McLean, VA  22102
    This paper describes two case  studies  funded by EPA's Waste
Reduction Evaluation  at Federal  Sites  (WREAFS) Program.   This
program  consists  of  a  series of  demonstration and evaluation
projects for waste  reduction conducted  cooperatively by EPA and
other Federal agencies.  The case studies  described herein were
performed at  the Philadelphia Naval Shipyard  (PNSY)  and Fort
Riley, Kansas, and  included  the  following  industrial processes:
metal  cleaning,   spray  painting,  bilge cleaning,   and vehicle
maintenance  operations.   The  work  included  a  survey of the  indus-
trial operations,  data collection  efforts,  the  identification and
evaluation of waste minimization  (WM) options and development of
WM  recommendations.    The  procedures  employed  during  these
projects were  patterned  after  EPA's   Waste   Minimization
Opportunity  Assessment Manual.


    The  project at  PNSY was performed  by  Science  Applications
International Corporation (SAIC)  under contract to EPA  (Contract
No. 68-C8-0061).   The  Fort  Riley project was  conducted by Versar,
Inc. under subcontract to SAIC.  This paper  extracts information
contained in the Project Summary Reports developed by EPA's Risk
Reduction Engineering  Research  Laboratory,  Cincinnati, Ohio.


                           INTRODUCTION


    The purpose  of these projects was to develop waste  minimiza-
tion  (WM) plans for specific processes at the Philadelphia Naval
Shipyard (PNSY)  and Fort Riley  using  the Environmental Protection
Agency's (EPA)  Waste Minimization Opportunity Assessment Manual.
This manual  provides a systematic  planned procedure for  identify-
ing ways to reduce  or eliminate  waste.   The development of this
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procedure  was  supported  by  the  Risk Reduction  Engineering
Laboratory,  U.S.  Environmental  Protection Agency,  Cincinnati,
Ohio.

    Each project  was initiated  with  a meeting  at the  site  to
organize the project team,  discuss  the  planned approach,  and to
select several industrial  processes  for  evaluation.  This meeting
was also used  as  a starting point  for  applying  the  waste mini-
mization assessment procedures.   These procedures consist of four
major steps:   1)  Planning  and  Organization -  organization and
goal setting; 2)  Assessment—careful  review of a facility's opera-
tions and  waste streams and the identification and screening of
potential  options  to minimize  waste;  3)  Feasibility  Analysis—
evaluation  of the  technical and economic  feasibility  of the
selected options  and selection of options for implementation; and
4) Implementation—procurement,  installation, implementation, and
evaluation.  This  project  completed  much of  the first three  steps
of the procedures  for several selected industrial activities.


                    PHILADELPHIA NAVAL SHIPYARD


    The  PNSY project  was  conducted  in  cooperation  with the
Environmental Safety and Health Office of the Philadelphia Naval
Shipyard.  The Shipyard has an  on-going program for waste mini-
mization.   With their  guidance, several  industrial operations
were  selected for  application  of  the  new waste  minimization
procedures.  The Shipyard plans to utilize the results from this
project  as a  guidance  tool for evaluating waste  minimization
opportunities at  other industrial  activities at the PNSY.


    The  following  three   industrial  areas at  the  PNSY  were
selected for evaluation  during this project.


    • Building  990  - Aluminum cleaning and spray painting

    • Citric  Acid bilge cleaning operations  conducted  in drydock


    The  assessment  phase  of the project  was  initiated  with a
three-day  survey conducted  by engineers from SAIC and supported
by the  Environment, Safety and  Health  Office,  with cooperation
from other affected departments at the PNSY.  The survey focused
on the  collection  of process and waste  data and the identifica-
tion  of  procedures  for   waste  management.    The  survey was
concluded with a briefing  of the  PNSY Production Officer.
                               205

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DESCRIPTION OF AREAS  SELECTED FOR WM ASSESSMENT
    The industrial activities selected  for  this project include
Building 990  where  fabrication  and surface  coating of aluminum
products is  performed and  the  citric acid  derusting operation
which  is  located at  the drydocks.   The  following  is  a  short
description of these  operations.


Building 990
    An aluminum cleaning  operation  is performed to remove oil and
other materials from the  surfaces of aluminum sheets.   The clean-
ing line consists of four tanks:  two process tanks  and two rinse
tanks.   The  cleaning procedure  consists  of loading aluminum
sheets into  a metal  basket, hoisting the basket  into a process
tank  (5  min.) ,  and rinsing  in  one of  the  rinse  tanks.   The
process tanks  contain  a  proprietary cleaning solution.   One of
the process  tanks is  heated  (steam coil)  and  the other  is at
ambient temperature.   The heated tank is used more often since it
provides better oil removal.  The rinse tanks contain  tap water.
Both rinse  tanks are  heated.


    The process tanks become diluted after repeated  operation due
to dragout losses and tap water replenishment.  These  tanks also
collect floating oil, and the solution becomes contaminated with
suspended solids.  After  approximately three  months  of  operation,
the process tanks  are pumped to  a tank  truck  and   contractor
hauled to disposal.


    The rinse tanks are  operated as nonflowing  rinses.  This is
due to the  low  pH of the rinse  water  and  the lack  of  facilities
for neutralization.   The rinse tanks  are disposed in the same
manner as  the process tanks, but  on  a more frequent schedule,
usually every two weeks.


    During  this project,  drag-out reduction methods  and an alter-
native rinsing  procedure were evaluated which  would   reduce the
frequency of discharge  for these wastestreams.

    A spray painting process is  present in Building 990 which is
used  for small  and  medium sized  aluminum  parts.  Aluminum parts
are degreased by wiping with rags that  have been dipped into
xylene.   The parts  are  then spray painted in a  water curtain
booth.   The painting process  typically  consists  of a  zinc
chromate primer,  air drying,  a final enamel paint  coating, and
air drying.   A  new  booth water  chemical system  was used for the
first time during the survey.   The new process has  been investi-
gated and selected by the PNSY.
                               206

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    The new  process consists  of several  steps.    Initially,  a
booth  cleaning  chemical is used to remove overspray  and paint
sludge from the booth  surfaces.   These paint  solids are removed
and drummed and the booth water is discharged to the sewer.  This
cleaning  process  will  be scheduled  every six  months.   After
cleaning,  the booth is  refilled with fresh  water and a detackifi-
cation chemical is  added along with a buffer.   The detackifica-
tion  chemical  is  an  organic polymer which  causes the  paint
overspray to  form  a  fine  colloidal  precipitant,  which  is
dispersed throughout the booth.  The buffer maintains the optimal
pH for precipitant formation.   In this form, the paint particles
do  not clog  the  booth  water recycle  spray  nozzles  or piping
system and tend not to adhere  to  booth surfaces.  After approxi-
mately two weeks of operation, a  second organic polymer is added
which  coagulates  the  dispersed paint into a floating  mass or
sludge.  This sludge will be  removed by screening and drummed for
disposal.  The  booth water can  be  reused  after  the addition of
more detackification chemical.   After approximately six months,
the system is cleaned using the initial procedure.


    The economics  of the new booth maintenance  system were evalu-
ated during  this  project.  Also,  optional dewatering equipment
was evaluated which is  currently under consideration  by PNSY.
The dewatering  equipment will reduce  the volume of paint sludge
generated by the maintenance system.


Citric Acid Bilge  Cleaning
    PNSY  employs  a  chemical  cleaning  process  for  ships' tanks,
bilges and  void spaces  termed the citric  acid process.   It is
generally performed while  ships  are in drydock.  This process is
relatively new  (1976)  and it  replaces the mechanical methods of
cleaning  and  derusting metal  surfaces.   The  procedures involve
the use of a citric acid/triethanolamine  (TEA)  solution to remove
the oxides from the metal surfaces,  and subsequent neutralization
and rinsing with dilute solutions.


    The volume of  spent solutions from a  bilge  cleaning operation
is  typically  about  3,000 gal.   This solution  generally has a pH
below  4.0 and contains toxic metals.   It is contractor hauled to
treatment/disposal.


WASTE MINIMIZATION OPTIONS
    The  project  team  identified  seven  WM  options that  were
considered applicable to the wastestreams included in this study.
                                207

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Option 1 - Dragout  Reduction and Bath Maintenance for Al Cleaning
           Line
    The Option 1 system includes a hand-held  spray rinse which
will  be  applied over  the  process tanks.   After  impacting the
basket  and parts,  the  rinse  water will  drip into  the process
tank.  The  spray rinse  is  expected to  return 90% of the dragout
back to the process tank.  The amount of rinse water that can be
used  will  depend on  the evaporation rate  of  the process tanks.
This rate is expected to be in the range of 4-8 gph per tank.


    The acid baths  accumulate  oil from the parts and solids from
the parts  and  surrounding  air.   Returning dragout losses to the
tank will cause the process tanks  to accumulate contaminants at  a
faster pace.  These contaminants may interfere with the cleaning
process.   Therefore,  a bath maintenance  system  is recommended.
This  system includes an oil skimmer  for floating oil and grease
removal and a cartridge  filter for suspended solids removal.


Option 2 - Two Stage  Rinse  for Al Cleaning Line
    Rinsing is presently performed in  stagnant tanks  that are
pumped  and contractor  hauled every  two  weeks.    The  proposed
system would employ a two stage rinse.


Option 3 - Paint Booth Chemical System
    The Chemical  System consists  of  3 phases:  a biannual clean-
ing, normal operation,  and  biweekly paint  removal.  The  system is
currently being used on a  trial  basis  in  the Building  990 paint
spray booth at PNSY.   This  option  involves  the permanent adoption
of the process.


    This option requires a change in  raw  materials; however,  no
new  equipment is  required.   Booth  operators will need  to  be
instructed  in  the  use  of  the new chemicals.    Savings will  be
incurred  in  decreased  downtime for   the paint  spray  booth,
decreased  time for operator  maintenance of the  booth,  and less
wear and tear on the  booth  from cleaning.


Option 4 - Paint Sludge  Dewatering
    The paint  spray  booth generates   a  paint  sludge that  is
disposed  of as waste  during  routine  maintenance.   This  paint
sludge is composed of a high percentage of water.  If this water
can  be extracted  from  the paint  sludge, and  recycled  to the
booth, the volume of  waste  that is disposed of can be decreased.


    The paint sludge can be  dewatered  mechanically  using  a bag
filter, roll  bed  filter,  filter  press, or hydrocyclones.   The
                               208

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quantity of sludge generated in the paint booth makes the  hydro-
cyclone the most economical method of dewatering.


Option 5 - High-Volume Low-Pressure Spray Painting
    The current equipment  used  for  spray painting  in  building  990
is the common  compressed air type.  Testing during various stud-
ies at other facilities have  shown  that this type  of  spray  paint-
ing  has  a  relatively  low  transfer efficiency.    The  transfer
efficiency is the amount of the coating,  which is applied  to  the
surface,  divided by the amount of coating, which  is  sprayed from
the gun.   It is usually expressed as a percentage.


    A new  paint  spraying  technique,  which may  be applicable  to
these operations  is  the high-volume  low-pressure (HVLP) method.
The transfer efficiency of  HVLP is in the range  of 65% to 90%.
Compressed air equipment typically provides a 25% transfer effi-
ciency.   Other methods of  spray painting such  as  airless,  air
assisted airless, and  electrostatic spray painting have transfer
efficiencies ranging  from 35%  to  65%.   Of these, electrostatic
spray painting has the highest .transfer  efficiency.   However,
electrostatic  spay  painting  will  cost  significantly  more   to
retrofit than  HVLP and therefore is not considered as attractive
as HVLP for the PNSY.


    The equipment  needed  to retrofit  a  HVLP system includes  a
regulator/filter assembly,  air  hose,  control valve,  quick discon-
nect,  and HVLP  spray  gun.   The  existing air  compressors  are
expected to be adequate for the application of HVLP  painting  and
will not need to be replaced.

Option 6 - Operator Training  and Awareness
    Paint and paint wastes comprise the second largest  hazardous
waste stream generated at  PNSY.  A program that  encourages  opera-
tor involvement and responsibility  can  reduce  the  amount of waste
paint by controlling the amount of  paint  overspray,  the  amount of
unused paint  left in  the can,  and the amount  of paint that  is
unusable due to partial solidification prior to use.

    Option  6  relates  strictly to personnel/procedural related
changes.   No new  equipment or  materials are necessary.  Training
can be done in-house  and on-site by existing  Naval personnel  who
are  knowledgeable in  the  areas of waste  minimization, general
painting operations,  and booth  operating  procedures.  An applica-
tion of Option 6  base-wide  can reduce wastes generated in every
painting department.
                                209

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Option 7 - Recovery of  Concentrated Citric Acid Solution
    This option is  a batch  process for the recovery of  spent con-
centrated  citric  acid/TEA solution  from derusting  operations
(Figure 1).   This system employs  equipment that is used for simi-
lar processes  but  has  not  been  specifically applied  to citric
acid derusting wastewaters.


    The proposed recovery process includes three main operations:
1)  oil and grease  (O&G)  removal,  2)  suspended  solids removal, and
3)  dissolved  metal removal.   The recommended equipment  for O&G
removal is a device which is  specifically designed for  removal of
oils  from  hipboard  bilge  waters.    This  unit employs enhanced
gravity separation  and  coalescer  beds of polypropylene.  It has a
modular design which includes all necessary pumps  and controls.


    The  proposed  device for  suspended  solids   is  a floating
ceramic media backwash  filter.  An upflow service, downflow back-
wash design is recommended.  It is capable of removing suspended
solids with  a  size greater than 5 microns.   The  backwash cycle
can be  automatically   initiated  with a  pressure  differential
switch.  The  backwash   (1-5% of treated volume)  from the filter
could be recycled to the storage tank or drummed for disposal.


    The  discharge  from  the  filter  would be  collected  in  the
recovery tank.   A  level control would sense when  a  sufficient
volume has been collected and would  shut off the feed pump on the
oil removal system.  The electrodialysis  (ED)  unit would then be
energized.   The proposed  ED unit  is a technology specifically
designed  for removal  of cations  (e.g.,  iron,  lead,  trivalent
chromium, cadmium)   from acid baths.   It is most  often used for
bath maintenance of  hard chrome  plating  solutions,  but has been
successfully tested  in  the  laboratory  for  citric  acid/TEA solu-
tion maintenance.  This technology consists of an electrochemical
cell  (cylindrical  unit  placed  into  recovery tank)  and a cathode
tank.    The  cell is designed with a  set of  anodes which contact
the acid solution,  a  cation-specific membrane,  and  a  cathode
which is located within the membrane compartment.


RANKING OF OPTIONS
    The assessment  phase includes data collection,  selection of
target areas, data review,  and options generation and  screening.
Table  1  lists the  nine individual  wastestreams that  were con-
sidered during the  assessment,  and includes the building or loca-
tion  where  they are  generated  and  the  associated   industrial
process.  Table  1  also lists some  key data for each wastestream
including:    the  volume  generated  on  an  annual  basis,  the
hazardous characteristics of  the  waste, the annual disposal cost,
the raw  material costs for input materials that  are  considered
partially recoverable,   the waste minimization options that were
                               210

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-------
                                                     VOLUME
                    LOCAT1OH/PROCE8S/WASTE STREAM
                                                                 CHARACTERISTICS
                                                                                      DBPOSAL
                                                                                     COST. $/VH
                                                                                RAW MAT.
                                                                              COOTS, $/YR«
                                                                         WM OPTIONS
                                                                                                         WM OPTION
                                                                                                      SCREEMHG SCORE
ro
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 AUIMMUMCLEANMQ
  SPENT KRC-7X (WS-1)
  SPENT RMSE WATER (WS-2)

 SPRAY PAMTMQ OF ALUMNUM
  PAMT SUJDQE (WS-3)

  USED PAMT THINNER (WS-4)
  UNUSED PAINT (WM)

BUNJMNO 102*

 SPRAY PAMTMQ OF STEEL
  PAMT SUJDQE (WS4)

  USED PAMTTHMNER (WS-7)
  UNUSED PAINT (WM)

DRYDOCKS

 CfTRCACDDERUSTMS
  CONC. CrTRC ACID/TEA (WS-B)
                                                      7.040
                                                      45.760
2.000

 620
 UNK
                                                      3.600
                                                       520
                                                       UNK
                                                      15.000
               LOWpH
               UOWpH
                                                               TOXCMETALSflQNITABLE
TVWGN IT/TOXIC CWQANCS
TOJOC METALSAQNnABLE
                                                               TOXIC METALS1QNITABLE
        TIMONn/TOXICORQANICS       $878
         TOXIC METALSflQNfTABLE   MCLUDED ABOVE
 $14A10        $46.120       DRAOOUT REDUCTION AND BATH MANTBIANCE (OP-t)          383
 $70.028          $0                   TWO STAQE RMSE (OP-2)                    396


  $3.780          $2.800        BOOTH GUARD (OP-3)^ SLUDGE DEWATERMQ (OfM).          308.288
                                  AND HVLP SPRAY PAMTMQ (OP-5)                 339
  $978          $1480              AWARENESS AND TRAMMQ(OP-6)                 393
$350.000-         UNK              AWARENESS AND TRAMMQ(OP4)                 393
                         $8.768          $2300        BOOTH GUARD (OP-3). SUJDQE DEWATERNG (OP-4).          308.288
                                                         AND HVLP SPRAY PAMTMQ (OP-5)                 339
                                       $1 JStO              AWARENESS AND TRAMMQ (OP-6)                 393
                                        UNK              AWARENESS AND TRAMMQ (OP-6)                 393
                                                                LOW pH. TOXIC METALS
                                                                                       $45.750         $26*94          aECTHOOWLYSB RECOVERY SYSTEM (OP-7)
                    •HAW MATERIAL 
-------
considered  in the  screening step, and  the scores  from the  WM
option screening process.


CONCLUSIONS AND RECOMMENDATIONS
    The technical and economic results of the  feasibility analy-
sis phase are  summarized in Table 2.  This table indicates  for
each option, the total capital investment,  the  net  operating  cost
savings  and  the  payback period   (total capital investment/net
operating cost savings).


    The relative comparison  used  in this  study  indicates  that  the
best options  appear to be:    Option  6 -  Awareness and Training,
Option  I  - KRC-7X  Dragout  Reduction and  Bath  Maintenance  and
Option 2 -  Two  Stage  Rinsing.  The implementation of these three
options would cost  $39,560  and result in  and  annual savings  of
$158,680.   The implementation of all seven options  would  cost
$144,982 and result  in an  annual savings of  $246,180.


    Option  7  appears  to  be  a  viable  candidate  for  research,
development, and demonstration.    This option involves the imple-
mentation  of  equipment  for the  recovery  of  citric  acid/TEA
solution.


    It is important to note  that the PNSY is  not  a commercial
production  facility,  but rather  a government  facility  that  is
operated for revitalizing  and repairing ships.  As such,  the pay-
back period of the WM options evaluated may  be  different  than  for
commercial  operations.    Also,  other WM  options that  were  not
evaluated   in  this  study   may   be   applicable  to   commercial
operations.


                        FORT RILEY, KANSAS


    Fort Riley is a permanent U.S. Army Forces Command  (FORSCOM)
Installation  that provides  support and training facilities  for
the 1st Infantry Division  (Mechanized), Non-Divisional Units,  and
tenant activities.


    Among  the numerous  activities present  at  Fort Riley is  the
maintenance of the  1st   Infantry  Division's  vehicles   (trucks,
tanks,  armored personnel carriers,  etc.).  Routine maintenance  is
conducted  at   various motor  pools.   Equipment repairing  and
rebuilding is  carried out  by a contractor located on-base.   Most
of the hazardous waste generated at Fort Riley is generated from
these repairing and rebuilding operations.   Two operations  were
identified  which  account  for a major portion of  the  hazardous
waste generated.  These include battery  service  and  repair,  and
                               213

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ro
                  LOCATION, PROCESS &
                   WASTESTREAU  (WS)

                BUILDING 990

                 ALUMINUM CLEANING
                   SPENT KRC-7X (WS-1)
                  SPENT RINSE WATER (WS-2)

                 SPRAY PAINTING OF ALUMINUM
                  PAINT SLUDGE (WS-3)
   USED PAINT THINNER (WS-4)
   UNUSED PAINT (WS-5)

BUILDING  1029

 SPRAY PAINTING OF STEEL
   PAINT SLUDGE (WS-6)
                  USED PAINT THINNER (WS-7)
                  UNUSED PAINT (WS-8)

                DRYDOCKS
                               WASTE  MINIMIZATION
                                     OPTIONS
                              BATH MAINTENANCE (OP-1)
                               TWO STAGE RINSE (OP-2)
    BOOTH GUARD (OP-3)
PAINT SLUDGE DEWATER. (OP-4)
 HVLP SPRAY PAINTING (OP-5)
AWARENESS a TRAINING (OP-6)
AWARENESS ft TRAINING (OP-6)
    BOOTH GUARD (OP-3)
PAINT SLUDGE DEWATER. (OP-4)
 HVLP SPRAY PAINTING (OP-5)
AWARENESS & TRAINING (OP-6)
AWARENESS ft TRAINING (OP-6)
                              NATURE OF
                              WM OPTION
                               EQUPMENT
                               EQUPMENT
    MATERIALS
    EQUPMENT
    EQUPMENT
PERSONNEL/PROCED.
PERSONNEL/PROCED.
   MATERIALS
   EQUPMENT
   EQUPMENT
PERSONNEUPROCED.
PERSONNEL/PROCED.
CAPITAL
INVESTMENT
($)
$12,220
$3.116
$12,190
$9,550
$7,630
$24,226
SEEWS-3
SEEWS-3
SEEWS-3
SEE WS-4
SEEWS4
NET OP. COST
SAVINGS
($/YR')
$44,190
$34.592
$10,890
$7.720
$8.170
$79.900*
SEE WS-3"
SEE WS-3"
SEE WS-3"
SEE WS-4"
SEE WS-4"
PAYBACK
PERIOD
(YR')
0.3
0.1
1.4
1.2
0.3
SEE WS-3"
SEE WS-3"
SEE WS-4"
SEE WS-4"
                 CITRIC ACID DERUSfflNG
                   CONC. CITRIC/TEA (WS-9)
                              ED RECOVERY SYSTEM (OP-7)
                               EQUIPMENT
                    $76,050
$60,720
                                                                               1.3
                INCLUDES ENTIRE SHIPYARD.
                "OPTIONS 3 AND 4 INCLUDE BOTH BLGD. 990 AND 1028.
                               TABLE  2.   SUMMARY OF WM FEASIBILITY ANALYSIS  PHASE

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automotive  subassembly  rebuilding shop.   Battery service  repair
generates   waste  acid   (32%  to  37%  sulfuric  acid)   which  is
currently collected in drums and shipped  off-site for disposal  as
hazardous waste.  This acid contains trace concentrations  of lead
and cadmium.  The automotive subassembly  rebuilding  shop contains
a  parts washer  which  cleans  parts  with hot  aqueous alkaline
detergent.   This waste,  currently being  reclassified as  RCRA,
D007 and D008, is drained to an  on-site waste evaporation pond.


WASTE MINIMIZATION OPTIONS
Waste Battery Acid
    The Versar team proposed that  the waste acid be  gathered in a
holding tank,  filtered  to remove  any particulates,   and adjusted
in  concentration  to 37  percent sulfuric  acid  (using 60*  Baume
commercial  sulfuric acid) as needed for reuse  in reconditioned  or
new batteries.  To prevent  buildup  of  dissolved metal  impurities
in this recycling system,  part  of the acid would be purged from
the system.   This assessment assumes that  25 percent of the acid
would  be  purged and 75  percent reused.    The  acid  being  purged
would  be  neutralized,  treated ,to remove  trace  heavy metal, and'
disposed of onsite to a  lagoon as  a  nonhazardous waste.


Automotive Parts Washer  Wastewater
    The dirty  aqueous  alkaline detergent  solution  that results
from cleaning  automotive parts  contains  trace  concentrations  of
lead,  chromium,  and cadmium  at a  pH  >12 as well  as  the  oils,
grease, and dirt  removed from the automotive parts.   Currently,
the solution is drained  to  an onsite nonhazardous waste evapora-
tion pond.   This  waste,  heretofore regarded as nonhazardous,  is
being  reclassified  as  a RCRA  hazardous  waste because  of  it's
characteristics (D007,  D008).  When  reclassified,  it  will have  to
be disposed of as a hazardous  waste through DRMO.   The  Versar
team proposed option for  this  stream involves using equipment
external to the  automotive parts washer.   The  proposed process
would  include emulsion breaking  to cause  emulsified  oils  to
float,   removal  of de-emulsified  oils  and other  tramp oils and
grease  by  skimming,  filtration to  remove particulates  (in-line
cartridge  filter,  and addition of  fresh  alkaline  detergent  as
necessary.   The cleaned washwater would  then be recirculated  to
the  automotive parts  cleaner.    Buildup  of  impurities  in the
recycled washwater would be prevented by  purging 25 percent  of
the used alkaline detergent and recycling 75 percent.  The  mate-
rial being purged would  be neutralized  with an appropriate  amount
of waste battery acid,  treated to  remove precipitated trace  heavy
metal impurities,  and disposed of  as a nonhazardous waste.


Results of Waste Reduction  Audit
    The results of the  waste reduction audit are  summarized  in
Tables  3 and 4.
                                215

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      TABLE  3.  SUMMARY OF FORT RILEY, KANSAS, BUILDING  8100
                    WASTE REDUCTION ASSESSMENT
Source of
Hazardous
Waste Stream
    Waste
  Current
  Disposal
    Cost
 Current Raw
Material Cost
Battery repair
shop

Automotive
parts washing
7,200 gal/year
D002, D006, D008*

29,000 gal/year
D007, D008**
$27,900/yr
 $ll,530/year
$112,000/yr***  <$100/yr
*D002 - Corrosive waste (<2 pH >12).
 D006 - Cadmium-containing RCRA characteristic hazardous waste.
 DO08 - Lead-containing RCRA characteristic hazardous waste.

**D007 - Chromium-containing RCRA characteristic hazardous waste,

***Although this waste currently is drained to an onsite
evaporation pond, if it were disposed of as a RCRA hazardous
waste via DRMO at the same cost per gallon as the waste battery
acid, the costs and savings would be as indicated.
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        TABLE 4.  SUMMARY OF ECONOMIC ANALYSIS FOR PROPOSED
         WASTE MINIMIZATION OPTIONS AT FORT RILEY, KANSAS,
                           BUILDING 8100
Source of         Waste                       Operating
Hazardous       Reduction        Capital    Cost Saving,    Payback
Waste Stream      Option        Investment      $/year        year


Battery        Recycle of        $15,200        $36,000       0.42
repair         restrengthened
shop           battery acid

Automotive     Recycle of        $19,800        $107,100      0.18
parts          purified
washing        alkaline
               detergent
	   	     solution    	
                                 217

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                   SECURING SAFE SUBSTITUTES;
      POLICY MEASURES TO PROMOTE SAFE CHEMICAL SUBSTITUTES

          by:   Gary A.  Davis, Esq.
               Senior Fellow
               University of Tennesee
               Energy,  Environment,  and
               Resources Center
               Knoxville,  Tennessee 37996
                          INTRODUCTION


     Safe substitutes  are non-toxic  or  less toxic  chemicals or
alternative practices  that  reduce  or eliminate the  use  of toxic
chemicals.  Substitution  of   safer   chemicals   and  alternative
practices for the toxic chemicals now used extensively to provide
most goods and services would dramatically reduce hazardous waste
generation,  reduce  toxic air  and  water pollution,  reduce human
exposure to toxic chemicals in the workplace and in the home, and
reduce  subtle  damage  to the  ecosystem.    Furthermore,  as  many
companies have already  discovered,   reducing  the  use  of toxic
chemicals saves money spent on environmental controls, penalties,
cleanup costs,  and worker health care.

     The coming of  safe substitutes  can proceed  in  a haphazard,
market-driven and piecemeal regulatory approach,  or  there  can be
a conscious, comprehensive program for bringing about a non-toxic
21st  Century.   This  paper  summarizes  the  preliminary  policy
recommendations  from  a  two-year  study  of  the  potential  for
dramatically reducing the use of toxic chemicals. That study will
be published in book form in 1991.

     Since the use of toxic chemicals pervades the workplace, the
home, and the  farm,  policy measures  to promote  safe substitutes
must address each  of these areas. To this end,  the study first
evaluated existing  statutes  and regulations  that  directly  and
indirectly  impact  toxic  chemical  use.  In  addition, the study
evaluated  various   state  and  local  requirements  now   being
implemented that go beyond  federal laws by requiring labeling of
products, by banning certain  products, or by making toxics use
reduction an  explicit  policy. Last,  but not  least, the study
addressed the use of various measures for increasing the interest
and awareness  of consumers  and the public at  large  in promoting
safe substitutes.
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             STRATEGIES TO  PROMOTE SAFE SUBSTITUTES


     There  are five  areas  in  which  recommendations have  been
developed  for  the  promotion of  safe  substitutes through  both
government and consumer and citizen strategies. These are:

     National toxic chemical policy
     Testing and regulation of toxic chemicals
     Agriculture policy
     Industry and toxics use reduction
     Consumer products


NATIONAL TOXIC CHEMICAL POLICY


     The Toxic Substances Control Act  ("TSCA"),  enacted in 1976,
is "the sleeping giant" of  federal  environmental legislation: it
has the potential  to accomplish much positive change if it were
reformulated and given proper backing.  At present, the patchwork
of  toxic  chemical  regulations,   under  various  environmental,
consumer, and  worker protection laws,  is  inconsistent, slapdash,
and simply not effective in  controlling toxics production, use and
disposal. Furthermore,  there is  no clear goal benind TSCA to reduce
the use of toxic chemicals and to promote safe substitutes.

     The following recommendations are made:

     It should be the  policy of the  federal government to reduce
     the production  and use of toxic chemicals  in a coordinated
     fashion throughout the  fields of  industry,  agriculture,  and
     consumer products.

  •  It should also be the  policy  of the  federal government to
     encourage the use  of safe substitutes in an affirmative manner
     through research{  technology transfer, public education,  and
     financial incentives.


TESTING AND REGULATION OF TOXIC CHEMICALS


     The Toxic Substances  Control  Act should  be  the  vehicle  for
the comprehensive prioritization and  regulation of  toxic chemicals
from cradle to grave. It should  be coordinating risk assessment of
chemicals  through  all routes  of exposure and  deciding whether
chemicals should be  restricted  in their  use  or  production.  TSCA
should also  guide  the  regulation of toxic chemicals  in specific
regulatory  programs,  decide when more restrictive measures  are
needed, and affirmatively promote safe substitutes.

     Of the thousands of chemicals in use today,  how do we decide
which ones should be priorities  for substitution?  Where do we stand
in our ability to answer that  question?  And how  do  we  go about
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eliminating those priority chemicals? Unfortunately, the situation
is not encouraging:

     Worldwide, some 70,000 chemicals are in use with between
     500 and 1,000 new ones added each year. EPA has compiled
     a list of more than 48,000 chemicals in the U.S. existing
     chemical  inventory.  While only a  small  percentage are
     likely to be  harmful  to  people and the environment, no
     information is available on the toxic effects of nearly
     80% of those chemicals.

  •  Fewer  than  one-tenth  of  existing chemicals  have been
     tested  for   long-term  effects,   such   as  cancer  or
     reproductive  effects,  and virtually  no  evaluation has
     been  performed  of  the  cummulative  effects  on  the
     ecosystem.

     In the 14-year history of TSCA only about  10% of existing
     chemicals nave been reviewed by tne Interagency Testing
     Committee to determine if more testing is needed.

  •  There is  no requirement  for new chemicals  to be tested
     before introduction into the marketplace under TSCA.

     Ideally, criteria for prioritizing  chemicals for substitution
would take  into  account toxicity to humans and the environment,
including acute and chronic effects, and would  take into account
potential for exposure from production, through use, to disposal.
Much of the information needed to fully  assess chemical impacts in
this manner  simply does not  exist,  nor is any  agency seriously
looking at the full "life-cycle" impacts of chemicals.

     There has also been  paralysis by analysis.  The scientific
issues are very difficult, and EPA has set a difficult burden for
itself in selecting chemicals for testing and regulation.

     Although outright product or ingredient bans are politically
difficult, many  of the major  gains in protection of health ana
environment from the effects of toxic chemicals have come this way.
These include, for example, reductions  in lead  exposure from the
phase-out of leaded gasoline, reductions in PCB exposures following
the  Congressionally-mandated  phase-out,  reductions  in  asbestos
exposure, and reductions in chlorofluorocarbon use.

     Statutory authorities  that  can restrict  chemicals have been
used sparingly, largely because  of  the  heavy  burden imposed upon
the  government to  justify any  interference with the  chemical
marketplace. Under most existing  statutes agencies bear the burden
in demonstrating that chemical products pose "unreasonable risks"
and are often directed to  balance risks with the economic benefits
of the chemicals.

     Should chemicals be treated as innocent until proven guilty?
In  other words,  should they  be produced, marketed, used,  and
disposed of until a government agency musters enough evidence that
they should  be restricted? How  much evidence is enough,  and in
weighing  the  evidence,  where should  the burden of  scientific
uncertainty fall?  These are some of the  critical  questions that
must be answered in revamping  the system of chemical  testing and
regulation.

     Many now believe that  it  is important to move forward, even
with  imperfect knowledge.  For  instance,  the  Organization  for
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Economic Cooperation and Development Chemicals Group has begun to
set  priorities for  requiring testing  of high-volume  chemicals
without laborious rulemaking  pr9ceedings.  The Swedish government
has gone even further by initiating the "sunset chemicals" program
to select high-priority chemicals to phase  out production and use.

     Despite the lack  of information  and the slowness of testing
programs,  it  should  be  possible to  at  least  develop a  rough
priority  scheme  for  chemicals  that  should be candidates  for
substitution.  Using  such a  priority scheme,  we  can  at  least
implement  positive  non-regulatory  measures to encourage  safe
substitutes without getting bogged down in an impossibly detailed
analysis.

     The following are general recommendations in this area:

  •  The Toxic Substances Control Act should be revamped so as to
     become the overarching statute for testing, risk assessment,
     regulation,  and  standard  setting  for   toxic  chemicals
     throughout   federal   regulatory    programs    that    have
     responsibility for protecting the public and the environment
     from exposure to toxic chemicals.

  •  The  regulation of  and  standard  setting for  toxic chemical
     exposures should be integrated and made  consistent throughout
     all  uses of  toxic  chemicals  and  all  routes  of  exposure.
     Cummulative  exposures  and  synergistic effects  should  be
     considered in chemical risk assessment and standard setting.

  •  For   existing   chemicals,   priority  chemicals should  be
     identified  and  the burden  of   proof should  shift to  the
     manufacturers  and  users to  demonstrate  their safety  for
     continued use.

  •  For new chemicals, testing should be mandatory under TSCA, and
     manufacturers should have the burden  of demonstrating safety
     before introduction of the chemicals  into the marketplace.

     The  patent life  for chemicals  should  be   extended so that
     thorough testing prior to introduction of new chemicals into
     the marketplace is not penalized.

  •  EPA  and other  nations,  with coordination  by  international
     organizations, should implement a range of policies to phase
     out the production and use of priority  (sunset) chemicals.

     Policy measures for the phase-out of priority chemicals should
     include   bans,   restrictions on  certain   uses,  financial
     incentives, research and development, and public eduction.


AGRICULTURE POLICY


     Current American agricultural practices, centering on large-
scale  use  of  pesticides  and   synthetic  fertilizers,  are  not
physically, economically,  or  politically sustainable.  Since 1945
the use or synthetic pesticides  in the United States  has grown 33-
fold, but  the percentage of crop losses due to pests,  including
insects and  weeds  has not decreased. Losses  due to insects have
nearly doubled since 1945, but those losses  have  been  offset by
technological  changes,  such  as  new plant varieties and increased
use of fertilizers.
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     The  U.S.   now  spends  about  $4.1 billion  on  agricultural
pesticides annually.  These costs do  not  include the  health and
environmental costs of massive pestide use,  however.  In addition
to these unaccounted for costs, the efficacy of pesticides is being
eroded as pest resistance grows.

     Today,  alternative  agriculture  (also  called  "low-input,
sustainable agriculture" or "organic farming") is on the rise. The
number of acres of land  cultivated by organic practices is growing
by 15% per year. Consumers  are demanding reduced use of pesticides
because of concerns over residues  of cancer-causing chemicals in
food and are willing to pay a premium for "safe" food.

     Three countries, Denmark,  Sweden and the  Netherlands,  have
recently mandated a  50 percent reduction in the use of agricultural
pesticides:  Sweden in  five  years,  Denmark by  1997,  and  the
Netherlands within 10 years.  Is such a reduction possible in the
United States and at what cost to farmers and consumers?

     According to a recent study at Cornell University, pesticide
use can be reduced by at least 50% in the United States through a
combination  of  relatively  simple  alternatives with  no loss  in
yields and only  slight  increases in retail food costs. The study
estimated  that  reducing pesticide  use  by 50 percent  would  cost
approximately $1 billion.  If there were no  decline in crop yields,
the total price increase to the consumer would be only about 1.5%.
The increased costs of  alternative  pest control  methods would be
9ffset by reduction in pesticide costs alone, without even taking
into  account  the  indirect costs  of pesticide  use,  such  as
environmental damage and human health problems.

     Aside from the federal government role in regulating the use
of pesticides,  federal agricultural  policy also plays a large role
in pesticide use.  In  this case,  farmers  themselves  could  effect
dramatic  reductions  in  pesticide use  if   the federal  government
would, first, just get out  of the way,  and, second, give them some
encouragement.

     Obstacles to reducing pesticide use include:

     overproduction of  crops with  attendant pesticide use,
     supported  by  the  farm subsidy  program,  which  also
     depresses farm product prices;

     the  commodity  program,  which  discourages  farmers from
     using simple alternatives  to pesticides,  such  as crop
     rotations;

  •  crop insurance policies, which often require the use of
     pesticides at certain levels;

  •  simple  resistance  to  change by  farmers who have been
     using pesticides for years;  and

     lack of  emphasis on alternative practices in agricultural
     extension and education programs.

     Implementing pesticide  reductions through farm policy  will
take longer than simple pesticide bans and phase-outs.  It  may be
too little, too late,  to save ground water and protect the safety
of food. But  the two methods of pesticide reduction can go hand in
hand.  There are  some pesticides that should be taken off the market
immediately,  and for which immediate bans will  find wide support.
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But because of the scientific uncertainties and the political clout
of pesticide manufacturers, reductions  in use of most pesticides
can best be brought about by a concerted  effort to remove obstacles
to  alternative  practices  and  to  greatly increase  educational
programs for farmers.

     The following are general recommendations in this area:

     Farm subsidy programs should be  revised  to remove obstacles
     to safe substitutes, such as crop rotation.

     Crop insurance policies  should be regulated, if necessary, to
     permit  the  use   of  alternatives  to  pesticides  without
     sacrificing coverage.

     The  Federal  Insecticide   Fungicide  and  Rodenticide  Act
     ("FIFRA11) should be amended to explicitly adopt the "Delaney"
     approach to pesticide residues in food. The only "de minimis"
     levels of pesticides that cause cancer or  reproductive hazards
     in animals that should  be  permitted are  those in background
     concentrations.

     FIFRA  should also  be  amended to  remove the requirement that
     EPA must purchase stocks of banned pesticides. Alternatively,
     there  should be a tax levied  on all pesticides  to create a
     large fund for purchase of stocks of banned pesticides and for
     other purposes.

     Increased funding  should be made available for research and
     education  on  alternative  farming  practices that  reduce 9r
     eliminate  pesticide  use.   The  National  Research  Council
     recommended that funding be increased tenfold from $4 million
     to $40 million.


INDUSTRY AND TOXICS  USE REDUCTION


     Virtually every industry uses some toxic chemicals, even if
the products ultimately produced and sold are innocuous themselves.
The  Toxics Release  Inventory,   based  on  an  EPA survey  of 1987
releases  of  toxic  chemicals   into  air,  water,  and  soil  by
manufacturers, found that  22.5  billion  pounds of toxic chemicals
each year are released to the environment or  transferred from the
plant site  for  disposal: 2.7 billion pounds  to air;  9.6 billion
pounds to surface water;  5.7 billion pounds to  soil and underground
injection;  and  4.5  billion  pounds  to  off-site disposal.  The
chemical industry generates  by  far the greatest amount with 12.1
billion pounds released and transferred.

     Although there  are some notable exceptions,  most companies
have simply not considered safe substitutes for the toxic chemicals
they use  or produce. The  Toxics Release Inventory,  for instance
found that  only  about  6% of  the respondents stated that they had
substituted inputs or reformulated products to  reduce environmental
releases of toxic chemicals.

     Why  are safe substitutes  not being implemented  rapidly by
industry?  Because  we have focused on pollution  control in this
country  for 20  years.    Our  environmental programs  have rarely
challenged  the use of  toxic  chemicals or the production of toxic
 ?roducts,  since  the  focus has been on controlling pollutants and
 reating wastes.
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     There are  several  disincentives  to making  a  wholehearted
search for safe substitutes in industry. Among those disincentives:

  •   Safe substitutes  are  the most complex waste  reduction
     strategy,  since  they require  intimate  knowledge  of
     chemical processes, creative engineering, and potentially
     expensive equipment modifications.

  •   Chemical product manufacturers and users  are  reluctant
     to try new products when the ones in long use perform the
     manufacturing functions satisfactorily.

  •   Product    specifications,    including    military
     specifications,  sometimes  force manufacturers  to  use
     toxic chemicals in their manufacturing  operations.

  •   Chemical-user  industries,  such  as  the  electronics
     industry, are in a sense, "captured and dominated" by the
     chemical producers, since the users  do  not usually have
     the capability to develop alternatives themselves. Small
     users rarely nave the clout to demand  safe substitutes
     from large chemical producers.

  •   Engineers are not taught to consider reduction in use of
     toxic chemicals in designing processes, and once capital
     investments are made,  redesign cannot be considered for
     several years.

     What government initiatives can help overcome these obstacles?
The  new  Massachusetts  Toxics Use Reduction  ("TUR")  Act is  a
promising initiative for moving industry  toward safe substitutes.
The TUR legislation  is  primarily a mandatory  planning process to
force companies using  toxic chemicals to plan  for  a  reduction in
use.  The Act includes  oversight  from  the  state  environmental
regulatory agency and  some public  access  to  planning information
as well as training and certification for TUR planners.

     Industry may resist toxics  use reduction strategies because
of the  seeming  intrusion  into internal business and engineering
decisions. The Massachusetts legislation tempers this intrusion by
focussing  on  flexible  policies,  such  as  planning,  technical
assistance, and training.

     The  following are recommendations in this area:

  •  Toxics use reduction should become a  major goal of federal and
     state waste reduction  programs, relying primarily on technical
     assistance and planning requirements as does the Massachusetts
     Act.

  •  Permits  for air  and  water pollution  and hazardous waste
     management should be  coordinated,  so that transfers of toxic
     chemicals from one environmental compartment to another do not
     occur  and  so  that   overall  reductions  in  toxic  chemical
     releases can be achieved through the permit process.

  •  Incentives  should be  provided  to  promote the  use  of safe
     substitutes. EPA  should  give  clear  signals about priorities
     for  substitution and  use  research  and  development grants,
     information  transfer,   and,  if  necessary,   subsidies,  to
     encourage use of  substitutes.
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CONSUMER PRODUCTS


     Many of  the products  we use  in our  homes  or purchase  as
consumers contain  chemicals  that  can cause  illness or  injury.
Products that  are  not toxic  in  and of themselves may  result  in
secondary problems  due to the processes used to produce them or the
impacts caused by their disposal.

     The following illustrate the scope of the problem:

     5-10 million household poisonings are reported every year
     involving a wide variety of chemicals.

     Air samples in typical buildings include 100-200 volatile
     organic chemicals,  including suspected carcinogens, from
     sources   such   as  cleansers,   disinfectants,   paints,
     carpets, and wood products.

  •  Formaldehyde is found in thousands of products, including
     permanent pressed  clothing, paper products,  cosmetics,
      ?lywood,  paneling,  spray  starch,  cleaners,  and  air
      resheners. Its  presence  in indoor  air has been linked
     to respiratory ailments, allergic reactions,  and in one
     study,  to cancer of the nose and pharynx.

  •  Nearly  90% of  American  households use  some  type  of
     pesticides, including  termite  and  roach  sprays,  flea
     bombs,  pesticide strips,  flea powder  for  pets,  garden
     insecticides,  and lawn chemicals.

  •  Disposal of toxic household products causes injuries to
     waste management workers, contamination of ground water
     from landfilling, or air pollution from incineration.

     The  feasibility  of   safe  substitutes   has   been   better
established in the area of  consumer products  than anywhere else.
Until the Chemical  Age that  followed World War II, most homes were
constructed   with    non-toxic   building   materials,   and   most
householders used a few  simple substances to keep the house clean,
odor-free, and pest-free.  Current alternatives to the usual toxic
materials of  a  house  and  of  household products  are  not  only
available, but can be more economical.

     Given adequate  information, consumers  can  speak with a loud
voice  for safe  substitutes.  The  primary  vehicle  for  consumer
education about product choices is the product label.  Product
labeling can be either positive or negative. Positive labeling is
exemplified by  "green labeling"  or  "environmental  labeling" that
has taken hold in Western Europe and recently in Canada and Japan.
Negative labeling is most often seen as hazard labeling or simply
a listing of product ingredients, so that consumers can determine
for themselves if they believe the product to be too hazardous for
their use.


Green Labeling


     The purpose of  "green  labeling" or  "environmental  labeling"
is to  give  consumers an  easy way  of recognizing products  that
create  relatively   few  health  or   environmental  impacts.  Such
advertising  claims   have  already become the  hot  new  marketing
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strategy of  the Earth-Day conscious  1990's.  Ideally, in  such a
labeling scheme an independent body would award products with the
right to use an easily  recognizable  environmental logo  after a
careful  assessment of  their  life-cycle  impacts  including  the
impacts of  the product itself,  the packaging, and the process that
produces it  (the 3 P's). Programs that have been  set  up in other
countries are voluntary for manufacturers and depend upon consumer
interest in  "environmentally  friendly"  products  to  create  the
incentive for manufacturers to produce such products and seek the
label.

     West  Germany  and  Canada both have  comprehensive  labeling
programs. Could such a program work in the U.S.? Interest in this
country is only beginning,  and such  issues as who is to  do the
labeling, how criteria for labeling are to be established, and what
types of products should be considered are still to be answered.


Hazard Labeling


     Hazard labeling informs  the consumer of the identity of toxic
chemicals present in the product or uses simple hazard statements.
Government standards  are set  for  the contents of  hazard labels
under  federal and  state laws. How much  information about  the
hazards of products should consumers be given on labels, and what
form should that information be in? Is there such thing as too much
information,  and who should decide what is needed?

     The recently  enacted California  Proposition  65,  goes beyond
typical labeling requirements  to warn consumers of products that
contain carcinogens, mutagens,  and  teratogens,  even in levels that
may be considered "safe" by federal regulatory agencies. Althpugh
there have  been problems with the adequacy of the warnings required
by a sometimes unwilling state  bureaucracy, Proposition 65 has had
an impact.  Companies have been  reformulating products that contain
the listed chemicals to avoid potential consumer rejection.

     There is a need for expanded labeling  for products containing
toxic chemicals, including expanded listings  of hazards and more
complete listings  of product  ingredients. Support for expanded
labeling stems from the limited information currently required for
product labels. Such support  also stems from the desire to provide
the public  with personal autonomy when it comes to decisions about
personal health and product hazards, rather than having the science
bureaucracy make all of the decisions for them about "acceptable"
risks.

     Community  and worker  right-to-know laws,  which  are another
aspect of  providing chemical  hazard information,  are  also having
an  impact  on toxic chemical  use.  The Toxics  Release Inventory,
discussed  above,   provided   communities  for  the   first  time
comprehensive information on  the toxic chemicals released into the
air and water.  As  a result,  local toxic use  reduction campaigns
have sprung  up, and  companies interested in their  images have
voluntarily  initiated programs for reducing toxic  chemical use.
Worker  right-to-know  programs have also  had  an  impact  in  the
workplace,  as replacement of  toxic  chemicals has become an item in
labor negotiations.

     The public has a  right to take control over their exposure to
toxic chemicals, as happened  very  quickly  once information about
the pesticide Alar was  made  widely  available.  The  Alar public
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information campaign demonstrated that government agencies do not
have a monopoly on  decision-making  about  acceptable risks.   With
better information,  the  marketplace can react more quickly than
cumbersome government regulations.

     The following are recommendations in this area:

  •  A national environmental  labeling  program should be created
     to give consumers clear signals about the most environmentally
     acceptable products,  including  those  that do not contain or
     are not derived from toxic chemicals.

  •  The  nationwide labeling  program  should be  created by
     federal legislation but  administered by an independent
     non-government organization for the sake of credibility.

       •  The national labeling program should preempt other
          environmental claims on product labels to preserve
          the credibility of environmental labeling.

       •  The program should be voluntary,  and high standards
          should be  set for receipt  of the label in order to
          maintain  the program's  credibility in the eyes of
          consumers.

       •  The  criteria  for labeling should  assess the
          life-cycle  impacts  of products  as  much as is
          necessary  and practicable.

       •  Some  entire  classes of   products  should not be
          considered for labeling,   since  some  classes as  a
          whole are  too polluting.

       •  Monitoring of producers who receive the logo is very
          important  to insure  that products  continue to meet
          labeling  standards.

   •  Hazard  labeling should  be expanded to include  warnings on
     products that contain chemicals that have been shown to cause
     cancer  or reproductive damage  in animals.

   •  Public  education programs should target all segments  of the
      §opulation concerning the hazards of household toxics,  proper
      isposal methods and,, most importantly, safe  substitutes for
     those toxic products.
                            CONCLUSION
     Ultimately,  a mix of strategies will be necessary to hasten
 the  use  of safe  substitutes.  The  most  important step  is  for
 governments at  all levels to  begin to  take a  leadership role,  and
 for consumers and the general  public, eager to "do the right thing"
 for the environment,  to be given accurate, objective  information
 on the products they buy  and the  releases of toxic chemicals  in
 their  communities.
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      OPEN-GRADIENT MAGNETIC  SEPARATION FOR PHYSICAL COAL CLEANING;
           RESULTS  FOR PITTSBURGH #8 AND UPPER  FREEPORT COALS

                       by:  R.D. Doctor and C.D.  Livengood
                            Energy Systems Division
                            Argonne National Laboratory
                            9700 South Cass Avenue
                            Argonne, IL  60439
                                 ABSTRACT

       Open-Gradient  Magnetic  Separation  (OGMS)  using  superconducting
quadrupole  magnets offers  a novel  beneficiation techology  for removing
pyritic  sulfur  from  pulverized  dry coal.    It  is  estimated to  have a
power  demand  752  lower  than  techniques  using  conventional  electro-
magnets,  while  achieving  higher  separation  forces.  Additionally, the
system  operates in  a continuous  mode  and uses  no chemicals.   Because
OGMS  is  specifically applicable  to finely ground coal  (120-325 mesh),
its  development could  encourage  the commercialization  of  other uncon-
ventional coal technologies, such as coal-water  slurries,  fluidized-bed
combustion, and  synfuels.
                     OBJECTIVES OF COAL BENEFICIATION

       Deep  cleaning  of  high-sulfur  Midwest  coals using  conventional
technologies  should reduce  total  sulfur from 20 to 50%  by  removing the
inorganic  sulfurfl].    However,  all  physical  coal-cleaning  processes
(including  open-gradient   magnetic  separation)  are  limited  by  their
inability  to   remove   organic  sulfur  intimately   bound  to  the  coal
macerals.  [2]   Inorganic  sulfur  in  coal  exists   primarily  as  pyrite
crystals  (FeS2) of varying  size,  with a  size distribution  that differs
from coal  to  coal.[3]   The specific-gravity of the pyrite  particles is
about  4.9,  while  that  of the  coal macerals  ranges from  1.7 to 1.3.[4]
In current commercial  practice, pyrites and  other minerals are separated
from  the coal  macerals  on the  basis  of  specific gravity  differences
(e.g.,  in cyclones)  or differences in  surface-wetting  characteristics
(e.g., by  froth flotation).  Subsequent  handling and dewatering of coal
slurries   produced  during  processing  has  proven  costly,  and  this
situation  is   worsened  by  fine  grinding   to  liberate  small  pyrite
crystals.

       The  physical basis for open-gradient magnetic  separation (OGMS)
is  that  mineral  inclusions  in  the  coal  are  paramagnetic (attracted
toward  a  magnetic  field),  while  organic   coal  materials  are  weakly
                                  228
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Accordingly, the U. S. Government retains a
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or reproduce the published form of this
contribution, or allow others to do so, for
U. S. Government purposes.

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diamagnetic (repulsed from a magnetic field).  Because these two classes
of components are  subject  to opposing forces when  placed  in a magnetic
field gradient,  they can be  separated  into different streams,  such as
waste, middlings, and clean product.

                         SINGLE-PARTICLE MODEL

       This  program was designed  to use  a quadrupole  magnetic field,
because  it  is capable  of  producing  a  very uniform,  intense magnetic-
field gradient in the central bore, characterized by a high field at the
bore  wall  and a zero  field at the  center. [5]   This  conveys  certain
advantages: 1) a high  field  gradient  is  produced and 2)  coal and pyrite
move  in  opposite   directions.    Coal  maceral   and  pyrite   speeds  and
trajectories  under  the   influence   of   such   a  magnetic  field  were
modeled.[6]    Input  parameters  included   particle diameter,  density,
magnetic  susceptibility,  position when  entering  the  magnetic  field,
field  strength,  and gas  viscosity.   The  magnitude of the separating
force on these  two classes of  compounds may be compared by noting that
the  volume  susceptibility  of  pyrite is  19 x  10    dimensionless  MRS
units,  while  that   of  diamagnetic  coal  is  -3  x  10~°  dimensionless  MRS
units.

       The  predicted maceral  and  pyrite  trajectories are  compared in
Figure 1 for a 60-Wb/m  field.  These predictions compare favorably with
subsequent  experiments  run at  53.3 Wb/m .   From  the  calculated pyrite
and maceral  trajectories,  it can be  seen  that  even a short bore length
should  prove  adequate  for separation.   As  an  example,  a  100-um pyrite
crystal  starting from  the  mid-radius of the bore  should reach the bore
wall  within 0.3  s  after  falling about 0.3  m.   Starting  from the same
position,  a  100-ym coal maceral  should  move in  the opposite direction
and  reach the center  of  the  bore within  1.25  s  after  falling about
0.5 m.
                         EXPERIMENTAL APPARATUS

       Based  on  encouraging  modeling  results,  an  experimental  OGMS
facility  was  constructed at Argonne  (Figure 2).   Coal  is metered into
the  system  through  an AccuRate® pulverized-coal screw feeder capable of
feeding coal  at  0-20 kg/h.  Typically,  the feed rates  average 2.4 kg/h
for  these experiments.  Coal  continuously spills  into  a  vertical pipe
that  permits  6  ft  of  free-fall before  passing through  an  annulus  of
1.25-1.625  in. and entering the high-magnetic-field zone.

       The  superconducting quadrupole  magnet is  wound  from  a niobium
alloy and operates  at 4 K with  liquid  helium cooling.   Once the magnet
has  been  energized,  its  electricity consumption  is  negligible.   In a
commercial  system only the refrigeration power should prove significant,
which  led  to one  estimate for  a  superconducting magnetic-separation
process that  put the energy savings over  conventional  magnets at about
75%[6].   The  Argonne experiments  operates  in  a  costly  liquid helium
                                 229

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boil-off mode without recirculation to a refrigerator.
       The magnet length is 0.68 m, the diameter of the bore open to the
coal  is  0.064  m,   and  the  maximum   field  gradient  is  53.3  Wb/m .
Operational problems  with air icing on the upper portion  of  the coils
limited  the  magnetic  gradient  to  a  value lower  than  the  61-Wb/nr
operation previously achieved.  The quadrupole field (Figure 3) exhibits
four "separatrix" zones of zero field strength that are analogous to the
middle of  the bar for a conventional bar magnet.   The coal is confined
to  the  zones of  maximum field  strength  by being  blocked with  four
attached rods from passing through the separatrix zones.

       After  the  coal  passes  through  the  magnet,  it  is  recovered  by
three nested  concentric pipes  of 1.125, 2.0, and  2.5  in.  (O.D.) 316 SS
tubing with a knife-edge finish.  Each  of  these splitter  pipes in turn
is  connected  to  its  own separate canister containing  a  vacuum-cleaner
bag that could  satisfactorily accomodate 500  g  of  coal.  The suction on
each individual canister  is monitored and  is  adjustable at a downstream
rotometer.
                              EXPERIMENTS

       Two fresh coals, a Pittsburgh Seam #8 and an Upper Freeport, were
tested  through  the  separator.    For  both  coals,  the magnetic  field
measured at the  bore wall was maintained  at  a constant maximum value of
16,100  gauss  (53.3 Wb/m3).   The  experiments ran  in  a batch  mode  for
approximately 10 min, with a constant  vacuum and speed on the AccuRate®
feeder.  For comparison, the same  coals were run through the system the
following  day  without  any  magnetic field.   This  made it  possible to
determine the effect of the vacuum flow through each individual splitter
tube.
                                 RESULTS

       Table 1 summarizes results  for  the  two  coals tested in a single-
stage  OGMS  system.   The coals  were  passed through  the  separator both
with the field on  and off.   With the field off, the product streams for
both coals show a modest concentration of pyrite (7.9-10.1%) and ash (0-
9.5%), which the  separating force of  the  magnetic  field  needed to work
against.  This was a consequence  of the vacuum draw being set somewhat
higher than necessary.

       Both  coals  exhibited  significant  beneficiation  of pyrite  and
ash.   Product-stream (center pipe) sulfur was  reduced  by 29.7% for the
Pittsburgh #8 coal,  while the  Upper  Freeport  coal  showed  an improvement
of   18.3%.     Corresponding  ash  reductions   were  27.8%  and  23.0%,
respectively.
                                 230

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          TABLE  1. OPEN-GRADIENT MAGNETIC  SEPARATION OF  COAL*
  Coal
      Magnet
    Collection
     (g/min)
                        Sulfur   Ash
                         «)     (Z)
Pittsburgh #8
(28 x 0) PETC
ON
                OFF
11.53
11.84
13.30
36.36

12.76
13.01
12.25
38.02
P
M
R
Total

P
M
R
Total
3.24      8.3
3.93      9.7
6.30     15.7
4.61 Ave 11.5 Ave

5.16     11.6
4.71     12.1
4.46     11.5
4.78 Ave 11.7 Ave
Upper Freeport ON
(27 x 0) PETC


OFF



11.33
12.90
19.63
43.86
12.94
13.63
15.84
42.41
P
M
R
Total
P
M
R
Total
1.78
1.84
2.64
2.18 Ave
2.51
2.17
2.17
2.28 Ave
19.4
25.7
28.3
25.2 Ave
28.7
26.0
23.8
26.2 Ave
*Pf • fProduct, Mf * ^Middling, R# » fReject, Ave * Average.
                                 231

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                              CONCLUSIONS

       Single-stage  coal  beneficiation  using  open-gradient  magnetic
separation was  investigated,  and the results demonstrated  that  OGMS is
capable of effecting a respectable reduction  of  24% for both sulfur and
ash.  The  coal  residence time in the system  was  short, and the product
was dry.

       Additionally, because the separation force is proportional to the
square  of  the   magnetic-field   gradient,  even   small  changes  in  the
gradient can  significantly  improve  performance.   Further opportunities
to  improve OGMS  performance  should  develop in the  future when the next
generation of quadrupole magnets is constructed.   These magnets will be
capable of generating gradients  as high  as 90 Wb/m ,  a 285% increase in
magnetic separating force.

                            ACKNOWLEDGMENTS

       This work was  sponsored  by  the Exploratory  Research  Fund of the
Argonne  National   Laboratory   Energy,   Environmental,  and  Biological
Research  Office.   The  coal  samples were  provided  by  Tom S.  Link,
Pittsburgh Energy Technology Center  (U.S. Department of Energy).
                                  232

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                                     Radial Bore Position (m)
                         0.000  0.005   0.010  0.015   0.020   0.02S   0.030   0.035
                    I  **'
                    .0
                    I?  -0.4-
                    s.
                    8
                       -0.6-
                       -OJ-
                              50 /am
                                  • Pyrite
                                  • Maceral
                                    Radial Bore Position (m)
                         0.000   0005   0010   0.015   0.020  0.025   0.030  0.035
                      -0.8-
                              100)ttm
                                  • Pyrite
                                  • Maceral
Figure  1.
                                    Radial Bore Position (m)
                        0000   0.005  0.010   0.015  0.020   0.025  0.030
                   1
                   S
                   £
                   3
                   •
Predicted  Trajectories of Pyrite  Particles  and  Coal  Macerals
in 60-Wb/m  magnetic  field
                                               233

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Collection
Canisters
                              Feed Annulus
                           Superconducting
                           Quadropole Magnet
                              Splitter Assembly
                                         A	f—4-	A'
U   U   U
Magnetic
  Middlings
      Product
                                                                2-3/8"
                                                             1-7/8"
                                                           1"
                         To Vacuum
Figure  2.  Experimental  System  for the  Superconducting  Open-Gradient
           Magnetic  Separation of Coal.
                               234

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         N
    Electromagnetic
    Windings
                     OOOOOOOOO
                     OOOOOOOO
                      ooooooo
                       OOOOOO
             00°0°0
             ogogo°
             ogoo
                      oooooc
                       oooooo
                      ooooooo
                     oooooooo
                     ODOOOOOOO
§°§°S°8) N
Bore
Configuration
with
Separatrix
Blocked
Figure 3.  Cross Section of Superconducting Quadrupole Magnet
                             235

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  AN INTERNATIONAL ENVIRONMENTAL CONSCIENCE AND AMERICA'S ROLE

                    by:   Donald J.  Ehreth
                         Versar, Inc.
                         Springfield,  VA 22151
    We in the United  States have become very  conscious of the
state of the environment in recent years and have taken  a number
of  steps  to reduce  or eliminate  the effects  of environmental
pollutants.  At the  same time we expect other nations to follow
our lead  and make  environmental protection  a  priority.   As a
consequence, Congress  has begun to  introduce  legislation that
would  impact not  only the  U.S. but  other countries  as well.
However,  these  other nations,  particularly  the  developing
countries,  have other concerns that  must  be  addressed  before they
can concentrate on the environment.  This paper explores some of
the  factors  involved  in  recently  promulgated  or  introduced
legislation.

    In  1989,   Congress   enacted   Public   Law   101-240,   the
INTERNATIONAL DEVELOPMENT AND FINANCE  ACT OF 1989.  Subtitle C-of
this law,  Environmental Assessments,  instructs the United States
Director  of each  multilateral  development bank  to   vote  in
opposition to any action proposed to be taken by the bank which
would have a significant impact on  the human environment unless
an   environmental   impact   assessment  is  first   provided.
Environmental Assessments  are  made available to  the borrowing
institution or country, the bank, non-governmental organizations
(NGO's) and  affected  groups.    The law further  specifies that
Director's should work  together to develop and propose  a procedure
for systematic  environmental assessment, taking into consideration
the Guidelines  and Principles for Environmental  Impact Assessment
promulgated  by  the  United Nations Environmental  Programme and
other  bilateral  or  multilateral   assessment procedures.    In
addition,  PL 101-240  requires  interagency and public review of the
impact assessments. Congress expected Treasury to develop  thorough
and adequate guidelines for implementing PL 101-240.

    Also  during the 101st  Congress, S 1089 was introduced.  The
Bill would amend the National Environmental  Policy Act of 1970
(NEPA) to consider the impact of Federal.agency actions outside
the United  States on  "global climate change, depletion of the
                               236

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ozone  layer,  transboundary  pollution, biodiversity,  and  other
phenomena of  international environmental concern.   Furthermore,
another bill, S  1045,  was introduced to amend NEPA  to  encourage
multilateral development  banks to  adopt procedures for  assessing
the environmental impact  of development projects  funded by those
banks.

    Under S  1045,  the  Council  of  Environmental Quality  (CEQ)
would be charged with identifying and promulgating internationally
accepted  criteria  for environmental impact assessments  in order
to  facilitate  the  consideration  of  environmental  impacts  in
lending decisions.   Like PL 101-240, S  1045 would require that the
bank directors and the public have access to environmental impact
assessments at  least 120  days prior to a U.S. vote  to  support a
bank loan.   The bill  seeks to secure an assessment for public
scrutiny that contains relevant environmental information without
disclosing unnecessary  confidential details.

    There is  little disagreement  that the  U.S.  has  important
domestic  objectives  that cannot  be achieved without cooperation
from other nations.   Yet a number of questions can be raised.   Is
America in any  position to expect foreign countries to  abide by
the mandate  of  NEPA and its assessment  process when  its  own
government agencies have not always taken NEPA seriously until the
courts held them in strict compliance?   Is the U.S. exporting its
litigious culture with the enactment of this legislation?  Is this
the best utilization of U.S.  expertise  and knowledge?  Should the
U.S.  do   a   better  job  of transferring  its  knowledge   of
environmental   science   (fate,   transport   and   effects)   and
environmental engineering?  Many  questions  need  to be  answered
before any additional legislation  is passed.

    NEPA  is the  basic national charter by which the United States
protects the environment.  It establishes policy,  sets  goals and
provides means for carrying out that policy.  It contains "action-
forcing"  provisions  to  make sure  that  federal  agencies  act
according to the letter and spirit of  the act.  The  NEPA process
is intended to help public officials make decisions that are based
on  understanding  of the environmental  consequences  of  their
actions and to take actions that protect, restore,  and enhance the
environment.   Federal  agencies  are to use  practical  means  to
restore and enhance  the quality  of the human environment and to
avoid or  minimize  any possible adverse effects of their actions
upon the quality of the  human  environment.  They are also expected
to identify and assess actions that will have similar objectives.

    The NEPA  provisions are supposed to be applied  early in  the
process so that the environmental effects and values of the action
can be identified  in adequate detail  to  allow for  economic  and
technical  analyses.     In  this  initial phase  of  the  process,
significant environmental  issues  that  deserve further study  are
                               237

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identified  and insignificant  issues  are de-emphasized,  thereby
narrowing the scope of the environmental impact statement. The act
requires procedures to identify projects that clearly require EIS
preparation,  determine  when  an  environmental  assessment  (EA)
should be completed, or ascertain when to prepare a finding of no
significant impact  when  the  agency's  EA leads to a determination
that an EIS is not  necessary.

     Congress did  not attempt to  anticipate the  administrative
adjustments that would be required in order to  apply  the act to
the widely  varied  activities of the  federal  government (Cramton
& Berg, 1971).  Thus, the primary impact of NEPA has been largely
limited to major federal actions,  ignoring the requirement for an
EIS for any proposal  for legislation  or any major federal action
which "significantly affects  the quality of the human environment"
(Robinson, et. al.,  1979).

     Questions regarding what  constitutes a "federal  action," a
"major action," or "significant effects" have largely been left
to the courts  to decide.  Determining the sufficiency of an EIS
has been another problem for the courts to resolve.  Although the
number of  suits brought against federal  agencies has  steadily
decreased since implementation of NEPA,  questions still exist as
to whether the act simply provided an instrument  to stall or kill
development projects.   Although NEPA is a policy act, it is widely
interpreted  by  lawyers,   judges,   and  -journalists   as  being
essentially procedural because the legal  profession is primarily
concerned with the specific performance that is stipulated by the
act and open to challenge  and  litigation  in the  courts.

     Has  NEPA  simply  become  a  powerful  tool  used  by  special
interest groups to  press  their  concerns?  Many observers hold this
view and believe it is a potential problem with this legislation.
Others have objected to NEPA on the grounds that incorporation of
an EIS into the decision-making process would enable  citizens of
another country to employ U.S. courts to block  actions proposed
by their own country.   This could have a significant impact on the
caseload of our court system and place potential  liability on the
United State for the  impacts of a project implemented in another
country after  the  impact assessment  was performed  by  experts in
the host country.

     L.  K.  Caldwell,  considered  the  architect of  NEPA,  believes
that   Congress  and   the  president   have  generally   ignored
implementation  of  the national  policy.   While NEPA   has  been
largely successful  at forcing government agencies to ascertain the
probable consequences  of their actions, Caldwell states that the
impact  analysis and evaluation  involved  in an  EIS   are  not
sufficient to achieve NEPA's  goals.  He calls for a constitutional
amendment to fully  achieve the  intent of the act  (Caldwell, 1989).
                               238

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     It  is  expected that some would support this contention, while
others would reject it out of hand.  Although  society might view
environmental  issues  as increasingly  important,  it is commonly
believed that  such support  is  not broad enough to encompass the
passage of  a  constitutional amendment.   There is no indication
that  NEPA  is  the unproclaimed  answer to  global environmental
problems or that its embodiment in a treaty would have much useful
effect on the major forces behind global  environmental  impacts.

     There   is  considerable  evidence  that   the  environmental
assessment  process   is  already   employed   by   a   number   of
industrialized   and  developing  countries   (Atkeson,  1989).
Multilateral  development banks  (MDBs) have  already instituted
procedures for environmental assessments  (EAs).  The U.S. Agency
for International Development (USAID)  procedures  are  a good model
for  international projects.   The United Nations Environmental
Programme  is  considering an international treaty dealing with
incorporation  of the  EIS  process.    Reaction by  American and
international  experts  concerning  the  EIS process,  however, raises
questions  about  the  appropriateness of  requiring   the  EIS,
especially in  view of  the  fact that all countries may not consider
environmental  quality to be  a basic right.

     The additional benefits gained from  enacting  action-forcing
legislation are unknown at present.  U.S.A.I.D.'s  procedures are
already action-forcing  and  presumably that is the intent of the
MDBs.  At  this time,  however,  it is appropriate to  question how
much  the   addition  of  such   legislation  will   improve  the
environmental  sensitivity of  foreign  countries.    Not only  do
developing  and developed  countries  differ in  their  political
atmosphere and attitudes toward the environment, but there is also
a  wide variation in  their  ability  to  pay  for environmental
protection.  In general,  human activities undertaken in developing
countries  usually cause local  environmental   degradation, while
those in  developed nations  tend to  create global environmental
problems (Ehrlich, 1990).

     Two frequent objections made by  scientists to NEPA  have been
that  the  state of  science is  seldom  adequate to assess the
environmental  impact  of  human  activities  and that  the use  of
science  in a  political  context  runs the risk  of corrupting
science—the  consequence being the dishonest or distorted use  of
science.   In  the  past critics of NEPA have alleged  that  the EIS
was an instrument of "bad science";   however,  it is now generally
conceded  that  there  have   been improvements  in environmental
science, and  thus the quality of the more  recent  EISs  should  be
improved.

     In the 1960s,  air  and water pollution  were the  principal
environmental  concerns in the United States.  From the perspective
of  the  public,  aesthetic   values  contributed  greatly  to the
                                239

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determination of the quality of our environment.  Waterbodies with
reported  fishkills  or contaminated  with  sewage,  garbage,  or
industrial waste was unappealing.  Today, the  U.S. environmental
program has  shifted its  focus on control of toxic and hazardous
chemicals discharged into the environment,  instead of  disease-
causing agents  that formerly occupied  our  attention.    However,
disease-causing  agents  are  still  of  major  concern   to  the
developing countries.

     If  legislation  requiring environment  impact  statements  is
passed,  criteria might be imposed on lesser developed countries
(LDC) that would preclude  them from achieving success in providing
for clean drinking water and the sewage collection  and  treatment.
Moreover many LDCs  have  yet to address the fundamental  needs of
public health.   Program maturity, therefore,  differs significantly
throughout the world,  and  congressional action might inadvertently
misdirect the efforts  of developing countries.

     When   people  are  starving,  environmental   problems   seen
insignificant.   Impoverished people  generally  rank  their  needs in
the  order of  agriculture,  public  health,  and  then,   perhaps,
environmental protection  (Carter, 1990).  More important to them
might be technology to triple or quadruple their grain  production
per acre.   Poverty detracts  from  the significance of environmental
issues.    Only when people are  shown  the direct  benefit  of  an
action,  that protects  the environment will their leaders be able
to focus on  environmental issues.   While it is  very appropriate
for the U.S.  to be  concerned with addressing global environmental
issues,   it  is  equally  important   to  understand  the   diverse
priorities of the many nations on our planet.

     LDCs  generally view  development as being imperative to the
very survival of their bulging populations.  They  tend to regard
environmental concern as  a luxury that only industrialized nations
can  afford  (Timberlake,  1984; Arad, 1979).   In fact,  there are
some who would  say that  the environmental standards or  criteria
used  by developed  nations are  a  function of their  affluence.
These critics point to a correlation between  growth in  U.S. GNP
and  increasingly  more  stringent  criteria  for  air  and  water
pollution that have evolved since the  1960s.

     Nevertheless,  there is considerable pressure on LDCs  to  adopt
the  standards  and criteria of  the  developed  and  industrialized
countries.   Yet on  the other  hand, there is debate as  to whether
adoption of  these standards/criteria has led  to any improvement
in  the  environmental  quality  of  these  countries  or  even the
developed countries.

     The proposed  legislation, S  1045, S 1089,  etc., calls for the
establishment of  appropriate environmental criteria that can be
applied to projects covered by  the MDB efforts.  This  call for
                               240

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environmental criteria  appropriate  for LDCs is not new, but who
has accepted the challenge of producing the data base?  Would this
not be a better utilization of U.S. expertise?  Is there not  a way
in which environmental protection and the sustainable development
goals of developed countries as well as  the  more  immediate  goals
of  the  LDCs  could be  accommodated more  effectively?   As the
scientific evidence mounts,  developed nations will be  in a better
position  to  point to  examples  of  the  environmental  benefits
resulting from environmental preservation,-thereby encouraging the
developing nations to take a more active role.

     Multinational   development  banks   have   developed   and
implemented procedures to assess the environmental impacts of the
projects that they fund.  There are those who would say that  their
procedures do little  more than  pay  lip service to the review  of
environmental impacts  (Kumar  &  Sharma, 1988).   Critics  point  to
projects costing billions  of dollars  and  affecting millions  of
people in countries such as India, Botswana, Sudan,   and Brazil.
They maintain that the  lack of  a public process  makes a sham  of
the World Bank's environmental review process.  It is possibly for
this reason  that Congress has deemed it necessary to  invoke the
power of  law to ensure that  impacts having major environmental
consequences  are   reconciled  before   the  project   design   is
completed.

     USAID uses a  multi-step  process.   The  purpose  of  this
approach  is  to  ensure that  the environmental  consequences  of
USAID-financed  activities are identified and considered by both
USAID and the host country  prior to reaching the final  decision
to  proceed  and that  appropriate environmental  safeguards are
adopted.  Their program also produces capacity building within the
host  country, identifies impacts upon  the  environment and the
biosphere, and  leads  to the definition  of environmental factors
that constrain development.  Restoration  of the renewable resource
is an important  goal of USAID policy.

     The USAID   process  begins  with  an  Initial Environmental
Examination that provides a brief statement  of the factual  basis
for a Threshold Decision, that  is,  whether an EA or  an  EIS will
be required.  The key to making this determination is whether the
proposed action is a major  action "significantly affecting" the
environment  (22  CFR Part 216).    "Significant effect"  is defined
as doing significant harm to the  environment.  If such an effect
is  predicted, a  Positive  Threshold Decision  is made.   USAID,
following the procedures prescribed by NEPA, has  defined Classes
of Actions that  would normally be expected to have a  significant
effect on  the environment.   Thereafter, either  an EA or an EIS
will be  prepared for the project unless there is justification
under the USAID process for making a Negative Declaration.   AID'S
procedures comply with NEPA.   They provide  an excellent model for
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other countries  and MDBs whose procedures  are  in the formative
stages or could benefit by additions.

     In  the  late  1970s, the Asian Development Bank (ADB) concluded
that it must systematize its approach to environmental  issues  and
incorporate  environmental  concerns  into  each  stage of the  project
cycle.   Between 1981  and 1987,  over 3,000 development  project
reports were reviewed, 1,102 of which were the subject of formal
comments from Environmental  Specialists..  These reviews  advised
project staff about the significance of potential environmental
impacts and provided detailed remedial measures where necessary.
The opportunity  was also  taken,  where appropriate,  to delineate
the wider environmental implications of the project (e.g., water
resources  development,  resettlement of tribal people, rural
development opportunities,  etc.)  and to emphasize the advantage
of conducting environmental assessments in the planning  and design
phase (ADB,  1988).

     Environmental    Specialists   review   the   ADB's   economic
development   projects.     This   review  first   involves   the
identification of  potentially  significant environmental  impacts
associated with the proposed development projects; then agreement
is  reached  on   the appropriate  budgetary  provisions  for   the
necessary services.   This is achieved,  in part, by dividing  the
proposed  ADB projects  into four  broad impact  categories that
reflect the severity of their potential  environmental impacts  and
thus their need  for environmental analysis:

     Category A:     Projects rarely  having  significant   adverse
                    environmental impacts;

     Category B:     Those generally inducing significant  adverse
                    impacts,  but which can be readily identified
                    and  quantified,  and   for   which  remedial
                    measures  can  be  prescribed  without much
                    difficulty;

     Category C:     Projects invariably having significant adverse
                    impacts  requiring   detailed  environmental
                    analysis; and

     Category D:     Environmentally oriented projects.


     To  date,  the  ADB  has  published  several  Environmental
Guidelines  to help staff determine  whether or  not  a proposed
project is likely  to generate significant environmental  impacts-
-adverse  or  beneficial.    Since formalizing  its environmental
policy in 1980,  the ADB has moved beyond the exploratory  stage in
the  field of environmental  planning  and management and  has  now
established  a framework  in which  this important  but hitherto
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neglected dimension can be blended with the overall objectives and
strategies of socioeconomic development  (ADB, 1988).

     Like the  ADB,  the  World  Bank  (Bank)  has  also  adopted
environmental assessment procedures.   In addition, the Bank has
identified categories  of  projects  for which an EA  might be  either
necessary or unnecessary.   The EA must be submitted to the Bank
before Bank appraisal.  The borrower is expected  to describe how
major  environmental  issues have  been  resolved   or  are  to  be
addressed,  noting  any  proposed  conditionality.    The  EA's
recommendations   are  expected  to   reflect  the  borrower's
consultations  with the NGO's and other  affected groups as a basis
for formal environmental clearance prior to the authorization of
negotiations  with the Bank.    EAs also  provide   the  basis for
supervising the  environmental  aspects  of project  implementation
(World Bank, 1989).

     For  all practical purposes, the scientific aspects of all of
these procedures are very similar.  Terminology and structure of
the overall process differ, as does legal recourse.

     Nevertheless,  they all have the same objective—identifying
the  environmental  impact of MDB-financed development projects.
From experience,  the U.S. consulting  engineering profession knows
that the conduct of environmental assessments and preparation of
environmental  impact  statements  are  complex   and  difficult
processes.   This  group  also  supports the proposed  effort for
resource-sustainable development  for countries  at all stages of
development.  Throughout the world, the U.S. consulting engineer
has been at the  forefront  of the development of methodology for
preparing EISs and managing environmental programs and projects.

     Those companies engaged in consulting generally lack the full
complement of specialists  required to  assess large projects and
thus  form consortiums  or  teams  to   address  the  more  complex
problems.   Because of their experience in the  field,  however,
these  firms are  aware of  the  unsupportable burden that  may be
placed on developing countries if they are required to meet U.S.
NEPA requirements too quickly.

     All  developing countries  are  unique  and  must  not  have
requirements  imposed  upon  them  across  the   board.     Such
requirements could delay and even paralyze  crucial development
efforts.   Shortage  of trained  staff,  general lack of experience
with a public process, differing priorities, and  introduction of
a litigious culture are all  factors to be weighed when considering
alternatives to  Congress1  call for application of the NEPA EIS
process.    Furthermore,   it  is  doubtful whether these countries
would  have the  resources  necessary  to  implement  a NEPA  EIS
approach.  An  approach that would be effective is one that assists
countries in improving their capacities to assess environmental
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needs, while ensuring that the  best  expertise is used to assess
priority projects in the interim.    This,  in short,  is the role
of assistance of U.S. consulting engineers and scientists.

    To   assist  developing  countries  in  strengthening  their
systems, the following kinds of actions should be taken:

    *    Designating USAID  as the  lead  agency  to  transfer
          environmental  assessment  expertise  to LDCs  and MDBs.

    *    Programs for their national  and state-level  legislators,
          e.g.,  visits  to  their  U.S.  counterparts  to  gain  an
          understanding  of  how environmental  laws are developed.

    *    Assistance from U.S.  agencies to their counterparts in
          developing    countries,     where     appropriate,    on
          administrative   support   systems,   recruitment   and
          classification of personnel,  on-the-job training,  and
          other areas as needed.

    *    Assistance    from    U.S.   universities,    technical
          consultants,  professional associations,  and technical
          schools on  curriculum  development  that will  enable
          countries   to  produce better-qualified  environmental
          specialists.

    *    Short- and long-term training courses in the  U.S. and by
          U.S.   specialists  in-country  to   train   engineers,
          scientists,  technicians,  and managers.

    *    Development of improved  contractual  arrangements  for
          technology  transfer  by  U.S.   companies   to  their
          developing country  associates  and subcontractors.

    *    Provisions for on-site project  training of developing
          country engineers  and   specialists on  environmental
          projects being implemented  in  the U.S.

    *    Development of a  process within the U.S. Environmental
          Protection Agency's standard/criteria  setting process
          that   would  assess the   impact  of   U.S.  environmental
          standards/criteria  on  LDCs.

    Whether any of  the previously mentioned  bills become law or
not,  it  is clear that  development projects  will continue to be
closely scrutinized for their environmental effects.  Imposition
of U.S.   standards  and  law on  the sovereignty of host countries
is not  likely  to improve the quality of -those reviews.    It is
quite possible  that the full intent  of  NEPA  needs to be brought
to bear on this issue.   Perhaps  such an action will point Congress
in the right direction.
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                           REFERENCES
Arad, R.W. and U.B. Arad  (1979)  "Scarce Natural Resources and
     Potential Conflict."   In:   Arad,  R.W.,  et.  al.  Sharing
     Global  Resources.   New York:   McGraw-Hill.

Asian Development Bank  (1988)  Environmental Planning and
     Management and the Project Cycle.

Atkeson, T.B.  (1989)  "Overview."  Environment:  Vol. 31,
     No.  10,  p.  2+.

Caldwell, L.K.  (1989)   "A Constitutional Law for the
     Environment:   20 Years with NEPA Indicates the Need."
     Environment:   Vol.  31,  No. 10, pp.  7+.

Carter, J.  (1990)  In:  New Age Journal, March/April.

Erlich, A and P  (1990)  "Thinking  About Our Environmental
     Future."  In:   EPA Journal,  Vol.  16,  No.  1.

Kumar, P. and Sharma, K.K.  (1988)  "Development and the
     Environment — A Third World Perspective."  The
     Forestry Chronicle, p.  464+.   (December)

Robinson, Gellhorn and  Bruff (1979)   The Administrative
     Process. 2nd Edition.  West Publishing Company:
     St.  Paul, Minnesota.

Schafer, J.  (ed)  Environmental Quality. -1987-1988;  Council oh
     Environmental Quality.  Annual Report.  1988, p.  189.

Timberlake,  L. and Tinker, J.  (1984)  Environment and Conflict.
     London:   International Institute for Environment and
     Development,  Earthscan Briefing Document No.  40.

World Bank  (1989)  Background  Note;   Maior Provisions of World
     Bank Operational Directive on Environmental Assessment.
     Operational directive 4.00,  Annex A.
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                       STRATEGIES FOR SOURCE REDUCTION
                                    Christine A. Ervin
                              The Conservation Foundation
                                 Washington, D.C. 20037
                                      ABSTRACT
      The Strategies for Source Reduction Project is exploring changes in product
design and use as ways to help reduce problems in the municipal solid waste stream.
The project, being conducted by The Conservation Foundation with funding from the
U.S. Environmental Protection Agency, is directed by a  broad-based steering committee
that will complete its work in  the fall of 1990.  Three issues relating to the
environmental effects of products are highlighted in this paper among the various
project activities designed to influence national policies.

      Definitions for municipal solid waste source reduction abound. But without
widespread agreement on what source reduction means,  national policies cannot
achieve their full potential.  This project is grounded  in the perspective that source
reduction: 1) involves a range  of activities outside the management of the waste
stream,  2) is a resource conservation measure, and 3) should not increase the net
amount or toxicity of wastes generated over a product's  life.

      Public interest in  the tools for measuring the environmental effects of products
has surged recently.  A one-day forum was held to explore policy issues emerging
during this time of green consumerism and renewed concern for the environment.
Among the many issues identified, panelists discussed how the expansion from private
to public uses of product life information might require changes in the way studies are
conducted and results communicated.

      One of the uses of product life information is in labeling programs that intend
to help  consumers choose products that are environmentally preferred.  The steering
committee has developed recommendations that can be used to help overcome
challenges in designing an effective program and to evaluate alternative approaches to
product labeling. Several of those recommendations, including the need to avoid
multiple programs, are addressed.
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       How can changes in the design and use of products help reduce the volume and
toxicity of the waste communities must manage? That question is being addressed for
the first time on a nationwide basis by the Strategies for Source Reduction project at
the Conservation Foundation. While the project will not be completed until the fall of
1990, this paper highlights several issues addressed so far:  the definition of source
reduction, policy issues surrounding the nature and use of product life or "life cycle"
studies, and product labeling programs.

       The Strategies for Source Reduction project grew  out of several recommendations
in EPA's Agenda for Action for solid waste management.  Undertaken with funding
from EPA's Municipal Solid Waste Program, the project  is designed to provide
pragmatic guidance for those seeking to influence source reduction at the national
level.  A 19-member steering committee was convened in the  fall of 1990 to guide the
analysis and to develop project recommendations.  Members represent:

       o    federal and state governments;
       o    authorities responsible for managing municipal waste at the  national and
            local level;
       o    manufacturers and a retail chain; and,
       o    national and local public interest groups, as well as the academic
            community.

       This diversity in perspectives is essential to help forge a nationwide consensus
on policies that encourage source reduction. We have not focused on packaging  per §£,
because there are other major efforts underway  doing just that—such as the Source
Reduction Council of the Coalition of Northeast Governors.  Nor have we  sought to
develop a comprehensive list of actions for all sectors to  take, or to conduct a
comprehensive analysis of incentives and disincentives for source reduction.  Such
recommendations would run counter to our belief that many source reduction problems
and solutions must be dealt  with by the various sectors concerned and at the
community and state level.
            WANTED:  A COMMON DEFINITION FOR SOURCE REDUCTION
       Recently, another organization conducted a survey of all the definitions for
source reduction being used around the country.  The tally was about twenty then, and
that number probably has grown.  Some of the definitions include recycling; others
adamantly exclude any form of waste management. Some emphasize resource
conservation; others don't mention it at all.  Some definitions are lengthy
descriptions; others simply a sentence or two.

       One of our first priorities, then, was  to try to build a common understanding of
what this Steering Committee meant by source reduction for its own activities, and
further, to make that definition available for others to adopt.  Will it prove to be just
one more definition?  Hopefully not.  By bringing together the different needs and
viewpoints represented in this project, we believe the resulting definition will help
establish common guidelines for the goals and priorities we need to make source
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reduction happen in this country.  It has not been easy to reach a definition that
meets all expectations but we are very close.  To start with, we have defined source
reduction to be:

       ....the design, manufacture, purchase or use of materials or products (including
       packages) to reduce their amount or toxicity before they enter the municipal
       solid waste stream.

Furthermore, our final definition will  include two related concepts:

       ....a recognition that source reduction is a resource conservation measure; and

       ....that source reduction should not increase the net amount or toxicity of wastes
       generated throughout  the life of a product.

These central ideas—that source reduction involves a whole range of activities outside
the management of the waste stream; that it serves to conserve resources; and that it
recognizes effects stemming  from the entire life of a product—are pivotal to the entire
context of our project.  The  latter concept, for  example, leads to another issue  our
project has dealt with as discussed below.


             PRODUCT LIFE ASSESSMENTS: POLICY ISSUES UNLIMITED
       On May 14, the Conservation Foundation, at the suggestion of our Steering
Committee, brought together a panel of twelve individuals to explore the nature and
use of what we are calling product life assessments. Sometimes known as life-cycle
or cradle-to-grave studies, these assessments are used to identify the resource effects
associated with a product over its  entire life spectrum.  A comprehensive study of this
type identifies energy use, material inputs, and types of pollution generated during a
product's life: from extraction and processing of raw materials, to manufacture and
transport of a product to the marketplace, and finally, to use and disposal of the
product.

       Product life assessments are not  a creation of the last year or so.  The first
studies were conducted in the late 1960's and early 1970's during a period in which
energy efficiency, recycling and solid waste  were issues of public concern.   In fact, at
least two such assessments were performed in the late  1970's to compare  alternative
products much in discussion today: disposable versus reusable diapers.  Many more
studies during that period, however, focused on the energy and environmental impacts
of packaging alternatives--particularly  beverage containers.

       While such studies are not new,  they recently have surfaced as an issue of
great public interest and controversy.  Private and public sector demand for product
life assessments has surged. One private firm is doing twice as many studies this
year as in the previous decade or so; a  nonprofit firm is undertaking a study of
unprecedented scale for a consortium of states and other interests; EPA has launched a
major research effort to design and use product life assessments.
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      It is not difficult to understand the surge in interest during this era of
renewed environmental concern and green consumerism. Product life information
might be used by companies in selecting which products to sell, by consumers in
choosing among products offered and by governments in setting policies involving
specific materials or substances. Architectural and industrial design associations might
use product life information in specifications for their clients and professions.  The
array of potential uses—and misuses—is daunting. Which is why we held the forum.

      Despite the enormous role  of product life assessments, there is no clear
consensus among prospective users and developers of the information on: what the
study should actually consist of, which analytic methods and data are appropriate,
whether or not technical detail should be available to the public, and a host of other
issues.   Lack of resolution on such issues poses an obstacle to their constructive use
and opens the door to abuse.

      Our forum did not presume to resolve such issues. Rather, it was intended to
serve as an early opportunity to identify and explore exactly what the policy issues
were surrounding these studies to help speed their resolution.  We  are in the process
of compiling a report on that discussion, but several issues are presented here.

A NEW PUBLIC ARENA

      The expanding use of product life information for development and marketing
brings them into the public arena as never before. Issues have become more complex
and the "groundrules" appear to be changing quickly. This expanded context carries
with it new concerns regarding the analytic tools themselves and sources of
information.  For example,  there  will be considerable pressure to examine underlying
data and assumptions in order to  verify study conclusions.  That can come in conflict
with the confidentiality of company data, which if perceived to be a threat, could
affect the quality of information  made available to consultants carrying out the studies.
New methods of building and standardizing databases, one panelist likened to economic
input-output matrices, may need  to be developed to  resolve this conflict.

MEASURING ENVIRONMENTAL EFFECTS

      One of the major issues raised at the forum concerned how far the analysis
should go in identifying and weighting environmental effects. This topic generated
numerous opinions and points of  view. For example, some panelists believed that
product life assessments, for public uses in particular, will be incomplete without
measures of risk assessment. Others believe that including risk data would make the
analysis too unwieldy for widespread use. Some believe that  risk assessment is beyond
the scope of the studies, partially because a floor of  protection is furnished already by
federal  laws and regulations. Some panelists, however, pointed to the recent shift
toward pollution prevention as  a good example of the changing groundrules.  By getting
at the source of pollution through product design, we are looking at an expanding
universe of pollutants and their effects.  Ability to meet OSHA  or EPA standards alone
may no longer be sufficient.
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       Even more basic, however, is the question concerning whether or not individual
pollutants should be weighted in some way.  Many studies tend to summarize  the
amounts of individual pollutants by their categories of release, such as water and air
pollutants. Some panelists pointed out that adding up individual pollutants in this
manner implicitly assigns an equal weight to each.  Since  there may be  disagreement
over the relative weighting of pollutants, studies could either identify and list all
amounts of pollutants for the reader to  interpret or make  assumptions explicit.

COMMUNICATING RESULTS

       The challenge in communicating product life results to the public was another
point of discussion.  Clearly  there is tension between simplicity and accuracy.  If
results are too simple, the inherent complexity of the data may be lost.  If too
complex, the study will die of its own weight. All parties concerned with  product life
assessments will need to address these tradeoffs and develop workable solutions.

STREAMLINING THE PROCESS

       Our environmental problems are such  that we may not be able to postpone  work
until hundreds, or thousands, of product life assessments are performed. Many
panelists, if not all, seemed to agree that we  may need to devise different tools for
different uses; there may not be, in fact, a single instrument called a "product life
assessment."  To avoid the quagmire of needless complexity, we may need to develop
sound but efficient shortcuts for evaluating relative environmental effects of
alternative products  and materials.  One immediate issue,  for example, will be how to
tailor and use these assessments  for the product labeling programs  currently proposed
in the United States.
                 THERE'S LABELING AND THEN THERE'S LABELING
       Our Steering Committee has evaluated two different types of labeling
approaches that could be used to help consumers choose products on the basis of
their environmental characteristics. If effective, such programs  could harness the
private market to produce goods that are compatible with source reduction, i.e. goods
that generate less waste, and waste that is less toxic.

       The first type, "environmentally preferred" labeling, is the kind practiced in
West Germany and Canada and currently proposed by Green Seal, Inc.,  for use in the
United States. Such  an approach is voluntary (manufacturers can choose whether to
apply); positive (only relatively superior products are distinguished); and is based on
specific technical criteria such as some of the factors included in product life
assessments discussed above.

       Environmentally preferred labelling is quite different from an alternative called
"standard setting."  This method controls the use of certain terms (such as
"recyclable" or "recycled content")  by defining the terms and establishing conditions
for their use.  Standards could also be used to control the use of symbols such as the
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three-arrow recycling logo.  If implemented by a government agency through
regulations, as being considered in the northeast states, the standards could be
mandatory.  Standards developed by industry associations or independent testing
organizations can also be implemented on a voluntary basis.

       Our project has not endorsed any particular labeling program—either existing or
proposed.  It has, however, laid out certain guidelines and recommendations that can be
used to help evaluate labeling programs currently being explored at the national, state,
or community level. For example, the steering committee recommends that a labeling
program should base its criteria on product life assessments.  The discussion below
reflects and amplifies on several other points concerning an environmentally preferred
labeling program.

IMPLEMENT AT THE NATIONAL LEVEL

       Product labeling should be done at the national level, preferably through a
single program.  The logic to that recommendation would seem clear enough.  Labeling
is intended to reduce consumer confusion about the myriad of products available in
stores.  Even with a single program, there is some potential for confusion because
consumers may misinterpret the label's meaning.  For example, a consumer might
believe it safe to pour a household paint down the drain because they think the label
means the product is completely benign. That type  of educational challenge is why
countries are steadily abandoning labels that read "environmentally friendly" or other
absolute terms that imply that a product has no effect on the environment or is even
"good" for the environment.

       Now multiply that challenge with a variety of labeling programs that are likely
to  be inconsistent with each other.  Clearly, multiple programs pose a greater risk of
aggravating the confusion they intend to remedy. Moreover, a major consumer
turnoff to such an educational tool could have long  term consequences quite at odds
with our current thrust toward pollution prevention. There is another practical
reason for recommending a national  program: it  would reduce the burdens on
companies associated with multiple labeling programs.

CAREFULLY DEFINE THE CATEGORIES

       The categories used to label products should  be selected with great care. An
environmentally preferred label provides relative information only about  products
within some logically designated category, such as paper products, detergents, light
bulbs, etc.  If not defined properly, however,  the category could exclude alternative
products that clearly are superior for the use intended. One example of that can be
found in West Germany's Blue Angel program.   In that program, low-solvent paints and
varnishes are eligible for the  logo while latex paints that contain no organic solvents
are not, since no one brand of latex paint is environmentally  superior.  Canada'
Environmental Choice  program solves that problem  by selecting low pollution water-
based paints as a category in  itself.
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STRENGTHEN THE CRITERIA OVER TIME

      Criteria need to be reevaluated and strengthened periodically. Source
reduction—as reflected in a product's right to bear a label—is not a static level of
accomplishment.  As manufacturers seek new and innovative  ways to reduce
waste.competition should drive technological innovation further.  Within each product
category, therefore, criteria should be reviewed periodically to provide an incentive for
continued innovation.

INVOLVE INDUSTRY

      Finally, among other recommendations made, industry should be involved in any
national labeling program.  While the exact nature and degree of involvement may
take various forms, it is clear that labeling will not accomplish its potential for
source reduction if manufacturers choose not to participate.  Such participation can
be encouraged through industry involvement in the labeling program effort. It also
will be encouraged by an open and  transparent decision-making process that draws on
public input and comment.
                             OTHER PROJECT ACTIVITIES
      This paper has focused on three of the issues being explored by the Strategies
for Source Reduction project. Two of those issues--product life assessments and
labeling programs—will require continued study before we realize  their full potential.
But we need not await further research to move forward on many  other fronts.  This
conference, with its many success stories, testifies to that.  Many steps in source
reduction are being carried out throughout the country, often driven by local
initiatives.

      Another element of our forthcoming report, therefore, is to demonstrate just a
few of those actions  that can be undertaken without the need for any additional
research.  An example of "things we can  do now" is the use of volume-based disposal
fees for municipal trash pickup.  Such fees provide  a direct and tangible incentive for
households to reduce the wastes they generate.  It is a straightforward concept that is
working  well in cities ranging from Seattle, Washington to High Bridge, New Jersey.

      Another element of the project, and a major one at that, is  our effort to
develop a framework that others can use  to identify source reduction opportunities in
the municipal solid waste stream. As currently envisioned, the framework's set of
questions could guide an analyst through  a process of selecting priorities for study,
identifying source  reduction techniques that might pertain to a particular kind of
product,  and addressing issues that could affect whether or not a strategy is desirable
or feasible.  By developing this kind of "roadmap," it is our hope to extend the results
of our analysis manyfold. To make sure  the framework does indeed work,  we are
testing it with several product categories  and will share the results  of that application
in our final report.
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                                    CONCLUSIONS
      The Strategies for Source Reduction project is just one step in moving forward
with national policy that helps address our municipal solid waste problems and to
improve the state of the environment. This conference is testimony to the range of
actors that must be involved in reducing wastes at the source.  Actions at the
community level surely will play a major role in determining how much we accomplish.
By structuring a steering committee to include actors at the local level, as well as
other sectors, this project recognizes that many of best and most innovative ideas
spring from the community.  And that local support for a national program can
determine whether or not it succeeds.
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     MULTIMEDIA LOCAL GOVERNMENT POLLUTION PREVENTION PROGRAMS

                by:   Anthony Eulo
                     Local Government  Commission
                     909 12th Street,  Suite  205
                     Sacramento,  California   95814
                            INTRODUCTION

     While the United States has entered a period of extreme waste
management problems, nowhere is the problem more severe than in
the hazardous waste arena.  Hazardous waste landfills are closing,
air pollution is getting worse and the wildlife in our waterways
is dying a toxic death.  The EPA database of environmental
releases indicates that reporting facilities released over 4
billion pounds of toxic chemicals in 1988.  What is most revealing
about this statistic is that it only includes a small subset of
U.S. waste-producing facilities.  While less than 20,000 polluters
reported their releases to the EPA, health officials in Los
Angeles estimate that there are over 20,000 hazardous waste
generators in Los Angeles County alone.

     Hazardous waste reduction, reducing the use of toxic
chemicals and generation of hazardous waste, is the superior
solution to our waste management crisis.   Through input changes,
operational improvements, production process changes and product
reformulations, it is possible to significantly reduce the amount
of toxic chemicals used and hazardous waste generated.  While
treating and/or recycling waste always results in the release of
some form of the pollutants to some part  of the environment, waste
reduction eliminates waste generation and the need for treatment
and recycling.

     WASTE REDUCTION IMPLEMENTATION:   THE ROLE OF GOVERNMENTS

     While waste reduction often saves industry money along with
improving the environment, it is often necessary to provide
educational,  economic and technical resources to help industry
discover the benefits of waste reduction.  While the federal and
state governments encourage industry to reduce waste generation,
they are unable and unwilling to effectively solve the problem
alone.   Each industrial facility presents unique opportunities for
waste reduction that cannot be fully addressed at the national or
state level.   In addition, federal and state regulatory agencies
spend extremely small percentages of their budgets on waste
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reduction activities.  The inadequacies of the federal and state
governments leave local governments with a significant role to
play in encouraging industrial waste reduction.

     There are two major reasons why local agencies are often
better suited to encourage waste reduction than their state and
federal counterparts:

• Local governments have the most to gain in waste reduction
  activities.  By reducing the amount of pollution created
  locally, they are reducing the risks posed to local citizens,
  saving local businesses money and improving the economic
  vitality of their community.  Additionally, waste reduction
  reduces the need for highly unpopular hazardous waste management
  facilities; and

• Local agency staff have the most contact with local industries.
  There are many more inspectors at the local level than there are
  at the state and federal level.  Local staff have a greater
  opportunity to encourage waste reduction and a greater sense of
  partnership with local industries.

     Finally, given the pollution problems facing the earth, it is
imperative for all levels of government to be intimately involved
in solving them.

        LOCAL GOVERNMENT HAZARDOUS WASTE REDUCTION PROGRAMS

     California local governments have a history of implementing
successful waste minimization programs.  Led by Ventura County in
1986, many local governments have established educational,
technical assistance and regulatory programs designed to encourage
local industries to reduce their hazardous waste generation.
Tools employed by local governments include having workshops for
local businesses on hazardous waste reduction, establishing a
waste reduction library, handing out ready-to-use waste reduction
resources, providing in-depth technical assistance to local
businesses, and establishing regulatory planning requirements for
waste reduction.

         COMMISSION  ACTIVITIES  IN HAZARDOUS WASTE  REDUCTION

     For the past three years, the Commission  (See Appendix A for
a background on the Local Government Commission) has focused on
local government programs to reduce the use of hazardous
substances and the generation of hazardous wastes.  The waste
minimization project began with the distribution of a guidebook
and model resolution establishing waste minimization as the
priority hazardous waste management strategy.  After providing
important background information at conferences and workshops,
over 60 local governments in California adopted our model
resolution.
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     With the passage of the Hazardous Waste Management Planning
Act of 1986 (California Assembly Bill 2948), the Commission worked
with counties to get waste minimization established as a priority
in county hazardous waste management plans.  All 58 counties in
the state have now established waste minimization as their
priority in their plans.

     During the fall of 1987, the Commission trained 500 local
government officials at a series of four regional waste
minimization workshops.  An ongoing network evolved from these
activities.  A bimonthly newsletter, the "Waste Minimization
Update," is published by the Commission to keep workshop
participants,  Commission members, and others in touch with the
progress of state and local programs.

     After the workshops, guidebooks were developed to assist
local agencies in implementing waste minimization programs.  Each
was the result of an intensive study of model programs around the
nation and of extensive peer review.  Low Cost Ways to Promote
Hazardous Waste Minimization is a two-volume set designed to
assist local governments in implementing a waste minimization
program which does not require additional staff or excessive
resources.   Minimizing Hazardous Wastes:  Regulatory Options for
Local Governments details how to initiate local regulatory efforts
that encourage waste minimization.  Reducing Industrial Toxic
Wastes and Discharges:  The Role of POTWs is designed specifically
for water pollution control agencies.  It details how these
agencies can use existing tools and resources to encourage
reductions in the amount of toxic discharges entering their
system.

     After these guidebooks were developed, the Commission
obtained funding from the California Department of Health
Services, San Francisco Foundation, Harder Foundation, Sierra
Foundation and C.S. Fund to provide policy assistance to
communities throughout California to help in the establishment of
local hazardous waste minimization programs.  As a part of this
program, we have facilitated the delivery of introductory-level
training programs for local agency staff.

     Policy assistance can take a variety of forms.  At its
simplest, technical assistance consists of conducting one or more
phone conversations with key local staff and/or elected officials
to help them develop a program.  Information provided can include
innovative program ideas from other local governments, resources
that are available to support a local effort, and other basic
information.  Written comments are also frequently desired.  Along
with the above, more intensive technical assistance activities
include making site visits, repeatedly phoning local staff,
researching issues, and customizing resources for the local
agency.  Finally, the most complex technical assistance activities
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involve more intensive staff resources.   As an example of this
type of activity, the Commission organized a training session on
waste reduction exclusively for the staff of the Los Angeles
County Health Department.

     As a result of Commission activities and other trends, 25
California local governments, representing nearly 80% of
California's population, are implementing hazardous waste
reduction programs.

               THE  COMMISSION'S  MULTIMEDIA  ACTIVITIES

     After working in this area for several years, the Commission
has recognized that hazardous wastes are often transferred from
one medium to another as a means of disposal, e.g., a treatment
unit removes heavy metals from wastewater only to have the metals
then deposited in a landfill.  This waste transfer does not result
in real reductions in the use of hazardous materials or generation
of hazardous waste.

     To reduce this problem, the Commission has worked on
designing multimedia programs.  Multimedia reduction programs work
to reduce toxic releases to the land, water and air.  By focusing
on coordinating the efforts of environmental health, water
pollution control and air pollution control agencies, the
Commission is assisting local governments develop programs that
will maximize environmental and economic benefits.  With varied
amounts of support from the Commission,  Contra Costa, Los Angeles,
Orange, San Francisco, Santa Clara and Santa Cruz counties have
taken the initials steps toward establishing a multimedia program.

     To encourage other local governments to engage in multimedia
waste reduction programs, the Commission has developed a model
multimedia resolution and distributed it to key contacts
throughout the state.  The resolution is included as Appendix B.
During presentations, a multimedia handout, developed by the
Commission is distributed.  This handout,  laying out a four-step
suggested process, is included as Appendix C.

                              RESULTS

               MULTIMEDIA LOCAL GOVERNMENT  ACTIVITIES

     Several California counties have taken the initial  steps
toward developing multimedia programs.  The following case studies
are excerpted  from the Local Government Commission's "Waste
Minimization Update":

          The  County Sanitation Districts  of  Orange County,  Orange
     County  Health Care Agency and South Coast  Air Quality
     Management  District  have  established  the  "Orange  County Multi-
     Agency  Task Force  on Waste Minimization."  With
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representatives from the agencies regulating wastes released
to the water, land and air, the task force is the first
multimedia, waste minimization body to be formalized in
California.  According to Rich von Langen of the County
Sanitation Districts, "The Task Force was established with
three major goals:  1) To educate the business community on
multimedia waste minimization; 2) To provide technical
assistance on multimedia waste minimization audits; and 3) To
incorporate waste minimization into the permitting and
enforcement aspects of all three regulatory agencies."  Task
Force members have begun compiling a library of educational
materials and resources to support their educational efforts.
In addition, they recently compared their individual lists of
top companies and targeted 41 companies to receive the first
multimedia waste minimization technical assistance. After
sharing information and about their individual programs and
planning the multimedia program for several months, the Task
Force sponsoring a joint workshop on November 2, 1989.

     The Santa Cruz County Environmental Health Department
has arranged a series of meetings with all of the water
pollution control agencies in the County.  Representatives
from the agencies discussed the pollution-control and
minimization issues facing the County and opportunities for
coordinating these activities.  The group identified the need
to tighten the "regulatory loop" between media-specific
agencies and improve the system for notifying agencies about
new hazardous materials users in the community.  Cross-
training inspectors and coordinating inspections were two
activities discussed at the meeting.  The group has decided
to meet monthly to flush out these issues in greater depth
and develop more closely coordinated programs.

     Los Angeles County has had a "Hazardous Materials
Coordinating Committee" for several years.  At a recent
meeting, the Committee established a Minimization
Subcommittee to work on coordinating and expanding the
County's minimization efforts.  Representatives from the
water pollution control, air pollution control and
environmental health agencies will participate in the
Subcommittee.  After the first meeting, one participant
commented that "it was great to see a representative from
another agency realize that their pollution-control
'solutions' were creating pollution problems for us.  I hope
that, in the future, all agencies will realize that pollution
prevention, eliminating the generation of a waste, should be
considered as a potential  'best management technology' when
developing regulations."

             BARRIERS TO PROGRAM DEVELOPMENT

As may be expected, it can be very difficult to get media-
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specific regulatory agencies to cooperate with each other.  The
long histories of each agency often interfere with their ability
to cooperate and their ability to even consider the impacts that
their actions and regulations may have on another environmental
medium.

     A second problem is the difference in the number and type of
pollutants that each agency regulates.  While environmental health
and water pollution control agencies generally regulate the same
toxic pollutants, air pollution control agencies in California
focus on pollutants contributing to ozone formation and, to a
lesser extent, carbon monoxide.  Few regulations in California
limit the emission of pollutants based on their toxicity or health
threat except as they relate to ozone formation.

     A fourth problem is the lack of staff resources available to
implement multimedia problems.  Local agencies, especially in
smaller jurisdictions, often have a difficult time implementing
their own media-specific waste reduction programs.  Many of them
are unable to adequately enforce even their own regulations and
are not ready to implement a waste reduction program.  Considering
multimedia programs can be completely unrealistic for these
agencies until they are ready to implement their own reduction
program.

     A final problem is the presence of bureaucratic inertia.
Even when resources are available, agency employees are often
unmotivated and unwilling to consider any expansion in their role.

                           FUTURE PLANS

     The Commission is currently preparing a guidebook on waste
reduction opportunities for air pollution control agencies.  Once
completed, this guidebook will complement the resources already
developed by the Commission for environmental health and water
pollution control agencies.

     The Commission has assisted the California Department of
Health Services obtain a grant from the U.S. Environmental
Protection Agency to develop multimedia waste reduction programs
at the local level.  Under this grant, the Commission will be
producing six training workshops around the state.  Each three-day
workshop will focus on multimedia waste reduction opportunities
for various industries.  In addition, a series of roundtable
discussions involving key contacts from the federal, state and
local governments regulating pollutant releases will be developed.

     Another aspect of this grant is the development of four model
multimedia reduction program.  Grant funds will help Ventura
County, San Diego County,  San Bernardino County, and Orange County
make the connections between regulatory agencies needed to develop
multimedia programs.
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                            APPENDIX A

                     ORGANIZATIONAL BACKGROUND

     The Local Government Commission is a nonprofit, nonpartisan,
membership association of over 350 county supervisors, city
councilmembers and mayors which serves as a "think tank" to help
locally elected officials develop innovative programs and policies
to address the problems of our day.  The Commission researches and
develops model programs and policies primarily addressing
environmental concerns.   Since 1979,  the Local Government
Commission has addressed conservation and alternative energy
development, the prevention of toxic contamination, transportation
alternatives, and recycling and solid waste reduction.  We have
written over 30 how-to guidebooks which provide specific policy
options, stimulating numerous programs in California communities.

     The Commission has its roots in the Office of the Governor of
California.  In 1979, a special "Council" of experts from the
private sector was appointed by the Governor and assigned the task
of devising a plan to promote energy conservation and alternative
energy development in the State.  The group identified local
government as key to the implementation of effective policy.

     The Governor acted on the Council's advice by establishing
the "SolarCal Local Government Commission" in the State's
Department of Business and Transportation.  About 35 city
councilmembers, mayors and county supervisors were appointed and
charged with the task of implementing local government energy
conservation and alternative energy projects.  The group was
provided with model programs and policies, invited to conferences
and workshops, and was given technical assistance.

     In 1983, a new governor phased out most State energy programs
including the SolarCal Local Government Commission and the members
voted to build the Commission as a nonprofit, membership
organization.  Between 1983 and 1987,  the organization focused
primarily on toxics issues.  In 1988,  recycling and solid waste
source reduction were added as major program elements.  The
Commission has also provided limited programs on child care, water
conservation, growth management, and transportation.

     In the area of solid waste, the Commission has had a
particular focus on local government procurement policies which
favor the purchase of recycled materials.  When the Commission
first began working on this issue over a year ago, only one local
government had developed a procurement policy.  Now, over 22
cities and counties in California have established formal policies
to purchase recycled products and many more such policies are in
the planning stages.
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                                 APPENDIX B
     MODEL RESOLUTION  FOR  INITIATING A MULTIMEDIA ENVIRONMENTAL
   POLLUTION PREVENTION EFFORT IN  THE CITY/COUNTY/DISTRICT  OF
In the matter of establishing a multimedia program to assist businesses in
adopting pollution prevention measures in the City/County/District of 	
      WHEREAS,  pollution prevention includes  reducing the  use  of  hazardous
substances, reducing the generation of waste  at the source,  and recycling
waste to reduce pollutant releases to all environmental media; and

      WHEREAS,  pollution prevention protects  the health and  environment  of  the
community, saves businesses money, decreases  employee exposure to workplace
chemicals, and reduces the need for hazardous waste management facilities;
and

      WHEREAS,  pollutants released to each environmental medium (land, air  or
water) historically have been regulated separately and without regard to
other environmental media, thereby encouraging the transfer  of pollutants
from one medium to others; and

      WHEREAS,  these medium-specific regulations have created  barriers and
reduced incentives for pollution prevention activities; and

      WHEREAS,  the City/County/District of 	  encourages  businesses,  where
feasible, to employ multimedia pollution prevention practices, rather than
treat and/or dispose of toxic chemical waste  into the land,  air,  and water;

      NOW THEREFORE BE IT RESOLVED that the 	(lead dept. or division)	
convene a coordinating committee with the city, county and regional agencies
regulating pollutant releases to all environmental media for the  purposes of
sharing information, comparing pollution control activities  and regulations,
coordinating regulatory efforts, and establishing a multimedia pollution
prevention program; and,

OPTIONAL CLAUSES TO STRENGTHEN THE PROPOSAL:

      FURTHER,  BE IT RESOLVED that the multimedia coordinating committee
evaluate the feasibility and appropriateness  of educational  techniques,
technical assistance and regulations to encourage multimedia pollution
prevention; and

      FURTHER,  BE IT RESOLVED that the (lead  dept.  or division) submit a
proposed work program to this Council/Board by 	(date)     that identifies
the multimedia pollution prevention activities selected for  implementation,
along with a timetable and required financial support; and

      FURTHER,  BE IT RESOLVED that the (lead  dept.  or division) submit a
progress report to this Council/Board on multimedia coordination  activities
by
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                           APPENDIX C      HANDOUT USED

Local coordination among the local environmental health/resource management
department, the local POTW, and the local air pollution control agency can
provide the context for significant environmental gains.  Working together,
these local agencies can:  strengthen the enforcement of traditional
pollution control regulations to prevent the transfer of chemical wastes from
one medium to another; and develop innovative educational, technical
assistance, and regulatory waste minimization programs.   Local agencies can
work toward these important goals through a 4-step process:

Step 1:  Information Sharing   Cooperation among the media-specific agencies
should begin with information sharing, a sorely needed activity given the
fragmented nature of the state and federal toxics regulatory system.  Often,
the regulators in one arena know surprisingly little of the nuts and bolts of
the other media-specific programs.

Step 2:  Interagency Regulatory Review   Based on the knowledge gained from
the first step, each agency should agree to critically analyze its own
regulations from several vantage points:  (1)  Which regulations encourage
pollutants to be transferred from the agency's medium of concern to other
media?  (2) Can the agency's regulations be modified to deter this cross-
media transfer?  (3) Can the regulations of another agency be modified to
prevent the transfer?  (4)  Which regulations discourage or encourage waste
minimization practices?  Proposed regulations should also receive this type
of review prior to their adoption.

Step 3:  Coordinated actions   With the information collected under the first
two steps, the various agencies can now plan any number of coordinated
activities, from interagency agreements to resource sharing,  planned division
of labor,  and other forms of joint actions.   Initially the actions may be
informal.   For example, waste minimization technical assistance efforts could
be organized to most effectively utilize the technical expertise within the
various media-specific programs.  Or, suspected violations could be routinely
cross-reported to the proper regulatory agencies.  Eventually, the
cooperation may become more formal.

Step 4:  Integrated Actions:    Over time, the multimedia coordination may
evolve into a more sophisticated system of joint inspections,  integrated
waste minimization technical assistance, or integrated enforcement and
permitting.  Through eliminating redundancy and streamlining regulatory
requirements, an integrated system has the potential for significantly
cutting program costs and the associated industry fees.   It would also reduce
the need for firms to work with a multiplicity of different regulatory
agencies,  currently a costly burden for the nation's businesses.

Due to the media-specific nature of state and federal regulations, integrated
actions may be difficult for local agencies to implement if the corresponding
state agencies are not actively supporting the concept.   However,  successful
programs can be based on creative intergovernmental coordination,  which does
not require the participating agencies to alter their basic regulatory
structure.
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      MATERIALS SUBSTITUTION AT THE ROCKY FLATS PLANT

        By:  Ann C. Ficklin     and        Gordon L. Hickle
        NFT, Inc.                         EG&G Rocky Flats, Inc.
        Golden, Colorado 80401           Golden,  Colorado   80402

                            ABSTRACT

The  Rocky  Flats Plant  established a Waste  Minimization  Program in
January 1988.  One of the major goals of this program is the
elimination of three hazardous solvents:   1,1,1 -  trichloroethane
(TCA), carbon  tetrachloride,  and 1,1,2 - trichloro  - 1,2,2
trifluoroethane  (freon-113).

These solvents are used mainly for cleaning  in maintenance  and
manufacturing throughout the plant.  There has been an 80%
reduction  in  the use of TCA and freon-113 in the maintenance and
non-plutonium manufacturing areas since  January  1988.  This
reduction  of 21,000 gallons  per year is based on procurement
records.

A plan has been  drafted  and is under review by the Design Agencies
to  test alternatives to TCA  in the final cleaning of  plutonium.
Some of the alternatives under consideration  are:

  1.  Water
  2.   Liquid carbon dioxide
  3.   A non-hazardous alternative solvent

Testing  is already  underway to identify alternatives to carbon
tetrachloride as  an "in process" cleaner in the plutonium
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manufacturing areas or changing procedures so a  solvent is  not
needed (i.e. dry machining plutonium instead of  using  oil).

The  employees  in the plutonium manufacturing areas  reduced their
use  of carbon  tetrachloride from 14,000 gallons in 1988 to  10,500
gallons in 1989 (25%  less) through more careful use  of this  solvent
in  their cleaning operations.
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The Rocky Flats Plant is part of a  nationwide nuclear weapons
research,  development,  and production complex  administered by the
U.S. Department of  Energy.  The prime operating contractor is EG&G
Rocky  Flats,  Inc.

The primary  mission of Rocky Flats  is the  production of metal  and
metal components for nuclear weapons.  The plant  is involved in  the
fabrication of components  from plutonium,  uranium, beryllium  and
stainless  steel.   Production activities include metal fabrication,
assembly,  chemical  recovery and purification of recyclable
transuranic radionuclides,  as well  as related quality control
functions.

Rocky  Flats'  operations result in  the generation of  solid,  liquid and
gaseous waste streams.  Waste  classifications include:
1) transuranic waste;  2) low-level  waste;  3)  radioactive mixed
waste; 4)  hazardous waste; and  5)  sanitary waste.  Waste  handling
operations at the  plant  include on-site storage,  transport,
treatment, packaging of waste materials for  off-site disposal, and
on-site  sanitary disposal.

Hazardous and mixed waste management  activities are regulated  by
the Colorado  Department of Health and U.S. EPA under the Resource
Conservation  and Recovery Act (RCRA).  Site environmental cleanup
activities are  regulated under both RCRA and  the Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA).

               WASTE MINIMIZATION ORGANIZATION

EG&G has established a Waste Minimization  Program (WMP) within
Environmental and Waste Programs.  The WMP Manager reports to
the General Manager through the Waste Programs Manager, the
Waste Programs Director, and the Associate General Manager for
Environmental Restoration  and  Waste Management, as illustrated in
the organization chart provided  in  Figure 1.  Through this chain of
command, the WMP Manager has been assigned the responsibility
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for overseeing the  planning, management  and implementation of
waste minimization activities at the  Rocky Flats  Plant in
accordance with applicable EPA and  Colorado Department of Health
(CDH) requirements, as well as applicable DOE Orders and EG&G
policies.

                   DESCRIPTION OF PROGRAM

The  main  priority  of the waste  minimization program  is avoidance
of waste generation, or source  reduction.   The program focuses on
source  reduction  activities that minimize  or  eliminate the
generation of waste, and  recycling processes  that use, reuse, or
reclaim  a  material  from  a waste stream.

                               FIGURE  1
              WASTE MINIMIZATION ORGANIZATION CHART
                           EG&G ROCKY FLATS
                           GENERAL MANAGER
            ENVIRONMENTAL RESTORATION & WASTE MANAGEMENT
                      ASSOCIATE GENERAL MANAGER
                           WASTE PROGRAMS
                               DIRECTOR
                        ENVIRONMENTAL & WASTE
                          PROGRAMS MANAGER
                          WASTE MINIMIZATION
                           PROGRAM MANAGER
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                WASTE MINIMIZATION ASSESSMENT

Following  EPA assessment guidance 0), a Rocky Flats waste
minimization assessment was completed in December  1989.  Areas
of focus were identified and options for addressing those areas
evaluated.   Implementation of the selected options is in  progress.
As part of the  Waste  Minimization Program, further waste
 minimization assessments  will  be conducted annually to track the
progress and identify further ideas for implementation.  Program
goals and program evaluation are based on the results of these
assessments.

                     SOLVENT SUBSTITUTION

One  of the  major goals of the  waste minimization program is the
elimination of three  hazardous solvents:   1,1,1  - trichloroethane
(TCA), carbon tetrachloride and 1,1,2 - trichloro - 1,2,2 -
trifluoroethane   (freon-113).

These solvents  are  used mainly for cleaning in  maintenance and
manufacturing  throughout the plant.  There has  been an 80%
reduction in the  use  of TCA and freon-113 in the maintenance and
non-plutonium manufacturing area  since January 1987.  The
reported reduction of 21,000  gallons per year between January
1987  and  January 1988 is based on procurement records.

This  dramatic  reduction  is due to substituting aqueous based
detergent  cleaning for the TCA and freon-113.  Water  has replaced
freon-113  for density measurement of uranium components.  The
equipment  is being   installed to eliminate  the last major use point
of TCA in  these  areas of the plant. Tables 1 and 2:  Table 1 shows
the reduction in  freon-113 use  for 1988 and 1989 and the
projected  reduction  for 1990.(2)  Table 2 shows this same
information for TCA.   With reductions  in solvent waste there is
also  a reduction in the volume  of paper and other combustible
wastes contaminated with  these  solvents.
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Now the focus of this effort is on the plutonium manufacturing
areas.  There are three uses of solvents that will be  addressed:

  1.  Cleaning
  2.  Machining coolant
  3.  Density measurement

                         TABLE  1
             FREON USE IN NON-PU BUILDINGS
       FY 1988                  250  gallons/month

       FY 1989                    64  gallons/month

       FY 1990                    25  gallons/month
       (projected)
                         TABLE 2
                 TRICHLOROETHANE USE
                  IN NON-PU BUILDINGS
       FY 1988                   250 gallons/month

       FY 1989                   100 gallons/month

       FY 1990                     50  gallons/month
       (projected)
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A plan has been drafted and is under review by the  Design Agencies
to  test alternatives to TCA in  the  final  cleaning of plutonium.
Some of alternatives under consideration  are:

  1.  Water
  2.  Liquid carbon dioxide
  3.  A  non-hazardous  alternative solvent

Preliminary  laboratory testing has  shown  each of these
alternatives  cleans plutonium  and is  compatible with this  metal.(3)

Testing  is  also  underway to  identify  alternatives to  carbon
tetrachloride as  an "in process" cleaner and coolant in  the
plutonium manufacturing  areas.  The  two alternatives showing  the
most  promise are:

  1.  Dry machining  plutonium instead of  using oil  and  solvent
  2.  A  non-hazardous  alternative solvent

There will probably be  a phased  replacement  of freon-113  in
measuring the density of plutonium.  The  first  phase  will  be the use
of  less-toxic chlorofluorocarbon (CFC)  which  is  not  restricted  for
land disposal under RCRA and not covered by the Montreal Protocol.
The  use of  this CFC will continue until  aqueous testing is complete
and the use of water  is approved by the Design Agencies.  Table 4
shows projected  reduction in  plutonium-contaminated  hazardous
solvent  waste.(4)

             PAINTS, THINNERS AND PAINT STRIPPERS

A latex-based paint is now being  used  wherever an oil-based paint
is not specified  in the Plant Standards.   These  latex-based paints
do not require organic thinners and are stripped using  a  caustic-
based paint stripper  instead of methylene chloride.

Since 1988  plant usage  of oil-based paint has dropped
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 approximately 80% and the use of methylene chloride-based  paint
 stripper has dropped 30 gallons per year  (12%).  There isn't as much
 opportunity  for  reduction  in  methylene chloride stripper waste
 because Maintenance uses sand blasting whenever possible for
 stripping paint.  The corresponding reduction on organic thinner
 waste has been from  600 gallons per year to 120 gallons per year
 (80%).  These estimates are based on  Maintenance Department
 records.  The remaining  oil-based  paint use points and  projected
 substitution  with  latex-based  paints are shown in  Table 5.
                           TABLE 5
    OIL-BASED PAINT USE AT THE ROCKY FLATS PLANT
Description
Annual Use
  (1989)
Projected  Reduction
Oil-based poly-amide    1000  gallons    Total elimination  by
floor  paint                              1991
Oil-based  road stripping 800  gallons
paint
Co-polymer  vinyls
500  gallons
Total  elimination  by
August  1990

200 gallons/year  by
1991
Oil-based exterior
10% of all
exterior
paint
Evaluation  of  alter-
natives  underway
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                RADIATION PROTECTION SHIELDING

Lead shielding has been used on gloveboxes and on tanks to reduce
worker exposure to gamma radiation in  plutonium areas.  For the
Plutonium  Recovery  Modification Project, Building  371, Health
Physics  is calculating  the  thickness  of stainless steel that  will
replace lead in providing  this protection.

The generation rate for waste lead shielding is 0.5  cubic meters
per year.(5)  This is  based on Waste Operations data from January
1989 through October 1989.  Although  the generation rate  of this
waste  form is low,  there is currently no U.S DOE site  permitted to
dispose  of this low-level  radioactively  contaminated  mixed waste.

                        LIQUID FILTRATION

Wound polypropylene filters  are  used to recover or  remove trace
amounts of  radioactive  materials from  a  variety of  liquid streams.
These  filters are called FulfloR  and are standard cylindrical
industrial cartridges,  approximately 9.25 inches long and 2.5
inches in diameter.

The  filters are placed  in an  in-line cartridge where the  liquid
flows  through  the  filter  until  the  buildup of filtered  material
increases the pressure  and the filter must be changed.

A  new filter  is being developed which  meets the following
requirements:

    1.   Capable of being regenerated by  backflusing, leaching,  etc.,
        for reuse.

    2.   Provide for  one micron nominal  filter  capability.

    3.   Be inert to  filterable  liquids used at Rocky  Flats.
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   4.   Cost effective  with  regards to:   initial cost,  plutonium
        recovery cost,  and waste  treatment  and disposal costs.

Kevlar fiber, a  polymer of paraphenylene-diamine and  terephthalic
acid,  was chosen as a material to investigate for the fabrication of
a filter.     Kevlar has  excellent thermal and chemical resistance,
does  not shrink or melt, and  has a degradation temperature around
500 C and  incinerates  clearly with about 1% ash.

The fabricated  Kevlar filters have  been evaluated with  regards to:
Filtering  efficiency, flow rates,  and pressure drop as  a function  of
loading capacity in an  nitric acid media.  Test results show  these
filters  are  90% more  efficient  than the polypropylene  filters now
in  use.  Similar tests have now started in an oil  and  solvent media.

Regeneration studies have not  been successful  using  zinc oxide to
simulate plutonium.   Recovery  of the zinc oxide  was  only
successful  by shredding  the  filter and  centrifuging  the  shredded
material.   Plutonium testing  is  now  planned to determine  filtering
efficiency and  recoverability.

By crushing and dewatering the shredded Kevlar  media,  a 33%
volume reduction  can be achieved  over the  currently  stored  or
discarded filters.  There  is a possibility of  reducing the amount of
transuranic  filter waste generated  by 100 drums  per  year based
upon  the non-radioactive filtering  efficiency tests.    This  reduction
would be a result of using  fewer of the  more  efficient filters and
then  shredding  and crushing the spent filters.
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                         REFERENCES

1.     Hazardous  Waste Engineering  Research Laboratory, Office
      of Research and Development.  The EPA Manual for Waste
      Minimization Opportunity  Assessments.   EPA-600/2-88-
      025,  U.S. Environmental  Protection Agency,  Cincinnati,
      Ohio, 1988.

2.     EG&G Rocky Flats, Inc. Waste Minimization Assessment
      Report Amendments, Rocky Flats Plant.  March 16, 1990.
      pp.  VI-2 and VI-3.

3.     Motyl, K.M. Cleaning Metal Substances with  Liquid-Super
      Critical Fluid Carbon Dioxide.  RFP 4150, Rockwell
      International, January  25,  1988.

4.     EG&G Rocy Flats, Inc. p. V-6.

5.     EG&G Rocky Flats, Inc.  Federal Facilities Compliance
      Agreement/Compliance Order, Inventory  Report,
      November  16, 1989, pg. 39-41.
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                   Moving Bevond the Rhetoric:
                     Challenges  for  the 1990s

                   Kathryn  S. Fuller, President
                     World Wildlife Fund and
                   The Conservation Foundation

        International Conference on Pollution Prevention:
              Clean Technologies and Clean Products
                       Omni Shoreham Hotel
                      Tuesday, June  12, 1990
     Good afternoon.  It is a pleasure to join you today for this
first International Conference on Pollution Prevention.

     Looking through your ambitious agenda for these several
days, I'm struck by how far we've come in the past several
years.  We now see the logic of treating the source of our
ailments, and not just the symptoms.  The idea of preventing
pollution—rather than collecting it, treating it, and shipping
it from one place to another—is taking hold.

     This conference itself—with speakers from government,
industry, universities, environmental groups and other
organizations—testifies to this evolution.
     Our new emphasis on pollution prevention makes sense for the
reasons you have heard so persuasively already.

     First, while we have made much progress over the past 20
years, in many areas we have been treading water, or have even
lost around.

     Many of the countries represented here have made tremendous
strides in controlling the pollution from industrial
smokestacks, discharge pipes, and landfills.  Nonetheless, we
continue to lose ground.  For example, we know that each new car
in this country is cleaner than any model on the road twenty
years ago.  But the number of cars and the miles they are being
driven are overwhelming our goals for pollution control.  Half
this country's natural endowment of wetlands has been lost, and
500,0000 acres of what remains are being consumed each year.

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     In the developing nations we are seeing wholesale
destruction of tropical rainforests on a truly horrifying scale,
only dimly imagined in 1970.  As we meet, the tropical
rainforests continue to be cut and burned at the rate of one
percent per year—over 100,000 square kilometers each and every
year.

     Reliance on present approaches is not enough.

     Second, many of the environmental problems we face today are
of unprecedented complexity and scale.

     As many as 100,000 chemical substances are used commercially
around the world, and for many produced in very high volumes—
10,000 metric tonnes or more annually—the public can get no
toxicity data.  In a long-needed step, the major manufacturing
countries have just agreed to share the responsibility for
getting toxicity information.  The next step is a "sunset" and
"sunrise" program.  We need to "sunset" uses of chemicals already
known to present hazards and encourage the "sunrise" of
substitutes for these uses—in both the industrialized and
developed world.  Plainly, we can't wait until developing
countries reach the state of some- parts of Eastern Europe before
we turn the focus of environmental policy to prevention.

     We are just beginning to contend with global problems that
were barely known not many years ago.  The prospect of global
warming and climate change ranks at the top.  Assessing the
prospects for climate change, Stephen Schneider says the
possible three to five degree Celsius increase in the earth's
surface temperature over the next 50 to 100 years "would be
unprecedented in human history; it would match the five-degree
warming since the peak of the last ice age...but would take
effect between 10 and 100 times faster."

     In the tropical forests, to cite E. O. Wilson, deforestation
costs us 4,000 to 6,000 species per year—a rate of extinction
"10,000 times greater than the naturally occurring background
extinction rate that existed prior to the appearance of human
beings."

     These statistics give us reason for pessimism.  But there
are grounds, too, for encouragement—for pollution prevention has
the promise of making good, economic and business sense.

     Last week, we published an executive summary to a study
which explores the costs of slowing climate change.  Experts in
eight industrialized nations were asked to evaluate the
prospects for reducing fossil-fuel based carbon emissions in
their respective countries, using the best economic models
available to them.  Their analysis demonstrates that many of the
measures needed—such as improved energy efficiency—will


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actually strengthen economics rather than weaken them.   By
showing that we can act to preserve our biosphere without
incurring enormous costs,  this study helps save the way for more
constructive policy debate on the benefits of pollution prevention.

     We have only begun to see the fruits of the technological
innovation that now leads industry in the direction of  pollution
reduction and improved economic efficiency.  It was only recently
that Vitronics, a new company in New Hampshire, first marketed a
natural terpene derived from orange peels to substitute for
chlorofluorocarbons in cleaning electronic circuitboards.  This
"sunrise" of a new product presents one business opportunity.
Opportunities also come through using resources more efficiently.
It is no coincidence that some of the most successful and
profitable corporations see pollution prevention as the key to
international competitiveness.  Indeed, the potential for
improved productivity may explain why many of you are here today.


Moving Beyond the Rhetoric

     Accepting, then, that pollution prevention is the hallmark
of future environmental policy, how does that translate beyond
rhetoric into everyday practice?

     First, we must clarify our goals and establish longer-term
strategies.

     That means a couple of things.  All of us—whether we act in
official capacities or as individual consumers—must be clear
about our priorities and set up specific milestones to measure
progress.

     Within my own organization, we have just gone through a
goal-setting process.  It has been exhausting and exhilarating,
but the result has been worth it.  We have arrived at an
intellectually sound, constructive set of principles—including
the promotion of more efficient use of resources and energy and
the maximum reduction of pollution—to guide our actions.

     A little background might be in order.  As some of you know,
The Conservation Foundation was established four decades ago.  It
has built a reputation for independent policy analysis on many
important issues:  groundwater protection, wetlands conservation,
agricultural pollution, public lands policy, risk assessment,
integrated management of pollutants across different
environmental media, and so on.

     The U.S.-based World Wildlife Fund organization was created
in the early 1960s by Russ Train—the first administrator of the
Environmental Protection Agency.  From the outset, it has focused
on protecting endangered species and scientifically valuable
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habitats, principally through field work in Latin America, Africa
and Asia.  World Wildlife programs create parks and reserves,
train local managers and build their capabilities, and support
economic practices which are compatible with those natural resources.

     Drawn this way, the two organizations look quite different.
On the one hand, a policy research shop, focusing on domestic
pollution and conservation issues.  On the other, a nature-
preservation group, focusing on direct delivery of field services
outside the U.S. to protect biodiversity.

     But in fact, we believe that the world has changed—that the
environmental issues have evolved so that those distinct
approaches must be brought to bear in a concerted way on common
problems.

     Let me illustrate.  Just recently I was in Bhutan, a
wonderful place, still two-thirds forested, reflecting the dual
protections of a gentle Buddhist ethic and the nearly
impenetrable Himalayan frontier.  Yet when I followed the
footsteps of the few thousand people who trek the mountains each
year, I found the trails littered with discarded juice packs—the
same boxes you buy at grocery stores here and tuck in your
children's school lunches.  The need for pollution prevention and
recycling emerges even there.

     More broadly, World Wildlife Fund has been remarkably
successful in establishing parks and reserves for many critical
habitats in the tropical rainforests of Latin America.  But not
far outside those parks and reserves are economies that
increasingly produce toxic waste, airborne pollution, a growing
demand for electricity—all the effects we associate with
industrial society, all of them oblivious to park boundaries
drawn on a map.

     In many instances, the specific victories we have won in
protecting a rare ecosystem can be quickly undone by these new
threats.  And so to protect nature, we must bring broader public
policy skills to bear on pollution and the other problems of
insensitive growth.

     Conversely, the health of nature has much to tell us about
pollution and human health.  Last year, The Conservation
Foundation completed a comprehensive study of the Great Lakes
ecosystem, and the efforts by the U.S. and Canada to enhance that
magnificent resource.  Some of the things we found were
disturbing:  that Lake Superior, the least industrialized of the
lakes, has serious problems from toxic contaminants blown in from
cities and farms hundreds of miles away.  That Great Lakes fish,
birds and other species exhibit gross developmental defects,
raising legitimate concern about human effects from exposure to
the same substances.
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     In other words, we are learning that the quality of natural
systems and the quality of human life—the nature conservation
and pollution strains of environmentalism, if you will—are
more intimately related than we knew.

     In that context, we have merged World Wildlife Fund and The
Conservation Foundation into a single institution.  Together, we
are part of a network of more than four million members in 28
national groups worldwide, working toward the conservation of
nature by:

          —protecting natural areas and wild populations of
          plants and animals;

          —promoting sustainable approaches to the use of
          renewable natural resources; and

          —promoting more efficient use of resources and energy
          and the maximum reduction of pollution.

     This mission statement is not an end in itself.  It is just
the beginning of an ongoing process to lay out a system for
measuring our progress and to change strategies when needed.

     In the same way, we must reevaluate our laws, regulations.
and institutions to see if they can deliver the progress we need
so desperately today.

     Our regulatory process has been designed to treat pollution
at the end of the pipe, one medium at a time, though we now know
that pollution respects no boundaries but often moves from air,
to land, to water—even though its form may change.

     Make no mistake.  Pollution control and strong enforcement
have played an important role in our achievements of the past 20
years and must continue to do so.  But it would be a mistake to
assume that these same institutions and decision-making
structures will put effective meaning into the words "pollution
prevention."

     So where do we turn for a model for the future?  One example
at the state level is the Massachusetts Toxics Use Reduction Act.
The result of a long process of negotiation, the  law also aims at
long-term change.  It establishes reduction in use as the
preferred means of complying with environmental and occupational
health laws, and it sets a goal of 50 percent reduction in the
amount of toxic wastes generated by 1997.  Through a new system
of environmental permits, Massachusetts seeks both to reduce the
total waste entering the environment and to improve the
efficiency of the permitting process for both companies and  the
government.
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     Put another way, pollution prevention means more than
incremental change.  For example, last year The Netherlands
issued a national environmenta1 policy plan—not separate plans
for air, water, and waste—that includes measures to reduce
sulfur dioxide and nitrogen oxide by 80 to 90 percent by the year
2010.   (Our organization just published a book with the Institute
for European Environmental Policy in London that includes a case
study describing how this environmental policy plan evolved.)
Last month, two Japanese companies, Isuzu and Fuji, announced
that they have developed a supercapacity, rapid recharge battery
that contains no mercury or lead at all.  And a group of
inventors and rubber scientists, working out of the old B.F.
Goodrich plant in Akron, Ohio for the past five years, is now
ready to market a high performance replacement for aerosol cans
that uses no CFC's or volatile organic chemicals.

     Now to reach such ambitious longer-term goals, we will need
new and better strategies.

     It is sometimes said that there are very few new ideas —
only a recycling of old ideas.  Often what is called innovation
is a concept used, and perhaps discarded, in the past.
Certainly the term "pollution prevention" sounds familiar to the
3M officials who pioneered their now-famous Pollution Prevention
Pays program in the 1970s.

     True innovation or not, we must fashion a set of strategies
for our changing circumstances.

     Our new pollution prevention strategies will require us to
look at the entire life of a product:  the way we extract and
process raw materials, how we manufacture and transport products
to the market, how products are used and how they can be reused
or recycled.  As many of you know, various tools have been
developed to analyze product life cycles.  We need to examine
whether these same tools remain appropriate today—for companies
in selecting which products to sell, for government in setting
its policies, and for consumers in choosing which products to
purcnase.

     On a much broader scale, my organization has just embarked
on a process to explore the fundamental changes needed in
environmental policy.  That process began two weeks ago with a
roundtable discussion among former administrators of the
Environmental Protection Agency, chairs of Council on
Environmental Quality, and heads of state environmental agencies.
All participants agreed that the time and conditions are right
for us to identify new directions for environmental policy.  We
have laid out the kinds of issues to address with challenges to
our traditional definitions of consumption and quality of life
high on the list.
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     The third course of action involves each and every one of
us.  We must accept responsibility for our actions on a local as
well as global scale.

     Think of this frightening statistic.  The United States,
with 5% of the world's population, consumes 25% of the world's
resources and generates approximately 25% of its waste.  Now
think of the resource implications were today's global population
of 5 billion people to live as we do.

     It doesn't take advanced mathematics to realize that the
earth's resources couldn't possibly support that lifestyle.  We
all must change.  And changes around the margins won't do.  U.S.
national policy must recognize its responsibility locally, and in
world markets, for its role in polluting our environment.  There
are no long-run alternatives.

     Likewise, businesses cannot use green technology
selectively, and export old, dirty technology to developing
markets.  Rather than export mistakes from the past, we must seek
to provide the best and most appropriate technology.  In the
longer term, we do ourselves no favors by sending outmoded or
excessively technical or costly technology to countries whose
pollution problems dwarf our own.

     In their drive to develop and market clean technologies and
products, businesses must also recognize that public sentiment
for a cleaner environment cannot be taken for granted.  Right
now, public opinion polls show unprecedented levels of support
for the environment.  U.S. memberships in my organization are
growing at a 30 percent annual rate—and remarkably, that lags
behind the experience of World Wildlife Fund affiliates in other
nations.  Businesses are hurrying to meet consumer demand—for
dolphin-safe tuna, recyclable containers, and a host of other
"green" products.

     But if we don't clearly and consistently define what we
mean by clean products, we will see consumers increasingly
confused about the choices they face, put off, and finally
disenchanted.  None of us can afford to let that happen.
Businesses making investments to develop improved products can't
afford to lose those consumers.  Neither can the environment.

     Individual organizations must also take responsibility for
their office practices.  My organization is currently doing just
that, as I know many of yours are.

     We are reevaluating products that we have purchased in the
past, such as bleached paper, to find better alternatives.  We
are substituting reusable dinnerware at meetings and conferences
for the disposable products we once used.  I was pleased to see
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that the organizers of this conference, too, have made that a
priority.  And we are using products differently, by copying on
both sides of paper, for example.

     Sometimes the decisions we face are more complicated.  World
Wildlife offers a catalog of products including balloons,
watches, and so forth.  While it is one thing to make sure our
paper products use recyclable material, it is quite another to
decide whether or not the product itself serves as a symbol of
unnecessary consumption in a world that can no longer afford to
use resources wantonly.

     And that brings me to the role we each play as individual
consumers.  Even now, when record numbers of people profess
support for environmentalism, their actions suggest to the
contrary.  For example:

     —At a time of rising concern about toxic substances,
     Americans have made pesticide and herbicide treatment of
     their lawns a growth industry—as if Superfund and RCRA
     alone addressed all aspects of preventing toxic pollution.
     Will NaturaLawn, a company in Maryland, which specializes in
     lawn care to reduce pesticide and fertilizer use be able to
     lure us away?  Given its rapid growth, perhaps so.

     —Everyone who buys a car is free to choose energy-
     efficient models, yet what have we gained if our lifestyles
     lead us to drive more and more miles with those same cars?

We each have a role to play in making prevention a reality in our
daily lives.

     In sum, these three courses of actions — setting goals,
finding new strategies, and taking responsibility for our
actions — converge in one overarching message:  We must
aggressively design policies that lessen the impact of economic
activity on the environment.

     Now, let me emphasize that environmental protection does
not mean forgoing economic growth.  Indeed a healthy environment
depends on raising real standards of living around the world.

     To prevent pollution we must absorb the costs of building
more efficient factories and retrofitting existing ones, of
producing and purchasing cleaner cars, of designing
refrigerators that operate without CFC's.  A vigorous economy
helps businesses and consumers pay for those investments, and
speeds up replacement of our existing capital stock with newer,
more benign processes and equipment.  Our policies should favor
this investment, and we should strive to remove obstacles which
retard the updating of our industries.
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     The message is even clearer in Eastern Europe.   What we see
as the Iron Curtain crumbles is nothing less than an
environmental hell-hole:  a huge zone of "acid blast" in East
Germany, Poland and Czechoslovakia; poisoned cropland,  sterile
rivers; people forced indoors and even underground to escape the
choking air.  Here the answer is unmistakably capital investment
and economic reform, to replace outdated,  environmentally
disastrous production systems on a national scale.

     In the developing world, too, rising incomes are part of the
solution.

     I deplore the fires in Amazonia, and work hard to reverse
the misguided policies that encourage this destruction:  the
subsidies and tax incentives that lead corporations to clear
land for uneconomic farms and cattle ranches in Brazil.  But
much of the destruction is caused by desperately poor people who
are struggling to eat and build rudimentary shelter for their
families.  They are driven by hunger, and guided by ignorance:
they do not know that the soil will play out in a season or two,
or that they are wasting priceless resources.

     For these people, the answer is a better, more assured
standard of living sustained by careful husbandry of the trees
and indigenous species and crops.  It means small, local
sawmills, and roads so they can reach markets.  It means banks
where they can get credit for seeds and fertilizer.  And it means
basic education.  Those are the changes that will turn people
from miners of a resource into its stewards.

     How, then, do we resolve the seeming conflict between
increasing the standard of living for the world's poor and the
pricing of natural resources more realistically?  Certainly,
developing countries, now exporting their natural wealth at
unprecedented levels, will benefit from selling resources at
higher prices.

     But what about our own  incomes and standard of living?
Won't increasing resource prices reduce our incomes?   The answer
to that question is "not necessarily," if we define economics to
encompass more than the dollars and cents of business
transactions.

     Economic analysis must  also include measures of social
welfare, of the quality of life.  The price of cheap gasoline at
the pump is no real measure  of its price to society.  Consider
the waste from sprawling land use patterns which developed
without regard to the full cost of fuel.  Consider the obstacles
to mass transit in cities mushrooming across the country.  And
consider the waste associated with artificial prices of the  land
and water themselves.
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     No, it is only through more accurate pricing—whether in
the market place or in the form of strict regulation—that we
will drive innovation in our technologies and products and
maintain, even improve, our quality of life.
     As I conclude, let me review where we've been and what I
think it means for the future.

     We are here today because we understand that a healthy
environment requires preventive and not simply remedial action.
We understand that pollution prevention is not just another
implement in the toolbox of environmental reform.  We understand
that preventive policies reflect fundamental changes in resource
use and economic behavior.

     To meet these challenges, to make sure we move beyond
rhetoric, we need to take strong actions:  set priorities and
find ways to change our institutions, devise appropriate
strategies, assume responsibility for our own roles — as
consumers, employees, and heads of organizations and political
states — and redefine our understanding of economic costs.

     The matter is urgent.  If we view the history of our planet
within the yardstick of just one year, our species has inhabited
this world for only the last minute or so.  All this
accomplishment, and all this destruction, occurring in the last
few minutes..of the last day..of that single year.

     If I sound passionate about reinventing ways for humans to
live on this planet, it is because I have indeed become so.  And
I would enjoin all of you to share in that passion.  For it will
take all our passion, commitment, and innovation to secure the
most important of all gifts to the next millennium — a planet on
the mend.

     Thank you.
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                      Regulatory Impediments to the
                        Reclamation and Reuse of
                           Spent Potliner from
                      Primary Aluminum Production


          Jack H. Goldman, Ph.D.                 Jeffrey S. Holik, Esq.
          The Aluminum Association, Inc.          Andrews & Kurth
          Washington, B.C.                       Washington, D.C.


          In 1988, the U.S. Environmental Protection Agency (EPA) listed spent
potliner, a byproduct of primary aluminum production, as a hazardous waste under
provisions of the Resource Conservation and Recovery Act (RCRA).  Many of the
technologies utilized by the industry to reclaim and reuse spent potliner ceased as a
result of the hazardous listing. This paper examines some of the regulations that
serve as disincentives to recycling a byproduct, such as  spent potliner, which has
valuable energy and material values.

     I. ALUMINUM REDUCTION AND SPENT POTLINER GENERATION

          Aluminum metal is produced by the electrolytic reduction of aluminum
oxide. The process takes place in a reduction cell, or pot, which consists of a strongly
reinforced steel box or shell lined with heat insulation ("second cut material"), and
prebaked carbon block and/or rammed monolithic carbon liner ("first cut material").
The steel shell, first and second cuts of the lining, and electrical conductors ("collector
bars")... are collectively termed the "pot shell", which is used to contain the molten
aluminum and electrolyte and conduct the electricity out of the pot (and therefore
serves as the cathode). The anode is made of carbon.  It is suspended over the pot
shell by a superstructure that immerses it into the molten electrolyte. Electrolytic
reduction cells are linked together electrically in series to form a potline, which may
be housed in one or more buildings.

          A pot can normally operate for five years; in several cases, up to ten years
of operation have been reported.  A pot "fails" when iron is detected in the molten
aluminum, when cell  voltage increases, or when the shell leaks molten metal or
electrolyte. The iron contamination can be caused by the development of cracks or by
erosion in the carbon lining, which allow electrolyte to come in contact with the steel
collector bars or the steel shell.  Comments of the Aluminum Association on the
proposed relisting of spent potliner (January 2, 1986) ("Association Comments") at
76-80.  Electrolyte is absorbed by the lining, which becomes saturated in the first 80
to 85 days of operation. When a pot fails, the lining is removed and the steel shell is
relined. Id. at 76-83. The removed lining is called spent potliner.

                     n. REGULATORY BACKGROUND

          EPA first addressed  spent potliner under RCRA in 1979-1980, when it
proposed and finalized a rule listing the material as a hazardous waste based on its

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cyanide content.  However, both industry and EPA lacked complete, reliable
information on the characteristics of spent potliner at that time.1/

          The 1980 regulation never took  effect.  On October 21, 1980, Congress
enacted the Bevill Amendment to RCRA, codified at 42 U.S.C. §§ 6921(b)(3) and
6982(f),(d). The Bevill Amendment excludes from RCRA Subtitle C regulation "solid
waste from the extraction, benefication, and processing of ores and minerals." EPA
was directed to study these wastes and report the results to Congress before deciding
whether to impose Subtitle C regulation under RCRA. On November 19, 1980, EPA
interpreted the Bevill Amendment to exclude solid waste  from the smelting and
refining of ores and minerals, 45 Fed. Reg. 76,618 (1980), and withdrew the listing of
spent potliner before its effective date. 46 Fed. Reg. 4614 (1981). EPA planned to
study spent potliner as directed by the Bevill Amendment.

          In October 1985, EPA proposed to reinterpret the  term "processing" in the
Bevill Amendment to apply to only "high volume, low hazard" wastes. 50 Fed. Reg.
40,292 (1985).2/ At the same time, the Agency proposed again to list spent potliner as
hazardous, based on the assumption that the material was not "high volume" or "low
hazard,"3/ and the assumption that spent potliner met the criteria for listing.*/ The
proposal invited comments supplying new  (i.e.. post-1980) information  about the
hazards posed by spent potliner. Id. at 40,295.

          In  response  to the proposal, the Association and its members filed
substantial comments with EPA. The comments advised that data made available
since 1980 show that as much as 60 percent of spent potliner  does not contain cyanide
levels that pose a threat to human  health or the environment.  The Association
explained that the nonhazardous portions of spent potliner could be readily separated
and removed  from the pot. The Association's comments requested that alternatives
l/   The background documents for the 1980 listing stated candidly that EPA "does
not presently possess reliable data on iron cyanide concentrations in spent potliners
themselves, but concludes that the  concentrations of cyanide in potliners are
substantial, based on  cyanide concentrations in leachate from potliners."
Background Document, Listing of Hazardous Wastes (Phase IB) at 278 (July 7,1980).
As of 1980, industry also lacked reliable data on the constituents of spent potliner.

2/   The 1985 proposal was in response to a lawsuit filed by environmental groups
seeking to compel EPA to immediately regulate spent potliner as hazardous waste.
The Court refused to grant this relief and instead put EPA on a rulemaking schedule.
Concerned Citizens of Adamstown, et al. v. EPA, Civil Action No.  84-3041 (D.D.C.
Mem. Op. Aug. 21,1985).

3/   Industry  data  show that potliner is  generated in substantial volume,
approximately 120,000 metric tons annually.  As will be seen, industry data also
show that substantial portions of potliner are low hazard.

v   In 1985, EPA had  contracted with Radian Corporation to conduct a study of
spent potliner .  Radian analyzed data from 12 samples of spent potliner and potliner
leachate.  EPA  relied on the Radian Report as support for its proposal to list spent
potliner.

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to the proposed listing be considered, including defining spent potliner by reference to
a threshold for free cyanide.

          The Association's comments also pointed out that the proposed listing
would subject all potliner management, including reuse and reclamation, to full
Subtitle C regulation. The Association estimated that as much as 55 percent of all
spent potliner currently was being reclaimed, and that the potential existed in the
near term for reusing even more.  The Association's comments stated that the
proposed rule threatened to sharply reduce or eliminate potliner reuse and mandate
landfilling the material. The Association identified 13 technologies — either  in
commercial scale or actively being developed — that were designed to capture the
substantial energy and fluoride content of spent potliner.5/   The Association
requested EPA to remove disincentives to spent potliner reclamation.

          EPA's initial response to the Association's comments was to withdraw the
proposed listing in October 1986 because of uncertainty about the scope of the Bevill
Amendment. 51 Fed. Reg. 36,233 (1986). The Environmental Defense Fund and the
Hazardous Waste Treatment Council filed suit challenging EPA's withdrawal of the
proposed regulation. On July 29,1988, the United States Court of Appeals ruled that
spent potliner was not a Bevill waste and ordered EPA to list spent potliner by
August 31, 1988. EOF v. EPA, 852 F.2d 1316, 1318, 1331 (B.C. Cir. 1988), cert.
denied, 109 U.S. 1120(1989). On September 13,1988, EPA issued a rule listing spent
aluminum potliner as hazardous waste  under RCRA.  The Association  has filed a
petition for review challenging the September 13,1988 regulation. That petition is
pending in the United States Court of Appeals for the District of Columbia Circuit.

                   HI. THE REGULATORY IMPEDIMENTS

          The present regulatory framework of the Resource Conservation and
Recovery Act ("RCR^") has discouraged and in many cases eliminated the prospects
for capturing the high energy and material y?1 >e of spent potliner. Application of
Subtitle C to byproducts of industrial operations - including current rules defining
solid waste, the mixture and derived-from rules, delisting procedures, and the storage
prohibitions in the land disposal restrictions — in some cases inhibits and discourages
resource recovery. Instead, present rules virtually mandate costly, counterintuitive
waste management, and in particular landfilling.  Current regulations must be
modified, preferably through  a comprehensive, "holistic" approach designed  to
encourage resource recovery while controlling environmental risk.

          Set forth below is  a discussion of how the current RCRA  regulatory
framework inhibits the safe resource recovery of spent potliner, together with some
proposed solutions.  The discussion is divided by subject matter, though the issues
raised are interdependent.  They are: Classification  and Delisting; Resource
Recovery; and Storage.
5/   The technologies identified in the Association's comments were: cement kiln
combustion, caustic leach cryolite recovery, basic oxygen steel furnace combustion,
mineral  wool furnace combustion, foundry cupola furnace combustion, lime kilns,
sulfide roasting, recycling in Soderberg anodes, production of aluminum fluoride,
pyrohydrolysis, pyrosulfolysis, reclamation in carbon linings, and fluidized bed
combustion.
                                     286

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A.   CLASSIFICATION AND DELISTING

     1.    Threshold Issue: Hazard Determination

          a.    The Problem

          Substantial, segregable portions of spent potliner do  not contain
hazardous levels of cyanide, the Appendix VIQ constituent which caused EPA to list
spent potliner as hazardous waste under Section 3001 of RCRA.  53 Fed. Reg. 35,412
(1988).  Data developed by industry in the last five  years show there is wide,
predictable variability in the cyanide content of spent potliner, depending upon its
location within the pot shell. The primary aluminum  industry has demonstrated
that as much as 60 percent of the material is not  hazardous  and  can be readily
separated and safely handled without imposition of Subtitle C regulation.

          The  1988 listing regulates all spent potliner. There is no  threshold for
cyanide in the listing. The Agency's efforts to ameliorate this recognized problem --
by "defining" the listing to exclude all insulations/ --  is, unfortunately,  overbroad: It
excludes material from the listing that contains significant levels of cyanide and
continues  to encompass material  that does not contain  cyanide  levels  of
environmental concern.

          b.    Discussion

          Using a  protocol developed in conjunction with EPA,  the Association
submitted data on the characteristics of spent potliner  to the Agency on April 16,
1986 and September 18,1987. The data set was assembled from thirty-one pots and
included three  subsamples from each pot,?/  for a total of 93 subsamples.  The  data
show a high variability of free cyanide, covering  four orders of  magnitude.  A
significant number of samples do not exceed 20 mg/L. In fact, of the 93 subsamples
taken, all 31  second cut samples, 26 of 31 bottom block carbon samples, and 17 of 31
side- and end-wall  carbon samples were below 20  mg/L.  The specific  threshold
proposed in  1986 was based on  one hundred times  the Public Health Service
recommended level for cyanide of 0.2 mg/L.  The attenuation factor is the same one
used in the Toxicity Characteristic Leaching Procedure. 52 Fed.  Reg. 29,993-94,
29997 (1987). In response to recent delisting petitions, EPA has used an even higher
level of 0.7 ppm (equivalent to mg/L) instead of the Public Health Service level.  See.
e.g.,53 Fed. Reg. 36070,36075, Table 4 (1988).

          All samples passed the tests for volatile and semi-volatile organics and the
hazardous waste characteristics, including  extraction procedure metals and
 6/    See Letter dated March 3,1989 from Sylvia Lowrance to Jack Goldman.

 '/    Separate subsamples were taken from 1) side- and end-walls, 2) bottom block,
 and 3) insulation. Spent potliner is  easily removable from the pot in these three
 segments.  OSW staff witnessed "digging" a pot and separating its portions at a tour
 of Alumax's Mt. Holly, South Carolina facility on January 21,1986.
                                      287

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reactivity .8/ Accordingly, based on free cyanide content and the hazardous waste
characteristics, a significant proportion of spent potliner is not hazardous.

          Thus, the Association proposed that second cut material not be included in
the proposed listing and that first cut material be subjected to a characteristic test for
free cyanide9/ as described in the protocol. Under this approach, industry estimated
that over 75,000 tons of potliner per year would not warrant control as hazardous
waste.

          In an effort to accommodate the industry, the Director of OSW issued a
letter on March 3, 1989 "clarifying" the scope of the listing. By that clarification,
EPA takes the position that "thermal insulation composed of insulating brick or
aluminum [sic.] [should be alumina]" is not considered to be "spent potliner." The
Association has responded to  EPA's clarification by noting that the clarified
definition excludes from the scope of listing portions of material that  contain
significant levels of cyanide, and continues to regulate material that does not present
a cyanide risk.

     c.    Proposal

          EPA should amend the listing of spent potliner by:

               i.    Adopting  a threshold  level of free cyanide in the leachate,
based on 100 times  the drinking water standard so that material exhibiting
concentrations of free cyanide below the threshold would not be hazardous waste;10/
and

               ii.   Refining its present definition of spent potliner to clarify that
the insulation layer of spent potliner (refractory brick, alumina and/or insulating
board) below the carbon bottom block, and  refractory brick insulation behind the
carbon side- and end-walls, is not part of the listing.
 8/    Because it is a solid, spent potliner does not exhibit the  characteristics  of
 ignitability or corrosivity. The April 1986 data set showed no failures for reactivity
 due to cyanide or sulfide concentrations. There were difficulties in achieving a pH of
 2.0 in the reactivity test due to the buffering properties of spent potliner. However, if
 the pH-adjusting step had been modified to achieve a pH of 2.0, it appears that all
 samples would have passed.  The September 1987  data set did not  analyze for
 reactivity or organics.

 91    The Association explained in its comments that measurement of free cyanide,
 rather than total cyanide, should be the regulatory trigger. Association Comments at
 129-31. Cyanide complexes in spent potliner do not readily degrade.

 10/   The Association's November 9,1988 letter to EPA (see note 7 supra) proposed a
                                                             e thres"
specific test method and an attenuation factor for development of the threshold.


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2.    Mixture and Derived-From Rules

     a.    The Problem

          Application of the mixture and derived-from rules also discourages
resource recovery. Under the deriyed-from rule, 40 C.F.R. 261.3(c)(2)(i), all residue
from treating a hazardous waste is itself hazardous until and unless it is delisted. For
example, all ash from combusting spent potliner in a reclamation process is presumed
hazardous.

          In addition, the mixture rule,  40 C.F.R.  261.3(a)(2)(iii),  defines as
hazardous the entire mixture  of a hazardous and solid waste.  So if potliner is mixed
with a nonhazardous solid waste, the entire mixture is considered hazardous because
of the complex cyanide content of the listed waste, spent potliner. In addition, the
current delisting mechanism (see below)  is not an adequate  solution  to the
deregulation of residues.

          When  the  two rules are both  applied to spent potliner reuse and
reclamation, the  incentive for independent facilities to process the material is
virtually  destroyed.  For example, a coal-fired electricity generator  could replace
0.5% of its feed with spent potliner. However, because the derived-from rule renders
spent potliner ash hazardous,  and the mixture rule renders all of the coal-derived ash
hazardous when mixed with the small volume of spent potliner ash the facility would
now have to comply with all hazardous waste regulations.  There is simply no
incentive to do so. The situation is  repeated, in one degree  or  another, in all
reclamation and reuse processes available to spent potliner.

     b.   The Solution

          Application of the rule must be modified on a case-by-case basis to
facilitate  resource recovery.  In place  of  the derived-from rule, a de minimis  level
must be established for the constituent of concern. When the residue from processing
is produced,  it is not presumed hazardous, but must be tested for levels of the
constituent. If thje de minimis levels are exceeded, the residue is hazardous.

          Exceptions to the mixture rule  must be considered on a case-by-case basis,
so that the EPA's prohibition of dilution is not abrogated.

3.   Delisting

          When  spent potliner was listed as a hazardous waste, EPA officials
expressed hope that the delisting process would be a vehicle for addressing the
industry's concerns of over  regulation. Unfortunately, the present delisting
mechanism does not work well for spent potliner.

     a.   The Problem

          A problem with the current approach to delisting is the failure to integrate
exposure assessments into the process. Although delisting petitions must be
prepared by generators on a facility-by-facility basis, the present reliance on generic,
risk-based constituent levels does not account for exposure potential.  Exposure
potential is a key determinant of environmental risk.


                                    289

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     A second, compounding problem is the cumbersome nature of the delisting
mechanism and the concomitant uncertainty over whether a permit will be obtained.

     b.    Discussion

     The delisting process  does not permit site-specific risk evaluations, viz..
determinations of acceptable risk based on an assessment  of both exposure and
toxicity potential of management practices utilized at particular receiving sites.11/ It
is axiomatic that risk  assessments are site-specific and that baseline risk can be
determined only after summarizing and combining outputs of exposure and
toxicity.12/ Current procedures require a petitioner to prove — regardless of exposure
potential - that the waste or residue does not meet any of the criteria for which it was
listed (40 C.F.R. § 260.22(a)(D), and that factors (including additional constituents)
other than those for which  the waste was  listed cannot cause the waste  to be
hazardous (id. § 260.22(a)(2)).

     c.    Proposal

          Several steps should be taken to make the delisting process more effective.
First is to permit site-specific risk assessments based on evaluations of toxicity and
potential exposure.  A generator should be allowed to delist a waste or residue at the
site of generation and at the facility or facilities where the waste will be processed,
based on an evaluation of toxicity and exposure potential at the site.  A generator
would be required to certify that the waste will be managed in a certain way and that
failure to adhere to all specified conditions would result in the waste being subject to
full Subtitle C regulation.

          Second, EPA should streamline the  delisting process by  defining the
universe of information that is relevant for a particular waste. The establishment of
threshold limits for specific hazardous  constituents would make  the delisting
procedures more effective and less cumbersome.  To facilitate these proposals, a
guidance document should be developed for spent potliner delisting petitions.


B.  RESOURCE RECOVERY

     1.   The Problem

          The rules defining "solid waste" discourage reuse of spent potliner for
energy recovery. Present rules subject virtually all burning of hazardous waste for
energy recovery to Subtitle C.  A further impediment to  capturing energy and
material value from spent potliner is the Agency's view that a material is "inherently
waste-like" if it contains Appendix VIE constituents not ordinarily found in material
substitutes and which are not used or reused in the process. See 40 C.F.R.
§261.2(b)(2),(c)(2),(d)(2).
 11/   Apparently, EPA has concluded that the Agency lacks control over how a waste
 will be managed after delisting and thus believes that it is inappropriate to consider
 site-specific factors. See, e.g.. 53 Fed. Reg. 50551 (1988).

 12/   gee, e.g.. Risk Assessment Guidance for Superfund. Vol.  1. Human Health
 Evaluation Manual (Part A) at 1-6.1-7 (December 1989).
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     Spent potliner has substantial energy and material value which can and should
be utilized. Cyanide, the constituent for which spent potliner is listed, is destroyed in
a variety of heat recovery processes.  Other constituents in spent potliner are
commercially valuable and used beneficially.  Combustion of spent potliner for
energy recovery should not be discouraged simply because it is burned or because
cyanide is not "reused" in the process.

     2.    Discussion

          Congress enacted RCRA "to promote the protection of health and the
environment and to conserve valuable material and energy resources." 42 U.S.C. §
6902. In an effort to comply with this statutory mandate, EPA has promulgated
regulatory controls to govern resource recovery.  Unfortunately, these regulatory
controls have made resource recovery very difficult, if not impossible, in many cases.

          Under existing regulations, virtually all burning of hazardous waste for
energy recovery is subject to Subtitle C regulation. 13/  EPA has taken the position
that a material is "inherently waste-like" if it contains Appendix VHI constituents
that are not ordinarily found in material substitutes and that are not used or reused
in the process. The reuse of spent potliner as a fuel or material  substitute should be
considered legitimate recycling.  The fact that the constituent for which  spent
potliner  was listed as a  hazardous waste (i.e., cyanide) is not recovered in  these
processes should be no barrier to reduced regulation. Cyanide is destroyed in these
energy recovery processes and is not, therefore, released into the environment.14/  In
addition, fluoride and other constituents in spent potliner are commercially valuable
and are used beneficially and safely in these recovery processes.

     3.    Proposal

          Spent potliner that is processed for energy or material recovery should not
be presumptively characterized as hazardous waste treatment.  If there is significant
material recovery or if the Btu content is substantial and hazardous constituents in
the material are destroyed  or rendered nonhazardous in the resource  recovery
process,  then the material should not be a solid waste for regulatory purposes.
Qualifying material  would, instead, be subject to special rules for tracking, storage,
performance standards for resource recovery,  and for testing  residues for
nazardousness.
 13/  The proposed burning and blending rules contain an exemption for burning
 "indigenous" listed hazardous wastes in industrial furnaces.  The  exemption
 suspends application of the derived-from and mixture rules for qualifying furnaces.
 54 Fed. Reg. 43,718 (1989). The proposed exemption would not provide any relief for
 spent potliner because it is not indigenous to the furnaces in which it  has been
 successfully burned, ej^ mineral wool and cement kilns.

 14/  The Association has submitted extensive data to EPA showing that cyanide is
 destroyed to the limit of detection levels in several processes.


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C.   STORAGE

     1.   The Problem
          Spent potliner can be safely stored prior to reuse or treatment.  Current
regulations appear to preclude storing spent potliner without a permit for up to 90
days and in any manner once BDAT rules go into effect.  The aluminum industry
needs to store spent potliner prior to resource recovery because of batch generation,
volumes, and distances involved.

     2.    Discussion

          Materials regulated as hazardous waste can be  stored at the site of
generation for up to ninety days without a permit, provided that the materials are
stored in tanks or containers. 40 C.F.R. § 262.34.  Spent potliner is generally stored
in buildings designed to prevent exposure to the environment.  These buildings
typically have concrete  floors and are  enclosed,  thereby  preventing exposure to
precipitation and the risk of hazardous constituent run-off into the environment.
Storage in such buildings for up to 90 days without a permit  is safe. Unless these
buildings are considered "tanks" under present regulations, the aluminum industry
would be required to obtain a permit for storage of less than ninety days.

          In addition,  present  regulations implementing the  land disposal
restrictions under RCRA would prohibit any storage of spent potliner in buildings
prior to processing once BDAT standards are developed for the material.15/  Current
regulations flatly prohibit storage other than in tanks  or containers once BDAT is
established.  40 C.F.R. § 268.50(a). Accordingly, all storage of spent potliner prior to
processing would be prohibited. 16/

     These regulations must be modified.  The buildings in which spent potliner is
stored meet the performance requirements of 40 C.F.R. § 264.250(c), which excludes
certain waste piles in buildings from leachate collection and liner requirements as
well as  groundwater monitoring provisions provided that: 1) liquids or materials
containing liquids are not placed in the pile;  2) the pile is protected from surface
water run-on; 3) the pile is designed and operated to control dispersal of the waste by
wind; and 4) the pile will not generate leachate. Aluminum industry management
15/   EPA is expected to promulgate land disposal BDAT standards for spent potliner
in 1991 or 1992.

16/   This result appears not to comport with the Agency's intent.  The preamble to
the land disposal restrictions for the third-third rule recognizes that the prohibition
against storage may be too broad. EPA has acknowledged that M[t]he intent of RCRA
section 3004(j) and 40 CFR 268.50  is to prohibit use  of long-term storage to
circumvent treatment requirements imposed by the land  disposal restrictions.  54
Fed. Reg. 48,372, 48,496 (1989). With spent potliner, the storage prohibition should
not apply because it is not surrogate disposal, or otherwise undertaken for purposes of
evading a land disposal prohibition. The Association made this comment to EPA on
January 8,1990.

                                     292

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practices,  including the buildings used to store spent potliner, fully meet these
requirements.

     3.    Proposal

          The aluminum industry has designed and built structures meeting the
performance requirements of 40 C.F.R. § 264.250(c) and which can be used to safely
store spent potliner and ensure protection of the environment. The 90-day storage
exemption and the exception  from land disposal restrictions for temporary storage
must be modified to include such buildings.
                             IV.  CONCLUSIONS

          While the list of impediments just discussed may not be exhaustive, it
represents a set of major regulations that impede the reclamation and reuse of spent
potliner. As mentioned earlier, the list is interdependent, and solution of several of
the problems would break the logjam and allow the aluminum industry to use spent
potliner beneficially.

          It should also be  noted that the approaches outlined in this paper attempt
to ease the regulatory burden while maintaining environmentally safe processing.
The key is to focus regulatory requirements on the material being processed; the use
of generic requirements to guard against all possible worst cases of all wastes causes
beneficial materials such as spent potliner to be land disposed.

          The problem of disincentives to industrial waste reclamation and reuse is
finally being recognized by the  administrative branch, Congress, and even the
environmentalists.  It is hoped that, through discussion, the major disincentives can
be eliminated in the next few years.
                                      293

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   RECLAIMING FIBER FROM NEWSPRINT BY DRY METHODS

                  Dennis E. Gunderson, Research General Engineer
                          C. Tim Scott, General Engineer
                     Rollie L. Gleisner,  Engineering Technician
                USDA Forest Service, Forest Products Laboratory
                            One GifFord Pinchot Drive
                         Madison, W! 53705-2398 U.S.A.
                                 Teresa M. Marten
                    U.S. EPA Waste Minimization, Destruction
                         and Disposal  Research Division,
                                 Cincinnati, Ohio
                                 INTRODUCTION

       United States publishers presently use 40% of the total world consumption of newsprint
(more than 12 million tons annually); 57% is imported from Canada, and another 1% to 2% is im-
ported from Scandinavia.  The cost of these imports is about $5 billion annually (1,2). At present,
old newspapers (ONP) represent both a serious solid-waste problem and a valuable resource
(3-6). Although approximately one-third of all newspapers printed are recycled, ONP still ac-
counts for almost 7% of the solid-waste landfill burden (3-5). Legislation requiring the recycling
of ONP has been enacted  in several states, and literally hundreds of bills are being considered in
other states and municipalities (6).

       With the continuing improvement of deinking and secondary fiber recovery systems, a
natural market for ONP lies in the manufacture of newsprint. Innovative papermakers around the
world have demonstrated  that significant fractions of ONP can be used in newsprint with accept-
able results using existing technology (7-10).  Impediments to broad adoption of this approach
are (a) the high cost of backshipping ONP to newsprint mills, often located many hundreds of
miles from the urban source of the ONP (11), and (b) the large capital investment and massive
water demands inherent in converting ONP to newsprint by conventional means. Water demand
is not a problem at the present sites of virgin newsprint mills, but it is a serious limitation to ur-
ban siting of recycle mills. If we could choose the best of all worlds, we would convert ONP to
newsprint in  urban areas using "mini-mill" processes involving little or no net demand for water
and simple, low-cost machinery. Given the need, one is almost compelled to ask, "Is there any re-
ality in such  an attractive fantasy?"
   The Forest Products Laboratory is maintained in cooperation with the University of Wisconsin. This
article was written and prepared by U.S. Government employees on official time, and it is therefore in the
public domain and not subject to copyright.

                                        294

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       The purpose of our research is to explore this conceptual territory. Specifically, our objec-
tive is two-fold; first, to explore (bench-scale) methods for liberating fiber from ONP with min-
imal use of water and with minimal damage to the fiber, and second, to explore papermaking
techniques that would yield an acceptable newsprint using less water than do current methods,
based on machinery that is less costly to purchase and operate than current machinery. Deinking
is not a part of this study. Our research is funded by the American Newspaper Publishers Associ-
ation (originators of the mini-mill concept), the Environmental Protection Agency, and the USD A
Forest Service. All participants recognize the risk associated with a radical departure from estab-
lished, effective methods—particularly in a mature industry. Yet, contemporary resource changes
and societal needs to reduce landfill waste argue the merits of another look at alternatives—risky
or not (12).

       In this paper, we report three experiments; two are related to mechanical fiberizing of dry
or semi dry newsprint, and the third describes progress in the production  of a newsprint-weight
handsheet by an air-forming technique. These experiments describe what we have observed on
the "road not taken" in prior developments. The work has not been highly successful, but con-
cepts and processes that may make urban conversion of ONP to newsprint not only feasible but
highly attractive may yet exist.

                           EXPERIMENTS AND  RESULTS

Screening Test for Fiberizing Methods

       The purpose of this initial experiment was to find a combination of machine type, feed
source, and operating conditions  that would be  successful in liberating individual fibers for use as
a furnish in subsequent forming of newsprint sheets. The ONP source (for the screening test and
all experiments reported here)  was a clean, never-printed, stub roll of virgin spruce furnish—75%
groundwood and 25% chemithermomechanical pulp (CTMP). This stock entered the fiberizing
process  as either strips (cut to  75 by 500 mm) or "crumbs." Crumbs were prepared by hydropulp-
ing the roll stock, followed by bulk dewatering in a screw press, shredding, and drying to various
moisture contents. The crumb  pulp is intended  to represent output of a wet-deink process. Mois-
ture  contents from 4% to 60% are to be anticipated.

       Based on our own earlier attempts with  a variety of devices and on the experience of oth-
ers (13), we selected three machines with very different actions for the first set of controlled fiber-
izing experiments.  We hoped to generate a range of products that  would  point toward effective
fiberizing concepts as opposed to optimizing a set of operating parameters. The machines were as
follows:

1.  A laboratory 200-mm single-disk atmospheric refiner with three blade sets of various de-
sign. The refiner is powered by a 3.7-kW motor at 3,600 rpm. Blade gaps ranging from 0.05 to
1.25  mm were investigated.

2.  A 260-mm-diameter commercial hammermill in which a large number of articulated blades
impact and abrade the furnish  between the blade and a perforated screen. The blades rotate at
4,000 rpm; hole sizes  of 3 mm and 1.5 mm were  investigated.

3.  A commercial, variable-speed  "deaglomerator" in which a single rotating impeller propells the
furnish at high speed within a perforated basket. Particle size is reduced  by repeated impact of
the furnish against the basket surface until the furnish passes through the perforations.  Impeller
speeds are variable from 0 to 4,200 rpm. We selected hole patterns of 0.8 mm diameter, 28% open
area, and 1.9 mm diameter, 51% open area; impeller speed was 900 rpm.
                                          295

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                  Nit-s«porotor
                                                  Fiberized pulp

                                                  Seporotor screen
                                                   (24,26, or 30 mesh)
                                                  Rotating  air-jet agitator
                                                            Compressed air
                                                              (500 kPa)
                                                     Separated fiber  "accepts'
                                                     Fine mesh screen
                                                     filter
                                                        To vacuum source
                                                               (7-10 kPo)
Figure 1.  FPL-designed nit separator. Fiber fluff is agitated by air jets to separate individual fibers from paper
fragment* and fiber bundles.
       We were able to find a range of operating conditions for each of the three machines that
produced a fiber fluff containing a high proportion of individual fibers. This fiber was generally
mixed with paper fragments or fiber bundles, which we have called nits. To determine the yield
of individual fibers and to separate fiber from nits for sheetmaking, the fluff must be screened or
classified. We developed the apparatus depicted in Figure 1 for this purpose.
                                            296

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         TABLE 1. SELECTED SCREENING TRIALS OF FIBERIZING METHODS
                Fiberizing method
           Moisture  Separator   Fiber
Feedstock   content     yield    length*
             (%)       (%)      (mm)
56-Control+
75-Disk refiner #1 blade
74-Disk refiner #1 blade
71-Disk refiner #1 blade
72-Disk refiner #1 blade
50-Hammermill 3.0-mm holes
76-Disk refiner #3 blade
52-Deaglomerator 0.81-mm holes
77-Disk refiner #3 blade
78-Disk refiner #3 blade
80-Disk refiner #3 blade
73-Disk refiner #1 blade
70-Disk refiner #1 blade

Crumb
Crumb
Strip
Strip
Strip
Crumb
Crumb
Strip
Strip
Crumb
Crumb
Strip

18
18
16
16
8
18
4
7
16
4
4
7
100
100
72
82
100
50
69
98
75
71
81
88
92
1.26
1.20
1.20
1.18
1.18
1.15
1.02
1.00
0.97
0.96
0.90
0.88
0.84
        'Weighted fiber length determined by Kajaani FS-100.
        +Furnish disintegrated in hot water.


       Our initial measure of the quality of pulp obtained from disintegration and separation
processes was the fiber length distribution of accepts as measured by a Kajaani FS-100 fiber
length analyzer1 (14). The Kajaani instrument employs a narrow capillary tube that allows sin-
gle fibers to pass through.  It optically measures the length of each fiber in a very dilute sample
composed of thousands of fibers. After a sample has been run, the instrument calculates distribu-
tion of fiber lengths and a  weighted-fiber-length average in millimeters. Reduction in the percent-
age of long fiber in the furnish (seen as reduced weighted fiber length) is direct evidence of fiber
damage in the fiberization process and predicts degradation in mechanical properties of hand-
sheets (15-18).

       Table 1 cites the operating conditions, yield, and weighted fiber length for the most suc-
cessful 12 of 20 initial mechanical fiberizing trials and for the  control (furnish disintegrated by
gentle agitation in hot water (85°C)). Feed rate for all fiberizing processes exclusive of control and
for the hammermill was  approximately 50 g/min. The hammermill was fed at approximately five
times that rate. Blade gap setting for all disk refiner trials reported in Table 1 was 0.13 mm. The
table is arranged in order of decreasing resultant fiber length and shows a variety of yields ranging
from 50% to 100%.  In this experiment, the strong differentiation relating to machine type that we
had anticipated did not occur.

       Given the undifferentiated response from machine to machine and the ease of use, flexibil-
ity, and  range of results obtained from the disk refiner, we have used the disk refiner almost ex-
clusively for subsequent  processing experiments. The high nit content of low-yield processes was
apparent to the eye, but differences in fiber length were not.  All high-yield products appeared
equally good. The data suggest a tendency toward better fiber length retention for higher mois-
ture content furnish. The most significant finding of this  work is that either crumb or strip fur-
nish can be mechanically fiberized with good yield and little loss of fiber length.
1 The use of trade or firm names in this publication is for reader information and does not imply endorsement
by the U.S. Department of Agriculture of any product or service.
                                           297

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                  50
z
x
4>
•o
C
                  30
                  20
                   10
                                Control; wet disintegrated
                                 (75)
(74) A>- (72)
                                                 (76)
                                                       (78)
                                                               (73)
                                   (50)
                               J_
              JL
                                                  (52)
                                                   j_
                                                             (80)
                                   JL
                                                                   (70)
                    1.3
    1.2        I.I         1.0        0.9
     Weight average fiber length (mm)
                                                         0.8
 Figure 2. Tensile index of TAPPI water-laid/press-dried handsheets made from fiber obtained in selected dry-
 fiberization processes. Fiber length measured by Kajaani FS-100.  Numbers in parentheses correspond to fiber-
 izing methods (Table 1).


        In the second phase of this experiment, fiber produced by the various means was formed
 into handsheets by the wet process described in the Technical Association of the Pulp and Pa-
 per Industry (TAPPI) Standard T205, press dried in accordance with methods described by Horn
 (19) at 135°C at 700 kPa, and evaluated for tensile strength and tear resistance according to
 TAPPI methods T494 and T414. respectively. Figure 2 shows tensile strength index as a function
 of the weighted fiber length measured for the various methods. (Tensile index represents force per
 unit of specimen width per gram of fiber.) The highest strength value, at 1.26 mm weighted fiber
 length, is that for the control fiber liberated by gentle agitation in water.  Results show the tensile
 index dropping 46% as fiber length declines 7% from 1.26 to 1.18 mm.  Reductions in fiber length
 below 1.18 mm show a less pronounced effect.

        Barring a unique sensitivity to small initial reductions in fiber length, the results suggest
 a difference in the  mechanically liberated fiber that compromises sheet tensile strength.  Hand-
 sheets made from mechanically liberated fiber at fiber lengths of 1.20 mm and 0.88 mm had low
 strength, strain-to-failure, and tear index values compared to handsheets made from control pulp
 and virgin roll stock (Table 2).  The clearly superior performance of the fiber processed at 18 per-
 cent moisture content compared with that of fiber processed at 4 percent moisture content sug-
gests the potential for better results in fiber processed at still higher moisture content. The con-
trol pulp handsheets had higher strength properties than did the sheets from the roll stock as a
result of the greater density and strength-enhancing qualities of press drying (20-22).


 Effect  of Moisture Content on Fiber Length and Handsheet Strength

       We evaluated handsheets made by different fiberizing methods over a range of moisture
contents from "as pressed" at 67% moisture content to ovendry at less than 4% moisture con-
tent. Quantities of crumb  furnish were tumbled at 50eC in a commercial drum-type dryer to ob-
tain intermediate values of 52.5%, 42.5%, and 31% moisture content  (as well as ovendry). These
                                            298

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                  TABLE 2. STRENGTH PROPERTIES OF NEWSPRINT
                      AND RECYCLED WATER-LAID HANDSHEETS


Material
Roll stock
Control pulp*
Disk refined pulp*
18% moisture content
4% moisture content

Fiber
length*
(mm)
—
1.26
1.20
0.88


Density
(kg/m )
640
776
630
700

Tensile
index*
(nm/g)
39.0
48.2
38.8
22.9

Strain
to failure*
(%)
1.37
1.42
0.73
0.48
Relative
tear
index+#
(mNxm/g)
120
100
91
52
         'Weighted fiber length determined by Kajaani FS-100.
         +Geometric mean of machine-direction and
          cross-machine-direction properties.
         *Expressed as percentage of control.
         tTAPPI water-laid handsheets, press dried at 135°C, 700 kPa.
furnishes were subsequently fiberized in the single-disk refiner using blade set 1 at a clearance of
0.13 mm.  (Crumbs at 67% moisture content would not fiberize but tended to stick to blade sur-
faces in the refiner, which eventually stalled the motor.) A control pulp was prepared by hydrop-
ulping roll stock in water at 20°C. The relative fiber length of the pulps mechanically fiberized at
various moisture contents are shown in Figure 3. Increasing moisture content was clearly benefi-
cial in promoting retention of fiber length; disk-refined fiber at 52.5% moisture content retained
97% of the length of the control fiber. The control pulp and the four pulps produced at ovendry
to 52.5% moisture content were then formed into handsheets by TAPPI method T 205, as in the
previous experiment, and press dried at 135°C. 700 kPa. Because of the high yield in this process,
nits were included in the test sheets with no apparent effect.

       Handsheets were evaluated for tear strength, tensile strength, stiffness, strain to failure,
and energy absorption. Results for the four disk-refined pulps are shown in Table 3. The tear
resistance for the best of our mechanically fiberized pulps  was 93% of that for the control pulp.
Tear strength tends to decline for the other pulps as fiber  length decreases (15,16,18). Strain-to-
failure and tensile strength followed a similar pattern, but the highest value of each was limited to
approximately 70% of that for the control pulp. Tensile energy absorption was 46% of the control
for our best pulp, and it dropped to 25% of the control for the fiber produced at ovendry condi-
tions. We conclude that although we have been successful in liberating fiber from crumbs at 52%
moisture content with almost no loss of fiber length, we have not yet produced a fiber that can
replicate the performance of the control furnish in terms of sheet strength or toughness.

Web Formation

       This experiment explored air-forming methods as an alternate means of web formation.
The objective was to determine if the net demand for water in the recycling process can be re-
duced by use of forming means other than conventional wet-forming, which occurs at water to
fiber ratios of 100:1 and higher (<1% consistency).  It has  long been known that webs with ex-
cellent formation can be made by air deposition of fiber at low moisture content (air-laid webs)
(13,23). These webs can be wetted with water and then dried under restraint to create hydrogen
bonding between the fibers. The strength of sheets produced in this way has characteristically
                                           299

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             o
             u
               lOOr
                90
             o>
             u
             01
             
             c
             01
             I  60
             o>
                50
                                       (88% yield)

                                (88% yield)
                                          (86% yield)
(94% yield)
                           10      20      30     40      50
                         Moisture content of pulp crumbs (percent)
                                              60
Figure 3. Relative fiber length of pulps fiberized at various moisture contents in single-disk refiner.  Reference is
water-disintegrated control pulp. Numbers in parentheses specify separator yield.

              TABLE 3. EFFECT OF PROCESSING MOISTURE CONTENT
                  ON FIBER LENGTH AND HANDSHEET PROPERTIES

                                         Handsheet properties (%)*
Moisture
content
(%)
52.5
42.5
31.0
4.0
Fiber
length
(mm)
97
89
86
76
Tensile
strength
69
59
63
57
Stiffness
79
67
77
76
Strain to
failure
70
60
71
48
Energy
absorption
46
33
44
25
Tear
93
72
79
43
             "Shown as percentage of control handsheet values.  TAPPI water-laid
              handsheets, press dried at 135°C, 700 kPa.
been less than that of sheets produced from water-laid webs. However, with the development of
press-drying technology and its demonstrated ability to enhance the strength of webs with poor
natural bonding potential (20-22), it is reasonable to ask if the combination of air-laid web for-
mation and press drying can yield a recycled newsprint of acceptable strength (24).

Air-Forming and Water-Forming Methods

       For this evaluation, a quantity of pulp was dry fiberized from crumbs at 25% moisture
content in the disk refiner using Method 75 (see Table 1). With this fiber, we then formed a se-
ries of air-laid and water-laid handsheets varying the temperature of the forming or rewetting
water,  the forming substrate, and, because press-dry effectiveness has  been shown to vary with
sheet weight, the grammage. Our results showed the forming substrate for the air-laid webs had
                                          300

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                                                Air distribution volve
                Pulsed air jets
               Agitation
               chamber
                                           Separating screen
                                              (16 mesh)
                                              Removable  tower
^—Air supply
  (500  kPa)
                                                             Removable forming screen

                                                             Supporting grid
                                                             Vacuum source
                                                               (7-10 kPa)
                                                     Plenum
       •Vacuum gage
Figure 4.  Forming apparatus for handsheets. Fiber liberated in agitation chamber is drawn through 16-mesh
screen and deposited to form web on removable forming screen.

little effect on the outcome of the experiment. To simplify presentation, we report only four pro-
cedures that span the range of results: two water-laid methods and the best and worst of the air-
laid methods.

       Air-laid handsheets were made in an apparatus designed by the Forest Products
Laboratory (Fig. 4). The fiber for one sheet is placed into the agitation chamber and the top
of the chamber is sealed. A 7- to 10-kPa vacuum is applied to the plenum by an industrial vac-
uum source. The air jets are then alternately pressurized by 500 kPa compressed air, causing the
fiber bundles to agitate and the individual fibers to shake loose from each other.  As the fibers are
separated, air flow carries them through the 16-mesh screen and down through the tower. The
forming screen at the bottom of the tower retains the fiber as the air passes through creating a
uniform web of fibers. The process takes approximately 1 min. The web is then removed with
the forming screen for rewetting and drying. In  this experiment, webs were formed at 50, 70, and
90 g/m:.

       The rewetting procedure was found to be a significant variable for air-laid webs. Air-laid
handsheets wetted with cold water were rewet by placing the web, on its forming screen, onto a
plastic grid in a shallow pan. The water level in the pan was just slightly above the top of the
                                           301

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grid. The water was able to soak up into the web through the forming screen by capillary action.
The water temperature was 19°C; wetting time was approximately 1 min. Once wetted, the web
was wet pressed between blotters at 3.0 MPa and subsequently press dried at 149°C, 3.0 MPa for
1 min.

       Air-laid handsheets wetted with hot water were treated in the same manner as hand-
sheets wetted with cold water except that the temperature of the rewetting water was 55°C.
After rewetting, the web was held in a saturated environment at 38°C for 1 h to ensure thorough
wetting of the fiber prior to wet pressing and press drying.

       The temperature of the forming water was a significant variable in the performance of
water-laid sheets (formed in a British sheet mold). To form cold-water-laid sheets, fiber for one
sheet was mixed in 19°C water for 15 s. The slurry was then added to the sheet mold, diluted
with more 19°C water, and drained to form the web. Webs were couched off the screen, wet
pressed between blotters in groups of six, and press dried.

       Hot-water-laid sheets were made in similar manner, but fiber preparation was modified in
a manner intended to enhance fiber flexibility and remove latency (25) prior to forming. Fiber for
six sheets was weighed out and mixed in 55° C water for 15 min.  After the fiber was mixed, the
fiber slurry was added to a doler tank and diluted with more 55° C water. The fiber was allowed
to mix in the doler tank for an additional 45 min  before forming, wet pressing, and press drying.
The overall formation and appearance of the better air-laid and water-laid sheets were good to
excellent. However, the air-laid sheets  were subjectively inferior to the water-laid sheets in their
appearance and characteristically  exhibited a small number of pinholes not seen in the water-laid
sheets.

       Density and tensile strength results are shown in Figure 5. The data show the superior
performance of water-laid webs and the beneficial effect of hot water (and extended sorption
time) relative to cold water.

Air-Forming and Liquid-Forming Methods

       Another experiment provided a better understanding of the significant difference in per-
formance of the webs made by air-forming as opposed to liquid-forming methods. The orientation
and networking of fibers in an air-laid web is presumably different from that in a liquid-laid web.
It is reasonable to ask if the reduced performance of air-laid webs is related to such differences in
web structure. In this experiment, dry fibers were air laid, using methods previously described,
or liquid  laid, using ethyl alcohol as a forming medium.  Results were compared with those from
experiments with  water-forming methods.

       The experiment involved three primary processes and four supporting methods. All used
the same mechanically fiberized furnish made in the disk refiner from crumbs at 50% moisture
content.  The primary processes were (a) water-laid, hot rewet (as described in previous section),
(b) air-laid, cold rewet (as described in previous section), and (c) alcohol-laid, cold rewet.

       In the alcohol-laid process, the fiber furnish was dispersed in ethyl alcohol rather than wa-
ter or air. The alcohol extracted water from the fiber, reducing its moisture content to near zero.
Handsheets were formed !n a sheet mold using alcohol as the fluid medium. After forming, the
alcohol-saturated  web was held for 48 h in a humidity-controlled room at 90% relative humidity
where the alcohol evaporated and  the fibers regained moisture to approximately 18% moisture
content.  The web was then rewetted with cold water, wet pressed, and press dried in the man-
ner of the air- and cold-water-laid webs.  In this way, we were able to compare air-laid and liquid-
laid webs made with dry fiber.  To verify that no fines were lost in the forming process, a sample
                                           302

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    50

    45

^  40

2  35
X
-g  30
C
.-=  25

£  20

    15

    10
                              Water laid, hot
                                                70g/mz
                                                              90g/mz
                            50g/m2

                             Air laid,  hot
                            -•"^-Air Ini
Air laid, cold rewet
           560   600    640
                          680    720    760   800   840
                            Density (kg/m3)
                                    880
Figure 5. Density and tensile strength of water-laid and air-laid handsheets weighing 50, 70. and 90 g/m2.
Temperature of forming and rewetting water was 19° C (cold) or 55° C (hot).
        TABLE 4. PROPERTIES OF AIR-LAID AND LIQUID-LAID HANDSHEETS'

Web type
A. Hot water laid
B. Air laid
C. Alcohol laid
D. Alcohol wash, air laid
E. Hot water soak, alcohol wash, air laid
F. Hot water soak, alcohol laid
G. Hot water soak, alcohol wash, hot water laid
Tensile
index
(nm/g)
44.8
17.5
21.7
17.8
23.6
27.9
49.3

Density
(kg/m3")
723
683
640
637
660
700
726
Fiber
length"1"
(mm)
1.00
1.07
1.07
1.06
1.04
1.01
1.00
        •Press dried at 149°C, 3.0 MPa.
        +Weighted fiber length determined by Kajaani FS-100.
of each handsheet type was dissolved in water after forming and then analyzed in the Kajaani
FS-100. The results show no significant variation in weighted average fiber length (Table 4).

       A comparison of tensile index values for handsheets made from webs A and B (Table 4)
shows that the hot-water-laid web significantly outperformed the air-laid web. Comparing B to C,
we note that performance was only slightly improved by alcohol laying of the dry fibers. The re-
sults indicate that the reduced performance of the air-laid webs was not simply a function of fiber
placement or arrangement in the web but also involved the relative ability of the fiber to bond
with other fibers in the network. Web types D through G verify that (1) bond potential of the
                                         303

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Figure 6. Scanning electron micrographs of air-laid (a) and water-laid (b) handshects at l.QOOx. Handsheets
were formed from the same dry-fiberized furnish; differences in fiber fibrillation and fibrillar bridging of bond
sites are apparent.


air-laid fiber was not diminished by the alcohol wash (compare D with B), (2) a hot water soak to
remove latency (residual twist and curl in the fiber) prior to forming was helpful even in air-laid
webs (compare E with D), (3) a hot water soak was helpful for dry fibers, alcohol laid (compare F
with C), and (4) the alcohol wash did not reduce the strength or bonding potential of hot-water-
laid webs (compare G with A).

       The failure of the alcohol-laid web C to perform significantly better than the air-laid web
B leads us to infer that the performance of webs formed from dry fibers will not be greatly im-
proved by further refinements in forming methods. That is, the challenge appears to lie with the
fiber itself: its fibrillation, forming flexibility, and ability to re-establish strong bonds within the
web. We see evidence of this challenge in  Figure 6. The air-laid web (a) shows almost no evidence
of fiber fibrillation; the wet-laid web (b), which was made from the same fiber, exhibits extensive
fibrillation and bridging of bond sites—characteristics known to be associated with effective bond-
ing and development of sheet strength.

                              CONCLUDING REMARKS

       Old newspaper (ONP) can be mechanically fiberized at moisture contents ranging from
ovendry to >50% moisture content with a high yield of individual fibers.  The potential for fiber
damage (shortening of mean fiber length) is greatest at low moisture contents. At moisture
contents from ovendry to approximately 20%, individual fibers can be disentangled from fiber
flocks relatively easily and paper particles (nits) can likewise be separated from  fibers. Disentan-
glement of fiber groups becomes significantly more difficult as moisture content  increases above
20%.  A variety of methods (machines) are potentially useful for fiberizing, but the fiber prod-
uct is highly sensitive to operating parameters. We have not systematically optimized any of the
methods we evaluated.

       In our best effort to date, we fiberized ONP at 52% moisture content—retaining  97% of
the fiber length measured in the control pulp obtained by the wet-disintegration in hot water.
When wet-formed into 70 g/m2 handsheets and press dried, this dry-fiberized pulp delivered 93%
of the tear strength, 69% of the tensile strength, and 46% of the tensile energy absorption ca-
pability of the control pulp. Thus far, our best air-laid/press-dried method has  produced hand-
                                            304

-------
sheets with 91% of the density and 53% of the tensile strength of water-laid/press-dried hand-
sheets made from the same dry-processed fiber.

       How then can the strength and toughness (tensile energy absorption) of air-laid hand-
sheets made from mechanically fiberized pulp be improved? At least four possibilities are
apparent:

1. Optimize the  mechanical fiberizing process to retain fiber length and enhance rebonding
potential.

2. Chemically modify the fiberized ONP to activate lost bonding potential.

3. "Enrich" the ONP furnish with long fiber, either virgin or recycled, from higher grade
products.

4. Add "adhesive" to the air-laid fiber and/or to the rewetting water.

       For the present, our experience with dry disintegration of ONP and air laying of newsprint-
weight webs does not dispute the wisdom of 100+ years of development in papermaking. Wet-
forming methods are hard to beat. Dry or semidry processing of newsprint will not come easily—
and it may never be successful. However, if the demand for urban recycling of ONP is sufficiently
strong, there is enough promise in our results to warrant further effort and exploration.

                               ACKNOWLEDGMENTS

       The authors gratefully acknowledge the guidance, consultation, and tangible support pro-
vided by William Rinehart and George Cashau of the American Newspaper Publishers Associ-
ation, Ivars Licis of the Environmental Protection Agency-Cincinnati, and Vance Setterholm of
the Forest Products Laboratory.

                                    REFERENCES

  1. Monthly Statistical Report (January 1990). Newsprint Division, American Paper Institute.
    260 Madison Avenue, New York, New York 10016.

  2. Carter, M. G. Newsprint: Part I—How we get it. Presstime 10:32,1988.

  3. lannazzi, Fred  D. The economics are right for U.S. mills to recycle old newspapers. Pulp and
    Paper 63:  114, 1989.

  4. Carter, M. G. Newsprint: Part II—How we dispose of it.  Presstime 10:38,1988.

  5. Hardy, Sandra C. Recycling old newspapers. Reprint of address to Pennsylvania Newspaper
    Publishers Association Annual Convention, Allentown, Pennsylvania.  September 28,1989.

  6. Garcia, Debra  A. Recycling  capacity to increase at record rates as laws proliferate. Pulp and
    Paper 64:S1,1990.

  7. Lyden, Kevin.  Recycling newsprint mills to the rescue-absorbing the old news glut. In: Pro-
    ceedings: Wastepaper I, Demand in the 90's.  Miller Freeman Publications, San Francisco,
    California, 1990.

  8. Marley, Margaret. Secondary fiber improves the quality of newsprint.  Paper Technol.  30:46,
    1989.
                                           305

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 9. Scott, William B. Waste-based newsprint—quality and trends in consumption.  Paper
    Technol. 30:12,1989.

10. Cogger, R. C. Making newsprint from a 100% wastepaper furnish. Paper Technol.  Ind.
    29:78,1988.

11. Angulo, Jeffrey and Linsen, Paul.  Recycling: The coming age of recovery. 2,000 and beyond,
    Tappi Press, Atlanta, Georgia, 1990.

12. O'Leary, Philip R., Walsh, Patrick W., and Ham, Robert K. Managing.solid waste.  Sci.  Am.
    259:36,1988.

13. Hanson, James P. Air-laid forming installations using wood pulps. Proceedings: Second  In-
    ternational Air-Laid and Advanced Forming Conference. Marketing Technology Service,
    Kalamazoo, Michigan,  1980.

14. Bichard, W. and Scudamore, P. An evaluation of the comparative performance  of the Kajaani
    FS-100 and FS-200 fiber length analyzers. Tappi 71:149,1988.

15. Clark, J. d'A. The measurement and influence of fiber length. Paper Trade J. 115:36, 1942.

16. Clark, J. d'A. Effects of fiber coarseness and length. Tappi 45:628,1962.

17. Horn, Richard A. What are the effects of recycling on fiber and paper properties? Paper
    Trade J. 15:78, 1975.

18. Seth, R.S. and Page, D.H. Fiber properties and tearing resistance. Tappi 71:103, 1988.

19. Horn, Richard E. Press drying of high yield pulps.  Tappi 64:105, 1981.

20. Setterholm, V.C. An overview of press drying. Tappi 62:45, 1979.

21. Setterholm, V.C. and Koning, J.W. Jr. Press-dried paper. Appita 37:361, 1984.

22. Horn, Richard A. and Bormett, David W. Press drying recycled fiber for use in  paperboard.
    Tappi 68:78, 1985.

23. Bouda, F.J. Air-formed webs-the  products and the processes. Paper Technol. 30:21, 1989.

24. Byrd, Von L. Bonding  of air-laid webs. Tappi 65:153, 1982.

25. Beath, L. R., Neil, M.T., and Masse, F.A. Latency in mechanical wood pulps. Pulp Paper
    Mag. Canada 67:T423,1966.
                                          306

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       International Conference on Pollution Prevention:
             Clean Technologies and Clean Products

  Session 37:  Hazardous Waste Minimization in DoD Operations
                         June 12, 1990

 DOD OIL AND HAZARDOUS SUBSTANCES POLLUTION PREVENTION PROGRAM

                               by
                  Brian P.  J.  Higgins,  PhD,  PE
                       (Session Chairman)
                Civil and Environmental Engineer
   Office  Deputy Assistant Secretary  of Defense (Environment)


                            ABSTRACT

     The Department of Defense (DoD)  is continuing to expand
its Pollution Prevention/Hazardous Waste Minimization Program.
In 1988, DoD presented an extensive report to Congress on DoD
hazardous waste minimization efforts.  In 1989, DoD issued a
DoD Directive on "Hazardous Material Pollution Prevention."
The goal of this directive is pollution prevention, rather than
"end of the pipe" solutions, throughout DoD.  The preferred
method of pollution prevention is to avoid or reduce use of
hazardous material through selection and management over their
life cycle.  DoD's pollution prevention program also includes
prevention of, preparedness for, and response to oil and
hazardous substance spills under the National Contingency Plan.
This session consisted of a panel of representatives from the
Office of the Deputy Assistant Secretary of Defense for the
Environment (ODASD(E)), each of the Military Services, and the
Defense Logistics Agency.  Panel members discussed pollution
prevention/hazardous waste minimization programs and planned
initiatives within their Components.


                          PRESENTATION

     Good afternoon.  This is Session 37 on DoD Hazardous Waste
Minimization.   I'm Brian Higgins, an Environmental Engineer in
the Office of the Secretary of Defense (OSD).   I work for Bill
Parker, who gave one of the keynote speeches at the Plenary
Session yesterday morning.
                             307

-------
     If you haven't had a chance, I recommend that you visit
the DoD exhibits downstairs.  We have exhibits for OSD, the
U.S. Army Toxic and Hazardous Materials Agency (USATHAMA),  the
Navy, and Rocky Mountain Arsenal.
     Our speakers, who we will introduce in more detail a
little later, are:

     o  Bob Bartell from USATHAMA,
     o  Paul Yaroschak from the Navy's Office of the Chief of
Naval Operations  (CNO),
     o  Major Brian Mccarty from the Air Force Systems Command
(AFSC), Brooks Air Force Base, and
     o  Joe Hoenscheid from the Defense Logistics Agency (DLA).

     Bill Parker  spoke about many topics yesterday which I
don't need to repeat here.  Something that may not be covered
elsewhere in this Conference is something I have had first hand
knowledge of for  the last 1.5 years as DoD's representative on
the National Response Team  (NRT).

     As you may know, the NRT is responsible for national
policies and procedures in preparing for and responding to
spills of oil and hazardous substances as part of the Clean
Water Act and the Superfund Acts.  EPA is responsible for
consulting with the NRT, which is composed of 14 federal
agencies, in developing the National Oil and Hazardous
Substances Pollution Contingency Plan, better known as the
National Contingency Plan (NCP).

     For more than 20 years, DoD has had an Oil and Hazardous
Substances Pollution Prevention and Contingency Program.  Our
Directive requires that we be represented on the NRT and on the
Regional Response Teams  (RRTs).  Our bases are supposed to have
Spill Prevention  Control and Countermeasures  (SPCC) Plans and
Spill Contingency Plans so that every aspect of our operations
is covered by some pre-planning, equipment, and construction,
in some cases, to prevent spills in the first place, and to
clean them up if  they do occur.

     We're responsible for reporting spills to the National
Response Center  (NRC).

     EPA or  the Coast Guard provide the On-Scene Coordinator
 (OSC) for oil spills on or  from  our bases.  We are responsible
for  cleaning up all of our  own spills, for acting as OSC for
our  hazardous substance releases, and for providing the
Remedial Project  Manager  (RPM) for long-term responses on our
bases.

     A  large part of our effort  is to assist EPA or the  Coast
Guard in responding to emergencies caused by others.   I  have a
personal example, one which you  are all very  familiar with -
                              308

-------
the Exxon Valdez incident.  Since 1980, the Naval Sea Systems
Command Supervisor of Salvage  (NAVSEA SUPSALV) has had an
agreement with the U.S. Coast Guard for mutual support in the
event of oil or hazardous substance spills in the marine
environment.  The Coast Guard and Exxon called SUPSALV for
assistance within 12 hours after the Exxon Valdez went aground.
The Air Force Military Airlift Command was flying Navy
equipment from California to Alaska within 1.5 days, and it was
also transporting equipment from Scandinavia and the Soviet
Union for use in Prince William Sound.

     During an interview about 40 days after the spill began,
Admiral Yost, the Coast Guard Commandant, described the Navy
equipment on scene and made the comment "Thank God for the Navy
Supervisor of Salvage."

     The Mega Borg incident in the Gulf of Mexico has, of
course, received national attention this week.  The Coast Guard
has called in some Navy salvage experts to help in supervising
the ship owner's contractors on-scene and asked for some Navy
oil skimmers to be ready if needed.

     Since this is an International Conference, I've gotten
calls from other countries for information and/or assistance
from DoD.  Two weeks ago, EPA received a cable from the
Philippine government requesting help with 45 leaking barrels
of anhydrous hydrazine, a very toxic and explosive substance,
at a Philippine Navy base.  Jim Makris, EPA's Director of
Chemical Emergency Preparedness & Prevention and Chairman of
the NRT, requested technical assistance from DoD.  We had some
Air Force experts from Tyndall AFB, Florida, Kelly AFB, Texas,
and Clark AFB in the Philippines, as well as Navy explosives
ordnance demolition (EOD) personnel from Subic Bay Naval
Station assist EPA and the Philippine government.
                            SPEAKERS

     Our first speaker, going in order of Service seniority as
usual, is BoB Bartell, from the U.S.  Army Toxic and Hazardous
Material Agency at Aberdeen Proving Grounds.  He's the Chief of
the Research and Technology Development Branch.  He has 10
people working for him, and he's responsible for about a $12
million/year program to develop technologies for our
Installation Restoration Program (IRP) and Hazardous Waste
Management.  He's been with USATHAMA since 1980, and he's grown
up with the IRP, which has grown tremendously since then.  We
talk frequently with EPA.  Russ Wyer, who was Chief of the
Hazardous Site Control Division, mentioned that one of the
first groups that they talked with in 1979-80 when they were
getting into the Superfund business was USATHAMA,  because of
                             309

-------
THAMA's experience going back to the mid-1970s in site studies
and cleanups at several of our bases.

Bob Bartell:  "The Army's Hazardous Waste Minimization Program"
(separate paper)

     Just a sidelight.  The Army's Chemical Demilitarization
Program Manager at Aberdeen Proving Grounds used to be part of
USATHAMA.  The Army is DoD's Executive Agent for demilitarizing
our chemical weapons.  They currently have a $3 billion program
to dispose of our unitary chemical weapons by incineration.
With some of the arms control agreements, that may increase in
the next few years.  With the Chem Demil Program is a $150
million emergency preparedness program in which the Army is
working closely with FEMA and EPA to prepare for any
eventuality in the storage and disposal of these weapons.

     Our next speaker is Paul Yaroschak, who is the Head of the
Shore Facilities Environmental Protection Branch in the Office
of the Chief of Naval Operations.  As such, he is responsible
for developing policy for a $100 million/year shoreside
environmental program for our Navy.  His responsibilities
include getting funds for that program and seeing that it
functions properly.

Paul Yaroschak:  "Hazardous Waste Management: Making it Happen"
(separate paper)

     Next is Major Brian Mccarty, a Bioenvironmental Engineer
with the Air Force Systems Command in their Center for
Hazardous Materials Management at Brooks Air Force Base, Texas.
His co-author, Jeffrey Short, who is also here, was scheduled
to speak, but kindly deferred to Brian to do the standup.  Jeff
is with the Air Staff at Boiling Air Force Base, here in DC.

Major Brian Mccarty:  "U.S. Air Force Hazardous Materials
Management Initiatives"  (separate paper)

     Our next speaker is Joe Hoenscheid, a Senior Environmental
Specialist for the Defense Logistics Agency.  He is the Program
Manager for the Agency's overall hazardous materials management
program.  He has worked in our part of the Office of the
Secretary of Defense, for the Defense Reutilization and
Marketing Service, for the Defense Logistics Services Center,
and for the DoD Inspector General on a special assignment to
review DoD Hazardous Waste Management.  He is the Deputy to
Walker Beddoes, who some of you may know is the Chief of DLA's
Regulated Property Disposal Office.

Joe Hoenscheid:  "Defense Logistics Agency Comprehensive
Hazardous Materials Management Program"  (separate paper)
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                     QUESTIONS AND ANSWERS

Q.  Jeff Short, U.S. Air Force:  What is DASD(E) doing with the
General Services Administration?  GSA provides hazardous
materials sometimes, also.

A.  I'm not aware of anything that we are doing directly with
GSA.  Our Directive on hazardous materials pollution prevention
came out nearly a year ago, on July 27, 1989.  It calls for an
annual briefing to the Assistant Secretary of Defense
(Production and Logistics) on progress in implementing the
directive.  We're looking to a meeting with the Components late
next month to see exactly where we stand in a lot of these
areas and to prepare the briefing for ASD(PSL).

A.  Joe Hoenscheid:  As of late last year, the hazardous
property disposal people in GSA, along with some other groups,
were planning to convocate a meeting of federal officials to
talk about just where the whole program would go within the
federal government.  We were expecting that to get off the
ground by now, but don't think it has.

A.  Jim Edward, EPA Office of Pollution Prevention:  There is
going to be a conference of federal agencies on recycling in
October.  It will be a joint thing with EPA and GSA.  Right now
the scope is fairly limited to recycling and not waste
reduction.

Q.  David Wigglesworth, Alaska Department of Environmental
Conservation:  One thing I'm curious about, at the base
commanders level, as the bases try to implement some of these
measures, how the mechanisms are going to transfer this work,
through directives or other means?  My other question is how
can state programs assist in helping with that whole process.
We've got a number of. ideas.  The federal agencies in Alaska
certainly are a large contributor to our waste stream.

A.  That's an excellent guestion, and each of the Services may
address it a little bit differently.  After our directive, one
major step is our initiative with EPA to look at model bases
and come up with a hands-on guide for our base commanders on
how to implement pollution prevention in many areas, not just
hazardous waste, but transportation, energy, and a number of
other areas.  We just started meeting with EPA in developing
that concept.  It would be similar to a guide which USATHAMA
came out with last year for base commanders in the whole realm
of environmental compliance.  It's easy reading, take-home, bed
stand type of thing, but it really covers a wealth of
information for the base commander who may have career
experience in infantry, but also in leading and commanding and
                             311

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in taking responsibility.  He can pick that up and see what he
needs to do and determine which of his staff he needs to bring
in to do all of these things.  You should work with the base
commander because he is responsible for what happens on his
facility and for working with the State and local governments
and the local communities.

Q.  In terms of human health and the effects of hazardous
materials, the thing we tend to rely on in the field is the
Material Safety Data Sheets (MSDSs).  We have a system in place
to put all these MSDSs into CD-ROM, which is really nice and
handy for getting the information at the base level.  But my
main concern is how complete and accurate are the MSDS data?

A.  There is no question that some of the data sheets are
sketchy and questionable.  DLA and our Force Management and
Personnel people are developing a better Hazardous Management
Information System (HMIS) and Hazard Communication System to
satisfy OSHA requirements.  I would hope that the MSDS data is
upgraded as time goes by.

Q.  How are you practicing pollution prevention in your
Installation Restoration Program?

A.  As Bill Parker mentioned in his keynote speech yesterday,
Section 121 of CERCLA states that the remedial action
preference is for treatment to permanently and significantly
reduce the volume, toxicity or mobility of hazardous
substances.  We would have to look at individual feasibility
studies or records of decision to get specifics, but this
preference should always be part of our selection of remedy
process.

                              END
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       International Conference on Pollution Prevention:
             Clean Technologies and Clean Products

  Session 37:  Hazardous Waste Minimization in DoD Operations
                 Washington,  DC -  June  12,  1990

    DLA COMPREHENSIVE HAZARDOUS MATERIALS MANAGEMENT  PROGRAM

                               by
            W. Joseph Hoenscheid and Walker Beddoes
               Regulated Property  Disposal  Office
                    Defense Logistics Agency
                            ABSTRACT

     Until 1986, the Defense Logistics Agency (DLA) had a
number of individual programs dealing in varying degrees with
the management of hazardous material and hazardous waste.  Each
program was very worthwhile and commendable in its own right.
However, these were individual efforts, often lacking agency-
wide visibility and central direction.  To provide a
coordinated approach to hazardous material and hazardous waste
management within DLA, a task group consisting of
representatives of the cognizant DLA Directorates developed the
DLA Comprehensive Hazardous Materials Management Program
(CHAMMP) - the basis for continued management efforts in this
arena.  The task group took a "life cycle" approach in
developing the Program.  The six phases in the life cycle of
DLA managed hazardous property are:
     o    Determination of requirements
     o    Design
     o    Acquisition
     o    Supply systems (that is, how the hazardous material
is transported, stored, issued, etc., by our Defense Depots)
     o    Consumer use (DLA) - This phase deals with how
hazardous material is used within DLA itself
     o    Disposal
     CHAMMP has been incorporated into the DLA Strategic Plan
and provides for the continued "cradle to grave" management of
DLA controlled hazardous property.  It is a "living plan,"
reviewed and revised on a continuing basis to meet the changing
environmental challenges.  This briefing elaborates on each of
the phases of the plan.
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                          PRESENTATION

     The Defense Logistics Agency's business is support -
specifically, furnishing materiel support and services to the
military.  If the U.S. military forces fight with it, eat it,
wear it, burn it (fuel, that is), push its buttons, or use it
to carry out any of a thousand tasks related to combat
readiness, chances are that DLA buys, stores and ships the item
to the Military Services.  We manage more than 2.8 million
supply items in all, and each shares a common trait; whether
pasta or spare part, each item is a consumable.

     Our cradle-to-grave materiel support role starts at the
predesign phase and continues throughout the life of the
product until, eventually, we dispose of items no longer needed
by the Services.  During this process. DLA continually
emphasizes total quality management, which stresses quality
throughout the production cycle.  Some 50,000 civilian
personnel and 1,000 military, engaged in a wide variety of
occupations and skills, carry out DLA's logistics
responsibilities at facilities that span the globe.

     To assure the support essential to readiness, DLA uses an
array of technical, administrative, and managerial skills
ranging from computer programming to mechanical engineering.
Whatever the occupational specialty, our work force applies its
expertise in supporting the Military Services by:

     o    Buying and providing quality goods,
     o    Administering contracts, and
     o    Performing technical and logistics services.

     The DoD components use some 4.8 million national stock
numbered items.  The growing inventory of commodities that we
manage - spare parts, clothing, fuel, food, medical and
construction supplies - represent 69 percent of all items used
by the armed forces.  While only a small portion of these items
are considered hazardous materials, they require close and
continued attention to comply with environmental mandates,
assure the safety of those personnel that handle them and
preclude environmental degradation.

     It's difficult to pick up a newspaper, magazine, turn on
the TV, even listen to the radio today without being exposed to
some reference to the environment.  If the commentary doesn't
address new legislation or costly compliance, it all too often
concerns instances of damage to the environment.  In some cases
the damage is alleged to be the fault of a federal facility or
that of an activity of the Department of Defense (DoD).  The
environmental authorities, as well as the special interest
groups, are quick to point where we may have failed.
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     The recent Defense Environmental Restoration Program
annual report to Congress cited two significant quotes that
emphasize the importance the Administration places on
environmental compliance.  From the 1988 Presidential campaign,
the statement by President Bush that "Federal facilities should
lead the way in environmental compliance;" and from Secretary
of Defense Cheney on 10 October 1989 "...this Administration
wants the United States to be the world leader in addressing
environmental problems and I want the Department of Defense to
be the Federal leader in Agency environmental compliance and
protection."

     The continuous oversight by Congress, the General
Accounting Office, the Inspector General, the Department of
Justice, the Environmental Protection Agency and the
environmental authorities of the states, coupled with the
heightened environmental awareness of a sensitive public,
challenges us to examine the way we do business and seek
constant improvements in the management of hazardous
commodities.  The Comprehensive Hazardous Materials Management
Program, or CHAMMP, is part of the DLA effort to address those
challenges.

     Up until 1986, DLA had a number of programs and
initiatives involved with the management of hazardous material
and hazardous waste.  However, these programs and initiatives
were instituted and managed exclusively by the affected
functional element.  For instance, the Directorate of Supply
Operations had several ongoing programs at the Defense Supply
Centers and Depots which dealt with packaging and
transportation of hazardous material stocks; safety and health
professionals with the Office of Installation Services and
Environmental Protection were implementing programs at the DLA
field activities in conjunction with the OSHA Hazard
Communication Standard; the Defense Reutilization and Marketing
Service in Battle Creek, Michigan, was proceeding with various
hazardous waste disposal initiatives; and so forth.  Each of
these initiatives was very worthwhile and commendable in its
own right; however, these individual efforts, driven by diverse
requirements, often lacked agency-wide visibility and were
frequently being pursued without central  coordination or
direction.

     To provide a coordinated approach to hazardous material
and hazardous waste management within DLA, the Director
designated the Director of Technical and Logistics Services as
his Executive Agent.  Under this authority,  a task group of
representatives of the cognizant DLA Directorates was convened
to develop a DLA Comprehensive Hazardous Materials Management
Program - the basis for continued management efforts in this
arena.
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     The task group took a "cradle-to-grave" approach in
developing the program.  This chart shows the six phases in the
life cycle of DLA-managed hazardous property that were
identified:

     o    Determination of requirements
     o    Design
     o    Acquisition
     o    Supply systems (that is, how the hazardous material
is transported, stored, issued, etc., by our Depots)
     o    Consumer Use (DLA)  - This phase deals with how
hazardous material is used within DLA itself,
     o    Disposal.

     Within each of the six life cycle phases, we identified
one or more subphases or actions.  A total of 26 subphases are
incorporated into the program.

     The task group then made a complete review of all the
Principal Staff Element (PSE) hazardous property management
responsibilities and actions.  We noted a great deal of
duplication or contradiction of effort.  An example of this is
in the area of training.  We discovered that our supply
operations people were developing and providing hazardous
materials handling training for their Defense Depot stock-
handlers completely independent of the similar training being
developed and conducted by the Defense Reutilization and
Marketing Service for its hazardous property disposal
personnel.

     The task group rolled all these hazardous property
management responsibilities into the program with an eye to
eliminating duplications or contradictions.  Continuing with
the training example I just mentioned, we established an
initiative whereby development of all hazardous property-
related training courses is reviewed annually to preclude
unnecessary duplication.

     The "meat of the program," however, is in its Hazardous
Material Management Initiatives, or HMMIs.  Offices of Primary
and Collateral Interest (OPI/OCI) are assigned to each one.
Some of the HMMIs have joint action within DLA; that is, two or
more DLA Directorates are involved.

     The DLA OPIs have developed implementation plans for each
HMMI.  These implementation plans identify milestone actions
and target dates for completion of those actions.  At the
present time we have 90 HMMIs identified with a total of 254
separate milestone actions.

     The program is reviewed by the PSE representatives and is
briefed to the Director or Deputy Director on a periodic basis.
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                             LIFE  CYCLE OF DLA-MANAGED HAZARDOUS  MATERIALS
                                                             HI
                                        IV
                                                                                                  v
                                                                            VI
CO
                 DETERMINATION
                 OF REQUIREMENTS
DESIGN
                    ACQUISITION
                        SUPPLY
                       SYSTEMS
                      CONSUMER
                       USE (DLA)
                  • Planning
      DISPOSAL
i	1
> Engineering

 Research &
  Development
| Specifications

i Packaging
  Specifications

> Product
  Identification
• Solicitation

• Source
   Selection
• Contracting

• Quality
   Assurance

• Contract
   Administration
• Supply
   Management
• Depot
   Procedures
• Packaging &
   Transportation
• Space
   Management

• Quality Control


• Training
                                                  • Waste
                                                      Minimization
 • Program Policy

 • Receipt

 • Reutilization Transfer
    and Donation
 • Sales
                                                                                                               Ultimate
                                                                                                                Disposal Programs

                                                                                                               Special
                                                                           Safety &
                                                                           Health
                                                                                                               Facilities

-------
     As this is a "living-plan," new initiatives are introduced
as others are completed or revised.  Recent review of the
program increased the number of initiatives from 59 to the
current total of 90.  As the program embraces the life cycle
management of HM for DLA it has been incorporated intact into
the DLA Strategic Plan.  Due to the number of HMMIs, rather
than discuss each individual initiative, we will discuss their
overall objectives in each phase of the program.

     PHASE I - DETERMINATION OF REQUIREMENTS.  This phase is
not viewed as a DLA responsibility, but is seen in the context
of when the DoD component perceives the need for a product or
system.  However, we saw an opportunity to reduce hazardous
waste at the end of the life cycle of hazardous property by
minimizing the inclusion of hazardous materials at the front
end of the life cycle in the requirements planning process.
Thus, the Directorate of Contracting (DLA-P) has completed an
initiative to make a change to the DoD Supplement to the
Federal Acquisition Regulations (DFARs) to require planners to
minimize the inclusion of hazardous materials in their
requirements determinations.  A formal case was first presented
to the DAR Council in January 1988.  However, action was
deferred by the DAR Council for lack of formal DoD
environmental guidance to sanction change to the Acquisition
Regulations.  Upon publication of DoD Directive Number 4210.15
on Pollution Prevention, the case was resubmitted in September
1989 and has resulted in January 1990 coverage in the
Acquisition Regulations.  This will mandate DoD-wide
consideration of hazardous material minimization objectives for
all new major acquisition requirements at the front end of the
process.

     PHASE II - DESIGN.  In the design phase we have identified
ten initiatives that fall within the five subgroups shown on
the chart.

     Our Engineering initiatives consider minimization of
hazardous materials through revision of specifications,
materials substitution, specification evaluation criteria and
manufacturing processes.

     In Research and Developmentf we have an initiative to
coordinate with and influence the Military Services to minimize
the use of hazardous material in their systems as they are
designed and modified.

     In Specifications. we are incorporating hazardous property
requirements in training courses for preparation of acquisition
specifications.

     We have initiatives to improve Packaging Specifications to
prolong or eliminate shelf-life, and to revise preservation,
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packaging, packing and marking requirements to ensure adequate
protection during transportation and storage.

     Product Identification actions consider the application of
item reduction, interchangeability and substitutability
programs to reduce the number of hazardous items in the DoD
inventory and the number of items that become hazardous on
expiration of shelf-life.

     PHASE III - ACQUISITION.  In the acquisition phase we
identified five initiatives.

     We are reviewing Solicitations for procurement
specifications, material standards, and purchase description
criteria to ensure that shelf-life items have a minimum of 85
percent shelf-life at time of delivery.

     As an adjunct to the BAR Council case I mentioned a moment
ago, we have a joint action with OSD which seeks to introduce
Source Selection criteria into the acquisition regulatory
procedures which would favor suppliers who use hazardous
property minimization processes.

     In Contracting, the Defense General Supply Center in
Richmond, Virginia, is utilizing and evaluating the results of
a contract clause covering hazardous material inspection and
acceptance which allows contractors to be charged DLA costs to
correct or dispose of improperly contractor-packaged shipments.

     We have established a Quality Assurance initiative to
upgrade contract requirements as needed to include origin
inspection for shipments to Depots; review of sampling
procedures; judicious use of certificates of conformance; and
use of quality assurance letters of instruction.

     Contract Administration efforts are establishing specific
controls to ensure contract compliance for labeling, packaging
and quality assurance.

     PHASE IV - SUPPLY SYSTEMS.  There are currently 22 HMMIs
in the supply systems phase with eight new ones under
development.

     In Supply Management, actions include review of procedures
in the materials returns program to monitor  system abuse from
the return of unusable material and identify offenders back to
the Military Services.  An initiative addresses procedures to
minimize hazardous waste generations through central management
of hazardous materials.  The DLA suggestion program encourages
input from all levels of hazardous property  involvement by
making recommendations at regularly scheduled personnel
management surveys.
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     Depot Procedures call for review of procedures to expedite
processing of items in not-ready-for-issue condition.

     Under Packing and Transportation, procedures have been
established for correcting deficient or nonconforming packing.
This initiative provides for immediate repackaging by the
Depot, expedited follow-up actions by the Defense General
Supply Center (DGSC), Quality Assurance Representative (QAR),
Contracting Officer, and notification to the contractor.  Also
addressed is an initiative to assure that hazardous materials
are received from the manufacturer packaged in compliance with
contracting requirements.

     We are developing a list of preferred packagings and
containers for hazardous property managed or stored by DLA.  We
have developed a plan to implement the United Nations
Performance Oriented Packaging (effective date - January 1991).

     In Space Management,  we have reviewed and revised storage
systems for maximum space utilization (through adjustable
pallet racks, etc.), and identified a method for DSCs to
review, forecast, and adjust stockage levels to meet storage
segregation and facility requirements.

     In the area of Quality Control, we have established
procedures for Depot surveillance inspectors to monitor
specific hazardous material storage requirements (e.g.,
segregation protection).

     Under Training, we have standardized hazardous material
packaging training to appropriate Depot receiving personnel and
QARs.  We have implemented a mandatory hazardous materials
handling certification training program for Depot personnel.
We have reviewed the ongoing training programs and the
development of training to preclude unnecessary duplication of
DLA training efforts.

     In the area of Safety and Health, we are pursuing
resolution of problems related to the refinement of the
Hazardous Materials Information System (HMIS).  We have
developed initiatives to ensure implementation of the OSHA
Hazard Communication Standard as well as the implementation of
OSHA hazardous waste operations and emergency response
requirements.  We have also evaluated acquisition programs,
major facilities, and process changes to determine if system
safety applications were necessary.

     PHASE V - CONSUMER USE.  Consumer use in DLA is addressed
in our Waste Minimization programs.  Programs have been
established to provide Primary Level Field Activities  (PLFAs)
with direct assistance in the development and implementation of
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waste minimization programs to comply with the Resource
Conservation and Recovery Act  (RCRA).  This plan calls for
PLFAs to establish waste minimization committees, and provides
DoD Headquarters DLA technical assistance teams to visit field
activities to develop site specific waste minimization plans.
We are considering an additional HMMI regarding
decentralization of funding for hazardous waste disposal to the
field activity level.

     PHASE VI - DISPOSAL.  This brings us to the final phase -
Disposal.  To ensure that environmental safeguards are
incorporated into all phases of the disposal program, the phase
has been recently revised to include a total of 40 HMMIs that
address overall policy, receipt of hazardous property at our
disposal yards, screening and sales of hazardous property,
contracting for disposal, conforming storage facilities, and
special categories of hazardous materials, such as medical
items, precious metals, and ammunition boxes.

     Under Program Policy the CHAMMP has been incorporated into
the DLA Strategic Plan.  One of our key initiatives is to
incorporate the environmental leadership goals outlined by the
Deputy Assistant Secretary of Defense (Environment) last fall
as they pertain to hazardous property disposal.  These goals
include:  cultural change, compliance, people, organizational
structure, budgeting, training, communications and public
affairs, and regulatory climate.  Other initiatives concern the
revision of the Federal Property Management Regulation, the
Defense Utilization and Disposal Manual, and revision of
guidance on handling third party disposal sites.

     Receipt initiatives address training, storage
requirements, hazardous material identification and turn-in
requirements.

     Under Reutilization. Transfer and Donation, we have
initiatives to include liaison with state and federal agencies
to better identify hazardous materials offered for their
further use, review disposal program policy with GSA and
tightening controls on hazardous property issued to screening
customers.

     Under Sales,  emphasis is on efforts to ensure that
procedures for conducting national sales emphasize
environmental safeguards, including procedures to determine
whether prospective purchasers are environmentally responsive.
Our surveillance program, which has been used exclusively to
monitor our ultimate disposal contractors, has been expanded to
include hazardous materials and waste use and disposition by
our sales purchasers.   We also have an action to promote the
DoD recycling program.
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     In the area of our Ultimate Disposal contracting, we are
reviewing our contracts to ensure that they are written to
result in environmentally safe and legally compliant hazardous
waste disposal.

     Also, we are exploring alternatives for reducing contract
disposal costs through implementation of alternate disposal
procedures such as use of DoD facilities (IWTPs, incinerators),
on-site treatment by contractors (used oil, solvents, PCBs),
mobile incineration, and changes to contract specifications
(RCRA, non-RCRA).  We have provided for long-term contracts
(multiyear through use of options).  We are revising our
retrograde procedures in conjunction with OASD and CINCPAC in
order to facilitate the retrograde of PCBs in Japan.  In this
regard, we have an initiative to gain EPA approval to
retrograde U.S. owned foreign manufactured PCB items for
ultimate disposal action.  We have begun to perform liaison
with industry and the Military Services to discuss common
management efforts and initiatives, and to learn more of their
capabilities as well as provide information on DLA HMMIs.

     Under Special Programs. 2 HMMIs address environmental
consideration in the precious metals recovery program.  Federal
Supply Class 6505 medical items are receiving special attention
for DLA disposal mission assumption.  This does not include
infectious or pathological waste.

     Finally, our Facilities planning actions provide for
evaluation of alternatives to construction of conforming
storage facilities to include portable facilities, shared
facilities and continued 90-day hazardous waste removal.

     In Summary, the DLA plan has been presented to the Deputy
Assistant Secretary of Defense for Environment and accepted as
a landmark effort for life cycle hazardous materials management
and waste minimization.  It has been presented to the Military
Services at the Departmental level  and to other federal
agencies.  The recent revisions to  the initial program
increased the management initiatives from 59 to 90 with
additional actions under consideration;  and the program, in
total, has been incorporated into the DLA Strategic Plan.

     The development of the program has  been a challenging
process and has indeed been a "learning  exercise" for all who
have been involved.   It has provided opportunities for the key
DLA players to gain a better appreciation of the varied roles
that the PSEs play in the management of  DLA hazardous property,
the specific problems activities deal with,  as well as the
common problems we share.

                              END
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                  Testimony of


             SCOTT L. HOFFMAN, ESQ.
              Practice Coordinator
Environmental Facilities Finance and Development
        Nixon, Hargrave, Devans  & Doyle
                 Washington, DC

                     at the

        HEARING  ON  POLLUTION PREVENTION


                   before the

     United States House of Representatives
           Committee on Small Business
      Subcommittee on Environment and Labor
                 101st Congress
                  prepared with
             Michael H. Levin, Esq.
               Environmental  Group
        Nixon,  Hargrave, Devans  &  Doyle
             Tuesday,  August 1,  1989
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       ECONOMIC INCENTIVES FOR RECYCLING:  AN EXAMINATION OF U.S.
         ENVIRONMENTAL POLICY FOR FINANCING RECYCLING FACILITIES

              by:   Scott L.  Hoffman
                   Nixon, Hargrave, Devans & Doyle
                   Washington, D.C.
INTRODUCTION
    Flexible, cost-effective market mechanisms have been used
successfully in the past to address small or dispersed pollution
sources, activities or products which are not very amenable to
traditional rules and enforcement.  Market-based approaches to
environmental concerns must be used more widely in the future to manage
environmental problems,  successful use of economic incentives to
address recycling of used oils, which are currently dumped in trash
cans, sewers and back yards by tens of millions of consumers, can
provide a model for broader application to the nation's environmental
law framework in which economics reinforce environmentally-desirable
behavior to encourage and increase recycling of tires, batteries and
other components of the waste stream, without case-by-case government
intervention.

THE PROBLEM
    The nation's environmental policy has sometimes ignored the problem
of financing environmental facilities.  To ensure that environmental
facilities are developed and continue to operate, laws and regulations
must provide a reasonably predictable revenue stream to the operator to
satisfy financial institutions that loans received to construct the
facility will be repaid.  These financing considerations are_
particularly important where a major goal is to expand capacity to serve
an expanding market.

AN EXAMPLE
    One bill now before the U.S. House of Representatives is The
Consumer Products Recovery Act of 1989 (H.R. 2648).  H.R. 2648 would
increase operator's ability to finance and operate used oil recycling
facilities.  Under the Bill, operators would generate a double revenue
stream, from sale of credits as well as recycled product.  This revenue
stream provides a level of predictability that will help ensure that the
recycling project will support debt service.

CONCLUSION
    Incentive approaches are neither new nor radical.  Environmental
statutes have long relied on negative incentives to push people towards
compliance.  Moreover, there is a large body of implementation
experiences, at EPA, in Europe and elsewhere, on which Congress and EPA
can draw to assure that flexibility is accompanied by continued
environmental progress.  While it raises some implementation issues,
H.R. 2648 goes in the right direction.  It represents one good chance to
move from a static regulatory system to a dynamic one that continually
generates needed reductions in pollution and risk from within.
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INTRODUCTION

    Mr. Chairman and Members, I am honored to testify today on the use
of economic incentives, or more generally, market approaches, to address
the problem of used lubricating oil and encouraging
environmentally-sound recycling of this oil.  My remarks concern the
Consumer Products Recovery Act of 1989 (H.R. 2648), the principal
market-based vehicle before the Subcommittee today.

    Flexible, cost-effective market mechanisms have been used
successfully in the past to address small or dispersed pollution
sources, activities or products which are not very amenable to
traditional rules and enforcement.  Market-based approaches to
environmental concerns must be used more widely in the future to manage
environmental problems.  Successful use of economic incentives to
address recycling of used oils, which are currently dumped in trash
cans, sewers and back yards by tens of millions of consumers, can
provide a model for broader application to the nation's environmental
law framework in which economics reinforce environmentally-desirable
behavior to encourage and increase recycling of tires, batteries and
other components of the waste stream, without case-by-case government
intervention.

    I should make clear that I am testifying today as an independent
expert on use of economic incentives to address difficult environmental
issues, not on behalf of any particular client, agency or constituent
group.

    My qualifications to speak in that capacity include five years'
experience in development and financing of environmental facilities
throughout the United States.  These facilities include municipal solid
waste incineration facilities, recycling facilities, waste coal power
production facilities, waste tire power production facilities, landfill
methane gas power production facilities, and medical waste disposal
facilities,  I coordinate the Environmental Facilities Finance and
Development Practice of the Project Finance and Development Group at
Nixon, Hargrave, Devans & Doyle, a 250-attorney law firm with offices in
Washington, D.C. and throughout the country.

    This testimony was prepared with the assistance of my colleague,
Michael H. Levin.  Mr. Levin's qualifications include nine years'
experience, beginning in the Carter Administration, as founding director
of the Environmental Protection Agency's ("EPA") Regulatory Reform and
Regulatory Innovations Staffs, where he was responsible for
implementation of the air "bubble," emissions trading, and other
incentive approaches that cut regulatory costs and expanded compliance
options while maintaining or accelerating environmental progress.  The
idea of using a ticket or "credit" system to encourage used oil
recycling, and answers to many early implementation questions,
originated on those staffs during his tenure.  His qualifications also
include considerable experience over the last 15 months with
environmental permitting and the risks of financing compost,
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waste-to-energy, infectious waste and other environmental facilities.
He was actively involved in the recent Project 88 Report sponsored by
Senators Wirth and Heinz.  He currently chairs the Clean Air Working
Group's Project 88 Task Force, which is attempting to develop American
industry's umbrella positions on use of market approaches under the
Clean Air Act.

    I want to focus on two key topics:  why incentives are necessary and
how I think the Consumer Products Recovery Bill would work, with some
specific suggestions for improving and strengthening that proposal.


WHY ECONOMIC INCENTIVES?:  THE LIMITS OF TRADITIONAL REGULATION

    Market or incentive approaches are necessary not because they save
money (which they've been shown to do in large amounts), nor because
they reduce resistance and compliance delays (all of which they can),
but for environmental reasons.  Without them, this country can no longer
accomplish the environmental policies demanded by the People.  Like
intractable smog, stratospheric ozone depletion,  the general municipal
solid waste crisis, and greenhouse warming, the used oil problem
collides with the inherent limits of traditional regulation and cannot
be solved by centralized commands alone.

    What are these limits?

•   Poor agency information about further feasible ways to control the
    thousands of diverse products and activities that contribute most
    remaining pollution.

•   Limited government resources to throw at these problems in an age of
    budget austerity.

•   Soaring control costs, totalling perhaps as much as $150 billion per
    year now with no end to perceived crises or cleanup expenses in
    sight.  Cost may or may not be a consideration; but compliance is.
    No company or country can do everything at once; the smaller the
    sources or risks we seek to regulate, the higher the costs per unit
    of protection,  and the smaller the environmental returns.  As with
    Oreos or VCRs,  the higher the cost,  the less people are willing to
    buy.

•   Slow government responses to new knowledge or rapidly-changing
    circumstances through rules tailored to specific industrial
    processes or substances.  Such rules require massive data, take
    years to complete, and often freeze past control techniques, instead
    of stimulating new ones.

•   Few motives for regulated sources to do or disclose more than the
    minimum required, since such disclosure makes them targets for
    further regulation.
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    Third-generation problems caused either by bakeries, body shops and
    other small dispersed sources or activities, or by large sources
    whose further control threatens raging regional conflicts.
    Transcending these limits requires changes in lifestyles, behaviors
and local economies—results difficult to achieve with traditional rules
or enforcement.  Moreover, as the Prohibition Era taught, placing
intrusive, mandatory restrictions on ordinary citizens tends to erode
the compact on which social progress depends.  Only a shift towards
regulation plus incentives can deal with such problems by better
matching individual interests with environmental goals.  In short, we
must make it profitable for people and companies to reduce pollution, as
well as comply.

    That shift has been underway for more than a decade now at EPA,
which in response to diminishing returns of conventional regulation has
implemented or seriously explored use of incentives in over a dozen air,
water, pesticide and waste programs, which are summarized in the
attachments to this statement.  It is worth noting that the EPA's air
emissions trading policies are estimated to have saved the economy over
$5 billion in conventional compliance costs, from a relatively small
number of transactions.

    The EPA has steadily extended such approaches to new air pollution
sources, to fleetwide and interfleet trades for tailpipe compliance by
cars and trucks, to control of runoff from nonpoint sources, and to a
variety of other circumstances.  The EPA's stratospheric ozone program
relies entirely on market approaches.  Most significant for today's
hearing, the EPA's lead phasedown program cut lead in gasoline by 90%
within four years, while saving smaller refiners about $200 million
annually over the cost of refinery-by-refinery compliance, through a
credit system nearly identical to that in the Consumer Products Recovery
Act proposal.

    After exhaustive analyses, both the General Accounting Office and
the Conservation Foundation concluded that:   such incentive approaches
have saved up to 90% of the cost of conventional regulatory compliance,
without compromising environmental quality;  EPA has solved such critical
implementation issues as how to set fair "baselines" for measuring
credit, how to avoid "paper trades" and phony reductions, or how to
streamline procedures so these measures could be easily used; and market
approaches should be expanded, since their "notable benefits" (increased
flexibility, incentives for innovation, and easier enforcement, as well
as more rapid, inexpensive compliance) were only a sample of things to
come.

    If it follows his June 12 specifications and is enacted, the
President's Clean Air bill will accelerate this shift by legislatively
endorsing broad market approaches for control of acid rain and urban
smog—the first example of such explicit endorsement since Earth Day.
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THE TORRES BILL

    The Consumer Products Recovery Act of 1989, H.R. 2648, builds
directly on this experience.  When originally conceived as a regulatory
measure, the problem for resolution was how to increase recycling by
millions of dispersed do-it-yourselfers and service station operators
when the cost associated with the oil was already negative—people had
to pay to have it hauled away.  At the same time, the associated concern
was that hazardous waste regulation under the Resource Conservation and
Recovery Act would simply increase irresponsible dumping.

    The original answer was to link production and recycling, as well as
stabilize recycling markets, by requiring producers of virgin
lubricating oil to have a ticket showing, for example, that one barrel
must have been properly recycled for each four new barrels made.
Tickets could only be produced by recycling under appropriate management
standards; they could be freely traded or sold by recyclers to the
highest bidder; their value would be high enough to decrease the
disposal price for service stations and do-it-yourselfers, as recyclers
competed to collect used oil; and the overall cost of used oil recovery
would be minimized, since refiners would recycle, up to the point where
it was cheaper to buy tickets from others.  In short, market forces
would take care of the problem, except for government intervention to
make sure "recycling" was environmentally sound and that credits were
not sold to two buyers at the same time.

    H.R. 2648 represents a substantial and appropriately cautious
improvement over this initial concept, in part because it no longer runs
the dual risk of constraints on production of virgin oil or the
government printing tickets to make up any shortfall.  Instead it sets
mandatory, progressive recycling requirements for substantial producers
and importers of virgin lube basestock, based on their prior annual
production, and allows these requirements to be met by any combination
of self-recycling (e.g., direct rerefining), direct purchase of recycled
basestock, or credits generated by other rerefiners or reprocessors
producing specification, off-specification or hazardous-waste fuel
(where any contamination cannot be reduced to de minimus levels).

    The Bill continues to recognize that recycling is demand-pulled, not
supply-driven.  Mandated recycling is counterproductive if markets for
the recycled commodity are so thin, marginal or erratic that recyclables
return to sewers or landfills.

    Like EPA's stratospheric ozone rules, it maximizes administrability
and enforcement by applying recycling requirements to a relatively small
universe of less than 200 basestock producers and rerefiners, relying on
the pull of positive prices to draw used oil into the management system
from those farther down the chain.  Like the widely-hailed lead
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phasedown model, it creates a streamlined tracking system which both
assures proper recycling and lets recycling credits be easily traded,
based on normal business records.  It also reduces regulatory barriers
by providing automatic "permits by rule" to recycling facilities that
meet management standards, and for a self-executing plan by which EPA
may extend similar incentive approaches to encourage feasible recycling
of used newsprint, tires, batteries and other commodities.

FINANCING COMPLIANCE:  CREATING A LEGAL FRAMEWORK THAT ADDRESSES
FINANCING OF FACILITIES

    A significant aspect of the Bill is the attention given to financing
recycling facilities.  The nation's environmental policy has sometimes
ignored this important feature.  To ensure that environmental facilities
are developed and continue to operate, laws and regulations must provide
a reasonably predictable revenue stream to the operator to satisfy
financial institutions that loans received to construct the facility
will be repaid.  These financing considerations are particularly
important where a major goal is to expand capacity to serve an expanding
market, as described in the attached article on medical waste disposal.

    For example, when Congress responded to the energy crisis of the
1970's, it understood that new power production facilities could not be
developed without financing.  The Congressional response was the Public
Utility Regulatory Policy Act of 1978 ("PURPA").  PURPA requires
utilities to purchase the electricity produced by certain "qualifying
facilities" at the utility's avoided cost.  Because of this
Congressional requirement, developers of power facilities can apply for
construction loans based on a predictable, Congressionally-mandated,
revenue stream.  Thus, money received from the utility that is required
to buy the electricity serves as collateral for the loan.  The success
of new power facility development since PURPA's adoption is
well-documented.

    Similarly, H.R. 2648 would increase operators' ability to finance
and operate used oil recycling facilities.  Under the Bill, operators
would generate a double revenue stream, from sale of credits as well as
recycled product.  This revenue stream, although not as predictable as
the PURPA framework, nonetheless provides a level of predictability that
will help ensure that the recycling project will support debt service.

IMPLEMENTATION ISSUES

    No bill or rule is perfect.  Indeed, seeking perfection rather than
reasonable progress is usually counterproductive in the environmental
area, making the perfect the enemy of the good.  H.R. 2648 constitutes a
big step in the right direction.  But I want to point out some
implementation principles, drawn from experience with representing
financial institutions, and with incentives under other environmental
statutes, that could allow potential pitfalls to be easily fixed.
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Be predictable.  Because cash flow is critical to success and
incentive approaches ask people to change their behavior based on
money or investment decisions/ baselines for credit and the
procedures for generating it must be as clear and unambiguous as
possible.  The bill needs a definition section which clearly defines
such terms as "producer or importer" (including basestock),
"lubricating oils" (including grease and hydraulic or transmission
fluids), and "recycling" (making clear that oil recycling into
controlled burning for energy recovery creates valid credits).  It
also needs to address the "lag-time" issue—what past year's
production will be multiplied by the percent recycling requirement
to determine producers' present obligations and the size of the
current market, since the two cannot be simultaneous.  And what does
"begin to implement" in Section 3016(c) mean?

Use functional definitions and criteria.  Viewed broadly, the goal
is not recycling per se, but reducing the impact of used oil and
other discards on the environment.  Any approach which meets this
test should be eligible for credits, subject to management standards
sufficient to address the core environmental problem (not
hypothetical cases that are unlikely to materialize).  These
considerations are particularly important to avoid precluding new,
unforeseen recycling technologies, especially for commodities other
than used oil.  For used tires, e.g., any reading that precludes
controlled burning in waste-to-energy plants from meeting recycling
requirements or generating credits would destroy the market rather
than strengthen it.  Similar functional criteria should be included
to guide EPA in determining what additional commodities should be
subject to recycling schemes, what contaminating substances must be
tested for by recyclers (e.g., the smallest number consistent with
reasonable protection), and when a full RCRA permit may be required
(e.g., if, but only if, the Administrator determines such a permit
is necessary based on site-specific factors, with compliance with
management standards sufficient until a final Part B permit issues).

Balance speed and discretion.  Agency discretion is necessary and
laudable, but can also result in litigation and delay.  Since EPA
can establish a 40% recycling requirement simply by doing nothing,
there seems no reason not to establish a base year for annual
production through mandatory reporting and apply a presumptive
formula to years thereafter, with the burden shifted to producers to
show that a different annual production volume should apply.

Avoid perverse incentives.  For example, the presumption in §
3015(c)(2)(B) that a "small quantity" of used oil is not
contaminated could require small businesses or two-car families to
divide their used oil  into 5-gallon containers and deliver it
separately to collectors—a result that interferes with recycling
and makes little economic sense.
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•   Strengthen enforcement and credit trading.  As with lead phasedown/
    sales and purchases of recycled oil or credits should be promptly
    reported to a computerized EPA system that automatically flags
    discrepancies.  Data reported should include the sale price, so
    participants can make rational economic compliance decisions in a
    functioning market.  Also, while the bill promises "stiff penalties"
    for violations, it does not expressly deliver on that promise.  One
    way to do so is to impose noncompliance fees based on any recycling
    shortfall and the current price of oil sales or credits, in addition
    to normal RCRA enforcement.  Those fees could then be used to
    purchase credits from recyclers, creating both a secondary market to
    smooth transactions and a safety valve if recycling capacity does
    not keep pace with demand.

•   Address the role of the states.  States are only required to seek
    authorization if used oil should be regulated as a hazardous waste.
    Their role in other contexts, and how H.R. 2648 would mesh with
    current state or local recycling programs, should be, but is not,
    addressed.

CONCLUSIONS

    Incentive approaches are neither new nor radical.  Environmental
statutes have long relied on negative incentives to push people towards
compliance; the Torres bill would merely add positive incentives to pull
them there as well.  Moreover, there is a large body of implementation
experience, at EPA, in Europe and elsewhere, on which Congress and EPA
can draw to assure that flexibility is accompanied by continued
environmental progress.  While it raises some implementation issues,
H.R. 2648 goes in the right direction.  It represents one good chance to
move from a static regulatory system to a dynamic one that continually
generates needed reductions in pollution and risk from within.
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       SOCIETAL ECO-SUSTAINABILITY:  THEJDPPORTyNIJlES_AND
         BiSPONS IBILITIES FOR. COLLEGES AND  UN IVjEjRS IT.I ES

                  by:  Professor Donald Huisingh
                       Erasmus Universitiet
                       Erasmus Stud lecentruin Voor  Mi 1 ieukunde
                       Rotterdam,  The Netherlands
                         ABSTRACT

   If human societies are to become  increasingly  sensitive  to  the
imperatives for "Eco-Sustainabi1ity,"  faculty  and students  within
colleges and universities should become active  leaders  in helping
to bring about those changes. The moves in  society to shift the
emphasis from a basically reparative to a more  anticipatory and
preventative philosophy, within  government,  industry and society
at-large, will require substantially new modes  of thinking  and
teaching.  It will require new ways  of interacting with our local
and global eco-systems and with  each other.  If  this is  to be
accomplished, fundamental changes will have  to  be made  in many
facets of society, including the trend of dramatic  decreases in
support for education, at all levels. Additionally, the trend  in
research funding to support only short-term  projects that promise
to yield economic benefits in the market place  in two to five
years, must be reversed in favor of  longer  term support for
integrated research.

   Since the scientific information presently available is
inadequate for making the societal changes  essential to ensure
"Eco-Sustainabi1ity," increased  emphasis must be  given  to the
development of research and educational activities that will fill
those voids.  These activities should be interdisciplinary in
nature and be designed to provide cybernetic feedback to society
from the eco-systems upon which  we are all dependent.

   If this is to occur, governments, industries and society as  a
whole, must increasingly provide long-term support  for  research
and educational activities designed  to help  society prevent or  to
avert eco-disasters rather than  continuing  to react bo  crises
after they have occur.  "Crisis" management  must  be replaced with
"Eco-Sustainab i 1 i ty" management .  To accomplish thi<=> change in
approach, education must increasingly be regarded as the
essential investment in our future and not as has been  too  often
the case, as an expense.

   Course and curriculum changes will be essential within college
and university-level engineering, political  science, business,
law, journalism, economics  and  many other areas.  Eco-
sustainabi1ity considerations must be woven  into  the entire

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fabric of our  social,  political,  economic and industrial
decisions.   Educators  and  researchers will be increasingly
challenged  to  provide  the  essential  and unbiased leadership
essential for  the  transition to sustainable societies of
tomorrow.   In  addition to  helping to provide present and future
generations of young people with  the information and values
essential for  such  challenges,  continuing educational experiences
must be provided for the currently practicing engineers,
political leaders,  and for  industrial,  financial,  legal and media
specialists.   Also,  the general public  must be provided
information, in usable and  credible  forms to help  them make life-
style and investment choices that will  help make the transition.

   In regard to research,  the  issues of "ozone-layer thinning"
and "the greenhouse effect," underscore the urgency of the need
for substantial increases  in basic and  society-integrated eco-
sustainabi1ity research.   Industrial processes and products must
increasingly be assessed in comprehensive, life-cycle-impact
studies to  anticipate  and  to minimize the risks  to
sustainabi1ity.  Increasingly,  new products must be evaluated,
not from the "cradle-to-the grave phases," but more broadly, from
the "preconception-to-the  reincarnation phases."  Product
designers,  however, must be provided ecologically  sound
guidelines  for  the  assessment  of  future and present products and
processes.  Research is urgently  needed to provide these
guidelines  and evaluative  methods.

                           INTRODUCTION

   In 185^  Chief Seattle said,  "The  White Man's  appetite will
destroy the earth and  leave behind only a desert."   If he were
with us today, he would assuredly say,  "I told you so!1"  His
prophetic statements are becoming a  nightmarish  reality before
our eyes, as thousands of  hectares of tropical rain-forests are
stripped of their valuable  species for  the short-term gain of  the
sale of produce for a  few  years before  the soil  becomes incapable
of sustaining  even  subsistence  agriculture.

   While the desertification of the  tropics is occurring, and  the
erosion of  the productive capacities of many  of  the temperate
zones is also  accelerating,  the destruction of aquatic resources,
on a world-wide scale,   is expanding  at  an increasing1y rapid
rate.   Current human population growth  and consequent demands
upon the eco-system are increasingly ecologically,  UNSUSTAINABLE!
What is to  be  done  about these  trends?

   Recently, while visiting  a Dutch  company  near Amsterdam,  the
author observed the following  two questions above  the entrance to
the working area of the co nip any:
        a.   Are you here with the  solution7
                            or
        b.   Are you part of  the  problem?
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   Perhaps, these apt and sobering questions should  be  the
central questions for our conference here  in Washington.  Do we
have the solution(s)?  Or are we causing the problems by  ignoring
our educational needs  and our reluctance  to make  the necessary
changes in our priorities?  I hope our panel and others
throughout this conference will at least provide some methods for
developing the answers.

              ACTORS AND ACTIONS FOR SUSTAINABILITY

   The first issue of 1990, of INNOVATION,  is entitled,
"Educating Europe? Universities Today and  Tomorrow."1   This issue
contains seven articles devoted to the theme, "The Ethical
Premises and Consequences of Education," and five  articles
devoted to the theme? "The Practical Consequences  for the
Processes of Reform of European Educational Systems."   These
articles form a valuable contribution to the debate  of  the roles
of colleges and universities in the post "cold war"  era.

   Among the points made by the authors  is one made  by  Martin
Peterson of the University of Goteborg, of Sweden.   He  emphasizes
that ,
   "In September 1988, a manifestation of  mutual connection and
   unity among European universities took  place  in Bologna.  the
   900th anniversary of the University of  Bologna  served  as the
   convenient occasion.  It was at Bologna that  universalists
   such as Dante, Copernicus and Erasmus had received their
   education.  Hence the significance of Bologna for the
   rapprochement of European educational and research traditions
   and emancipation from a sense of inferiority  in relation to
   the USA and Japan.  Four hundred thirty-four university
   Principals from eastern and western Europe? signed a Magna
   Carta of the European universities containing a declaration of
   the fundamental principles and tasks of the universities.

   The 'principles state that universities  are everywhere
   autonomous institutions in the heart of societies, which
   otherwise may differ in construction due to geographical and
   historical conditions.  The university  investigates, evaluates
   and advances culture.  In the confrontation with  the
   surrounding world the university must be morally  and
   intellectually independent of all political,  ideological and
   economic power structures.  In order  to induce  the meeting
   with an excuse for not expecting too much one participant
   coined a phrase: "Autonomy was never easy, but  now  it  is very
   difficult."  This was underlined in an  almost facetious way by
   the ever present name of Fiat at the meeting, the car-industry
   being the sponsor of the anniversary celebrations.   So how
   much autonomy is there and what is it worth?"1-'

   Against this point, how can the universities  be,  as  one of the
other  authors suggested, "The Cultural I ntermed i ar ies? "::i>
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How can they be neutral cultural  intermediaries  when  cuts  in
state funds are forcing them to turn more and more  to  funds from
project oriented research, funded by industry or  government with
a very narrow time frame and content focus?  Is  that  the
direction to sustainable societies?

   In another recent publication, "TOWARDS AN ECOLOGICALLY
SUSTAINABLE ECONOMY,""* the organizers of the volume that resulted
from a two-day conference held in Stockholm, Sweden,  January  3  -
4, 1990, state, "The move in society to shift the emphasis from a
basically reparative to a more anticipatory and  preventative
philosophy raises issues about strategies concerning  decision
making in problem areas characterized by different  kinds of
uncertainty.  Such challenges cannot be met without a  development
of new indicator systems with regard to sustainabi1ity.  It also
calls for new forms of integration of ecological  information  into
the economic national long-term planning."  The  volume   includes
materials devoted to topics such  as:
   a.   Values
   b.   The interface between economy and ecology
   c.   Sustainabi1ity as a framework for national  environmental
        goals
   d.   National policy instruments
   e.   The international dimension

   The authors clearly indicate that colleges and universities
must increasingly be active in meeting the challenges  posed by
the sustainabi1ity issue.

   In a similar, but more narrowly focused vein,  the  issue no.  1
of ISWA TIMES,"5 published in early 1990, focuses  upon  the need
for educators to meet the shortage of trained professionals  in
the U. S. and elsewhere throughout the world.  An article by  Dr.
Diaz, of California Recovery Systems Inc, makes  the following
point, "The shortage of well-trained waste management
professionals in the U. S. A. is  serious, and the demand is being
met by those only marginally prepared to tackle  the complexities
of the problems."  	"Problems associated with the  management
of municipal solid waste have reached difficult  proportions
throughout the United States.  Despite the fact  that  they are
widely recognized, little or no attention has been  paid  to the
development of human resources to solve them."

   Because of the recognized shortage of university attention to
the development of adequate educational opportunities for
students of all ages, Ralph Kummler and his associates at Wayne
State University of Detroit, Michigan were recently provided  a
grant by the U. S. Dept of Health and Human Services  to  perform a
study of hazardous waste education and training  in  the United
States.  Their study documents university course  work  and degrees
as well as non-degree continuing  education short  courses.rt>
During the study, 1^69 four-year  degree granting  institutions
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were contacted.  Of the 732 institutions responding,  113  were
identified as offering course work of some  kind  in  hazardous
waste management. They found that the academic response for  the
provision of courses and the student response  to  participate in
such courses would not fulfill the growing  national  and
international needs.

   They emphasise that the estimates of the need  for
professionals from 1990 to 1995  just to meet existing  hazardous
waste clean-up needs in the LJ. S. are 22,500.  Further, they
state that the U. S. Dept. of Health and Human Services estimates
that 100.1000 environmental professionals will be  needed by  1992.
They suggest that the lack of trained professionals impedes  a
viable U. S. policy in hazardous waste management as much as
funding limitations.

   Two points to be made about this study,  are: a)  of  the <470
non-degree hazardous waste short courses offered, only 13
addressed issues pertaining to "Waste Minimization."   b)  of  the
three schools offering Masters Degrees in hazardous waste issues,
only two had courses devoted to  "waste minimization and
recyc1 ing."

   Additionally, with such a predominant focus upon hazardous
waste management and such a scarcity of attention being devoted
to the more comprehensive issues of waste minimization> pollution
prevention and "Product Life Cycle" approaches to prevention or
minimization of the generation of wastes in the first  place,  it
seems unlikely that the progress that some  companies have
experienced with pollution prevention and waste minimization,
will soon become the normative approach within the  U.  S.  and
elsewhere.

   To this author's knowledge, no similar,  comprehensive,
assessments have been performed, in other parts of  the world,  of
the needs for trained toxic and hazardous waste management
professionals and of the provision of courses  to  meet  these
needs.  However, based upon the needs within the  U.  S.,
certainly, the need worldwide must be in the millions. Millions
are needed .just to focus upon cleaning up the problems generated
in the past and to pay attention to controlling  those  being
produced today.

   If we wish to address the challenges to  move effectively  from
'crises' management to 'prevention' management,  throughout  the
world, the need and the urgency for major educational  and
research activities devoted to sustainabi1ity, becomes apparent.
Responses to this need are beginning to emerge within  colleges
and universities in a few countries.  However, much more  must  be»
done if society's needs for people educated in the  integrative
concepts of sustainabi1ity, are  to be provided.   If this  is  to
occur with the speed that is needed, major  funding  changes will
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 be  essential.   To  this end,  with the rapidly changing social-
 poll tical-mi1itary-ecological  situation of the world, it would
 appear  desirable and  timely  to consider the real location of 507.
 of  the  financial,  human and  material's resources,  currently
 devoted to  military activities,  to efforts designed to help
 ensure  "ECO-SUSTAINABILITY."  Many military personnel have highly
 developed skills that  could  be directly applied to the necessary
 environmental  work.   Others, being retired early from the armed
 forces,  could,  with some intensive retraining, be  effective in
 filling those  thousands of positions for environmental clean-up
 and  hazardous  waste management.

    Within the  next few years,  more fundamental real locations of
 resources and  refocussing  of societal  objectives must occur.  As
 a modest proposal,  since the very survival of societies is at
 stake,  it would  appear sensible  that if as little  as 50'/. of the
 world's resources,  currently utilized  for "DEFENSE AGAINST HUMAN
 INVADERS,"   were redirected  to "DEFENSE AGAINST MOLECULAR
 INVADERS,"  such  as CFC ' s ,  RGB's,  SO,., ' s , NO,., ' s , CO4a-excesses and
 others,  that conferences like  this one being  held  in 2020 would
 look back to  the 1990's as the turning point  in human history.

    Now  is the-  t. line? with the momentous changes that have occurred
 in  many nations  within the last  year still fresh in our memories?
 to  make bold new commitments.   I  propose that  1991  - 1995 should
 be  the  period  during which all  countries decide to initiate new>
 two-year training  programs for all  males and  females,  age 18 to
 20,  designed  to  help all to  become proficient, "soldiers," in the
 "ECO-SUSTAINABILITY DEFENSE  FORCES OF  PLANET  EARTH."  These
 programs should  be designed  to help  the youth, learn the basic
 skills  of eco-sustainabi1ity.  These programs  should include the
 basic skills essential  for monitoring  and correcting the toxic
 substance problems  that  are  threatening human survival.  Other,
 illustrative skills to  be  learned,  include habitat  restoration,
 contaminated site  clean-up,  eco-agriculture,  eco-aguaculture,
 eco-forestry,  including  reforestation  of mined and  otherwise
 denuded  landscapes.  All must  also learn the  basic  lessons of the
 need for the development and efficient  use of  renewable  energies.
 Lessons must also  be directed  to  the reformulation  of  the
 organization of  the infrastructure of  cities  such as Mexico City
 which,  according to a  recent report, currently has  as  many as 50*/»
 of  its  children  suffering  from various  forms of  lead related
 diseases.  Such  urban  centers  must be  redesigned to be attractive
 and healthful centers  for  human habitation or  the current
 civilization will become one more  in the series  of  civilizations
 that became extinct.

   As the youth, learn  these and other  basic eco-sustainabi1ity,
 skills  and put them into practice  while  working  within
 international teams throughout the world,  such work  will  help  to
 foster, within them, a deep  respect  for  the laws of nature and a
sense of purpose and unity with all  other  people.   Thereby,  many
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will increasingly learn that people of  all  colors and creeds can
and must work together to help ensure sustainable societies.

   After the youth have participated for  their  two-year  period
within the "Eco-Defense Forces," many may chose  to  enter the
universities to further develop  the skills  necessary to  becoming
the new engineers, politicians,  journalists, educators,  etc.,  of
tomorrow.

   Faculty and staff of many of  the colleges, universities and
technical institutes, could be involved  in  the  education of the
youth during their two years of  planetary service and in guiding
and challenging them as they continue their  subsequent studies.

   Erasmus Universiteit in Rotterdam, The Netherlands is among
those universities that is increasingly  reflecting  upon  its
responsibilities for developing  educational  and  research
opportunities in these areas.  Illustrative  of  this is the fact
that two new interdisciplinary courses will  be  taught, by the
author, during the fall semester of 1990.   These courses are
ent i 11ed:
   a.   "Cleaner- Production: Theory, Concepts and Practice"
   b.   "The Changing Context of Environmental  Management:
        Redefining the Roles of  Government"

   During the autumn of 1990, the author  will initiate an "Eco-
Sustainabi1ity Education," working group  within  the UNEP "Network
on Cleaner Production."  Anyone  wishing  to  become a participant
is invited to contact him at Erasmus Universiteit.

                          CLOSING NOTES

   The concept of Eco-sustainable societies  is  evolving.  With
this evolution, more and more attention  must be  addressed to the-
question, If we wish to help ensure sustainable  societies, what
changes must he made in the way  we interact  with  our eco-system7
While the answers to this question vary  widely  some tentative
formulations of principles have  been proffered  for  industrial
leaders and governmental authorities to  consider.  One such
formulation, THE VALDEZ PRINCIPLES is included  as appendix # I.
The author urges all to reflect  upon these  principles and
challenges everyone to work for  the implementation of these
principles throughout society.

   Of course, as with any new ideas, there  will  be those who will
say, "Yes that sounds good in principle,  but it  won't work in
practice."  Or "Let's think about that	later."  My
colleagues in the work psychology department of  the Danish
Technological Institute have assembled  a  list of 23, PROVEN AND
EFFECTIVE, 'NEW IDEA,' KILLERS.  They are included  for your non-
use in Appendix # B.
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                           REFERENCES

1. Jerschina, J. and Kinnear, R. Educating Europe? Universities
   Today and Tomorrow. Innovation Vol. 3, No  1.  1990.

2. Peterson? M. A Remodellinq of University Roles? Some
   tendencies in Sweden. Innovation  117, Vol.  3,  No  1.  1990.

3. Bovone, L. Cultural Intermediaries: A New  Role for
   Intellectuals in the Postmodern Age.  Innovation  61,  Vol.  35
   No. 1990.

4. Aniansson, B. and  Svedin, U. Towards an Ecologically
   Sustainable Economy, Swedish Council for Planning and
   Coordination of Research, Box 6710, S-113  85  Stockholm,
   Sweden, ISBN 91-86174-67-3.

5. Moller, J. ISWA TIMES, No. 1. 1990, Vester  Farimagsgade  29,
   DK-1606 Copenhagen V, Denmark.

6. Kummler, R. H., Witt, C. A., Powitz, R. W.  and Stern,  B.   A
   Comprehensive Survey of Graduate  Education and Training  in
   Hazardous Waste Management, JAPCA Journal,  32, Vol. 40,  No.
   January 1990.
   APPENDIX * 1

                      THE VALDEZ PRINCIPLES

   The Valdez Principles, developed by the Coalition  for
   Environmentally Responsible Economics  (CERES),  set standards
   for corporate environmental responsibility.

1. Protection of the Biosphere: We will minimize  the  release  of
   any pollutant that may cause environmental  damage  to  the air,
   water or earth. We will safeguard habitats  in  rivers?  lakes*
   wetlands, coastal zones  and oceans and will avoid
   contributing to the greenhouse effect, depletion of  the ozone
   layer, acid rain or smog.

2. Sustainable use of Natural resources: We will  make sustainable
   use of renewable natural resources such as  water soils and
   forests. We will conserve nonrenewable natural  resources
   through efficient use and careful planning. We  will  protect
   wildlife, habitat, open spaces and wilderness,  while
   preserving bio-diversity.

3. Reduction and Disposal of Waste: We will minimize  waste,
   especially hazardous waste, and whenever possible  recycle
   materials. We will dispose of all waste through safe  and
   responsible methods.
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t+.  Wise Use of Energy: We will use environmentally  safe  and
   sustainable energy sources to meet our needs. We will  invest
   in improved energy efficiency and conservation  in our
   operations. We will maximize the energy efficiency of  products
   we use or sell.

5.  Risk Reduction: We will minimize the environmental, health  and
   safety risks to our employees and the communities in  which  we
   operate by employing safe  technologies and  operating
   procedures and by being constantly prepared for  emergencies.

6.  Marketing of Safe Products and Services:  We will sell  products
   that minimize environmental impacts and are safe as consumers
   commonly use them. We will inform consumers of  the
   environmental impacts of our products or  services.

7.  Damage Compensation: We will take responsibility for  any  harm
   we cause to the environment by making every effort to  restore
   the environment and to compensate those persons who are
   adversely affected.

8.  Disclosure: We will disclose to our employees and to  the
   public, incidents relating to our operations  that cause
   environmental harm or pose health or safety hazards.  We will
   disclose potential environmental health or  safety hazards
   posed by our operations.

9.  Environmental Directors and Managers: At  least  one seat on  our
   Board of Directors will be designated for an  environmental
   advocate. We will commit management resources to implement
   these Principles, including the funding of  an office  of vice
   president for environmental affairs or an equivalent  executive
   position to monitor and report on our implementation  efforts.

 10.Assessment and Annual Audit: We will conduct  and make public
   an annual self-evaluation  of our progress in  implementing
   these principles and in complying with all  applicable laws  and
   regulations. We will work  towards the timely  creation of
   independent environmental  audit procedures  to which we will
   adhere.

   APPENDIX # S.
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         A FEW REASONS WHY WE CANNOT  TRY  THIS  NEW IDEA *

1. Don't forget that we must also  earn  money1. !

2. You will never be able to sell  this  idea  to the management.

3. Let's think more about that?  later.

4. I know it's not possible.

5. We are too small/big for that.

6. We have already tried that.    (We  haven't.)

7. That will he too expensive.

8. NJ2W.' i & r>ot the right time for  this  discussion.

9. That will mean more work.!!

10.We have always done it this way, so  why should we  change now?

11.You don't quite understand the  problem!

IS.Let's take it up again later.

13.In our branch it's different.

l^.Let somebody else try it first.

15.It doesn't fit into our long  term  planning.

16.Talk to Hans, this is not my  field.

17.We have already over-spent our  budget  for this year.

18.It won't work, and besides that, it's  against  our  policy.

19.We have no time for that.

20. 11 sounds fine in theory, but how  will it work in  practice?

21.We don't have enough employees  to  implement  that  idea!

22.We are not ready for this idea  yet.

23.It is too late to make changes  now.

   *    Proven and Effective 'New  Idea' Killers,  adapted from
   materials developed by the Work Psychology  Dept. of the  Danish
   Technological Institute in Taastrup,' Denmark.
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    THE LEGAL BASIS FOR WASTE AVOIDANCE  AND  WASTE
     UTILIZATION IN THE FEDERAL REPUBLIC OF GERMANY

                          Will A. Irwin*
The Federal Republic of Germany amended its Abfallgesetz (Waste Act)
in 1986,  Section la(l) of the Waste Act declares that "wastes shall be
avoided in accordance, with regulations based  on section 14(1), No.'s
3  and 4 and [section  14](2),  Sentence  3,  No.'s 2  through  5."
(Emphasis added.)  Section la(2) of the Act provides that wastes "are
to be utilized" in accordance with section 3(2), Sentence 3 of the Act
or to the extent prescribed in regulations promulgated under section
14(1),  No.'s 2 and 3  and  14(2),  Sentence 3, No.'s 2  through  4."
(Emphasis added.)  These provisions authorizing regulations for waste
avoidance and utilization are set forth below.
                         Waste Avok
Section 14(1) of the Waste Act authorizes the Federal Government, for
'the  avoidance  or reduction of harmful substances in wastes or for
their  environmentally compatible  management," to  provide in
regulations that
     "3. distributors of certain products are only allowed to put them
     on the market in connection with the offering of the possibility of
     returning them or the charging of a deposit on them," and

     "4. certain products may only be put on the market in a certain
     condition  or for  a certain  purpose that  ensures the proper
     management of their wastes or may not be put on the market if
     the management of their wastes cannot prevent the release of
     harmful substances or can only do so with unreasonably  high
     costs."
Section 14(2) provides  that the Federal Government  is  to establish
"goals to be met within appropriate time limits for the avoidance,
 *  A.B.,  J.D.,  The  University  of Michigan.   Secretary General,
 International Association for Clean Technology

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reduction,  or utilization of wastes from particular products" and to
publish these goals.  To the extent necessary for the avoidance or
reduction   of waste  quantities  or  their  management  in  an
environmentally  compatible manner,  especially to the  extent  this
cannot be  achieved by the  goals  established  in accordance with
Sentence 1  of section  14(2), Sentence 3 of that section authorizes the
Federal Government to provide in regulations that particular products,
especially packages and containers
    "2. may only be brought onto the market  in particular ways  that
    contribute noticeably to waste management,  especially  in a form
    that can be used more than once or that facilitates utilization,

    "3. must be taken back by  the manufacturer, distributor or third
    parties determined by them after use and  that the return be
    ensured by suitable receiving and deposit systems,

    "4. must be  transferred after use  in a particular way,  especially
    separated from other wastes,  in order to enable or facilitate their
    utilization or other environmentally compatible management, and
    "5. may only be brought on the market for particular purposes"
                         Waste Utilization

Section la(2)  of the Waste Act provides wastes are to be utilized  in
accordance with section 3(2), Sentence 3.   That sentence provides
that waste utilization has priority over other waste management if it is
technically possible, its  higher costs in  comparison to other forms  of
waste management are not unreasonable, and a market for exists for
the recovered materials or energy or can by created by hiring third
parties.  Section 14(1) No.  2, referred to in section la(2) concerning
regulations authorized for waste utilization  (but not in section la(l)
concerning those  for  waste avoidance), states that regulations  may
provide that  "wastes with particular contaminant contents  whose
proper  utilization or  other management requires special handling
must be kept, collected, transported, or treated separately from other
wastes," and that appropriate records of these efforts be kept.   Section
la(2) also  authorizes  regulations  for  waste  utilization under  section
14(1), No. 3 (but not 4), and section  14(2), No.'s 2-4 (but not  5), set
forth above under those authorized for waste avoidance.
Section la(l) of the Waste Act also states that it leaves undisturbed the
duty of operators of facilities that must obtain a permit in accordance
with the Bundesimmissionsschutzgesetz to avoid wastes by employing
low-waste  processes  or by utilizing residues,  (section 4  of the
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Bundesimmissionsschutzgesetz requires a permit for the construction
and  operation of a facility that, because of its  characteristics or its
operation,  is likely to  cause detrimental environmental effects or
otherwise  endanger  or significantly  disadvantage  or burden the
general  public or  the  neighborhood.   The Fourth  Regulation
Implementing  the  Bundesimmissionsschutzgesetz  specifies  the
facilities that must obtain permits if they may be expected to operate
for more than six months at the same location.)
Section 5(1) of the Bundesimmissionsschutzgesetz, last amended on
October 4, 1985,  requires  such facilities to  be constructed  and
operated so  that 1) detrimental environmental  effects  cannot be
caused, 2)  precautions are taken against such effects, and  3) "residues
are avoided unless they are regularly and  harmlessly utilized or, if their
avoidance or utilization  is not technically possible or is  unreasonable,
can be disposed of as wastes without impairment of the common good"
(Facilities that do not require a permit are to be operated  so that the
wastes they generate "can be  properly disposed of."  Section 22(1), No.
3.)       Although   "residues"   is   not   defined    in   the
Bundesimmissionsschutzgesetz,  it  includes  all substances whose
production by the facility was not intended.
In  October  1988,  draft administrative  rules  interpreting  and
implementing   section  5(1),   No.  3  were  approved  by  the
Laenderausschuss fuer Immissionsschutz. (Administrative rules are, in
general, binding on government  officials  responsible for implementing
legislation.)  These draft administrative  rules were  recommended to
the Laender as a basis for interpreting and applying the provisions of
the Bundesimmissionsschutzgesetz  discussed above  to the facilities
covered by that act and for the administrative procedures for doing so;
some Laender have adopted the administrative rules.
Similar purposes exist  for the document being developed under the
Waste Act --  the draft "TA-Sonderabfall" (Technical Instructions  -
Special Waste),  Part  1 — that interprets the provisions of the Waste
Act that waste utilization has priority over other waste management if
it is  "technically possible," its higher costs in comparison to  other
forms of waste  management are not  "unreasonable" and "a  market
exists"  for the recovered materials  or energy  or  can be created by
hiring third parties.  The TA-Sonderabfall also discusses permitting
and  enforcement  procedures,  e.g.,  the documents required  for
establishing the avoidance and utilization  of residues.

The  German  Federal Government plans  to issue administrative rules
for the avoidance and utilization of residues and special wastes that are
based  on the  provisions  of  both  the  Waste  Act  and  the
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Bundesimmissionsschutzgesetz.   These administrative  rules  would
apply to individual waste groups and would set forth the  current state
of the  art  of  avoidance  and  utilization,   criteria  of economic
reasonableness,  and ecological considerations.  The preparatory work
for these administrative rules is being done by Working Group 7 of the
"TA-Abfall (Technical Instructions - Waste)."  Priority is being given  to
waste groups with high reduction potential, e.g., aluminum salt slags;
organic solvents that  contain halogens; dye and painting residues;
galvanic  sludges; spent foundry sands; inorganic acids; halogen-free
organic solvent wastes; and oil emulsions. For each such waste group a
sub-group of Working Group 7 is convened made up of representatives
of business  and  industry,  universities,  and  federal  and  state
governments.
These administrative rules  are  being developed  by  the Federal
Government in Germany because  of its belief that economic markets
alone do not provide  adequate  incentive  for pollution prevention
measures.
Germany provides subsidies  to industry and research institutions  to
promote  research and  the demonstration of new technologies.  There
is also a government-industry commission to develop information  of
low-waste technologies for the use  of industries  that must comply with
the laws and officials that  must  enforce them.   A final factor that
encourages source reduction and recycling in Germany is the limited
capacity for treatment and disposal.
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                SEGREGATION FOR RECYCLE AND REUSE
                 OF  HAZARDOUS  CHEMICAL MATERIAL
                AT LOS ALAMOS NATIONAL LABORATORY

               PATRICK JOSEY
               LOS ALAMOS NATIONAL LABORATORY
               LOS ALAMOS, NEW MEXICO   87545
                     LA-UR-90-1116

1. INTRODUCTION

Los Alamos National Laboratory comprises 43 square miles in North
Central New Mexico.  The principal mission of the Laboratory is
the design and development of weapons for the nation's nuclear
arsenal; however, considerable research and development is
directed toward developing the peaceful uses of nuclear energy,
including research on controlled thermonuclear reactions, fission
reactors, nuclear safeguards, laser fusion, and medium energy
physics.  Extensive basic research programs in physics,
chemistry, metallurgy, mathematics and computers, earth sciences,
and electronics support these efforts.  Biomedical and
environmental research includes programs in molecular biology,
radiobiology, radio-ecology, and industrial hygiene.  Expansion
into nonnuclear areas is represented by applied technology
development of solar and geothermal energy and superconducting
power transmission lines.
2. POLICY

Pursuant to DOE Orders 5400.1, 5400.3 and 5820.2A, it is the
policy of the Department of Energy to conduct its operations in a
safe and environmentally sound manner.  Protection of the
environment and the public are responsibilities of paramount
concern and importance to the Department.  To this end, DOE is
firmly committed to assuring incorporation of national
environmental protection goals in the formulation and
implementation of Departmental programs.  Accordingly, all DOE
Contractors shall institute a waste reduction policy to reduce
the total amount of waste that is generated by DOE operating
facilities, including radioactive waste, hazardous waste and
mixed waste.

The Health, Safety and Environment Division, (HSE-DO) and Waste
Management Group (HSE-7) have the primary responsibility for the
management and minimization of waste.
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3. ECONOMICS
In addition to regulatory requirements, Los Alamos National
Laboratory recycles chemicals for economic reasons.  As the cost
of disposal (currently $5-50/lb.,  depending on material) rises it
becomes mandatory to reduce the amounts of materials in the
disposal stream.  Every pound of material that is recycled then
saves up to $50/lb. plus the cost of replacement materials that
may be required in the future.

The prioritization of materials that are chosen for recyclability
is based on the intrinsic value of the recycled materials.  For
this reason, recycling at the Laboratory is focused on precious
metals, strategic metals, and bulk organics.

The value of precious and strategic metals is high as well as the
cost of disposal these heavy metals and their oxidizer salts.
The environmental impact of heavy metals is also important to the
decision.

The Laboratory also uses a great deal of organic solvents.  The
use of these materials is being phased out by substitution, but
in the mean time recycling is used to minimize the amounts that
require disposal.

The economics of recycling becomes a matter of balancing the cost
of disposal versus nthe cost of recycling, the environmental
impact of disposal, and the limited financial and manpower
resources available for recycling.

4. WASTE STREAM TYPES

In calendar year 1988, the Laboratory purchased over 19,000
different laboratory chemicals.  Waste disposal records indicate
as much as 40% of disposals are over-purchased laboratory
chemicals.  The diversity of chemicals requires us to limit
recycling to various classes of compounds.

The Laboratory has few bulk, repeating waste streams.  The
organic solvents and machine coolants are the two waste streams
that are routinely recycled.  Scintillation fluids have been
replaced by non hazardous substitutes.

5. SPECIFIC CASES AND RESULTS
a)  Recirculating Laboratory Chemicals and Reagents
Chemicals that arrive at HSE-7 for disposal and are in reusable
condition are pulled out by the disposal technicians and are set
aside for redistribution.  A monthly list of available chemicals
will be circulated to user groups.  Users will be encouraged to
check the HSE-7 list before purchasing chemicals.

Certain chemicals of high value that are not recyclable by the
above method will be offered for sale outside the Laboratory,
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first through the Reportable Excess Automated Property System
(REAPS) and then by salvage through a limited end user system.
Initial efforts will be focused on toxic, heavy metals, strategic
metals, precious metals, industrial chemicals, and organic
solvents.  This salvage action is contingent on management and
legal approval, based on liability issues.

b)  Recovering Photographic Silver
the Laboratory has 70 photographic processing facilities.  Each
will be supplied with an electrolytic silver-recovery system for
their facilities.  This will eliminate disposing of silver-
bearing wastes and provide an economic return to the Laboratory.

This recovery process has started and 50 facilities use recovery
systems.  A large recovery unit will be put into the new
treatment facility for the recovery of the chemicals from the
remaining 20 operations and large slugs that can not be handled
by the existing units.

c)  Replacing and Recovering Halogenated Solvent
The Laboratory uses F-listed halogenated solvents in almost all
of its operations for degreasing, stripping, and cleaning.
Efforts have been started to find replacements for each of these
solvent operations on a system-by-system basis.  Each operation
is different and must be approached individually.  In some cases,
the use of a specific solvent is mandated by procedure, which
would require an administrative change.

The Laboratory is also researching the economics and technical
feasibility of distillation recovery of solvents to use in
operations where no adequate substitution can be found.

d)  Machine Coolants
All of the machine coolants in use at the Laboratory are being
recycled through redistillation.  The only new material used is
the replacement for material lost in still bottoms.

e)  Mercury

All elemental mercury is pulled out of the waste stream and
recycled through distillation.  It is them made available for
reuse through the waste management group.

f)  Lead
The amount of solid lead used for shielding material at the
Laboratory is high.  Currently, all lead is screened for
segregation by radioactivity.  Highly contaminated lead is sent
to the LANL Radioactive Storage Area.  Non contaminated lead is
sent to the salvage yard for reuse through the Idaho Lead Bank.
Slightly contaminated lead, 0-2 nanoCuries/gram, is reused as
shielding at the Meson Facility.

g)  Recycling Used Oil
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Pan Am World services recycles 200 to 600 gallons of used motor
oil per month for the Laboratory.  A licensed recycler refines
this motor oil into fuel oil.

h)  Recycling Paper
The Laboratory has an active paper recycling program for office
paper.  The initial goal of 50% recycled paper has been exceeded
an preliminary results in the first three months of 1990 indicate
a 75% recycle of white office paper.  White paper is recycled
from all other grades of paper by the generator at their desks.

6. FUTURE PLANS

a)  Chemical and Waste Tracking
Tracking of chemicals will be implemented to maintain better
information on the location and status of these materials.
Chemical and waste tracking within waste management will include
cost data for transportation, destruction, and disposal of waste;
a chemical tracking system enabling reuse or recycle of waste
materials, as well as matching user requests with surplus
chemicals marked for disposal; and access to the literature
reporting industry-wide technological changes resulting in
reduced waste.

This data base will contain:

     a. Cost information for treatment and disposal.  The data
base will contain cost information for the sampling, packing,
transporting, treating, and disposing of waste materials.  Costs
will be developed on a per unit-waste basis.  This information
will be used to inform the generator of the expense of waste
management and the savings realized through waste reduction.

     b. Waste materials inventory for Recycle/Reuse.
The data base will be used to record the location, quantity, and
characteristics of waste materials throughout LANL.  This
information will be circulated among user groups who may have a
need for the waste materials, thus recycling or reusing the waste
whenever possible.

b)  Bar-Coding
The Laboratory is developing procedures to initiate a bar-coding
system for tracking the thousands of different chemicals that are
purchased each year.  This bar-coding system will be tied into
the waste tracking system.  Bar-coding will give WGI a handle on
material flow that will provide information on purchasing trends
and over-purchases, and the ultimate fate of laboratory
chemicals.

This effort will be tied in with the data base that tracks
purchased materials and reoccurring waste streams.

c)  Recycling D38
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The Laboratory is currently negotiating with Grants Metals Inc.
to process the 1500 gallons a year of depleted uranium chips and
turnings that the Laboratory generates.  GMI has the patent on
modifying the Ames process that recycles depleted uranium with
virtually no environmental impact.  The D38 is then put back onto
the open market for reuse.

d)  Treating Chromium Wastes
To reduce toxicity, the Laboratory is will begin treating
chromium plating wastes by reducing Cr+6 to Cr+3.  Analysis is
being done on the feasibility of further reducing to Cr°.  This
would greatly reduce the liquid waste that must be disposed of
and puts the chromium in a form that would not be readily
available to the environment.

e)  Copper Stripping Solutions Recovery
The Laboratory uses an ammonia-based solution for stripping
copper in printed circuit-board manufacturing processes.  This
process produces a corrosive waste that must be neutralized.

Administrative procedural changes will require that copper be
electrolytically removed from the Cu-saturated solution, greatly
extending the useful life of the stripping solution.
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                       WASTE MINIMIZATION STRATEGY
                  FLEXIBLE  POLYURETHANE  FOAM  MANUFACTURE

                by:   C.M.  Kaufman and M.R. Overcash
                     EPA Research Center For Waste Minimization
                         And Management
                     North Carolina  State University
                     Raleigh, North  Carolina 27695-7905
                               INTRODUCTION

     Since the discovery of the dlisocyanate polyaddition process by German
chemist Otto  Bayer  in  1937i  polyurethane  chemistry  has  matured  into  a
sophisticated industry with applications in numerous industries. By  1985>
world manufacturing capacity for polyurethane foams had reached nearly five
million metric tons located primarily in North  America  and  Western Europe.
In the 1960's to increase penetration into furniture component  and bedding
markets (displacement of  latexes), polyurethane  foam density was reduced (to
increase  softness)  by  the  addition of  auxiliary blowing  agents  to  the
formulations.  The  primary blowing  process  involves  the  reaction  of  an
isocyanate with water to produce gaseous carbon dioxide which  expands  the
foam network.  The auxiliary foaming process involves no chemical reactions,
but is merely a change of state of  the  auxiliary  blowing agent  (methylene
chloride  or chlorofluorocarbon).  Volatilization  of  the auxiliary blowing
agent from liquid  to gas coincides  with the primary evolution  of C02  and
urethane polymerization to provide a significant Increase in the number and
size of foam cells. The  increase in cell size and number produces the  low
density   desired    for   specific   foam   end    uses.    Historically,
chlorofluorocarbons  (primarily  CFC-11)  were   utilized  to  decrease   foam
density due  to  the  low  boiling  points, thermal  conductivity, relative
insolubility, and chemical stability. In the past two decades,  CFC's have
been  linked   to global  warming  and  depletion  of  stratospheric  ozone;
consequently, many  foam  manufacturers have substituted methylene chloride
as the auxiliary blowing  agent. In addition to meeting market specifications
for cushion softness and  indentation, low density foams significantly impact
profit margins  by decreasing  the amount of toluene dilsocyanate (the most
commonly  used  isocyanate)  required  In formulations  and   the  amount  of
chemicals per cubic foot of product.

     Global   restrictions    on   the   manufacture   and    emission   of
chlorofluorocarbons  are  rapidly  propagating.  As  these  regulations  are
enacted,  the supply of current CFCs will tighten and the prices of CFCs are
expected  to  dramatically increase.  Additionally,  air toxics  legislation
within various  states may severely  limit emissions of  methylene chloride,
a suspected carcinogen.  Options  available to foam manufacturers which  limit
air  emissions  while  maintaining  worker   safety,   product  quality  and
profitability Include:

 -  Eliminate the use of auxiliary  blowing  agents and only  produce  water
    (C02)  blown  foams. Several questions  arise concerning  the capability to
    make a wide range of low  density foams. This limit  directly  affects
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   corporate marketing potentials. Additionally!  the  negative  cost  impacts
   (higher raw material costs) to small and medium manufacturers would be
   significant.
 - Substitute  materials  (such  as  HCFCs  which  supposedly   have lower
   ozone-depletion  and global warming  potentials)  as  auxiliary  blowing
   agents. Near  and long-term production capabilities of these materials
   along with consequent foam properties  are mostly  unknown.  In addition,
   manufacturing  plants  will probably be under  pressure to minimize any
   organic emissions.
 - Utilize new  chemical systems  to eliminate auxiliary blowing  agents.
   These new  systems require modifications  to  existing formulations and
   even  some  of  the recent  innovations  that  have  been  commercially
   introduced do  not  appear  to be viable  for low density foams.
 - Invest  in   latest-generation  enclosed  machinery   for  batch  foam
   processing.  Although this  option directly  addresses  air emissions,
   return  on  capital and production  capabilities  are very questionable.
   Control of product  quality and consistency is generally  more difficult
   in  batch processes.
 - Recover/recycle  auxiliary  blowing agents  by  modifying  the   current
   continuous process. Benefits  include the maintenance of current chemical
   formulations*  product qualities)  worker safety, productivity, and profit
   margins.  Recycling of  auxiliary  blowing  agents  would  also  offer  a
   potential cost savings by reducing material costs.

     The recovery of an auxiliary  blowing  agent is  a  complex Issue  coupled
directly with another  manufacturing  requirement)  the maintenance  of safe
plant working conditions in the presence of small quantities of  isocyanates.
Worker  safety is presently maintained with  adequate air flow to  keep  ambient
isocyanate  concentrations at acceptable limits (the maximum allowable indoor
air  concentration of TDI  is 0.02  ppm).  This air flow also lowers the
auxiliary  blowing  agent  concentrations   to   a  range  where  recovery
technologies  are not economically feasible.  Research  objectives were to:

 - quantify the dynamics of  blowing  agent  loss in laboratory prepared foams
   using representative  formulations>
 - validate laboratory experimentation with analogous plant data,  and
 - examine  innovative  means to  maintain  safe  worker  conditions while
   simultaneously recovering the auxiliary blowing agent and minimizing air
   emissions.

Basic Information on organic volatilization and concentration, recovery, and
recycle of fugitive emissions is transferable to  other chemical  process
industries.

                         EXPERIMENTAL OBJECTIVES

     Prior   experimentation  has   primarily   dealt  with the   mechanistic
chemistry applied to  product development. Additionally)  DuPont  (1), other
suppliers  of  halogenated  hydrocarbons)   and  Unifoam  (2)> an equipment
manufactureri  performed  investigations on the  emission of  volatiles from
polyurethane  foams.  Union Carbide (3), also  a supplier of raw  materials to
the  industry! conducted  an  elegant  study on the  sequence  of events and
kinetics  of   the   most  important  reactions  in  the   foaming  process.
Experimentation  in  the current  study was focused on  developing   a basic
quantitative  understanding   of  the  various  processes  involved   in  the
manufacturing operation (specifically events occurring within  the  foaming
tunneli curing)  and storage areas).  Previously,  these sequences were
                                   352

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understood only  qualitatively making  the  possibility  of  cost-effective
recovery very low as evidenced by three  decades of little change.  The steady
state plant  process  was successfully  simulated  using  a laboratory  batch
preparation commonly utilized by the Industry.  The  events  which  take place
as   the  foam   travels  down   the   tunnel   are    represented   In   the
laboratory-produced  foam  as  a  travel  time.  While  the  smaller  scale
introduces some limitations,  It  Is apparent that similar events occurred In
the  plant situations   and  the  essential   processes  were  unchanged.   To
concentrate the research effort,  only one type of auxiliary blowing agent,
methylene chloride, was Investigated  over  a range  of foams.  The  specific
objectives of the several experimental studies were as follows:

 -  Quantification  of the  rates  of  mass (volatlles) loss  for a  range  of
    foams In  an open system.
 -  Collection of volatlles In a  closed system with determination  of CH2C12
    and  CO, In various  stages of the process (collection  times  related  to
    times In  and out of  the foaming  tunnel).
 -  Determination  of the effect of vacuum application on  the  rate of mass
    loss In the curing  and  storage areas.
 -  Generation of Interior  foam temperature profiles throughout the process
    as a function of time.
 -  Collection of mass  loss  data at  three  foam manufacturing  plants  for
    comparison to  and validation of  laboratory data.


                          MASS LOSS  EXPERIMENTS

     A  formulation (courtesy of Hickory Springs Manufacturing Company)  for
a typical polyurethane foam applicable for furniture components was utilized
for laboratory experiments. This formulation yields  a product with a density
of  1.0-1.2 Ib/cu ft  with  an indentation load  deflection  (foam  resilience
or  firmness)  of 21  Ib.  (the  force required  to  compress  a  V  thick slab to
3").  Additional formulations  were  utilized  which varied  the  amount  of
methylene chloride  to  investigate  the effects of  changes  In  the  ratio of
primary to auxiliary blowing agents.

Laboratory  foams  were  prepared using  conventional techniques  developed
within  the polyurethane industry. All formulation ingredients were weighed
in tared beakers or syringes  and added to a tared  vessel; timing was started
with  the addition  of toluene diisocyanate. After  stirring  (using a tared
mechanical stirrer) the chemical mixture for approximately 12 seconds,  the
foaming liquid was  rapidly  transferred to  a  tared polyethylene (0.002"
thickness) lined cardboard cakebox (12" x 12" x 6")  sitting on an electronic
balance. Pouring a completely mixed and foaming mixture onto a solid surface
(cardboard)  can be  likened  to the  plant situation where a mixing head
discharges onto a  flat  conveyor  system.  Typically, balance readings would
stabilize at t-0.5  minutes  and mass readings would be collected periodically
for  Ik  hours.  The  stirrer  and mixing vessel were also  weighed at  24 hours
(when  all volatiles have  been lost)  to account  for  transfer losses  by
back-calculation.  Experimentation covered  a series of  foams prepared with
a range of auxiliary (methylene chloride) to primary (water) blowing agent
concentrations  (0:1, 1:1,  3:1,  4:1).  Average mass  loss  data are presented
in  Figure 1.  The laboratory data are characterized  by an initial rapid loss
of  approximately 60-70* of  the  available volatiles  in  10  minutes;  the
residual volatiles are  then slowly lost over 24 hours. These two regimes of
mass loss are logarithmically proportional to the elapsed time and represent
a complex mechanism of  volatilization. Simplistically, the first regime of
                                     353

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100%

B0%

60%
  % QAS LOST
                       lOASUUT
100*

10%
             TIME (nln>
        -Oil
            CH2CI2: H20
            -*- M  -*- ai
  Figure 1 - Normalized Mass
         Loss Profiles
                                   mass loss  is hypothesized  to relate to
                                   the  kinetically  fast reaction  between
                                   the  diisocyanate  and water  generating
                                   C02 and heat. The  heat  generated by the
                                   competing   reactions   increases   the
                                   temperature of the foaming mass and the
                                   liberation of  CH2C12 is  initiated.  The
                                   rapid loss of volatiles occurs from the
                                   surface   of    the   rapidly   expanding
                                   multiphase  foam  and  from  the  block
                                   interior  as  the  foam  becomes  an  open
                                   cell  structure (blow-off  point).  The
                                   second regime of mass loss appears to be
                                   a slow diffusion of volatiles through a
                                   open  cell foam  mass  as  crosslinking
                                   reactions  continue.  As  the  amount  of
                                   methylene  chloride  is  increased in the
                                   formulation (at constant water content),
                                   the mass  loss  rates  increase.  When the
                                   data  are  normalized  on  a   percent  of
                                   total volatiles lost, the time dependent
                                   mass loss rates and  total mass loss over
                                   the first  10 minutes for  1:1,  3:1,  and
                                   4:1 formulations appear  independent of
the amount of auxiliary blowing agent present in the  formulation.  After 10
minutes, the normalized 3:1 and 4:1 data continue  to  coincide. Conversely,
the mass loss rate for the 1:1 formulation  noticeably slows after 10 minutes
and looks similar in shape to the analogous water-blown  (0:1) foam data. The
reason  for  this  behavior is unknown  but  may relate  to a density  effect.
These observations support a rapid chemical  rate  of  formation and  loss of
C02 followed by a temperature and diffusion dependent  loss  rate  of  CH Cl .

                COLLECTION OF VOLATILES IN A CLOSED  SYSTEM

     To  further understand the loss of volatiles from soft polyurethane foam
and develop potential strategies for recovery/reuse of the auxiliary blowing
agent, a successive batch collection  of both carbon  dioxide  and methylene
chloride  was  developed  (4).   Methylene   chloride   was   gravimetrically
determined by  condensation in  a  tared alcohol/solid  CO cold  trap.  Carbon
dioxide was  adsorbed onto  solid ascarite (primarily NaOH)  forming sodium
bicarbonate  and  water;  C02 evolution  equaled the  increase in mass  of  the
ascarite scrubber and an anhydrous CaS04  trap (for HO).

    A polyethylene lined cakebox  was fitted with two inlet  and outlet tubes
located about  50 mm  from the bottom and positioned within a wire  cage to
support the air inlets,  gas outlets,  and an ingredients loading  tube.  This
entire assembly  was  placed  within a sealed  (airtight) large  plastic  bag.
Foam preparation was carried out  in  the usual manner;  after  stirring,  the
foaming liquid was poured through the  filling tube which was  quickly closed
with a screw cap. A  vacuum pump connected  to the end  of the  first  absorber
train was  started  and  gas  collection was  initiated  for  the  first  time
period.  At 10 minutes, the gas outlets were switched to a different  absorber
train for collection of volatiles for the second time frame.  Each  absorption
train consisted of  four cold traps in series (for  collection  of  CH.C1 )  and
one packed ascarite  absorber with two drierite tubes (for collection of CO
as NaHCO., and H20).  Particular  care was exercised when the absorbers  were
disconnected  for gravimetric  determinations;  tared  drying  tubes  were
connected to each sub-assembly  to prevent entry of  atmospheric water vapor.
Average volatile collection  data for 1:1,  3:1, and  4:1 formulations  are
graphically displayed in Figure 2. Independent of formulation, the ratio of
methylene chloride  collected to carbon dioxide collected increases as a
                                   354

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function  of time.  When  the data  are
normalized for  percent of volatiles, the
data are consistent with the normalized
weight loss profiles. These observations
support  a  rapid  consumption of  water
(generation of  CO,) and a  time  delayed
evolution  of   methylene  chloride  from
polyurethane foams. For  the less dense
foam  formulations  (3:1  and  4:1),  the
greatest   amounts  of  the  available
methylene chloride were recovered in the
first ten minutes; however,  the relative
concentrations  of  methylene  chloride
were   found  to  be  greater  in   the
subsequent  twenty minutes.

In   an   attempt    to   get   a   better
understanding  of  the loss  profile for
auxiliary   blowing     agents    from
polyurethane foams, normalized mass loss
data for water blown foams with  only CO,
evolution  were graphically  subtracted
from normalized mass  loss data  for the

lower  density  foams that  evolved  both
C02    and    CH2C1,    (3:1    and    4:1
formulations).  The  higher  methylene
chloride  content  (lower  density) foams
have    the   greatest   potential   for
recovery/   reuse  strategies.   These
extrapolated   data  are   presented   in
Figure 3.  Calculated  CHC1 :C02 ratios
increase  as a  function of  time and thus
exhibit   the   same  patterns  (but   of
greater  magnitudes)  observed  for  the
closed system data  described  above.
Since  these data  are calculated  from
averages    of   separate    experiments,
caution    must    be     exercised     in
interpreting actual magnitudes. However,
the  observable '  trends are  consistent
with   the  reaction kinetics;  i.e.,   a
rapid  loss of  CO, and  a  time displaced
loss   of   CH2C12.   Calculated CH2C12:C02
                                           flCHZCIZigCO!
g CH2CIZ i g COS
                                                   CH2CI2: H20 FORMULATIONS
                                                      TINE INTERVALS
                                                   lo-tomin
                                        Figure 2 - Collection of  Volatiles
                                          100%

                                          90*
                                          eo%
                                          ro%
                                           BO%-
                                            % GAS IOSS
                                                                 ftQASLOSS
       100%

       90%
                                                                       20%

                                                                       10%

                                                                       0%
                                           Figure  3  -  Calculated  CH2C12 and
                                                  C02  Loss  Profiles
ratios from the  data  yields  values for
the 0-10 minute interval of 0.77 (3:1)
and  1.06  (4:1)   which   compare  very
favorably with  the  data displayed  in
Figure 2. The  calculated 3:1 and  4:1  data coalesce when  normalized on a
percent of CH2C12  lost. Approximately 40* of the auxiliary blowing agent  is
left in the foam bun  as  it exits the  tunnel.  As the foam proceeds through
the plant, the concentration of CH2C12  relative to C02 is  enriched.  These
data  emphasize the  two  phase  nature  of volatile  loss and  are critical
Information in understanding  the time (plant location) dependent loss  of the
auxiliary blowing  agent. Only by understanding the magnitude and rates  of
loss can appropriate  recovery technologies  be  selected.
                                      355

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                      EFFECT OF VACUUM ON MASS LOSS
          Recognizing  the two regimes of mass loss from polyurethane  foams,
exploratory tests were  conducted  to  determine whether the application  of
vacuum to a freshly set  foam  would  accelerate the rate of volatile  loss.
These experiments address  the  slow  diffusion of volatiles (primarily  the
auxiliary blowing agent) within the manufacturing curing and storage  areas.

Foam was prepared using  the standard formulation at one-third  of  the  normal
batch weights  (for a cakebox to fit in the available vacuum oven). Mass loss
data were collected  for  foams  in an open system (0 - 30 minutes).  Analogous
data were recorded for  foams  that were started in an open system (0  -  10
minutes) and then placed in a vacuum oven at  ambient  temperature  (10  -  30
minutes). These collection times  correspond  to an average  tunnel residence
time of 10 minutes and an arbitrary post-tunnel interval of twenty minutes.
The data demonstrate a significant effect  ofvacuum application on the rate
of  diffusive  losses  from  polyurethane foams. The  application  of  vacuum
increased the rate of volatile loss from set  laboratory foams by  at  least
three-fold. Additional experimentation  needs to be conducted to quantify the
degree of vacuum, optimum temperature,  and  actual time required  to collect
the  residual  volatiles  from  a   foam  block.  The feasibility  of  vacuum
utilization coupled with entrapment by condensation within the  manufacturing
environment is unknown.

                  INTERNAL FOAM TEMPERATURE  MEASUREMENTS

     Reactions of the isocyanate with water, polyol,  and urethanes are all
highly exothermic. Internal foam temperature measurements  were recorded to
establish  the  rate   of  heat  generation  in  this  system.  Cross-linking
reactions during the curing period are also be affected by the way generated
heat is conserved in the system or lost to the environment. Measurements of
the time dependent temperature profiles at various spatial locations  within
insulated  and uninsulated foams  were used  to  determine  the  effects  of
convective and conductive heat losses  (4).
   TEMPff)
                          TEMP (F)
                               ro
               TIME IllW
             FOAM LOCATION

        •*• BOTTOM -*-WWM.e
-TOP
     Figure A - Interior Foam
           Temperatures
Six    calibrated    copper-constant
thermocouples  were   supported  on   a
laboratory stand  and located in an empty
mold box  to  correspond to the  desired
points of  measurement. The foam mold was
placed inside a larger box.  Polyurethane
foam was tightly  packed in  the 2-3 inch
spaces  (sides  and bottom)  between  the
foam  mold  and   the   larger   box  for
insulation. Three different levels  and
three different locations were measured
in insulated and  uninsulated molds (not
all  levels   and  all   locations   were
determined    for    each    insulation
condition). The three levels were chosen
at 0.5"i 2.5", and A.5" from  the bottom
of the  foam  mold (foam height  at  full
rise was  approximately 6");   the  three
locations  were  0.5"   from  a  side,  a
corneri and the  center  of  the mold.  To
Improve   reliability!   readings   were
carried out in duplicate runs. The six
                                     356

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thermocouples were connected to a  Leeds and Northrup Speedomax H Multipoint
recorder which was equipped with an internal temperature compensator and a
200 °F  - 2200 °F  range  card.  Foam  was  produced  in the  standard fashion and
poured  into the  mold  box  with  thermocouples  appropriately  positioned.
Special  care was taken  not to pour  the foam onto the  thermocouples  or
disturb  the thermocouple positions.  After  completion  of each  test,  the
thermocouples were carefully cleaned to prevent set foam (insulating) from
interfering  in subsequent runs.
   TEMPtF)
                          HL08T
                              100%

                              got
                              tot
                              Foam temperature data  are graphically
                              displayed    in   Figure    A.   Interior
                              laboratory  foam  temperature  rises  at
                              approximately a  linear rate (versus log
                              time)  and  reaches  a  maximum of  150  °F
                              after   about   15   minutes   and  then
                              gradually    decreases.    Therefore,
                              temperature continues to rise well after
                              the  blow  off  point  (opening  of cell
                              structures    and   maximum   loss   of
                              volatlles).  This   observation   implies
                              that the cooling effect associated with
                              gas  evolution   may not   significantly
                              contribute to the heat loss of the total
                              system.  To more fully  understand this
                              effect,    a    series   of    controlled
                              thermodynamic experiments  would  have to
                              be conducted.For uninsulated  laboratory
                              foams,  the  initial  temperature rise
                              appears  independent  of   the vertical
                              position  within the  mold.  However,  as
                              the  reactions progress, the temperature
                              at the  mold  bottom reaches the  highest
                              maxima. This observation Indicates that
conduction through  the  foam  bottom  surface  is   not a  major  factor;
              TIME (rain)
      -A- TEMP  -B-C02  -0-CH2CI2 Oil Md 4:11
 Figure 5 - Foam Temperatures and
        Mass Loss Profiles
heat
therefore, mass transfer through the foam top surface is a major mechanism
of heat loss from the system. Internal foam temperatures are plotted along
with the mass loss profile  (Figure 5). A loss of CH2C12 at temperatures lower
than its boiling point (104 °F)  Is apparent. This phenomenon was unexpected
and may relate to the fact  that  the CH,C12  loss data were calculated and not
directly measured.  If  the  loss  of CH Cl2 at  temperatures below the boiling
point is real,  it conceivably might  fee explained by  the thermal gradients
present within the foam and that there  is  a net flow of gas (CO,) out of the
system which could  sweep CH2C12  in the  vapor  phase out of  the  foam.

                COLLECTION OF MANUFACTURING MASS LOSS DATA

     Data  were  collected  at  three  polyurethane manufacturing  plants  for
comparison to and validation of laboratory  experiments.  Two of the plants
(Hickory Springs and Leggett  and Platt) utilize methylene chloride while the
third plant (Olympic Products) utilizes trichlorofluoromethane (CFC-11) as
the  auxiliary  blowing  agent.   Samples of  production  foam  were  cut  and
suspended; periodic  mass loss data on  each  bun  were  obtained using a load
cell. Initial bun weight (i.e.,  sum of input material weights) and initial
bun volatlles were calculated. Mass  loss data for the six manufactured foam
samples  are  displayed  in  Figure 6.  The  plant  data percent  weight  loss
profiles and rate curves (not displayed)  have the same general shape
                                    357

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      100%
       80* -
         % GAS LOST
                             % GAS LOST
                                   1001
       60%-
       40*
                                   ao*
                                   60%
                                   401
independent  of  the  type  or  level of
auxiliary  blowing  agent  (analogous to
observations  on laboratory foams). The
percent  weight  loss curves exhibit the
same general  shape;  however,  there  is a
spread to the data. There doesn't appear
to  be any  pattern to the   variations
related  to  a  specific plant,  sample
size,  a  specific  auxiliary  blowing
agent, or a specific  level of auxiliary
blowing    agent.    These    data    are
hypothesized     to   reflect    random
variations     within    the    various
manufacturing operations. The  flattening
of the mass loss profiles and mass  loss
rates of the  plant foams  is  comparable
to what is observed with laboratory  foam
at analogous measurement times.  Based on
the 30 °F difference  in boiling points,
CFC-11   would   be   expected  to   be
volatilized    earlier   than   CH2C12.
Comparison of the mass loss profiles for
foams of comparable formulation but  with
different   auxiliary   blowing   agents
yields conflicting data. CC1.,F  comes off  earlier in one comparison  (C  vs.
D)while  CH,C12  comes  off   earlier  in  the  other  (B  vs.  E).  The  time
differential between the two boiling point temperatures in the manufacturing
operation Is small. Therefore, the loss behaviors of methylene  chloride and
CFC-11 from flexible polyurethane  foams are  expected  to be similar.
                   TIME (nW
                 A1U ILOWINO 
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                               CONCLUSIONS

    We firmly believe that foamers will  eventually be restricted In  emitting
any  blowing  agent.  Retrofit  of  a  foam line  to  Isolate  the tunnel and
drastically  reduce  exhaust  flows  will  eliminate   worker   exposure   to
Isocyanates  and -significantly  Increase  tunnel   concentrations   of  the
auxiliary blowing agent. This Increase In ambient  blowing agent
concentration should allow for recovery by conventional means.

    Collection  and  recovery of halogenated hydrocarbons  such  as methylene
chloride and trlchlorofluoromethane  (CFC-11) by adsorption onto activated
carbon (or carbon fibers)  followed by  steam-out and condensation  has been
documented In the literature (5,6,7,8)  and commercial systems  are available
from many vendors.  Two of the key parameters which drive the size and hence
capital cost of a carbon-based recovery system are the concentration of the
material to be collected and  the flow  velocity  (9). The  Center's  approach
to  Isolating  the foam  tunnel and decreasing  air  flows would positively
Impact the economics of  any  recovery system. The higher  the  concentration
of  auxiliary blowing  agent and the lower the total flow,  the  smaller the
carbon bed required (lower cost). The recovery  of auxiliary blowing agents
from  polyurethane  foam  exhaust  gas  appears to  be technically feasible.
Design  parameters  and  economic  feasibility of various recovery  options
Including  emerging  technologies  (membrane separations,  etc.) need to  be
quantified  In  order  to Implement a waste minimization strategy to reduce
environmentally damaging air  emissions from PUF plants.

                                NEXT STEPS

    The Research Center For Waste Minimization And  Management Is  In  the
process of forming a consortium of cooperative foam manufacturers,  chemical
suppliers,  and relevant machinery manufacturers to develop  the necessary
design modifications for tunnel retrofit/Isolation and collection of tunnel
and  post-tunnel  emissions  on one foam line. This represents  the  scale  of
development necessary  to determine the feasibility of  the concentration,
recovery,  and  recycle strategy.  The Center's approach offers  a chance  to
address the environmental  problems while maintaining worker safety and  the
existing  continuous  process and  formulations.  If  the outcome   of  this
demonstration  Indicates  that  even this approach Is  Impractical, then this
Is  critical Information to the foam Industry In discussions with regulatory
agencies.  The  demonstration project  at one  plant would be  delineated Into
the following  three  major  areas  of Implementation  with go/no-go decisions
after each phase:

1.  Design and Install  tunnel  retrofit;  modify  tunnel  exhaust system;  and
    determine optimum tunnel exhaust  concentrations for recovery of CH2C12.
2.  Design methylene chloride  recovery system;  quantify specifications  of
    recovered  methylene chloride; produce a range  of foam  products  with
    recycled methylene chloride and compare product qualities to  analogous
    foams  prepared with virgin methylene chloride.
3.  Design and quantify  vacuum  recovery  system for  collection and recycle
    of post-tunnel losses of methylene chloride.

    Each Implementation phase would be  subjected to  cost and product quality
analyses,   quantification  of  actual  reductions   In   air  emissions,  and
measurements of  worker  exposure  to ambient toluene dllsocyanate and CH2Cla.
                                     359

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                             ACKNOWLEDGEMENTS

     The  initial  foam  preparation  technique,  closed  system apparatus,
preliminary weight loss data, and  weight  loss  data on  insulated foams were
conducted  by  Gertrude  Raumann as  a  research  assistant.  Internal foam
temperature measurements were performed by Scott Blaha, as part of a  summer
research  project.  Mass loss  data  on open and  closed 1:1,  3:1, and  4:1
systems and the  preliminary vacuum experiments were completed by Lisa Ashby
and Maresa Williamson as summer research projects. Water-blown foams were
prepared and mass loss  data  were  completed  by Allyson Bell as a  research
student.  Measurements  of volatile  losses  at  the  three  plant  sites  and
analysis of foam physical properties  were done by Valerie Martin as part of
her master's thesis. Special  thanks  go to the three manufacturing plants,
Hickory  Springs,  Olympic   Products,  and  Leggett  &  Platt  for  their
participation,  advice,  and supply  of raw materials.

                                REFERENCES

 1.  Burt,  J.G.,  "The   Capture  of  Freon 11  Emissions  in  Flexible Foam
        Manufacture",  E.I.  duPont  de Nemours  & Co,  Inc.  Freon  Products
        Division  Internal Technical Report KSS-8157, 1978.
 2.  Vreenegoor,  N.C.  "Environmental Considerations  in  the Production of
        Flexible  Slabstock",  Unifoam  publication, Switzerland, 1987.
 3.  Bailey,  F.E.  Jr and F.E. Critchfield,  "A Reaction Sequence  Model  for
        Flexible Urethane Foam" in Urethane Chemistry and Applications  edited
        by K.N.  Edwards, American Chemical Society, Washington D.C., 1981.
 A.  Raumann,   G.   and  M.R.   Overcash,  "Flexible   Polyurethane  Foam
        Manufacturing:  Waste  Reduction For Auxiliary Blowing Agents", 1988.
 5.  Kenson , R.E.,  "Recovery and Reuse of Solvents from  VOC Air Emissions"
        in Environmental Progress, Vol  A, No 3,  1985.
 6.  Knopeck,  G.M.,  L.M.  Zwolinski, and  R.   Selznick,  "An Evaluation of
        Carbon Adsorption  for  Emissions  Control  and CFC-11  Recovery in
        Polyurethane Foam Processes", Polyurethanes  88, Proceedings  of  the
        SPI 31st  Annual  Technical/Marketing  Conference,  October   1988,
        Philadelphia.
 7.  Urano, K. ,  "Progress Report  No. 1-B to  the International Isocyanate
        Institute,  January  1978.
 8.  Urano, K. and E. Yamamoto, "Removal and Recovery of Freon 11 Vapor  from
        a Polyurethane  Foam Factory by Activated Carbon"  in  International
        Progressin Urethanes, Vol  A,  1985, pp  35-55.
 9.  Zanltsch,  R.H., "Control of Volatile Organic  Compounds Using Granular
        Activated Carbon"  presented at Air Pollution  Control  Association,
        Southern Section Meeting,  September 1979.
                                   360

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                        WASTE MINIMIZATION ASSESSMENT CENTERS

                             by: F. William Kirsch and Gwen P. Looby

                          Industrial Technology and Energy Management
                              UNIVERSITY CITY SCIENCE CENTER
                                      3624 Market Street
                                    Philadelphia, PA  19104
                                        (215)387-2255
                                          ABSTRACT

       In 1988, University City Science Center (Philadelphia, Pennsylvania) began a pilot project to assist
small and medium-size manufacturers who want to minimize theirformation of hazardous waste but who lack
the in-house expertise to do so. Under agreement with the Risk Reduction Engineering Laboratory of the U.S.
Environmental Protection Agency, the Science Center's Industrial Technology and Energy Management
(ITEM) division established two waste  minimization  assessment centers (WMACs) at Colorado State
University in Fort Collins and at the University of Tennessee in Knoxville. During the second program period
of the project, a third WMAC established at the University of Louisville (Kentucky) has begun to conduct
assessments.

       Each WMAC is staffed by engineering faculty and students who have considerable direct experience
with  process operations in manufacturing plants and who also have the knowledge and skills needed to
minimize hazardous waste generation. The waste minimization  assessments are conducted at no out-of-
pocket cost to the client. Several site-visits are required for each client served. The WMAC staff locate the
sources of hazardous waste in each plant and identify the current disposal or treatment methods and their
associated costs. They then  identify and analyze a variety of ways to reduce or eliminate the waste. Specific
measures to achieve that goal are recommended and the essential supporting technological and economic
information is developed.   Finally,  a  confidential   report   which  details the  WMAC's  findings and
recommendations  including cost savings,  implementation costs, and payback times is prepared for each
client manufacturer.

       This presentation will discuss results from the first period of this project.


       This paper has been reviewed in accordance with the U.S. Environmental Protection Agency's peer
and administrative review policies and approved for presentation and publication.
                                             361

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                         WASTE MINIMIZATION ASSESSMENT CENTERS


                                       INTRODUCTION


       The amount of hazardous waste generated by industrial plants has become an increasingly costly
problem for manufacturers  and an additional stress on the environment.  One solution to the problem of
hazardous waste is to reduce or eliminate the waste at its source.

       University City Science Center (Philadelphia, Pennsylvania) has begun a pilot project to assist small
and medium-size manufacturers who want to minimize their formation of hazardous waste but who lack the
in-house expertise to do so. Under agreement with the Risk Reduction Engineering Laboratory of the U.S.
Environmental Protection Agency, the Science Center's Industrial Technology and Energy Management
(ITEM) division initially established two waste minimization assessment centers (WMACs) at Colorado State
University in Fort Collins and at the University of Tennessee in  Knoxville.  Each WMAC is  staffed by
engineering faculty and students who have  considerable direct  experience with process operations in
manufacturing plants  and who also have the knowledge and skills needed to minimize  hazardous waste
generation. During late 1989, a third WMAC at the University of Louisville was established.

       During the initial period of this pilot project, each of the two WMACs conducted  six assessments for
small and medium-size manufacturers at no out-of-pocket cost to the client.  Each client had to meet the
following criteria:

       •       Standard Industrial Classification Code 20-39

       •       Gross annual sales of not more than $50 million

       •       No more than 500 employees
       •       Lack of in-house expertise in waste minimization

       The potential  benefits of the pilot project include minimization of the amount of waste generated by
manufacturers, reduced waste treatment and disposal costs for participating plants, valuable experience for
graduate and undergraduate students who participate in the program, and a cleaner environment without more
regulations and higher costs for manufacturers.

       All told, the measures recommended by the two WMACs in these 12 plants accounted for an identified
cost saving of $1.28 million/year. This paper describes how the cost savings were found and identifies the
specific measures designed to reduce waste formation and emissions from two of these  plants.  However,
equally detailed accounts of the other ten plants could also be prepared.


                              METHODOLOGY OF ASSESSMENTS


       The waste minimization assessments require several site-visits to each client served. In general, the
WMACs follow the procedures outlined in the Waste Minimization Opportunity Assessment Manual. July 1988.
The  WMAC staff locate the sources of hazardous waste in each plant and identify the current disposal or
treatment methods and their associated costs. They then identify and analyze a variety of ways to reduce
or eliminate the waste. Specific measures to achieve that goal are recommended and the  essential supporting
technological and economic information is developed. Finally, a confidential report which details the WMAC's
findings and recommendations including cost savings, implementation costs, and payback times is prepared
for each client manufacturer.
                                             362

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                                            RESULTS


PLANT No. 1 (SIC 2851)

       This plant produces paints, coatings, stains, and surface-treating products at an overall rate of about
1.1 million gallons/year for regional distribution on a schedule of 2080 hours/year for 52 weeks. Its operations
primarily  involve blending and mixing of raw  materials, followed by product testing and packaging and by
cleaning of vessels and lines. Color separation in the product is obviously important, and each lot must meet
a variety  of other customer specifications.

Plant Operations

       Individual lots of water-based and solvent-based paints are mixed in a variety of tanks from 200 to
1000 gallons' capacity.  Ingredients for this initial  step  include (for water-based) water, latex, resins,
extenders, and dispersed pigments. For solvent-based paints the materials are generally similar in type, but
obviously solvent replaces  water and latex, and the  other new ingredients include plasticizers, tints, and
thinners.

       After batches are made up they are transferred to so-called let-down tanks, where additional water
(or solvent), resins, preservatives, anti-foaming agents, thinners, and bactericides are added.  Testing of
batches encompasses at least color, viscosity, and gloss, and those lots which meet specifications are filtered
and charged to cans for labeling, packaging, and shipping.

Waste Generation and Existing Waste Management Practices

       The principal waste streams are the result of equipment cleaning, especially from water-based paints.
For example, rinsing the let-down tanks ordinarily requires about 35 gallons of rinse water, but that value
increases to 53 gallons if light paint is to be blended after a dark predecessor. The hazardous nature of water
rinses is due to mercury from the bactericide in the paint.

       In some instances, rinse water from the mixing tanks is held in 500-gallon tanks and used in the let-
down tanks (instead of fresh water) to formulate future batches of water-based paint.  The rinses  are
separated according to the color intensity of paint in the tanks from which they were derived. For example,
rinses from white paint formulation amount to about 70% of the total, and they are invariably used again.

       Waste rinses not used again are piped to holding and flocculation tanks, to which alum is added to
lower the pH, in which some solid is precipitated  by adding flocculant, and from which supernatant liquid is
removed  for re-use in other  paint formulations.

       Tanks used for solvent-based paints are  rinsed with mineral spirits at a rate of about 5 gallons/400-
gallon tank.  These washings are sent off-site for recovery, followed by recycling or sale as fuel.

       In addition to re-use of rinse water and  recovery of solvent, this plant has adopted the following
measures to reduce waste generation:

       •       Cleaning equipment before the paint dries and hardens.

       •       Eliminating  hazardous materials, except for mercury in the bactericide added to outdoor
               water-based paint.

       •       Avoiding hazardous container waste by purchasing the bactericide in  water-soluble bags
               which dissolve during paint formulation.

       •       Scheduling  batch formulations so that light ones precede dark ones and thereby reduce the
               total volume of rinses.
                                              363

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       •       Reducing the inventory of raw materials to avoid degradation and spoilage and to assure
               high-quality product that can be sold, rather than low-quality paint which adds to the burden
               of waste disposal.

       •       Using bag filters to collect dust.

Waste Minimization Opportunities

       Table 1 summarizes the principal sources of waste, their amounts, the management method applied,
and the associated costs.

       Table 2 offers a brief description of each recommended WMO (Waste Minimization Opportunity) and
of current plant practice, together with savings and cost data.  Considered individually, the three WMOs
recommended could save over $22,000/year, which represents about 25% of current waste management
costs. Each has a simple payback time less than one year.

PLANT No. 2 (SIC 3443)

       This plant manufactures  aluminum brazed oil coolers for use in  heavy equipment.  It produces
approximately 59,290 units each year.

Manufacturing Operations

       The raw materials used in the production  of the oil coolers include aluminum in sheet and coil form,
aluminum castings and extrusions, tubes, fittings, brackets, caution labels, and plastic plugs.

       The following steps are involved in production:

       •       Shearing, punching, and forming operations to fabricate the oil cooler tanks, headers, air fins,
               sides, and oil turbulator fins.

       •       Degreasing  of oil  cooler tanks, headers, sides, fittings, and brackets.  The  solvent
               Chlorothene (95% 1,1,1  - trichloroethane) is  used in an  open-air, steam-heated vapor
               degreaser. The unit is equipped with a refrigeration unit which condenses Chlorothene vapor
               and minimizes evaporative losses to surrounding plant air.

       •       Recycling  of spent Chlorothene  to the  degreasing operation using an on-site still.
               Chlorothene is continuously circulated between the degreaser and a steam-heated solvent
               recovery still. Still bottoms containing spent Chlorothene, water, and oil are shipped off-
               site as hazardous waste.

       •       Assembly of oil coolers.

       •       Brazing of  assembled oil coolers to join the  internal and external coil fin surfaces for
               enhanced heat transfer. The oil coolers are first preheated in a gas-fired oven at 1020° F for
               15 minutes.  They are then dipped into an electrically-heated molten salt bath containing a
               sodium chloride-based compound, lithium chloride, and aluminum fluoride for 1 1/2 minutes
               at 1128° F and dipped in a water quench tank. Sludge from the salt bath and quench tanks
               is disposed in the outdoor on-site sand filter bed. Solids remaining in the filter are landf illed
               on company property; water is fed to the  settling pond and eventually discharged to a river.

       •       Cleaning of oil coolers to remove all residual salt, expose copper cells (which could cause
               corrosion failure), and condition  metal surface prior to painting.  The following steps are
               involved in the cleaning:

               • submersion in a 2% nitric acid bath (1 -2 hour residence time)
                                              364

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                 cold water rinse
                 dipping in NaOH caustic soda etching solution
                 hot water (102°F) rinse
                 cold water rinse
                 dipping in a 50% nitric acid bath
                 2 cold water rinses
                 dipping in a chromic acid wash
                 2 de-ionized water rinses
                 drying in a natural gas-fired oven

       •       Treatment of hazardous spent process solutions and contaminated rinse water streams. The
               liquids are treated in a neutralization tank with lime for pH control and flocculant to enhance
               removal of suspended solids.  The solution leaving the tank is pumped to a clarifier which
               removes solids and allows filtered water to flow to the settling pond. A solids-rich stream is
               pumped to a sludge-thickener settling tank for secondary sedimentation. Supernate from the
               settling  tank is transferred to  the sand filter beds for final water removal  before on-site
               landfilling of solids.

       •       Treatment of effluent from the chromic acid and de-ionized rinse water washes. These
               hazardous waste streams contain chromium in hexavalent form. The streams are treated to
               obtain a sludge containing less toxic trivalent chromium  compounds.   Several chemical
               agents are added to the waste to produce relatively insoluble compounds which are recovered
               on the sandfilter beds and disposed in the landfill. The liquid is  pumped to the settling pond
               and is eventually released to the river.

       •       Painting of oil coolers.  The coolers are dipped in a paint-filled tank, allowed  to drip after
               immersion, and transferred to a spray booth for additional spray painting. Paint is collected
               on floorcoverings (plastic sheetorcardboard) and in spray booth filters and disposed of daily
               in barrels which are sent to an off-site landfill.

Existing Waste Management Practices

       The plant has taken the following steps in managing its hazardous wastes.

       •       The plant owns and operates a landfill for its private use.

       •       Chromium reduction from hexavalent to trivalent form is performed in-house.

       •       A refrigeration unit and a solvent recovery still have been added to the degreasing unit to
               minimize evaporative loss and liquid waste.

       •       The plant constantly monitors its waste-stream effluents and has installed its own hazardous
               waste treatment facility.

       •       Water-based paints are currently used.

       •       The plant has a designated professional staff person based at corporate headquarters who
               periodically visits satellite plant  locations to provide assistance  in both hazardous waste
               monitoring and management techniques.

Waste Minimization Opportunities

       The waste currently generated by the plant, the source of the waste, the quantity of the waste, and
the annual treatment and disposal costs are given in Table 3.

       Table 4 shows the opportunities for waste minimization that the WMAC  recommended for the plant.
The waste in question, the minimization opportunity, the possible waste reduction and associated savings,
and the implementation cost along with the  payback time are given.
                                              365

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                                   DISCUSSION OF RESULTS


       The two plants described have annual waste management costs of $188,370 and the WMACs were
able to recommend to them a series of cost-saving measures which add up to $359,980 per year. The savings
total exceeds the aggregate waste management cost because, in  one of the two plants, the measures
recommended save more than the cost of waste treatment, disposal, and recycling.

       For example, in plant No.2, only a $13,485 waste management cost is presently associated with paint-
contaminated filters and cardboard and plastic sheets but elimination of the painting is estimated to save
almost $60,000 per year.  Typically, savings in raw materials costs  of 25 to 80% can be achieved by the
recommendations offered.  It is not hard to see how this kind of savings can add up to more than the costs
of waste management in some plants.

       The cost-saving approach taken with these results is generally conservative, because the WMOs
address only the avoidance of raw materials costs and the reduction of present and future costs associated
with waste treatment and disposal. Not claimed are the savings related to: possible changes in emission
standards, any liability incurred from waste management practices, and costs arising from employee health
and safety problems.  It should also be noted that each WMO identified is treated  as an isolated individual
measure and no consideration has been given to effects occurring because of interactions among WMOs.

       The WMAC program is continuing  to serve eligible manufacturers, and future results are expected
to allow more generalizations about the amounts and types of industrial waste materials encountered in the
nation's plants.

       It seems reasonable to conclude from recent WMAC program experience that small and medium-
size manufacturers:

       •       Have recognized many of their waste generation problems and have undertaken a variety of
               actions to address them.

       •       Are receptive toward practical quality assistance, offered  in their plants objectively and
               competently, that can help them to choose cost-effective waste minimization opportunities
               over and above what they have been able to achieve on their own.

Acknowledgment

       The authors wish to express their appreciation to EPA's Risk Reduction Engineering Laboratory for
support of the Waste Minimization Assessment Centers and the opportunity to prepare this paper. They also
want to acknowledge the waste minimization assessments performed and reports  prepared by Dr. Richard
J. Jendrucko and Ms. Phylissa S. Miller at the University of Tennessee and by Dr. Harry W. Edwards, Dr. C.
Byron Winn, Mr. John R. Bleem and Mr. Michael Kostrzewa at Colorado State University. Their work provided
the  data upon which this paper is based.
                                            366

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                TABLE  1.   SUMMARY OF WASTE GENERATED   (SIC 2851)
                                   HASTE TREATMENT
                               HASTE DISPOSAL
HASTE STREAM
   Amount
 Cost
Amount
Cost
HAZARDOUS LIQUID HASTE

A.   Water-based Waste:

     Equipment cleaning
     by water washing


B.   Solvent-based Waste:

     Equipment cleaning
     by solvent washing
26.700 gal
(Hg water
and paint)
$3.740       26.700  gal    $48.040
              off-site
                           27.200  gal    $37.080
                             (mineral
                             spirits)
                             off-site
     TOTALS
26.700 gal     $3.740
            53.900 gal   $85.120
                                     367

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                       TABLE  2.   SUMMARY OF WASTE  MINIMIZATION  OPPORTUNITIES RECOMMENDED  (SIC 2851)
WHO No.
Present Practice
                                            Proposed Action
Cost Savings
             Water rinses remove paint
             from tanks and pipes
             About 15 gal solvent per
             batch of paint is drummed
             and sent off-site for
             disposal.
             A bactericide containing
             mercury  is  being used in
             water-based paints.
                                 Install a pipe-cleaning system
                                 consisting of 3 different-sized
                                 foam plugs or "pigs" to be sent
                                 throughout the pipes by
                                 compressed air.  Paint is thus
                                 forced from the lines and to the
                                 canning line filter.  The use of
                                 water and amount of waste are
                                 lower.  (This WHO is applicable
                                 to non-white paints.)

                                 Use a solvent recovery system
                                 based upon distillation and ship
                                 the small amount of remaining
                                 solid to a hazardous waste
                                 disposal site.

                                 Eliminate the bactericide from
                                 water-based interior paints and
                                 substitute an organic material.
                                 (This WHO is applicable to  non-
                                 white paints.)  There is no cost
                                 difference between  these
                                 additives.
Estimated waste reduction
Estimated cost reduction
Estimated implementation cost
Simple payback
Estimated waste reduction .
Estimated cost reduction
Estimated implementation cost
Simple payback
 Estimated waste  reduction
 Estimated cost reduction
 Estimated implementation cost
 Simple payback
1.780 gal/yr
Sll.llO/yr
$1.600
2 months
3.300 gal/yr
$5.420/yr
$4.950
11 months
3.100 gal/yr
$5.580/yr
none
immediate

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                                                  TABLE 3.  SUMMARY OF WASTE GENERATED  (SIC 3443)
                  Waste  Generated
                                                  Source of Waste
                                                                              Quantity Generated
                                                                      Annual Waste
                                                                     Management Cost
CO
»
VO
Still  bottoms containing
spent, contaminated
Chlorothene (9BS-1.1.1-
trichloroethane).  water,
and oil.

Evaporation of
Chlorothene.

Sludge containing
compounds derived from the
salt bath constituents.
impurities from the baths,
and contaminants on the
products' surfaces.

Sludge containing various
solids from the treatment
of the spent cleaning
solutions.

Sludge containing various
compounds from the
chromium reduction
process.

Paint-contaminated filters
and cardboard and plastic
sheets.
                                                  On-site  solvent  recycling still
                                                  associated  with  the degreasing
                                                  operation.
                                                  Degreasing operation.
Salt bath  tank and water quench tank in
the brazing  process.   The  sludge is
collected  on the sand filter beds.
                                                  Treatment process for spent solutions
                                                  from the cleaning of the brazed
                                                  product.  The sludge is collected on
                                                  the sand filter  beds.

                                                  Chromium reduction process.  The sludge
                                                  is collected on the sand filter beds.
                                                   Painting of product.
                                                     150 gal/yr
                                                   6.525 gal/yr
                                                                                                    514.917 Ib/yr
$4.650
  0(a)
28.500
                                                1.171.060 Ib/yr
                                                   88.943 Ib/yr
                                                     9.812  Ib/yr
36.375
 16,500
 13.485
                   (a)    Currently there are no waste management costs associated with the evaporation of Chlorothene.

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                                              TABLE 4.  SUMMARY OF WASTE MINIMIZATION OPPORTUNITIES RECOMMENDED   (sic  3443)
                                                                                 Part  I
             Waste
Minimization Opportunity
                                               Waste Reduction          Net Annual
                                            Quantity      Per  Cent        Savings
               Implementation   Payback
                    Cost         Years
to
^j
o
             Evaporation of Chlorothene
             from the degreaser  unit..
              Still bottoms  from the
              on-site  solvent
              recycling  still.
              Evaporation of
              Chlorothene and
              Chlorothene contained
              in the still bottoms.

              Sludge from the water
              quench tank in the
              brazing process.
              Sludge from the salt
              bath and water quench
              tanks in the brazing
              process.
                                              30 gal/yr        20
                                                                                                                       1.010U)
Install  a conveniently  removable            3.263 gal/yr        50        $17.180(A)
cover on the vapor  degreaser
tank to reduce evaporative  losses.
Cover the tank except during  times
when parts baskets  are  being
lowered into or taken out of  the
tank.

Reduce the amount of  lubricants
used during metal-working and
the openness of machine work
areas to decrease the amount  of
oil picked up by parts  during
processing, thereby minimizing
the amount of degreasing required.

Replace  the vapor degreaser system
with an  ultrasonic  cleaning system
which utilizes biodegradable
detergents.

Modify  the  procedure  for dipping
the  coolers in the  salt bath to
minimize carry-over to the water
quench  tank.  Achieve maximum
salt  removal  by gently vibrating
or shaking  the parts baskets and
subjecting  the parts to a hot
air  blast.

 Replace molten salt bath brazing           411.934  Ib/yr        80        203.440(0
with vacuum brazing.   Vacuum
 brazing is  suitable for 801
 of this plant's products.
                                                                                                                                           $220
                                                                                                            0.01
                      290
                                                                                                                                                         0.3
                                           6.600 gal/yr        99
                                           23.171  Ib/yr
20.450CB)
20.520(C)
50.000
43.880
2.4
2.1
                                                                                            720.640
                                   3.5

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                                              TABLE A.   SUMMARY  OF WASTE MINIMIZATION  OPPORTUNITIES RECOMMENDED (SIC 3443)
                                                                                Part II
             Waste
Minimization Opportunity
   Waste Reduction           Net  Annual
 Quantity      Per Cent       Savings
                                                                                                                                    Implementation  Payback
                                                                                                                                         Cost        Years
             Paint-contaminated
             cardboard and plastic
             sheets.
Reduce paint loss by
installing-a low-pressure
air-jet system over the
paint dipping area to blow
excess paint downward into
tank.  Install an IR paint-
drying  lamp to prevent
dripping when coolers are
moved to the spray booth area.
2.180 Ib/yr
                                                                                                          22
                                                                          4.350 (D)
                    2.490
               0.6
CO
             Paint-contaminated
             filters and cardboard
             and plastic sheets.
 Install an electrostatic spray
 paint  system for application of
 the oil cooler second coat of
 paint  in order to reduce
 overspray loss.
3.513  Ib/yr
                                                                                                          36
11.200 (D)
13.200
1.2
              Pai nt -contami nated
              filters  and  cardboard
              and  plastic  sheets.
 Discontinue the practice of
 painting  oil coolers which
 will  be  re-painted by
 the  customer.
4.906  Ib/yr
                                                                                                           50
59.720 (D)
28.440
                                                                                                             0.5
              (A)   Includes  cost  savings  attributed to the avoided purchase of Chlorothene.
              (B)   Total  savings  have  been  reduced by the cost of detergents required.
              (C)   Includes  cost  savings  attributed to the avoided purchase of salt bath  constituents.
              (0)   Includes  cost  savings  attributed to the avoided purchase of paint  supplies.

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                   LIABILITY AND BENEFIT SHARING FOR JOINT
                    PRODUCTION ACTIVITIES INVOLVING RISKS

                             Paul R. Kleindorfer
               Departments  of Decision  Sciences and Economics

                               Akihiro  Watabe
                    Center for Risk  and  Decision Processes

                             The Wharton School
                         University of  Pennsylvania
                           Philadelphia, PA  19104
                                  Abstract

This paper presents a model of joint production actitivities involving risks.
The context for  this problem  includes  generating,  transporting and disposing
of hazardous  wastes.    The  economic agents  involved are viewed  as expected
utility maximizers  who  contribute  to carrying  out a  risky  activity  under
asymmetric information.  The problem is posed  as  one of providing incentives
from one  firm (the principal)  to  another firm (the agent)  to undertake the
risky activity and to invest in risk management in carrying out the activity.
The principal provides  such  incentives  through  the contract  form,  payment
scheme  and  ex  ante  agreed  liability  sharing  rules  for  the  potential
liabilities occasioned  by  the actitivity.  The framework  of principal-agent
theory is  used to formulate  the  problem  and to derive  optimal risk sharing
arrangements  and  levels of  protective  activity  for   the agent.    Policy
implications  of  the  results  and the relationship of these  to  several multi-
party waste reduction and disposal problems are discussed.
       This  is  a  condensed  version of  the  paper  "Liability Sharing  and
Incentives" by the authors.   The  full paper is available from the Center for
Risk and Decision Processes of The Wharton School.
                                    372

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                                1.  INTRODUCTION

    We  have   in  mind  the  following  context.    One  economic  agent,   the
principal,  delegates a risky  production  activity to another economic  agent.
A contract  is  negotiated  covering  liability  sharing between  the  principal  and
the agent in the event an accident occurs in carrying out the  activity.  At
the   time  the  delegation  contract  is  negotiated,  the  principal  faces
uncertainty regarding both the agent's safety characteristics and  the agent's
actions   (e.g.,  the  agent's  investments  in  durable  and  nondurable risk
management  activities).    The  principal  is interested in determining whether
or not  to  undertake the activity  and  in designing  a liability sharing
contract  which will provide proper  incentives  for the agent to exercise  due
care  if the activity is undertaken.

    In  this economic environment,  liability rules are crucial.   If  strict
liability for  the  agent  applies,  the principal bears no risk in the event of
an accident.   In this case,  accident  liability will not be  an  issue for  the
principal,  although the delegation  contract may  require higher payment  to  the
agent to ensure the agent's participation in the project.  On the  other hand,
if both the  principal  and  the agent  are jointly  responsible  for accident
liability,  the principal  must take into account her  share of  the expected
accident liability  in determining transfer payments to  the agent in designing
the delegation contract.

    Coase   (1960)  argued  that liability rules  and  transfer  payments   are
neutral to  resource allocations if bargaining costs are negligible.  However,
when  transaction   costs  are  significant,  or   when  there  are  information
imperfections  or legal impediments  to bargaining contracts, the  Coase theorem
fails to hold  (see  e.g.,  Farrell (1987),  Samuelson  (1985)).

   In the  presence  of  information  imperfections,   designing  the  optimal
delegation  contract is complex.  We will  be concerned with contracts based on
the agent's self-revealed  safety  characteristics  as  well as  self-motivated
safety  effort-,  with  liability  sharing  and   remuneration  based on  these
revealed characteristics.   First,  we will consider the case  where protective
activity by the  agent is  a choice  variable, which would naturally depend on
both  the liability  sharing rule adopted and the safety characteristics  of  the
agent.    This  is   the  general  case  where  both  moral  hazard  and  adverse
selection are present.  We then discuss the special case of adverse selection
only,  in  which the  level  of  protective  activity undertaken by  the  agent is
assumed  fixed, but the  accident  proneness of the  agent  may  vary and  is
unobservable by the principal.

    When the principal does not observe actions of the agent, and she engages
in negotiating contracts  before the actions of  the agent are  undertaken,  an
improper  contract  offered by the  principal  will  result  in  shirking  of
protective  activity.   The contract designed by the principal  must provide
proper incentives  to the  agent to undertake protective  activity.   Moreover,
when the principal does  not know the safety characteristics of the agent,  the
agent may have an  incentive  to misstate his  safety  characteristics to  the
                                    373

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principal during the bargaining process.  Therefore,  in  bargaining about the
appropriate  liability  sharing and  ex  ante compensation  for the  agent,  the
principal needs  to design  a  mechanism which  enables her to provide proper
incentives to the agent for protective  activity  as  well  as to learn from the
agent what his  safety characteristics  are.   If the  principal  could observe
the  agent's  actions and  already knew  his safety  characteristics,  then  at
least in  a  competitive market, the  principal  and the agent would engage  in
bargaining over the division  of the  economic surplus  available  through joint
production activities.   Depending on relative bargaining power,  the principal
might simply pay  the  agent an actuarial rate  equal to  the expected accident
liability.   Under  these  conditions, as  argued by  Coase  [1960],  liability
sharing would  not  be  an issue.   Moreover,  risky  activities  would  only  be
undertaken  if  efficient  to  do  so.   As  we  will  see,  the  existence  of
incomplete information, with accompanying adverse selection and moral hazard,
has profound effects on this perfect information scenario.
                                2. ASSUMPTIONS

    We assume  that  a principal is engaged in an  activity which is risky and
requires  the services  of  an agent  to  co-produce the  activity.    A typical
context might  be  a  manufacturing firm which produces hazardous wastes which
must be disposed of by a waste handling firm.  In the model of interest here,
the principal  delegates the  risky activity entirely  to  the agent to perform.
In the event of an accident, there may be substantial losses, which will have
to be  paid for by  either  the principal  or  the agent,  depending  on ex ante
agreed liability shares.  We assume that the principal hires the agent from a
market which determines the minimum payment the agent must be paid.  Both the
principal  and  the agent are  risk  neutral and have  enough assets  to finance
accident liabilities; bankruptcy is excluded here.

    We denote  the total losses (in $'s)  resulting from an accident by L and
the principal's benefits from  production  by  R;  L and R are fixed.   Denote by
P(a,t)  e  [0,1]   the probability  of  an accident  where  "a"  is   an  action
undertaken by  the agent and "t" is  the  agent's type.   We  may  think of t as
representing the  accident  proneness  of the agent, i.e.,  t represents agent-
specific  characteristics  related to  safety.    The  agent's action  is chosen
from a feasible set A.  Denote by C(a,t) expenditures (in $'s) for production
activities when the agent's action and type are a and t respectively.

   For  a given  agent,  the  principal's  problem  is  to determine  whether to
delegate the risky activity to the agent and how much to pay the agent if the
activity  is  undertaken.   We  assume that the  principal  does  not  know the
agent's type, but her uncertainty regarding the set of feasible agents' types
is drawn from  a continuous probability density function h(t) where t e T, and
T -  [t,  t] .   We  assume that h(t)  > 0 for all  t  e T and that its cumulative
distribution function H(t) is common knowledge.
                                     374

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                    3. ADVERSE SELECTION AND MORAL HAZARD

    The principal's  objective  is  to  design  a  contract  that maximizes  her
expected payoff subject to incentive compatibility and individual rationality
constraints on  the  agent.   The individual rationality  condition is that the
agent's expected  payoff under  any  feasible  contract  must  ensure  that  the
agent achieves his reservation utility level.

    The incentive  compatibility constraint we  require  is that  the contract
designed  should induce  the  agent  to reveal  truthfully his   actual  type.
Adopting  the  framework  of  the  revelation  principle   (see  Myerson  (1979,
1981)), this  constraint  can be  imposed without  loss  of  generality.   The
"contracts" of  interest  here  are  defined in terms  of  a triad  of functions
{x(t),y(t),z(t) |  t e T):

    x(t):  T -»  [0,1], y(t): T -» [0,1], and z(t): T —• »+,

where x(t) represents the liability share for an agent whose declared type is
t  if  the  activity  is  undertaken  with  this   agent,  y(t)  represents  the
probability  that  an  agent  with  declared  type  t  will be  contracted  to
undertake the actitivity, and z(t) represents the  payment from the principal
to an agent with declared  type  t  if  the agent undertakes the activity.  If a
contract  {x,y,z}   satisfies  both  incentive  compatibility  and  individual
rationality of the agent, it is assumed to be implementable.

    In designing contracts,  the principal announces  a  contract  {x,y,z},  all
of which  contingent  on  the  declared  type  of  the  agent.    The  agent  then
declares his  type  to be  s (possibly misrepresenting  his  actual  type t),  and
the specific  contract  (x(s),y(s),z(s)} is then  implemented.  The  agent  then
chooses protective  activity  "a",  knowing the specific  contract  implemented,
and the activity is executed.

    Given the assumptions above, the expected payoff of the principal U under
the contract  {x,y,z},  when  any agent  chosen by the principal  declares  his
true type and when the agent selects action a(t), is described by:
               ft
       ;,y,z) -
               Jt
U(x,y,z) -   [R - (l-x(t))P(a(t),t)L - z(t)]y(t)h(t)dt.               (1)
The  agent's  expected payoff  V  from  the contract  {x,y,z}  is  given by  the
following for an agent of type t who declares his true type to be s:

    V(x,y,z,a,s,t) - [z(s) - x(s)P(a,t)L - C(a,t)]y(s) + V(t)[l-y(s)].     (2)

The principal's design problem is therefore characterized by:

    Maximize   U(x,y,z)                                                    (3)
     x.y.z
                                    375

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   Subject to:  (a,s) e Argmax { V(x,y,z,a,s,t) }    (t c T)
                         acA
                         s«T

                 Max { V(x,y,z,a,s,t) |  a e A, s e T} > V(t)

where V(t)  is the reservation  utility  level of  the agent whose  type is t.
With  some manipulation  (see Kleindorfer  and Watabe  (1990)),  this problem
boils down  to an optimal control problem with a  fixed endpoint, with V as a
state variable and x and y as control variables as below.
  [ax     {[R-]
  :,y,v Jt
Max   I {[R-P(a(x(t),t),t)L-C(a(x(t),t),t)-Y(t)]y(t)-V(t)+Y(t)}h(t)dt
x,
 subject to:

     Vt(t) -  -  [x(t)Pt(a(x(t),t),t)L + Ct(a(x(t),t),t)]y(t)+Yt

     V(t) - V(t)

     0 < x(t) < 1

     0 < y(t) < 1

where subscripts  denote  derivatives (e.g., V  -  3V/dt).  The solution to the
optimal control problem is summarized in Theorem 1.
                                                   *  *  *
Theorem 1: The optimal contract of the principal {x ,y ,z } is given by:

    x*(t) - 1      if PtL <  |act/3x| for all t e T

          e (0,1)  otherwise

     *                        *          *     H    *
    y (t) - 1       if R > P(a ,t)L + C(a  ,t) + 	 (x (t)P L+C +Y ) + Y(t)
                                               h(t)         t
          - 0      otherwise


    Z*(t) - z*(t)y*(t) - [x*(t)P(a*,t)L + C(a*,t) + Y(t)]y*(t)


                                     [x*(s)P L + C  + Y ]y*(s)ds
                                           S     S    S


Corollary 1;  If  the  probability  of an accident P depends only on the agent's
action,  that  is,  P(a,t) #-  P(a),  then  the principal  selects  only strict
liability for the agent; x (t) - 1.
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                             4.  ADVERSE SELECTION

    This  section  specializes  the  above  model  to the  case  in which  the
functions C and  P  do  not depend in any essential way on the agent's actions.
This  is  the case  of pure adverse  selection.   The  following  result follows
from Theorem 1.

Corollary 2:  If the functions  C  and  P do not depend on  the agent's action,
then  the  principal's optimal  contract entails  no  liability  for  the agent;
i.e., x (t) - 0  (t e T).
                    5.  POLICY IMPLICATIONS  AND CONCLUSIONS

    In  this  section,  we consider  the  public  policy interpretation  of the
above  results.    First,  consider  social  welfare  and efficiency.    At the
principal's optimal contract, expected total surplus  (ETS ) is given by:
ETS* -

           t
                     *          *     *
                - P(a,t)L - C(a,t)]y(t) + V(t) [l-y*(t) ] ^h(t)dt.        (4)
    This  is  equivalent to the  expected social profit  from  joint production
activities, if undertaken, plus the agent's reservation utility level, if the
activities  are  not   undertaken,   weighted  by  the  probability  y*(t)  of
undertaking the activity.

    If the principal's benefit R exceeds the  expected  social  cost (PL + C +
V),  it  is efficient to  undertake  the activity.  At the  principal's optimal
contract,  however,  efficiency  is  not  always  satisfied   since  Theorem  1
requires  that  the  activity  not   be  undertaken  (y*(t)  - 1)  unless  the
principal's benefit exceeds  the  expected  social cost plus an "information
cost" (equal  to  (H/h) (x*P L + C  + V ))  imposed  on the principal (see y (t)
in^The.ore.m 1).  Thus,  from a social welfare perspective, the optimal contract
{x ,y ,z  } is ex ante  inefficient,  a consequence of incomplete information.

    Nonetheless,  if the  government  were  to  provide subsidies equal  to the
information cost  of the  principal,  then the activities  would be conducted
whenever  her  benefit  exceeds  the  expected  social  cost,  i.e.  ex  ante
efficiency would be assured  in this  case.   (This  assumes  that the government
could costlessly  obtain  the  agent's  revealed  type  and was otherwise fully
informed  on   the  technology  and  other parameters   required to compute  the
information cost).   Note  that,  when informationally feasible, subsidies  do
not  vaiolate  incentive  compatibility  of  the agent,  because neither  the
principal nor the agent faces bankruptcy in our analysis.

    Next consider liability rules.   Our results indicate that there are three
cases  for  the  selected  liability  sharing   for a contract.    Under  the
coexistence  of adverse  selection   and  moral  hazard,  the principal  chooses
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either joint liability or strict liability for the agent,  as shown in Theorem
1.   If the  probability of accidents  does  not depend  on  the  agent's  type,
strict  liability  for  the  agent is  selected  (Corollary  1),  but under  only
adverse selection, the  agent bears no  liability at  all  (Corollary 2).  It is
clear that because bankruptcy is excluded, the selection of liability sharing
rules will  affect the expected total  surplus,   i.e.,  social welfare,  only
through y (t) (see (4)).

    Throughout the paper,  neither  the  principal  nor the  agent  is assumed to
go bankrupt.  This assumption  is crucial  to  the  incentive and social welfare
results presented.  Suppose that the agent is not a large firm,  and will face
the  possibility  of bankruptcy under  strict  liability borne  by the agent.
Then, liability sharing offered by  the principal can result in the agent's
bankruptcy.   The  above framework would have to be  modified substantially to
capture the  incentival and welfare consequences  of such  bankruptcy.   On the
incentives side,  the costs of bankruptcy to both  the principal and agent need
to  be   carefully  modeled.     So   do  the   consequences   for  potentially
uncompensated victims in the event of bankruptcy.

    To  illustrate, suppose that the activities are undertaken  with an agent
with a  small asset base at risk to  cover eventual  liabilities.  In the event
of  an  accident and  the  agent's  bankruptcy,  there  may  exist  uncompensated
liabilities.   In  this  case, expected  total  surplus as measured by (4)  does
not  indicate  the  true  measure  of  social  welfare,  since  this  excludes
uncompensated accident  liabilities which must be  covered by either victims or
a third party.    If "third party"  means other insurers,  then it is possible
that we would  face the issues  currently confronting Environmental Impairment
Liability insurance in which incomplete information and small firm problems,
together with  regulatory uncertainties, have  led to a complete collapse of
the  EIL  insurance market.    Representing  these  problems  and  regulatory
remedies  in an extension of  the  above framework  is  an important  area for
future research.

    As  a final  point,  we have assumed  in  this paper  that  the  principal
engages in  negotiation with only one agent.   However,  it is quite often the
case, especially  in  the areas  of waste reduction and waste disposal, that a
firm  (e.g.,  a waste  generator)  faces  negotiation  with  several   firms  in
arranging for  a  team  of agents to  coproduce a jointly  risky activity.   Such
multi-agent  issues are  an  interesting area for future research.
                                  REFERENCES

Coase,  Ronald  (1960)   "The  Problem  of  Social  Cost,"  Journal  of Law  and
Economics. 3, 1-44.

Farrell,  Joseph  (1987)  "Information and  the  Coase  Theorem," Journal  of
Economic Perspectives.  Fall, 1, 113-129.
                                    378

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Kleindorfer, Paul R.  and Akihiro  Watabe,  "Liability Sharing and Incentives",
Working Paper,  Center for Risk and  Decision Processes, The  Wharton School,
June, 1990.

Myerson,  Roger  B.   (1979)   "Incentive   Compatibility  and  the  Bargaining
Problem," Econometrica. 47, 61-79.

Myerson, Roger B.  (1981)  "Optimal Auction Design,"  Mathematics of Operations
Research. 6, 58-73.

Samuelson, William (1985) "A Comment on the Coase Theorem," in Game Theoretic
Models  of Bargaining,  ed. by  Alvin  Roth,  New  York:  Cambridge  University
Press.

Shavell,  Steven  (1979)  "Risk Sharing and Incentives  in  the  Principal  and
Agent Relationship," Bell Journal of Economics.  10,  55-73.
                                    379

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        MANAGING A HAZARDOUS WASTE MINIMIZATION INVESTIGATION


             By:   Garry O. Kosteck, RE.
                   U. S. Army, Production Base Modernization Activity
                   Picatinny Arsenal, NJ  07806-5000

                   Stephen P. Sobol
                   Science Applications International Corporation
                   Paramus, NJ  07652


                                     ABSTRACT

INTRODUCTION

United States  Army policy is to reduce its generation of hazardous waste to lessen the life cycle
cost of manufacturing and to minimize potential enviromental liability including worker
exposure to hazardous materials. The Army's designated goal is to reduce its 1985 hazardous
waste generation levels by 50% by the year 1992. To accomplish this goal, the Army Materiel
Command selected the Production Base Modernization Activity to conduct hazardous waste
minimization (HazMin)  studies  at  selected  Army facilities.   The  Production Base
Modernization Activity through a contract with Day & Zimmermann Corp. and Science
Applications International Corp.  investigated six Army facilities to determine how hazardous
waste is produced and then to recommend HazMin alternatives.  This investigation focused on
each facility's individual waste streams and their on-site hazardous waste treatment facilities.
Waste streams included waste petroleum oils, paint sludges, plating wastes, etc.


METHODS

The HazMin study investigation is separated into three distinct phases: Phase I, quantification,
involves the pre-audit determination of how many waste streams and what type of on-site
hazardous waste treatment facilities exist. Phase II, qualification, involves the auditing of these
identified waste streams and treatment facilities to gain a complete understanding of which raw
chemicals are used, what chemical/mechanical processes exist, and what types and volumes of
wastes are generated.  Phase III, recommendations, involves  the selection of the most
appropriate HazMin reduction alternatives for each waste stream and each treatment facility.

SUMMARY

This paper will address HazMin audit procedures and review  the challenges of managing a
hazardous waste minimization  study.  Actual types of HazMin recommendations are discussed
including capital projects, process changes, and encouraging management initiatives. Also
provided are valuable lessons learned.
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                                  INTRODUCTION

The United States Army Materiel Command (AMC) has instituted a comprehensive program to
reduce the generation of hazardous  waste  throughout its industrial  base. The Army has
established a goal of 50% reduction of its 1985 volumes by 1992. The hazardous waste streams
which are involved in these efforts include propellant and energetics production waste and by-
products, waste oils, waste solvents, painting and paint stripping, etc. In order to accomplish
this reduction goal, a Hazardous Waste Minimization (HazMin)  program encompassing a
number of efforts is now underway. This paper discusses just one of these efforts, the HazMin
investigations at six facilities. These include four Army Ammunition Plants, one Army Depot
and one Arsenal.

The Production Base Modernization  Activity (PBMA) was established in 1973 to provide
centralized management of the Department of the Army's  (DA) armaments,  munitions, and
chemical production base modernization program. This program includes all Army ammunition
plants, arsenals, and government equipment located at contractor owned and operated facilities.
The environmental aspects of PBMA's involvement with these industrial facilities, plus current
environmental support to both AMC and DA, provided the necessary experience for managing
this environmental project.  This project was managed by PBMA and supported through its
engineering services contract with  Day & Zimmermann Inc.,  who retained  the services of
Science Applications International Corporation, to complete these investigations. This contract
is a essentially a task oriented, competitively awarded contract where individual Statements of
Work (SOW) are prepared and a firm fixed price is negotiated.

The completion of this HazMin study also benefited work which the Assistant Secretary of the
Army for Research, Development, and Acquisition (ASARDA) is currently conducting. The
purpose of the ASARDA study  is to identify Army-wide opportunities for reducing hazardous
waste generation throughout the materiel development and acquisition life cycle. The facility-
level HazMin studies discussed in this paper have provided valuable data which assisted the
ASARDA study team in their efforts.

                       PROJECT MANAGEMENT APPROACH

 A key part of this HazMin effort is the detailed study of 6 Army manufacturing and maintenance
facilities. This effort focuses upon how hazardous waste is generated at the facility production
line level. These HazMin audits are  intended to ultimately identify projects which can be
completed either by funding specific capital  projects, changing  processes or encouraging
management initiatives. These individual HazMin audits are organized into  a three-phased
approach. Phases II and III were initially modelled after the  United States  Environmental
Protection Agency's "Waste Minimization Opportunity Assessment Manual" (Manual). AMC
has adopted a similar waste reduction hierarchy as EPA with source reduction being preferred,
followed by recycling and treatment technologies.  This HazMin approach also includes the
review of all on-site hazardous waste treatment systems. The primary goal of HazMin is source
reduction, but in reality technological  solutions to source reduction are not feasible for all the
varied waste streams. The combination  of investigating each hazardous waste generator and each
hazardous waste treatment facility allows for a comprehensive HazMin audit.

The result of this approach is a complete facility hazardous waste  database on each waste stream
and each  waste treatment system.  Phase I identifies and quantifies these streams and systems.
Phase II gathers current data regarding the various processes. The  Phase III HazMin recom-
mendations are then tailored to each facility's specific needs and allows HazMin to be introduced
at a number of levels at a facility. A further explanation of each phase follows.
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PHASE I  - QUANTITATIVE INVESTIGATION
The intent of Phase I is to describe each waste generation process at the point where the waste is
actually produced and to describe each on-site hazardous waste treatment facility. The purpose of
Phase I is to produce an "order of magnitude" profile of an installation's hazardous waste
generation . Data which is to be collected includes : raw materials, a description of the waste
generation process, and the volumes for all waste streams. Examples of hazardous waste
generators include paint booths, automotive shops, propellant and explosive lines, etc.  See
figure 1 for a typical example of the Phase I databases.
Building
#
30
30
30
31
60
94
Raw Material
Motor oil
Batteries
1,1,1
Tricloroethane
Rags
Hydraulic Oil
Propellants and
Explosives
Process
Description
Vehicle
Maintenance
Vehicle
Maintenance
Degreasing
Boiler
Maintenance
Hydraulic
vibrator
Explosive
desensitization
Type Waste
Motor Oil
Sulfuric acid
Tricloroethane
Oily Rags
Hydraulic oil
Explosive
contaminated
sludge
Volume
per year
4700 Gal
220 Gal
1200 Gal
50 KG
240 KG
134 KG
EPA
ID #
x721
D003
F002
x721
x726
D001
                   Figure 1, Phase I Database for Hazardous Waste Generators
Phase I's hazardous waste definition included all waste petroleum oils even though currently
only thirteen states include waste petroleum as a hazardous waste. Hazardous waste treatment
systems were also considered a part of the HazMin investigation because : 1) they all generate
hazardous waste and as such, meet the definition of a waste generator, 2) knowledge of these
systems allows for a tracking of hazardous waste streams  from  their  generation to their
disposal, 3) the total elimination of hazardous waste generation at any facility  is not practical
with today's technology and associated costs. The possible improvement of these treatment
systems would however, still support the HazMin goals of generating less hazardous waste for
off-site disposal. See Figure II for a typical example of this On-Site Treatment System database.
                                         382

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Building
123
456
789
012
Waste
Treatment
Facility
Oily waste
system
Pink Water
Open
Detonation
Open
Burning
Waste
Oils, oily
sludge
TNT+ RDX
wastewater
Lead Azide
Wet scrap
pyrotechnic
mix.
Volume
Treated
per year
10,000
KG
1000 Gal.
1400 KG
27,000
KG
EPA
ID #
D008
K047
D003
K044
Contrib.
Process
Forging,
machine
clean-up
Washdown
QA/QC
House-
keeping
Building
Source.
123
C-12, C-
23, C-34
098,765
1,2, 3, 4,
etc.
                            Figure II, Phase I Database for
                      On-Site Hazardous Waste Treatment Systems

Phase I was a requirement of the initial project management plan. It was believed that the
complexity of the Army facilities necessitated a facility-wide hazardous waste profile before
implementing the EPA Waste Opportunity Assessment Manual. These two databases, one for the
generators and the other for the on-site treatment facilities, allowed for all the project participants
to gain the same perspective on that facility's hazardous waste profile.  Agreement on the
number, type, location and processes involved was then reached. Phase I became the foundation
which Phase II, the auditing, and Phase III,  the recommendations, could then be confidently
constructed.

PHASE II - QUALITATIVE AUDITING

The Phase I database allowed for a broad understanding of each facility's hazardous waste
generation and treatment. The needed detailed information on each stream and system is
gathered during Phase  II. The outline used to gather this information  mirrored the Manual's
approach. The Phase II  information goals were to complete as accurate a mass balance of each
hazardous waste generator as possible. Details as to raw material purchases, process flows,
waste types, and quantities, etc. were collected and analyzed.  The method utilized to collect this
data included interviewing shop personnel and plant environmental staff.  The collected data was
used to understand the hazardous waste generating process and to determine  if potential HazMin
recommendations were feasible within the scope of other production requirements.

PHASE III - HAZMIN RECOMMENDATIONS

Each of the six plants  visited has an active HazMin  Program as required by AMC. These
AMC/PBMA studies were intended to provide additional technical support to the facility's
HazMin plans. The use of an outside audit team can provide valuable new insights and serves to
highlight the importance placed on HazMin  by the Army. Although these studies  are still in
progress, valuable recommendations  have  been identified at each of the  sites.   HazMin
recommendations identified fall into 3 major categories, which we have termed employee
awareness, minor technical changes, and process/ procedural changes.
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Within the "Employee Awareness" category, we have identified a number of areas where
education, better housekeeping, and increased awareness would reduce quantities of waste
generated.  For example, we have identified areas where solid waste  is placed in hazardous
waste containers. Poor housekeeping procedures observed could result in spills of material
generating significant quantities of clean-up wastes. We have also identified areas where a plant
is overcautious in environmental matters.  This results in increased costs which are not really
justified, and may even have some negative environmental effects such as utilizing hazardous
waste landfill space that is not really necessary.

"Minor Technical Changes" is another area where improvements can be made.  Plants are
substituting alkaline cleaners (which are non-hazardous) in some degreasing operations where
1,1,1 trichloroethane is currently used.  On-site stills can be utilized for solvent reclamation.
Filter presses can dewater sludges resulting in decreased volumes for waste disposal.  Solvent
contaminated and explosive contaminated rags can be washed. These are just a few examples of
audit team recommendations or ideas that have already been implemented by plants.

"Process/procedual changes" can be costly to implement, and may need extensive documentation
to prove  their validity to plant managers and project officers.  We are currently investigating
whether changes to a pink water ( TNT) treatment plant could reduce waste generation.  It is
possible  that reducing the temperature of water entering the plant would allow for increased
settling of materials and would decrease the amount of anthrafilt needed for filtration purposes.
On explosive lines, conveyors and part holders may become contaminated with explosive
materials. At one plant, ultrasonic cleaning utilizing freon is the method currently used for
cleaning  conveyors and parts, and we will investigate the use of steam clean-out procedures for
this same purpose.  At another plant, a mixture of solvent and lubricant is used to lubricate
production parts. When the lubricant is depleted from the solvent carrier, perfectly good solvent
is then disposed. We are investigating procedures to determine the amount of oil necessary to
replenish the depleted solvent to meet the lubricating needs of the production line.  These
examples are in their initial phase of development and are only included here to give a general
feel for the types of waste minimization recommendations being investigated.

                                 LESSONS LEARNED

The following observations deal with experiences the authors had at these six Army facilities, all
of which have over 100+ hazardous waste streams. These  issues/ suggestions may aid those
professionals who need to conduct HazMin investigations at similarly sized facilities.

1. Conduct a Phase I Investigation
Phase I provides an "order of magnitude" view of the entire facility before implementing EPA's
Manual.  Without a clear view of all  hazardous waste  streams, a thorough facility HazMin
opportunity assessment cannot be accomplished.

2. Hazardous Waste Treatment Systems
HazMin should include an investigation of how to improve the on-site hazardous waste treatment
systems.  Although the primary goal of HazMin is source reduction, the reality of HazMin is that
technological solutions for all the waste streams do not now exist. The ability  to improve the
efficiency of any on-site waste treatment system will translate into less waste leaving a facility.

3. Allow  for Data Verification
The need for accurate data regarding raw materials, process operations, and types and volumes
of waste  produced is required for meaningful reduction recommendations. Typically, hazardous
waste generation involves many people and not all the needed information regarding a hazardous
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waste stream is known by any individual. Therefore, collected data has to be reviewed by many
people , not just the facility environmental staff, to insure that the information is complete and
accurate. The HazMin investigation should recognize this fact and allow for purposeful delays
between each of the three phases for verification.

4. Organizational Issues
The emphasis on organizational/personnel issues cannot be over stated. HazMin technical
aspects involve a through understanding of chemical and mechanical processes which generate
the waste(s). It has been our experience that the technical aspects require the participation of a
well seasoned professional team. However, the personnel and management aspects are equally
important. Management support, the cooperation of the facility's environmental staff and the
line supervisors, are key factors for the successful completion of this project.

5. Manual Forms
The various forms which appear in the Manual are well organized and are written in a logical,
useable format.  As helpful as these forms are to  engineers/scientists; they are, however,
intimidating to non-technical people. These forms were modified for use in this project to allow
for ease of completion by both the project participants and some waste generator supervisors
who were not interested in reading or understanding what the questions really involved. Those
professionals involved with conducting a HazMin investigation may want to prepare hybrids of
EPA forms to forestall the reluctance of some process supervisors to complete them.

6. Institutionalize HazMin
Many operations at the plant are not amenable to HazMin measures by the audit team.  Once a
production line has been established, HazMin possibilities  may be lost or may require large
capital expenditures  to modify an existing system. It is therefore critical that  HazMin be
incorporated as early as possible into the research and development and design process. Other
limitations at a facility result from  requirements to follow military specifications. For example,
changes in paint from oil-base to latex materials cannot be recommended as this would violate
an  existing military specification.  The ASARDA study recognizes this HazMin issue and is
working through other HazMin projects to modify various military specifications to remove the
hazardous constituents where feasible.

7. Ongoing HazMin
HazMin is a continuous process which must be constantly reviewed and evaluated. Changes in
production, funding availability, technology improvements, and new environmental regulations
all  will impact, upon reduction recommendations.  This HazMin investigation has tried to
incorporate both immediate and long-term recommendations based upon economic cost analysis.
Some HazMin concepts will require research and development as well as pilot studies to
determine their potential value and feasibility.

8. Avoid Temptation
In  the course of preparing HazMin recommendations, the temptation exists to reduce waste
volumes in any way possible.  However, production line quality cannot suffer as a result of
recommendations. Also, the temptation exists to reduce waste volumes in ways  that may not
significantly impact environmental quality. Examples of this are recommendations to dewater
sludges and stabilize/fix certain waste streams. While useful  for HazMin accounting purposes ,
these measures still result in the same amount of pollutants being generated.  Another temptation
is to ignore the waste streams which do not appear in waste manifests. One example is volatile
organic compounds  (VOC's) emitted directly to the atmosphere.  A comprehensive HazMin
investigation will assess this waste  stream, and propose reduction recommendations.
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9. MSDS Information
It is suggested that consideration be given to including HazMin recommendations on each
chemical's Material Safety Data Sheet (MSDS).  MSDS's are required to accompany all
purchases of chemicals by Army procurement regulations. These sheets describe a host of
chemical characteristics but neglect to add HazMin options. A HazMin section would help to
remind personnel of possible options before sending the waste for disposal.

                                    SUMMARY

The Army Materiel Command is actively searching for opportunities (in cooperation with the
other services, industry, and academia) to reduce its generation of hazardous waste. A number
of efforts to identify both Army-wide and individual facility HazMin opportunities are now
underway. The building block for identification of target waste streams and processes is the
database developed during the three phase HazMin audits. This audit allows for similar waste
streams to be grouped together allowing for efficiency in selecting the most appropriate HazMin
recommendations for that waste category. HazMin recommendations include specific capital
projects, process changes, and encouraging management initiatives.  The Army program
provides valuable lessons learned for other large scale waste minimization efforts.

                              ACKNOWLEDGMENTS

The authors wish to acknowledge the assistance of various Army persennel who  assisted in this
project including  Major  Peter von-Szilassy P. E., AMC, and Messrs. Robert Scola P.E.,
Andrew Perich, Rocco LoPrete, W. Gil Myers and Captain Roderick Walton of PBMA . The
authors wish  to thank all the Army facility staffs and contractor -  operator staffs for their
cooperation.

                                   REFERENCES

1. Waste Minimization Opportunity Assessment Manual, US Environmental Protection Agency,
EPA/625/7-88/003, Jan 1989.

2. Resource Conservation and Recovery Act, Hazardous and Solid Waste Amendments of 1984.

3. Michael D. Robinson, Stephen L. Kister, Ching-San Huang, and David  C. Guzewich,
"Hazardous Waste Minimization Studies  at US Army Materiel Command Installations", US
Army Environmental Hygiene Agency, Aberdeen Proving Ground, MD. 21010-5422, presented
at the 13th Annual Environmental Quality  R&D Symposium, Nov. 15-17, 1988, Williamsburg,
Virginia.

4. Army Materiel Command Hazardous Waste Minimization Plan, 18 Jan 1989.
   The opinions or assertions contained herein are the private views of the authors, and do not
 necessarily reflect the views of the United States Department of Defense or the Department of the
                                       Army.               	
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     IMPLEMENTING  INCENTIVES:  EXPERIENCE AND EXPECTATIONS

              by:  Michael H. Levin
                   Nixon, Hargrave, Devans & Doyle
                   Washington, B.C.
    "Waste    minimization"    (WM)    has   become    "pollution
prevention"	a term  which  has  been  forcefully  incorporated in
bills  to   make  EPA   a   Cabinet  department,^'   and  implies
reduction  of  residuals  throughout  the  production cycle,  not
just at disposal.  The  term  also  confuses means  and ends,  since
it  implies  that continued  reduction  is  good  per  s_e_.   But  the
goal  is  defined  reductions  in   risk  or  environmental  impact.
Reducing to  zero  is  not an end in itself  in  a world of limited
resources; if  the  goal  cannot be stated  or  little  reduction in
risk or impact  would  result,  there  is no apparent  justification
to  "prevent."   Finally, the  term implies new tensions between
regulatory means,  since prevention entails changes in behavior
and debate is already rising over the best mechanisms	
pollution fees,  marketable  permits,  or  the  negative incentives
of command-and-control regulation	to effect  such  change.

    Regardless  of  whether  prevention means  more  than  a  shift
away  from end-of-pipe  controls   to  avoid  intermedia  transfers
and diminishing regulatory returns	and  regardless  of whether
it  applies  just to hazardous waste,  to solid waste,  or  to  air
and  water   emissions  as  well	it   envisions   unprecedented
changes in  raw materials,  products,  production  processes,  and
disposal  practices.    These  changes   will   collide  with  the
inherent  limits  of   traditional  regulation,   requiring use  of
incentives for  their successful implementation.

    This  paper  first suggests why  use  of  incentive approaches
for pollution  prevention will  likely  be incremental, even where
•I'  See., e.g. ,  H.R.  3847,  101st  Cong.  2d.  Sess.  § 110,  passed
by  House   March 28,   1990  (requiring   a   new  EPA  Assistant
Secretary for Pollution Prevention).
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rules are being written  on a clean slate.   It  then  traces this
country's  considerable  use  of  such  approaches  to  transcend
traditional  regulatory  limits	experience  which  will  shape
future applications.   Finally,  it  distills  some  principles  for
implementing pollution prevention  as that  concept moves towards
a reality difficult to foresee.
                  I.   INCENTIVES AS  SUPPLEMENTS

    Incentive or market-based approaches will  likely be used as
supplements to  current  regulatory systems, not  as  alternatives
or replacements.  First, for most pollution this country is not
writing on a clean  slate.   Detailed regulatory systems mandated
and closely monitored by Congress already exist, and the power
of  the  familiar cannot be  overstressed.   Neither  industry,
states or  environmental groups,  nor  the  public  is  prepared to
scrap  those  systems  for uncertain  and potentially  disruptive
alternatives.    However  imperfect,   they  will   stick  with  the
devil they know.

    Second,  existing  regimes  are   savage  competitors  against
innovative alternatives.   Regulatory  systems  are  like  natural
ones	they  have  evolved  to  stable  equilibria,   and  resist
attempts  to  push  them in  different  directions.   Less  often
noted  are  the  reasons  for  such  competition,  which  range  from
asserted  ease   of   enforcement   ("is  the   required  equipment
installed?")    to   fears   that    government    jobs   will   be
transformed.   The  most  powerful  of  these  reasons  is  the  fact
that  the  traditional approach has  produced  large environmental
gains, for costs that have  mostly been hidden.   Any alternative
which seems to  erode such gains  in  the name  of  efficiency will
be   rejected.     Incentives  must    first   be   justified   on
environmental  grounds	as  ways  to  preserve  or extend  these
gains.  Only  a  hybrid  system,  in  which  incentives  supplement
direct   regulation   by   addressing   specific,   acknowledged
shortfalls in securing  further progress, is likely to do that.

    Third,  one  trend  on  Capitol   Hill  is   strongly  in  the
opposite direction	towards  more  detailed mandates  which  seek
to  limit  both  Agency  discretion   and   industry  compliance
flexibility.   E.g..  the 1984  amendments  to  RCRA progressively
banned  all  solvents,  chemicals  and  other  wastes  listed  or
characterized  as  hazardous  from  disposal  even  in  properly
permitted  double-lined   landfills,  unless  EPA  promptly  issued
national  technology-based   standards  requiring  pretreatment  to
"best demonstrated  technology"  (BOAT)  levels  for each specific
waste  disposed  in   such  facilities.   Even  pending  clean  air
bills  which  incorporate  sweeping  incentive  mechanisms  feature
stringent  reductions   and   bristling  commands	a  connection
which is not accidental.
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    Fourth, much  Congressional  effort has been  spent  buffering
the effects of environmental  policy	in  assuring  there are not
too many  big  losers too  soon.   Yet  pure  incentives  approaches
are intended to produce large groups  of winners  and losers very
rapidly	by  efficiently  "internalizing   pollution  costs"  or
"making  polluters   pay."    Moreover,  as   acid   rain  debates
demonstrate, many of these  losers  are likely to  be clustered in
the same  Congressional  districts.    Thus,  the "pure"  approach
does not stand much political chance.

    Finally,  past  experience  with   incentive  approaches  will
critically   shape   both   future   approaches  and   industry's
response.    E.g..  constraints   that  make   it  difficult  to  use
emissions  trades   for   cost-effective compliance  with  current
smog rules will discourage  investment in  surplus  S02  reductions
for acid rain.  Even for  pollution prevention a  clean  slate may
be hard  to find:    beyond  current  incentives  to  reduce created
by Superfund or tort liability,  explicit  incentives for process
or  product reformulation  to escape  the  Air Toxics  Title  of
pending  Clean  Air  bills  mean  that  prevention  has  already
arrived.
              II.   LIMITS  OF  TRADITIONAL REGULATION

    The problem is no  longer large  uncontrolled steel plants or
utilities  susceptible  to  standard  engineering  solutions.   The
stresses of  dealing  with the remaining universe,  combined with
budget   shortfalls,    trade   deficits,    and   concerns   over
international  competition,   have   faced   regulators   with  the
structural constraints on direct regulation:

    •    poor agency information about further feasible ways to
control  the   thousands   of  diverse,  changing   products  and
processes that contribute most remaining  pollution;

    •    soaring  control  costs.   estimated   by  EPA  to  have
exceeded a  half-trillion dollars since Earth Day 1970  and now
run   $80   billion  per   year,   not  counting   state   laws,
recordkeeping   and  reporting   (e.g..   SARA  Title   III)   or
opportunity costs;

    •    slow   government   response   to   new  knowledge   and
rapidly-changing  industrial  circumstances  through  centralized
rules  tailored  to  individual  processes  or chemicals.   Such
rules  require  volumes  of  feasibility  data,  take  years  to
complete,  and often  freeze  past  control  technologies  in place
rather than stimulating new ones;

    •    little  motivation  for regulated  emitters   to  do  or
disclose  more   than  the  minimum   required  (or  unregulated
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emitters  to  disclose  anything),  since  disclosure  offers  no
benefits while making them targets for further regulation; and

    •    the  "pollution  problems  of   the   1990's":    filling
stations,   farms,   commuters  and  millions   of   other   small
dispersed sources  of  smog,  runoff or  groundwater contamination
whose effective  control often turns  on local  or site-specific
factors, land use, or  lifestyle  changes; and  regional  or  global
problems  caused  either  by  hundreds  of  dispersed  activities
involving products rather than classic  pollution (stratospheric
ozone depletion),  or  by large controlled sources whose further
direct  control   often means  new  ways  of  doing business  and
invokes vicious regional disputes (global warming or acid rain).

         Such  problems   already  dominate   the  environmental
universe, and  are not  very  amenable  to centralized  regulation
or   enforcement.    Whether   the   incentives   are   financial,
informational  or  technical,  only   a   shift  from  regulation
towards  incentives   can  begin   to   overcome  them  by  better
matching individual private interests  with environmental goals.
                   III.  EXPANDING EXPERIENCE

    In  response  EPA  and the  Congress have  embraced  or  begun
seriously   exploring   a   broad   range   of   incentive-based
approaches.  EPA's Final Emissions  Trading  Policy (51 FR 43814;
Dec. 4, 1986)	which  set federal  rules  authorizing emitters to
create,  store  ("bank")  and   substitute  inexpensive  "extra"
emission  reductions  for  costly required  ones	is  merely  one
example.   But  because  this  "Bubble"  policy was  the  first,  has
been  thoroughly  tested,  and   provided   the  base  for  broader
applications,  it  is worth   noting  that   it  has  saved American
industry  nearly  a  billion  dollars  over  the  cost  of  uniform
stack-by-stack  controls, with  equal or  better  environmental
results;   balances   flexible   compliance  with   environmental
integrity  through  stringent  safeguards  against  "non-surplus"
reductions,  adverse   ambient   effects   or   incidental  toxics
increases; provides needed  safety  valves  allowing adjustment of
national   rules   to   site-specific   conditions;   and  protects
sources that  bank or  trade  against loss of  credits  if further
reductions  to  meet  health   standards  are  required.   Moreover,
the central  issue  it resolves	how  to  construct an objective,
predictable  "baseline" which fairly measures  "extra" reductions
without penalizing  early ones or  crediting  those  that  "would
have  happened  anyway"  through  routine  compliance  or business
decisions	is  crucial   for  any  use   of   incentives.    Such
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certainty  is  essential  where sources  are  asked  to  invest  in
extra reductions, and show they have made them.l'

    A short list of related initiatives might include:

    •    EPA's  NSPS  Compliance  Bubble  Policy  (52 FR  29046;
Aug. 4,  1987),  which  expressly  authorizes  emissions  trades
between different  "new  facilities"  to  meet technology-based New
Source  Performance Standards  (NSPS).   The  first  approved  NSPS
bubble was estimated to  save  a single  utility station up to $22
million annually over the  cost of conventional compliance,  with
about 2000 tons per year additional reductions in S02•

    •    EPA  "Netting"  Guidance  (Feb.  27,   1987)  giving states
broad  discretion  to  allow  plantwide  bubbles  that  encourage
modernization  without  cumbersome  "new  source  review"  (NSR).
Past "netting"  transactions  may have saved  at  least $5 billion
over the costs  of  conventional NSR,  without adverse air quality
effects.   See  Hahn & Hester,  "Marketable  Permits:   Theory and
Practice," Ecology Law Quarterly. Vol.   16 No. 2  (1989).

    •    EPA's   Stack  Height   Policy   authorizing  utilities
required  to  reduce  SO? emissions  under  tall  stack  rules,  to
make such  reductions through  statewide bubbles based  on total
loadings.   (53  FR   480;   Jan.  7,   1988).    The  final  Policy
selected  the  least  constrained  options;  opened  the  door  to
bubble  credits from  Least Emissions  Dispatching  (under  which
utilities  direct  more generation to lower-emitting rather  than
lower-cost  facilities);  and  was  estimated  to  save   affected
sources as much as 60% of compliance  costs, with nearly 50,000
tons per year more reductions.

    •    Lead  Phasedown  Trading  which  effectively implemented  a
nationwide marketable permit  system, based on ordinary  business
records,  for  refiners   who  reduced  average  lead  content  of
leaded  gasoline  below   a  shrinking  EPA  limit.    The   approach
yielded  "lead  reduction credits" which were sold  or bought  by
most of the industry;  accelerated  a  90% reduction  of  lead  in
gasoline  while avoiding  risks to  small  refiners  and  gasoline
supplies;  and   saved  several  hundred  million dollars  over the
cost  of  uniform  compliance   at  each  refinery.   See.  Hahn   &
Hester, supra;  50 FR 13116 (April 2, 1985).
—/  See,  e.g. .  Levin,  "Statutes and  Stopping  Points:   Building
a  Better Bubble  at  EPA,"  Regulation (March/April  1985).   See
also.  Levin  & Elman,  "The Case for  Environmental Incentives,"
Environmental Forum  (Jan./Feb.  1990); "The Clean  Air  Act Needs
Sensible Emissions Trading," Id. (March 1986).
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    •    CFG  permits  to  reduce  stratospheric  ozone  depletion.
U.N.  protocols   mandating   a  freeze  and   50%   phasedown  in
manufacture of these  substances  provide  a continent-wide bubble
for EEC countries and transboundary  bubbles  for others.   EPA is
implementing  this  first  global  regulatory effort  through  a
system  of  marketable  phasedown  permits  for CFC  manufacturers
and  importers,  allocated  by  historical  production  factors.
Proposed  supplementary  fees  to  remove   windfall  profits  have
been  superseded   by  Congress' first-ever environmental  excise
tax on these substances.  See Levin & Elman,  supra.

    •    Mobile  source   trades.   EPA  has long  allowed  use  of
emission   reduction   credits  from   mobile   sources   to  meet
stationary-source  requirements.    51  FR  at  43834  (April 7,
1982).   It has  also  authorized  use  of  fleetwide  bubbles  to
comply with  truck emission  standards  under  the Clean  Air Act,
saving  an  estimated  several  hundred  million dollars  per year
over the costs of engine-by-engine compliance  (see  50  FR 10606
(March 15,  1985)),  and  recently proposed interfleet,  multiyear
trading among  different engine makers to expand  these  effects.
54 ER 22652 (May 25, 1989).

    •    Risk  Bubbles.    In  1986  the Conservation  Foundation
proposed  authorizing  EPA  to approve up  to  10  applications
waiving compliance  with traditional  regulatory requirements if
applicants showed under  specified criteria  that  significantly
greater  risk  reduction  would result  from alternative  actions.
The  approach,  meant  to  use  existing rules as  an engine  for
better  knowledge  and   risk  reduction,    has  effectively  been
included  in  EPA's  draft pollution  prevention bill  (March 15,
1990 draft, § 203).lx
!•/  Similar  developments  include:   expanded  ability  to  use
emissions credits  from  past  shutdowns  without  EPA review,  54 FR
27274, 27290  (June 28,  1989);  plantwide trades to meet effluent
guidelines,  49  FR  21024  (May 17,  1984);  interplant  trades to
meet  ambient  water quality standards,  40  CFR  § 130.2(1),  130.7
(1989); point/non-point source  trades  to reduce nonconventional
or  toxic  loadings, EPA/OW,  Draft Final Guidance:   § 304(1) of
the  Clean  Water   Act.  § IV.C.d.2.  (Sept.   1987);  differential
user   fees   for  pesticide  registrations,  see   51   FR  42974
(Nov.  26,  1986),  53 FR 19108 (May 26,  1988);  a pending measure
to  automatically  phase  out  risky chemicals as  safer substitutes
become  available,   see  Memo,   "Proposed   'Safer  Pesticides'
Federal  Register   Notice,"  D.  Campt,  Director,  OPP/EPA,  to J.
Moore,  AA  (OPTS),  (June 17,    1987);  and  use  of  wetlands
mitigation  banks  to  reclaim  ecological  values  at  Superfund
sites  or   preserve  them  at   others.    See   Memo,   "Wetlands
Mitigation  Banking," R. Hanmer,  Acting AA  (OW) to L.  Fisher, AA
(OPPE) (May 1,  1989).
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    •    The  new  Clean  Air  Act,  which  features  a  national
trading/banking/auction  system  of  true  marketable  permits  for
SOo  credits to  achieve  a  10-million-ton  annual reduction  in
acid   rain   precursors   for    roughly   half    the   cost   of
plant-by-plant  controls,   but   may  also   envision  plantwide
bubbles  to  meet  new   air  toxics  requirements,   plus  broad
regional trades to meet  mandates  for  smog  reduction, clean cars
and fuels.  The  Act  represents  a quantum  leap  in Congressional
and  environmental-group  support  for  incentive  approaches  (as
well as  in  industry  reliance on  them  for  flexible compliance),
and has already accelerated their use elsewhere.-^'

    •    Recycling Tickets.   EPA's 1986  Report  to  Congress  on
Waste Minimization suggested  that if further controls  on waste
generation  become needed,  a  route preferable to WM standards or
bans  on waste  streams  might  be  tradeable phasedown  permits
which  let   market  forces  determine the  location  and   pace  of
individual  reductions.   Under  a  similar  approach developed  by
EPA to  address  the  millions of  gallons per  year  of  used engine
oil that are dumped  due  to  negative prices,  virgin oil  refiners
would need  tickets representing  one gallon of properly  recycled
oil  for every  four  new  gallons  produced; tradeable  tickets
would   be   generated  by  oil   recyclers  or  rerefiners;   and
recycling could  yield substantial  returns  from  these  tickets'
sale.

    The  original  approach was meant  to help  finance  recycling
facilities  by allowing  them  to generate  a  double revenue stream
(from sales of  tickets  plus recycled  oil).   But  it  could also
have endangered  lube oil supplies if  the  recycling ratio  was
set  too  high  or  the   recycling  market   could  not  promptly
respond.  Pending  House  and Senate bills to  establish similar
ticket  systems  would  correct   this  problem  by  imposing  on
producers or  importers  of  virgin  oil,  newsprint and  tires  an
escalating   recycling   mandate   (rather   than   a   production
constraint),  which  can  be met either  by self-recycling  or
purchase of covering tickets from downstream  recyclers.   See.
e.g. . H.R.  3735,  § 208   (used oil); H.R.  3483 (newsprint);  H.R.
4147 (scrap tires).   The tire bill  attempts  to  address  the fact
that  scrap  tires  cannot be  recycled into  new  virgin product
^  See, e.g.. Project  88;   Harnessing  Market Forces to Protect
Our Environment:   Initiatives for  The  New President.  A Public
Policy  Study Sponsored by  Sen.  T. Wirth  fD-Coll  and  J.  Heinz
FR-Pal   (Dec.   1988).   advancing   a   comprehensive   bipartisan
program of which acid-rain trades were only the first step.
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through  a  differential  credit  system aimed  at  drawing scrap
tires towards their highest-value secondary use.I''

    These  bills  would  shift  responsibility  to  producers  for
minimizing  waste caused  as  a result  of  their  products.  They
provide  suggestive  models for  aspects of  pollution prevention
discussed below.
     IV.  TRADEABLE POLLUTION PREVENTION PHASEDOWN PERMITS:
                         ANOTHER ROUTE?

    Clearinghouses  for  further  WM  seem   unlikely  to  provide
incentives  to use  that data  beyond  those already created by
landfill  bans,  potential  Superfund/tort  liability, and rising
tip  fees.2/   Indeed,  to  the  extent  downstream  liabilities
cannot  be  quantified  to  overcome   internal  company  "hurdle
rates"  for  returns on  additional  WM  investment,  such  data may
not be used at all.

    Two  major models  currently  seek  to   address  this  issue:
proposals  for  (a) mandatory  WM   audits  and  reduction  plans,
applicable  to facilities that  must file annual  Toxics Release
Inventory (TRI) reports under  SARA Title  III and enforceable by
public  disclosure;   and  (b) per-pound  or  differential  fees,
imposed  either  on   facilities'   TRI   inventories  or  on  new
materials ending  as  solid waste  (e.g.. plastic  resins).  There
are  arguments  for   both.   But  mandatory  WM  plans  turn  on
companies'  good-faith  execution  of  WM audits,   could  promote
risky  substitutes  because they cover only a  small segment of
                    and  seem  likely  to  generate   a  flood  of
                   reviewed.   Meaningful
                  cost  curves  and total
                   to  affect  behavior
                   small slice  of  most
                   to  zero  regardless
                    small   fee   imposed
the  HW  universe,
paperwork  seldom
data on  industry
set  high  enough
represent  only a
imply  reductions
Moreover,  even  a
allowable
desirable
ducks  the
           pollution
           directions
           issue  of
                    fees  require detailed
                    releases;  could not be
                    because  new  materials
                    finished  products;  and
                    of   risk  or  location.
                   on  the  last  slice  of
     meant  to   move  those  assessed  in
 and get  company  management  involved  --
what  reduction   goal  is  appropriate,  and
    See  Levin,  Written  [Testimony!.   Hearing  on  Scrap  Tire
Management  &  Recycling  Opportunities.  House  Small  Business
Subcommittees  on Environment  & Labor  etc.  (April  18,  1990).

^  See, e.g.. Levin,  "The  Trash Mess Won't  Be  Easily Disposed
Of,"   Wall   Street   Journal    (Dec.   15,   1988),   p.  A   18.
                              394

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could  undermine  valuable  behavior  if,   e.g.,  materials  being
recycled are also taxed.^

    Tradeable  phasedown  permits  for  solid  or  HW  generators
based  on historical  waste  generation  could  overcome many  of
these  problems,  link means  with ends,  and force  decisions  on
how much prevention is  appropriate.   While what  follows  deals
with   SW  involving  only   reductions   in  volume,   the   same
implementation  issues   apply   to   HW,   since  "toxic  hotspot"
concerns are  reduced  by the fact that all  HW generated remains
subject  to  RCRA management  rules.^   Those  issues  include who
to  permit;  how  to  measure  creditable  reductions;  whether and
how  to  use  "trade  ratios"  to  encourage  reduction  of  riskier
substances;  how to minimize  such  perverse  effects  as use  of
riskier  nonpermitted  substitutes;   and  how to  construct  safety
valves  that will  allow  the permit  system to  be  expanded  or
tightened   without   penalizing   those    who    have   already
participated.  Past experience suggests numerous answers.

    Suppose EPA,  instead of  mandating  reductions by generators,
were  to  issue  tradeable permits  requiring  municipal/private
landfills to  receive  2% less waste/year  for  the  next 10 years,
beyond pending  25%  recycling goals.  A city  like  Seattle which
recycles 40% would  get  both  assets  to  sell and a double revenue
stream  (from  sale of  credits  plus  extended landfill capacity).
A city like New York  which bought  those  credits to cover excess
landfilling would pay a double  penalty,  since  it  both exhausts
capacity more  rapidly and  pays Seattle  to do so.  This approach
would   mirror    the    credit    system   for  used   oil,   with
^  Despite  their attraction  as potential  revenue-raisers and
possible  use  as  a   "Clarke  tax"  to  encourage  more  accurate
pollution   reporting,   see.   e.g..   "Apple-Pie   Aspect   of
Environmental   Taxes  Draws   Proponents .  .  .,"    Wall   Street
Journal  (May  21,  1990),  p.  A  30;  "Truth  or  Consequences,"
Sonstelie  &  Portney,  Journal of Public Policy  Analysis.  Vol.  2
No. 2  (1983),  fees represent a declining  revenue  stream if they
work  properly,  and  could  distort  other  environmental  programs
by diverting industry choices to counterproductive  ends.


W  C_f_., e.g..  S.  1113,  101st.  Cong. 2d Sess. Title III, § 305,
tacitly  authorizing  plantwide bubbles  by  SARA  §  313 facilities
required  to  reduce  total  hazardous-substance  releases  to  no
more  than  5%   "of production  throughput"  of  such substances
within  10  years.   Facilities reducing  more or  earlier  could be
allowed  to  sell   credits  nationwide  to  those whose  reduction
costs were much higher.
                               395

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responsibility  imposed  on  the   "end-user"   rather   than  the
producer.  It  raises  classic questions,  not  least of  which is
how  to  credit  landfills that  shut  down.   But  it could  also
reward  innovative  SW  management   steps  and  provide  funds  for
such  measures,  while  strengthening  recycling  and  recognizing
that  the  test  is  reduction of  overall  environmental  impacts,
not waste.

    In  implementing   such   approaches,  some  do's  and  don't's
drawn from  past experience  should be kept  in  mind.    The  do's
include:   (1)  keep  the  approach   small  so  bugs  can  be  worked
out,  but  address  the  ability  to   expand  it  up front  (e.g. .  by
incorporating   "trade   ratios"   for  dealing   with  incidental
toxics).  Note that "small"  can refer either  to the universe of
sources  covered,   the  number  of  pollutants   covered,  or  the
initial size  of the  reduction required;  (2) keep  it  simple and
easy  to  use;  (3)  keep  it  predictable,  so potential  preventers
feel  comfortable they  won't be penalized for their actions and
can make  rational  investment decisions;  (4)  get  it out  on the
street  to  be  used,   so   specific   applications  can  provide
vehicles for midcourse  corrections and  dispel  regulatory fears;
(5) include safety valves  that allow  for such corrections and
for  inevitable evolution,  without  penalizing  those  who  have
already participated.

    The  don't's  include   avoid:    (1)  over-loading   incentive
approaches with constraints  aimed  at  achieving  other  program or
environmental  goals;   (2) defining the  experiment to  fail  by
seeking  optimality  in  credit markets  or  reductions   to  zero,
both  of  which are unrealistic  and divert resources  from tasks
based  on  sensible  expectations;   (3)  the  belief  that  every
problem  will   be  solved  by  mandated  technology  or  reduction
requirements;    (4) discouraging  new  technologies   (e.g.,   by
treating  potential  recyclables as  pollution);  the belief  that
government has all the  answers  and knows  "how to  do it" better,
or  that  states  are  incompetent and spineless,  therefore  not to
be  trusted;  and  (5)  the belief that  incentive  approaches (or
conventional  rules)  must  be written  to  treat  all  industrial
managers  like criminals by precluding every  chance  of  abuse,
rather  than  being written  to  be  usable and  leave abusers to
enforcement.
                              *  *  *
    Mr. Levin, Director of  the  U.S.  EPA's Regulatory Reform and
Regulatory Innovation Staffs  (1979-88),  practices environmental
law and environmental facilities finance in Washington, D.C.
                              396

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              IGT BIOPROCESS TECHNOLOGY DEVELOPMENT EFFORTS FOR
                        THE PRODUCTION OF CLEAN FUELS
            by:  Andrea Maka
                 Vipul J. Srivastava
                 Institute of Gas Technology
                 Chicago, Illinois  60616
     The Institute of Gas Technology (IGT) has been developing bioprocess
technologies for the production of clean fuels since 1970.  The scope of
these efforts has ranged from the laboratory through pilot plant using a
variety of feedstocks:  waste, biomass, peat, coal, oil shale, oil and
gases.  Some of the recent and ongoing research efforts are cleaning coal,
char, oil shale, and gases by microbial removal of sulfur and microbial
solubilization of coal to liquid fuels.  Development of such pollution
preventive bioprocess technologies involves the integration of microbial,
physical, and chemical systems and requires a concerted effort by engineers
and scientists.

     This paper discusses the research being conducted at IGT in the area of
microbial desulfurization of coal, char, sour natural gas and Eastern oil
shale and in the area of microbial conversion (solubilization/gasification)
of coal to liquid and gaseous fuels.  The paper also highlights the issues
and challenges facing the engineers and scientists in developing such
technologies.
                                     397

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                                INTRODUCTION
     The Institute of Gas Technology (IGT) has been developing bioprocess
technologies for the production of clean fuels from various feedstocks that
include biomass, waste, coal, oil shale, and gas since 1970.  Researchers at
IGT have developed bioconversion processes with improved yields and rates
for the gasification of both marine and land biomass.  The marine biomass
work included studies with untried biological species and the development of
advanced process concepts for kelp conversion through anaerobic digestion.
The land biomass involved a similar evaluation of herbaceous and woody
species for energy production by biological and thermochemical
gasification.(1-4)

     IGT researchers have been investigating an innovative anaerobic
digestion concept at a pilot-scale experimental test unit (ETU) for the
conversion of wastes generated in or around a typical community in the
United States.  The 160-ft3 digester, located at Walt Disney World, Florida,
was successfully operated on blends of water hyacinth plants and primary
sludge.(5)

     IGT has patented a two-phase anaerobic digestion process for high-rate,
high-energy-efficiency and high-stability conversion of biomass and organic
wastes (municipal as well as industrial) to high-methane-content fuel.  Work
has been conducted on the conversion of municipal solid waste and sewage
sludge to methane by the two-phase digestion process in IGT's BIOGAS®
process that has the flexibility to combine pre- and post-treatment schemes
with two-phase digestion for conversion of municipal solid wastes to
methane.

     IGT has been conducting research since 1980 in the areas of microbial
desulfurization of coal and biocatalytic gas desulfurization and since 1986
has been conducting research in the area of microbial solubilization and
gasification of coal to liquid and gaseous fuels.

     This paper reviews IGT research efforts in the area of microbial desul-
furization of coal, char, oil shale and sour natural gas and in the area of
microbial conversion (solubilization/gasification) of coal to liquid and
gaseous fuels.

                            RESULTS OF DISCUSSION
MICROBIAL COAL DESULFURIZATION

     Under  a  research  program funded by U.S. DOE/PETC on microbial coal
desulfurization,  IGT has  succeeded  in developing bacterial cultures that
specifically  cleave carbon-sulfur bonds in a range of model organic
compounds.  Gas chromatography/mass spectroscopy (GC/MS) analyses have
indicated that these cultures are capable of removing the sulfur from the
organic  substrates while  leaving the carbon intact.  These cultures are the
mixed  culture IGTS7 and the  pure culture Rhodococcus rhodochorous IGTS8 (the
active component  in IGTS7).  In addition to removing the sulfur from model
                                    398

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organic compounds,  these  cultures also removed the organic sulfur from
Illinois No.  6 coal.(6)   A  sulfur-by-type analysis of the coal showed that
84% of the organic  sulfur was  removed.  These samples were analyzed by an
ASTM procedure in which the organic sulfur content is calculated.  To ensure
that accurate and reliable  data were obtained, samples were also analyzed by
a modified ASTM procedure,  in  which the organic sulfur content is actually
determined, and by  the electron microbeam method for the direct determina-
tion of organic sulfur.   Analysis of the samples by the modified ASTM
procedure showed a  decrease in the organic sulfur of 91%, from 2.25% to
0.205%.  An analysis of the samples by the electron microbeam method reveal-
ed an 80% decrease  in organic  sulfur.  These results are all in agreement
and therefore confirm the microbial removal of the organic sulfur from coal.

     To make  a bioprocess technology economically attractive, the rate and
efficiency of microbial desulfurization needs to be improved.  Such an
improvement will require  biological, thermal, physical and/or chemical
approaches.   Research is  currently focusing on enhancing coal biodesulfuri-
zation by genetic modification which involves, identifying, cloning, and
.enhancing .the expression  of the genes responsible for the cleavage of
carbon-sulfur bonds.  The availability of organo-sulfur compounds in coal to
microorganisms may  also be  a limiting factor in microbial coal biodesulfuri-
zation.  Recently CRSC has  announced the funding of two one-year studies at
IGT to determine if the rate and efficiency of biodesulfurization is
improved when the coal has  been modified by thermal, physical, and/or
chemical methods.   It is  believed that the availability of organo-sulfur
compounds to  microorganisms can be increased by increasing the pore size
distribution  through a thermal, physical, and/or chemical process.  A team
of chemical engineers and biologists will be working on these projects.

MICROBIAL CHAR DESULFURIZATION

     Under a  research program  funded by U.S. DOE/METC, IGT is examining the
mild thermal  gasification of Illinois coal to fractionate the coal to
produce liquid products such as benzene, toluene, creosote, etc.   The by-
product of this process is  char.  To make this process more attractive,
efforts are being made to significantly enhance the yield and quality of
coal-products such as char.  The char produced still retains a relatively
high volatile matter content and heating value; however,  the sulfur content
is too high to meet the U.S. Clean Air Act Standards for sulfur emissions
and therefore must be reduced  before it can be utilized as a clean fuel.
IGT conducted research to examine the ability of the mixed culture (IGTS7)
developed for coal desulfurization to remove organic sulfur from char and
demonstrated  microbial desulfurization of char.  In the presence of IGTS7,
60% of the organic sulfur was  removed.  Future bench scale studies are
planned to optimize the system.  It is anticipated the mild gasification of
coal to produce value-added chemicals combined with microbial desulfuriza-
tion of char  will result  in a  technology that will produce clean products
for both the  chemical and energy industries.

     Another  area of research  that IGT is involved in, with the idea of
developing a  clean coal conversion technology,  where microbial systems may
have application is in the microbial conversion (solubilization/
gasification) of coal to  liquid and gaseous fuels.
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MICROBIAL COAL SOLUBILIZATION

     Research on microbial solubilization of coal  generally uses pure
cultures of microorganisms, mainly fungi and actinomycetes.  The majority of
these organisms are lignin degraders.(7-12)  Under an internally funded
program, IGT isolated mixed cultures IGTB1 and IGTMxlS that were able to
solubilize coal.(13)

     The ability of the organisms to solubilize coal seems to be dependent
upon the oxidation state of the coal.(12)  Low rank coals such as lignite,
which have a higher oxygen content than high rank  coals,  are microbially
solubilized.  Low rank coals that have been chemically pretreated with
oxidants such as nitric acid or hydrogen peroxide  are even more susceptible
to microbial solubilization.  Studies at IGT examined the role of oxygen
content on solubilization and confirmed other researchers observations that
the microbial solubilization of coal is dependent  upon the oxidative state
of coal.

     The demonstration and confirmation by several researchers that oxidized
coal can be microbially solubilized has led efforts to be directed towards
elucidating the mechanism(s) involved in the solubilization
process.(8-9,14-15)  Researchers suggest that either an extracellular
process, an alkaline formation by microorganisms,  or a metal-chelating agent
produced by the microorganism is involved.  This research determined the
mechanism involved in coal solubilization.  The mechanism of solubilization
for the cultures IGTB1 and IGTMxlS was alkaline formation.

     Preliminary characterization of products from microbial coal solubili-
zation by gas chromatography/mass spectroscopy (GC/MS) as well as Fourier
transform infrared spectroscopy (FTIR) indicated the presence of humic acid
type compounds.  Future characterization of the products are needed to
identify their market value.

MICROBIAL COAL GASIFICATION

     Because it has been generally thought that coal is resistant to
anaerobic decomposition only recently has there been any research in
microbial coal gasification.  Researchers have now demonstrated the direct
conversion of coal to methane.(16)  The microbial  production of methane was
observed in samples containing coal and solubilized coal products in the
presence of complex nutrients such as yeast extract.  Short chain acids and
alcohols were identified as the intermediary metabolic products that
accumulated during the bioconversion of coal to methane.

     IGT's approach to biogasification is a two-stage process concept.(17)
Stage I is aerobic and involves combined alkaline-biocatalytic oxidation and
solubilization.  Stage II is anaerobic  and involves the anaerobic conver-
sion of the products generated from Stage I to methane.  Bench-scale studies
are underway to test the feasibility of this microbial solubilization/
gasification system.

     Besides the production of methane in this anaerobic biogasification
system, H-S would also be generated.  IGT is conducting research in the area
of microbial removal of HjS from such gas streams  and from sour natural gas.
                                    400

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MICROBIAL REMOVAL OF HjS

     IGT has identified two microorganisms Thiobacillus thioparus and
Chlorobium limicola forma thiosulfatophilum that can metabolize H2S.
Preliminary research conducted at IGT has demonstrated that the aerobic,
nonphotosynthetic, chemolithotrophic, organism Thiobacillus thioparus, is
capable of converting H2S to elemental sulfur, which is excreted to the
medium by the bacteria and, therefore, could be separated from the bacterial
cells and medium.  Analysis of elemental sulfur production indicated that
78% of the H2S was converted to sulfur.  Future bench-scale studies are
planned to optimize the Thiobacillus thioparus system for removal of H^S and
conversion to elemental sulfur.

     IGT has patented a process utilizing Chlorobium limicola forma
thiosulfatophilum for removal of H2S.(18)  Research has demonstrated that
the anaerobic, photosynthetic autotrophic organism, Chlorobium limicola
forma thiosulfatophilum is capable of converting H2S to elemental sulfur
which is e.xcreted to the medium by the bacteria, and, therefore could be
separated from the bacterial cells and medium.(19-21)  Analysis of elemental
sulfur production indicated that >90% of the H2S was converted to sulfur.
These organisms are being proposed for application in a primary process to
remove H-S from sour gas or in a secondary process to cleanup the tailgas
resulting from a conventional physical/chemical gas cleanup operation.

MICROBIAL OIL SHALE DESULFURIZATION

     One of the many processes that release H2S into the environment is oil
shale retorting.  Under a program funded by the U.S. DOE, IGT is conducting
a research program to develop a pressurized fluidized bed hydroretorting
(PFH) process for the production of oil from Eastern oil shale.  During this
process, the hydrogen reacts with the sulfur in oil shale to form H2S.  It
is economically desirable to reduce the consumption of hydrogen.  One of the
ways this can be achieved is by removal of the sulfur compounds from the oil
shale before it is retorted.

     Because of the promising results obtained in the microbial desulfuriza-
tion of coal, microbial desulfurization of oil shale may be feasible.(6)  As
part of the research performance for the PFH program, IGT conducted research
to examine the ability of the cultures developed for coal desulfurization as
well as cultures enriched from oil shale to remove the sulfur from shale.
In shake flask experiments, desulfurization of oil shale was demonstrated.
Chemical analyses of the sulfur content of the oil shale after 14 days
incubation indicated as much as 24% reduction of the sulfur content.  No
sulfur reduction in abiotic controls suggested that the reduction observed
was the result of biological action.  Future bench scale studies are planned
to optimize the system.

                                  CONCLUSION
     These  results  show  that  microbial  desulfurization systems have  the
potential for  application  in  clean coal and gas technologies and for the
production  of  clean fuels  such  as char.  Though these systems are developed
or under development,  they offer challenges that must be overcome before
                                     401

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they can have application in a clean technology.   In these microbial
systems, the rates and efficiencies of removal are often slow to look
economically competitive, therefore the rates and efficiencies must be
improved.  One approach to improving removal rates is through genetic
modification of the organism or modification of the coal or oil shale to
make them more amenable for targetted microbial reaction.  Currently, IGT is
utilizing this approach to enhance the coal biodesulfurization capability of
IGTS8.  With the use of any microbial systems, there is always the challenge
of successfully separating the clean product from the cell biomass without
any loss of product.  One approach that would eliminate the biomass
completely is to develop an enzyme system for desulfurization.  Also, the
microbial systems unlike chemical and physical systems, can be thermally,
chemically, and mechanically unstable, creating additional challenges in a
clean technology development.  Therefore, the physiology, genetics, and
biochemistry of the microbial system must be well understood and effectively
communicated to engineers and bioengineers for a successful development and
scale-up of bioprocesses.  With the participation of multidisciplinary teams
who focus on various aspects of the technology development, it is conceiv-
able that some of these technologies will be in the field before the turn of
this century on early in the next century.

     In conclusion, clean technologies can be developed for the production
of clean fuels by using microbial systems; however, further research is
needed by scientists and engineers to overcome the challenges that exist and
to insure that these technologies and products once developed are environ-
mentally attractive and economically viable.

                                  REFERENCES
 1.  Srivastava, V. J., Fannin, K. F. and Isaacson, H. R.  Methanogenic
     Gasification of Wood.  Presented at Energy From Biomass and Wastes
     XIII, IGT, New Orleans, Louisiana, February 13-16, 1989.

 2.  Biljetina, R., Srivastava, V. J. and Isaacson, H. R.  Symposium Papers,
     Energy From Biomass and Wastes XI, IGT, Orlando, Florida, March 16-20,
     1987, D. L. Klass, Editions, 577-583, Chicago:  IGT, 1988.

 3.  Srivastava, V. J., Biljetina, R., Isaacson, H. R. and Hayes, T. D.
     Biogasification of Sorghum in a Novel Anaerobic Digester.  Proceeding
     Paper of 42nd Purdue Industrial Waste Conference, West Lafayette, IN,
     May  12-14, 1987.

 4.  Fannin, K. F., Srivastava, V. J., Chynoweth, D. P. and Frank, J. R.
     High Methane Yields From  Sea Kelp in Upflow Solids Anaerobic
     Digesters.  Paper presented at Fourth Southern Biomass Conference,
     Athens, Georgia, October  7-9, 1986.

 5.  Srivastava, V. J., Biljetina, R., Isaacson, H. R. and Hayes, T. D.
     Biogasification of Community-Derived Biomass and Solid Wastes in a
     Pilot-Scale SOLCON™ Reactor.  Journal of Applied Biochemistry and
     Biotechnology.  20:21:587-602, 1989.
                                     402

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 6.   Kilbane, J. J. and Maka, A.  Microbial Removal of Organic Sulfur From
     Coal.   Final Report for Department of Energy.   DOE Contract No.  DE-
     AC22-85PC81201.  March 1989.

 7.   Cohen, M. S. and Gabrielle, P.  D.   Degradation of Coal by the Fungi
     Polyporous versicolor and Poria placenta.   Appl.  and Envir. Micro.,
     (44) 1:23-27, 1982.

 8.   Cohen, M. S., Bowers, W. C., Aronson, H.,  and  Gray, E. T.  Cell-Free
     Solubilization of Coal by Polyporous versicolor.   Appl. and Envir.
     Micro.  (53) 12:2840-2842, 1987.

 9.   Pyne,  J. W., Stewart, D. C., Fredrickson,  J.,  and Wilson, B. W.
     Solubilization of Leonardite by an Extracellular  Fraction From
     Polyporous versicolor.  Appl. and Envir. Micro. 53, 12:2844-2848, 1987.

10.   Scott, C. D. and Faison, B. D.   Biological Solubilization of Coal in
     Aqueous and Nonaqueous Media.  Paper presented at the Workshop on
     Biological Treatment of Coals,  Washington, U.S.A., July 8-10, 1987.

11.   Scott, C. D. and Lewis, S. N.  Biological Solubilization of Coal Using
     Both In Vivo and In Vitro Processes.  Paper presented at the Ninth
     Symposium on Biotechnology for  Fuels and Chemicals.  Colorado, May 5-8,
     1986.

12.   Scott, C. D., Strandberg, G. W. and Lewis, S.  N.   Microbial
     Solubilization of Coal.  Biotechnology Progress (2):131-139, September
     1986.

13.   Maka,  A., Srivastava, V. J., Kilbane, J. J. and Akin, C.  Biological
     Solubilization of Untreated North Dakota Lignite by a Mixed Bacterial
     and a Mixed Bacterial/Fungal Culture.  Appl. Biochem. and Biotechnol.,
     20/21:715-729, 1989.

14.   Quigley, D. R., Wey, J. E., Breckenridge, C. R. and Stoner, D. L.  The
     Influence of pH on Biological Solubilization of Oxidized, Low Rank
     Coal.   Resources, Conservation, and Recycling, 1:163-174, 1988.

15.   Quigley, D. R., Breckenridge, C. R., Dugan, P. R. and Ward, B.  Metal
     Ions,  Ash and Microbial Coal Solubilization.  In press.

16.   Walia,  D. C. and Isbister, J. D.  Biological Gasification of Coals.
     Topical Report for the Department of Energy.  Contract No. DE-AC21-
     87MC23285.

17.   Akin,  C.  Testing of the Concept for Two-Stage Biocatalytic
     Gasification of Coal to Produce Methane.  Research Proposal submitted
     to Gas Research Institute.  June, 1988.  IGT Proposal No. S55R6/88A.

18.   Cork,  D. J.  Bioconversion of Coal and Gas to Biomass and Chemicals.
     Paper presented at the Midwest Conference on Liquid Fuels From Coal and
     Biomass.  Midwest Universities Energy Consortium, Columbus, Ohio,
     October 5-6, 1981.
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19.  Cork, D. J. and Ma, S.  Acid-Gas Bioconversion Favors Sulfur
     Production.  Biotechnol. Bioeng. Symp.

20.  Cork, D. J., Mathers, J., Maka, A. and  Srnak,  A.   Control of Oxidative
     Sulfur Metabolism in Chlorobium limicola forma thiosulfatophilum.
     Appl. Environ. Microbiol.  49:269-272,  1985.

21.  Maka, A.  Control of Oxidative Sulfur Metabolism in Chlorobium.  Ph.D.
     Thesis, Illinois Institute of Technology, Chicago, Illinois, 1986.
PAP/ICPPpape r/pp
19WP/ICPPpaper/PAP
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                      ENERGY RESOURCE VS.  BURIED WASTE;
                       SPENT POTLINER IN A CEMENT KILN

                 by:   Elbert G.  Massad
                      Alumax of  South Carolina,  Inc.
                      Goose Creek,  South Carolina  29445
     Aluminum,  one of the most  important materials  in the United States
 and  the  world,  is  produced by reducing  aluminum oxide (alumina),  a
 refined  bauxite ore,  in  an electrolytic cell  or "pot".   An aluminum
 reduction  plant typically has several hundred of these pots,  each
 producing  several  thousand pounds  of aluminum per day.

     With  a  sincere and  proven  commitment to  protecting the environment,
 aluminum plants are successfully coexisting with their surrounding
 neighbors.   Some immediate neighbors of this  particular plant are pine
 trees and  ground vegetation,  the protected red cockaded woodpecker,
 white tail deer, fox  squirrels, and, of course,  mankind.

     As  noted earlier, these  plants use many  pots to  meet the world's
 demand for aluminum.   The lower half of the pot is  a  rectangular  steel
 shell that is lined with carbon blocks  and insulating materials.  The
 carbon lining blocks  are made of calcined anthracite  coal,  using  coal tar
 pitch as a binding  agent.

     These pots  operate  continuously, until the pot lining  fails  and must
 be rebuilt.  This pot  "life"  is typically three to  seven  years.   The old
 lining is  demolished,  dug  out, and the  carbon and insulating  materials
 are  separated so that  the  components may be collected for recycling.  The
 carbon material  is  known as spent potliner (SPL).   It is  estimated that
 over 100,000 metric tons  of SPL is generated  annually.

     During the  operation  of  the pot, low levels  of fluoride  and  cyanide
 are  formed in the liner.   The level of  cyanide  varies greatly, and pre-
 dictably, within specific  locations of  the liner.  SPL  has  a  high energy
 value, 8000 to  9000 BTU/lb, making it a  valuable  resource as  a direct fuel,
 and a material that should not become a  waste.

     Years of recycling  efforts by the aluminum  industry have resulted in
 several productive and environmentally sound uses for SPL.  One of these
 successful methods  is the result of research by the Aluminum Company of
America  (ALCOA) and the Portland Cement Association.  Laboratory tests
 indicated that SPL could be used as a fuel supplement and mineralizing
                                    405

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agent in  a cement kiln.   In  1983, a one week  test was conducted  by Alumax
of South  Carolina and Santee Cement Company,  with the successful results
leading to a long term evaluation and practice.

     The  process for producing cement is briefly described and illustrated
by the process flow chart, Figure 1.  Cement  clinker is produced by burning
a carefully proportioned and finely ground, raw mix in a rotary  kiln.
Within the kiln, volatile components are driven off, and partial melting
occurs, leading to nodulation of the feed into rounded balls,  called
"clinker".  After cooling, the clinker is ground, with a small amount of
gypsum, to the fine powder known as Portland  Cement.
                 CEMENT PRODUCTION PROCESS
LIMESTONE
QUARRY



CRUSHER
\
,—

PACKAGING
AND
SHIPPING
/PRODUCT
f \STORAGE



FINISH MILL



                  Figure 1.   Cement production process.
                                   406

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     The high clinkering temperatures, about 2700 degrees F, make it
possible to burn almost any fuel once combustion has been initiated.  Since
most plants burn coal, and since cyanide dissociates at about 1500 degrees
F, the replacement of a small fraction (about 2%) of the coal with SPL is
a possible and sensible procedure (1).

     From 1984 to 1988, over 13,000 tons of SPL were beneficially used as
a fuel supplement and mineralizer in South Carolina cement kilns.  At the
Alumax of South Carolina aluminum reduction plant, the SPL was crushed,
stored safely in a large building, and shipped to the cement plant on an
as-needed basis.  It was then blended with coal for direct firing into the
cement kiln, with the following successful results:

1.  Reduction of fossil fuel costs was proportional to BTU content, with a
    net savings of about $100,000 per year.

2.  Fluoride emissions from the kiln stacks was negligible.  The fluoride
    present in the SPL was absorbed in the cement clinker and recycling
    system.

3.  Cyanide destruction was complete, stack emissions were at background
    levels, and no leachable cyanides could be detected in the clinker.

4.  Production rates, product chemistry, and product quality were not
    adversely affected.

5.  Land disposal of this material was completely avoided.

     The March 13, 1989 listing of SPL as a hazardous waste under Subtitle
C of RCRA, in the absence of specific rules encouraging beneficial and
environmentally sound reuse of wastes, terminated this waste minimization
effort, and forced the unnecessary and undesirable practice of land
disposal.

CONCLUSIONS

     The reuse of SPL in cement kilns is a proven safe and efficient method
of beneficially using both its energy value and its valuable constituents.
It has the support of industry, state and federal regulators and other
concerned environmentalists.  The responsible practices that have been
followed should be continued without the undue burden of additional
regulatory requirements and unreasonable costs.  Prudent efforts such as
this, which take advantage of a resource and prevent land disposal, should
be encouraged, not dissuaded by inflexible regulatory requirements.
REFERENCES

1. Dickie, R.C., Logan, L.L.  Spent Potliner in a Cement Kiln.
   Presented at the Portland Cement Association's Annual Meeting, March
   10-12, 1986, Chicago, Illinois.
                                    407

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THE ENLARGED EUROPEAN ENVIRONMENTAL MARKET: IMPEDIMENTS AND OPPORTUNITIES



         by Jan C. McAlpine, Director of the International Environment Committee

        of the National Advisory Council for Environmental Policy and Technology*

                              401 M Street, SW A-101 F6

                               Washington, D.C. 20460



       The  recent transformation of Central and Eastern Europe offers new challenges and

opportunities for business, non-governmental organizations (NGOs), multilateral development

banks (MDBs), and government agencies who are participating in environmental remediation

and reconstruction efforts.  The extent of the damage inflicted upon the environment by over

forty years of unrestrained and unregulated industrial development is only now coming into

focus. The list of designated "environmental disaster areas" grows with each day. In Poland,

the major river systems and  surrounding areas are fouled by that nation's chemical,

metallurgical, and energy industries.  Seven of the eight major rivers in Czechoslovakia are

dead or dying.  East Germany possesses one of the worst air pollution problems of any

developed country, due—in large part—to the burning of lignite coal for energy production.

Romania and Bulgaria are now just beginning to admit that they even have a pollution problem
 *   The National Advisory Council for Environmental Policy and Technology (NACEPT) is a free-standing
 body, consisting of volunteer representatives from business, academia, government,  and non-profit
 organizations and serves to advise and counsel the EPA Administrator on a wide range of cooperative
 environmental policies and issues. NACEPT is staffed by the EPA's Office of Cooperative Environmental
 Management which is located in the Office of the Administrator. The International Environment Committee
 provides  a  forum for individuals from  different—sometimes competing—sectors of the international
 community to identify international environmental issues, to devise cooperative solutions and strategies for a
 cleaner national and international environment, to initiate and sponsor projects and programs, and to support
 international policy and program development
                                          408

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at all. Across the region, high levels of ground contamination, water and air pollution pose a
substantial challenge to Westerners who hope to participate in the economic and environmental
revitalization of this region. Likewise, there are significant impediments to increased private
and public sector involvement. Each of these impediments—however—provides its own set
of opportunities and challenges.  In providing the context for this panel, I will touch on just of
a few of these.
       One of the greatest impediments to increased involvement is the fact that the entire
industrial infrastructure of this region is ill-equipped to accommodate sophisticated pollution-
control technology or clean technology practices. Whole industries seem impervious to the
application of state-of-the-art pollution controls. As a result, some countries—Poland for
example—have opted to raze entire factories instead of attempting to retrofit them. While
some argue in favor of  this approach, it is an expensive and drastic policy—and one,
unfortunately, that many of these countries cannot afford to undertake.  Reconstruction and
rehabilitation efforts in Eastern and Central Europe challenge the West to invent new ways to
apply current technology and practices and adapt it to the industrial plant in this region.  One
of the approaches being considered advocates fitting factories that cannot accommodate the
most up-to-date technology, with out-of-date Western technology.  Supporters of this
approach state that while this plan does not represent an optimal solution, it  may be the best
and most reasonable option for the short and medium term. Opponents argue strongly for the
introduction of totally up-to-date solutions and practices. In any case, while "stop-gap"
efforts are applied, increased exchanges of improved technology can provide a long-term
systemic solution to the problems of pollution emission controls and the impediment of an
inefficient and decaying industrial infrastructure creates  increased opportunities for the
exchange of technology between the West and this area. As a sidebar to this  point, I recently
returned from an environmental conference in the Soviet Union where several Soviet speakers
voiced fears that the West was planning to dump all of its obsolete technology onto the Soviet
                                        409

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Union market.  This is an issue that we must face head on so that these fears do not become
realities.
      A second major impediment is the lack of comprehensive environmental standards to
which newly-built and rehabilitated plants can subscribe and, most significantly, data on
which to base these standards.  Cooperative multilateral environmental standards must be
established by the West and these countries prior to the initiation of large-scale reconstruction
activities. One way in which environmental standards can be introduced is through the
lending policies of MDBs such as the World Bank and the newly-formed European Bank for
Reconstruction and Development (known commonly by its French acronym "BERD").  In
demanding comprehensive environmental assessments of industrial undertakings, MDBs can
provide  an  incentive for sound  development  projects.  Furthermore, by bolstering
environmental operations and maintenance outlays as an integral portion of loan packages,
MDBs can play a positive and aggressive role in determining environmentally sound
development strategies. The determination of common environmental standards, however,
can only result from cooperation among Western and Eastern European business, NGOs, and
most importantly, government agencies.  The lack of minimum environmental standards
remains  a large impediment to  the introduction of a comprehensive and successful
development strategy for this region.  Working in cooperation, MDBs, NGOs, business, and
government agencies can play an important role in determining sound development strategies
and environmental standards for this region.  The experience of the European Community
provides an interesting model of "do's, dont's, and maybe's" in this context.
      A third impediment is the lack of technical expertise among engineers and managers.
Because many engineers and managers were educated and trained merely to fulfill ever-
increasing production goals, most of them possess little or no  experience in  dealing with
environmentally-sound production methods and pollution reduction techniques.  Currently, an
entire generation of engineers and managers must be retrained and re-educated.  This situation
                                       410

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creates a valuable opportunity to provide technical experts and pollution-control specialists
who can re-direct industrial policy to reflect more environmentally-sound methods. Western
industry has acquired valuable knowledge in the area of pollution control and efficient, low-
impact production methods and is gaining experience in implementing pollution prevention
approaches.  By supplying Central and Eastern Europe with qualified  and experienced
experts, the West can transfer its own experience and prevent Eastern and Central Europe
from repeating the West's costly mistakes in its program for industrial development
       Finally, the most serious impediment to Western action in Central and Eastern Europe
is the lack of experience (on the part of the politicians, managers, and businessmen) with the
free market mechanism.  The lack of convertible currencies, the stress on mega-projects, the
heavy geographic concentration of industry, and the compartmentalization of the economic
decision-making  apparatus present formidable barriers to outside actors.  Successful
involvement will be contingent on decentralization and reconstruction of the prevailing
economic mindset. For the past forty years, the economic maxim that "bigger is better" has
held sway in the formulation of  all industrial policies.  As reconstruction efforts are
undertaken, this maxim must be abandoned. Massive, inefficient industrial projects must not
be supplanted by equally inefficient and massive environmental rehabilitation projects. There
is a temptation among Central and Eastern European economic managers to support mega-
environmental projects even though the market may dictate that smaller projects would provide
a greater environmental and economic return.  Intelligent and efficient environmental
remediation efforts will depend upon Western advice and know-how. Western businesses
and NGOs have accumulated a wealth of experience in and knowledge of the market
mechanism—each could provide valuable instruction and leadership in this area.
       The lack of a market mechanism also will impede immediate Western involvement in
remediation and reconstruction efforts. Even though most East European countries advocate a
return to the market system, it will be several years before it can be adequately established
                                       411

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throughout the region.  In the meantime, these nations are faced with an unenviable dilemma.
Each country needs Western funds and expertise in order to make the transition to a market
economy, yet Western funds and expertise will not be readily forthcoming until this transition
is completed. Business, NGOs, government agencies, and most important, MDBs can play
crucial role in providing funds and expertise so that the transition time can be short and less
painful. Public and private sector cooperation can provide a foundation for the implementation
of an effective environmental strategy.
       Despite the impediments of an inefficient industrial infrastructure, lack of common
environmental standards, a dearth of technical expertise,  and the  absence of a market
mechanism, the opportunities for business, NGOs and government agencies in participating in
the economic and environmental renaissance of Central and Eastern Europe loom large. A
successful development strategy for this region will depend on cooperative action on the part
of the public and (emerging) private sector.  The speakers this morning will elaborate on the
nature of this cooperation, and the impediments and opportunities presented by the enlarged
European Environmental Market
                                       412

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       International Conference on Pollution Prevention:
             Clean Technologies and Clean Products

  Session 37:  Hazardous Waste Minimization in DoD Operations
                Washington, DC  - June 12,  1990

   U.S. AIR FORCE HAZARDOUS MATERIALS MANAGEMENT INITIATIVES

                              by
                 Brian D. McCarty,  Major, USAF
     Air  Force  Systems  Command, Brooks Air Force  Base,  TX
                      Jeffrey J. Short
   Headquarters, U.S. Air  Force, Boiling Air  Force Base, DC


                           ABSTRACT

     The Hazardous Materials Integrated Management Program
(HAZMAT IMP) is an U.S.  Air Force initiative to prevent
pollution throughout the life of a weapon system,  from concept
to disposal.  The major elements of this program focus on the
hidden costs associated with hazardous materials when acquiring
new systems and supporting existing systems.  On-going process
and systems research by the Logistics, Supply and Maintenance
community will improve inventory control, remove requirements
and provide substitutes for hazardous materials. , Costs related
to the safe handling, storage and disposal of hazardous
materials must be considered as part of the total lifetime
system costs.  The HAZMAT IMP is a comprehensive program to
identify, track and replace hazardous materials.
     Long-term success will depend on designing the non-use of
hazardous materials into the weapons system as a part of
supportability.  In 1989, Air Force Systems Command requested
an unbiased, independent contractor, the MITRE Corporation, to
conduct a preliminary study of the existing weapon system
acquisition process within AFSC and to recommend initial tasks
to reduce the use and generation of hazardous materials.
Weapon system design, development, operation and maintenance
occurs within the context of a system acquisition process.
This acquisition process lays out an orderly strategy for these
activities; however, the process must be tailored to each
weapon system acquisition.
     The MITRE report defined a series of  issues that will
improve the efficacy of managing hazardous materials during
system acquisition.
                              413

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disposal practices and problems that result from the material
processes.

     It is clear that we need to change the way we do our
business.  We need to look at our material selections in terms
of performance characteristics and the processes and disposal
requirements that each material selection drives.

     For example, by selecting the aircraft skin as aluminum,
you have automatically determined the maintenance procedures
and the ultimate disposal problems.  What we are attempting to
do is to directly tie the material section to the maintenance
processes and disposal requirements.  Additionally, we hope to
identify the "hidden" costs for personnel protection equipment,
special training, medical examinations and differential pay for
AF civilian employees.  When we have evaluated all the
alternatives in the same fashion, then we can make meaningful
tradeoffs.

     Briefly, I would like to discuss the weapon system
acquisition process mandated by law.  The top schematic shows
the way we do business.  Although some steps can be combined
for a given item, the overall process is a stepped and orderly
approach.  Before entering the next phase, there are multiple
reviews to validate the need, the approach and the design.  For
a major weapon system, like a new aircraft, the overall process
can take 8-10 years.

     Throughout the classical acquisition process, we have
different organizations that have responsibility for the
program development.  The "planning shop" works with the using
command to get their ideas down right.  Once the concept has
been approved, the System Program Office  (SPO) has the
responsibility to move the product from the paper studies,
through design, into production and finally resulting in a
fully operational "fielded" weapon system meeting or exceeding
the user's original needs.

     The SPO can be very large for major weapon systems with
several technical experts assigned to one discipline.  Smaller
SPO's use matrixed technical support to cover their technical
requirements.  The various disciplines listed are only some of
the technical areas required for most weapon systems.

     Finally, the systems engineering design approach can be
applied to the AF Weapon System Acquisition process.  We begin
with system level engineering and work down to the detail
level, then correct and modify accordingly.

     How HM fits into the acquisition process is not new.  The
AF Scientific Advisory Board (SAB) studied this specific issue
on how we select and use this in the "business" process.  Their
                             414

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report concluded that we can significantly reduce our outyear
HM/HW problem by better identification and selection of
materials in the design phase.

     The SAB report concluded that the current acquisition
process does not even address HM issues and that even if it
did, the SPO's are not "technically capable" in this extremely
technical area to make a proper assessment of tradeoffs.  Even
if we could do an adequate job of making selection tradeoffs,
we have no way to grade ourselves on how well we have done.

     Our job is clear.  To make hazardous material management
(HMM) a consideration of the SPO and to provide the SPO with
the technical support to make sound material selection
decisions.

     Last fall, we contracted the MITRE Corporation to perform
a preliminary evaluation of both our current HM business
practices and identify the technical, regulatory and emerging
issues that will directly impact how we will do business in the
future.

     The following summarizes the current practice of HMM.  The
good news is that the issues are being addressed, albeit not in
any technical detail, by the system safety program.

     Interviews with our various product divisions pointed out
the bad news.  First, there is no consistent approach to HMM
from SPO to SPO.  Next, that there is no formal mechanism to
transfer information either from or within the SPO or from the
SPO to technical support laboratories, the "experts" in a
particular field.  We found that HMM issues generally needed a
"trained" professional to know the real issues facing the
weapon system design.  There was definitely a lack of
consideration of the total costs devoted to HM issues,  in fact
most people interviewed had never thought of the maintenance
and disposal costs that their decisions were driving.   Finally.
there was an overall limited consideration of HM issues.  Most
people accepted the "off the shelf" approach to material
selection instead of looking at each design decision as an
opportunity to reduce or eliminate hazardous materials  or
hazardous wastes.

     We are clearly not addressing the acquisition issue!

     How are we preparing to solve this problem?  We want to
design out the problem if at all possible.  In those instances
where we can't design away the issues, and there will be many
instances where we cannot, we want to be able to let the field
units know what they're getting in terms of maintenance support
and disposal requirements.
                              415

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     Our approach will be to give the SPO's the tools and
expert technical support they need to make sound decisions.  We
must also integrate our special HM/HW needs into the federal
acquisition process and to advocate these needs to our biggest
supporter, industry.  Our impact is simply to standardize the
way we think about HM/HW issues and enable a proper technical
tradeoff to occur.

     To make this program effective, we must address five key
issues.  First, we must tailor the existing federal acquisition
process to account for the diversity in products produced.  The
type, number and complexity of HM issues found in the
production of hand held radios is completely different than
those for a major weapon system, such as the B-2 bomber.

     Second, we must get a clear handle on what is a hazardous
material.  We are constrained by use of hazardous materials
listings such as Federal Standard 313 and Department of Defense
Directive 4210.15 which defines a hazardous material as:

     "Anything that due to its chemical, physical or biological
     nature causes safety, public health or environmental
     concerns that result in an elevated level of effort to
     manage it."

     We need to develop a "working definition" to evaluate the
material and the process and not just use laundry lists to
perform technical tradeoff evaluations.  For example, a smaller
volume of a hazardous material in a closed system may be far
more acceptable than a large volume of a less hazardous
material in an open system.  We must begin to look past the
obvious questions to properly evaluate HM for the total life
cycle of the weapon system.

     We also need to be more attuned to emerging regulatory
issues as we proceed through the development process.  It does
us no good to design an aircraft to meet very specific
technical specifications and not be able to sand, strip, paint
or fly in California.

     Early identification of HM issues is the key to
flexibility in the design.  As you proceed through the phased
acquisition process, it costs more and more to make a
modification to the weapon system design.  It pays to identify
our HM/HW concerns early in the process.

     Finally, we need to support the SPO personnel with the
right balance of technical expertise.  This does not mean to
assign a full time toxicologist to each SPO.  What it does mean
is to be able to handle each technical issue arising from the
SPO with the right expert.  This could result in a
                             416

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complimentary series of design handbooks, computer databases,
and consultative support from Air Force and other DOD sources.

     From the recommendations of the MITRE preliminary report,
we have consolidated and prioritized the follow-on tasks that
remain to be accomplished.  The first four have been ranked as
critical to our program success.  First and foremost we must be
able to get a tool into the hands of the decision makers.  That
tool will depend heavily upon the "working" definition of HM
described earlier.

     We also believe strongly that our relationship with the
contractor must be more refined in the HM arena.  We are
developing boilerplate contractual language and guidance to the
SPO's on how to tailor its use for the particular technical
evaluation at hand.

     To integrate HM concerns across the entire acquisition
process, we need a staged approach for identifying decision
points and roadblocks relative to the project timetable. It
doesn't matter how good the technical information we have is,
if we can't supply it to the right decision maker in a timely
manner.  The slower we are at identifying roadblocks the less
chance we have of having our concerns adequately addressed.  I
believe the dates reflected for these tasks to be achievable.

     The program tasks identified on this slide are not labeled
as critical, but they are nevertheless extremely important to
the success of this program.  A comprehensive training strategy
and identification of related industry and academic courses in
HM will go a long way in educating the SPO personnel on the
type and complexity of HM issues.

     To help eliminate the "not invented here" syndrome and to
let everyone gain from shared experiences, we will establish a
lessons learned repository or tie into the existing Air Force
lessons learned Databank.

     We feel that the contractor will be the key to this
program.  As part of our program, we hope to evaluate several
current contractor practices in HMM.  Not to critique them for
their efforts, but to learn from their management and
manufacturing techniques and apply those good ideas to our Air
Force programs.  Tying closely with this program task is to
define the criteria and procedures that will be used to
evaluate contractor designs as having adequately addressed our
HM concerns.

     The last four program tasks are more programmatic, but
still necessary for program success.
                              417

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We hope to better determine the support requirements, both
technical and non-technical as we work through the roadblocks
we encounter.

     As part of the technical support, we will need for this
program, it is obvious that we will need to tap into multiple
databases for toxicological, regulatory and other national and
international information sources.  The initial phase will be
to perform a requirements analysis for such a decision support
system.

     The final two program tasks are more for our own uses.  We
need to be able to define and document our wins and losses as
we progress through this program.  Finally, we need to maximize
cooperation between the services and industry by supporting a
technical exchange between all the players in HM.
                           REFERENCES

U.S. Air Force, Scientific Advisory Board, October 1986.
"Report of the USAF Scientific Advisory Board Ad Hoc Committee
on Air Force Current and Long-Term Response to Hazardous
Material/Waste Issues, Selection and Use of Hazardous and Toxic
Materials in the Weapon System Development and Acquisition
Process."

MITRE Corporation, March 1990.  "A Preliminary Study of
Acquisition Management of Hazardous Materials in the Air Force
Weapon System Acquisition Process," Working Paper WP-90W00103.


                           VIEWGRAPHS
                         US  AIR  FORCE

           HAZARDOUS MATERIAL MANAGEMENT INITIATIVES
         HAZARDOUS  MATERIALS  INTEGRATED MANAGEMENT  PLAN
                          (HAZMAT  IMP)

     o  Prevent pollution throughout life of weapon system
     o  Identify "hidden" costs associated with HM
     o  Improve inventory Control of HM
     o  Investigate substitutes for HM

              A COMPREHENSIVE PROGRAM TO  IDENTIFY,
            EVALUATE, AND REPLACE HM WHERE POSSIBLE
                             418

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                            OVERVIEW

          WHAT'S THE PROBLEM?
          HOW WILL WE SOLVE IT?
          WHAT PROGRAM TASKS REMAIN?
                      WHAT'S THE PROBLEM?

     O  MATERIALS
          (COMPOSITE FIBERS, CHEMICALS ..)
     O  MATERIAL PROCESSES
          (MANUFACTURING, STRIPPING, PLATING ..)
     O  DISPOSAL
          (PROPER HW DISPOSAL, WASTE STREAM MINIMIZATION
     O  WAY WE DO BUSINESS
          (IDENTIFY,TRACK, REPLACE HM/HW  ..)
         MATERIAL SELECTION:  ALUMINUM  (AIRCRAFT SKIN)
MATERIAL PROCESSES
  Corrosion treatment - chromic acid

  Priming - epoxy w/chromates
  Painting - polyurethane
  Stripping - methylene chloride, MEK
  Sanding - dust
DISPOSAL
  Chromic acid - toxic & corrosive HW
  MEK, methylene chloride - toxic HW
     HIDDEN COSTS
Eye protection,
protective clothing.
Ventilation, high
efficiency respirator,
protective clothing.
Ventilation, air-line
respirator, protective
clothing.
Ventilation, respirator
eye protection,
protective clothing.
Eye protection, hearing
protection, protective
gloves.
             (ALTERNATIVES:  FIBERGLASS, COMPOSITES)
                              419

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       WEAPONS SYSTEM ACQUISITION
 PHASE:
Pre-
Conoept
-
Concept
Exploration
-
Demonstra-
tion
Validation
-
Full Scale
Development

Production
-
Operation
and
Support
Disposal
 AIR FORCE ORGANIZATIONAL RESPONSIBILITY:
  Planning
   (XR)
System Program Office
    (SPO)
User/Support
 Commands
SYSTEMS ENGINEERING:

System
Level
-
Configuration
Item

Detail
Level
-
Deficiency
Correction
-
Modlfi atlon


HAZARDOUS
MATERIALS
MANAGEMENT
(HMM)
     ENGINEERING
 ACQUISITION
 MANAGEMENT
       SAFET
                       OGISTICS
                         CONTRACTOR
                          OVERSIGHT
                                      CONFIGURATION
                  DATA
              MANAGEMENT
               EST &
            EVALUATION
                        420

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             USAF  SCIENTIFIC ADVISORY BOARD  (SAB)
                           OCT  1986
FOUND:
     o    We can reduce outyear HM/HW problem through early
          identification and selection of materials
BUT:
     o    Current acquisition process does not address HM/HW
          issues
     o    SPO unable to do technical assessment of HM/HW issues
     o    There are no methods to assess the effects of HM/HW
          decisions
                SUMMARY OF OUR CURRENT PRACTICE

     Hazardous material management (HMM) concerns are not
          addressed within the system safety program
     Product division interviews showed:
     oo  No consistent approach to HMM
     oo  No formal mechanism for info transfer
     oo  A general lack of HMM expertise at the SPO
     oo  No clear consideration of total HM cost
     oo  Limited consideration of HM
          WE ARE NOT ADDRESSING THE ACQUISITION ISSUE
                     HOW WILL WE SOLVE IT?

o    GOAL - We want to design problem out or pass on lessons
          learned early
o    APPROACH
     oo  Provide SPOs with tools needed for sound decision-
          making
     oo  Integrate HM/HW into acquisition process
     oo  Advocate HM/HW issues to industry
o    IMPACT
     oo  Standardize HM/HW decision-making
     oo  Enable technical assessment of HM/HW concerns
                             421

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                     ISSUES TO BE ADDRESSED

o    Systematic approach - accounting for diversity
o    Working definition of hazardous materials - various
          approaches
o    Regulatory awareness - existing regulations and emerging
          issues
o    Early hazardous materials identification - flexibility
          versus uncertainty
o    Expertise - where and how much
     DODD  4210.15,  HAZARDOUS MATERIALS  POLLUTION  PREVENTION

"Anything that due to its chemical, physical, or biological
nature causes safety, public health, or environmental concerns
that result in an elevated level of effort to manage it"
                   WHAT PROGRAM TASKS  REMAIN?

                            CRITICAL
o  Identify cost drivers and develop LCC model (Fall 91)
o  Develop "working" definition of hazardous materials
     (Spring 91)
o  Develop HM contractor language and guidance on its use
     (Fall 91)
o  Define staged process for HM identification relative to
     acquisition timetable  (Summer 91)
                   WHAT PROGRAM TASKS  REMAIN?

o  Develop a training strategy and selected course materials
     for program personnel
o  Establish lessons learned repository
o  Evaluate current contractor practices in HMM
o  Define criteria and procedures for monitoring contractor
     efforts under AMHM
o  Determine support requirements
o  Perform requirements analysis for decision support system
o  Define measure of success in AMHM
o  Institute technical information exchange
                              END
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                    ILLINOIS/EPA WRITE  PROGRAM

                    by: Gary D. Miller, Ph.D.
                        William L. Tancig
                        Hazardous Waste Research and
                          Information Center
                        One East Hazelwood Drive
                        Champaign, Illinois  61820
                                and
                        Paul Randall
                        U.S. Environmental Protection Agency
                        Risk Reduction Engineering Laboratory
                        26 W. Martin Luther King
                        Cincinnati, OH  45268

                             ABSTRACT

     The State of Illinois, through the Hazardous Waste Research
and Information Center (HWRIC) and the University of Illinois, is
participating in U.S. EPA's three-year Waste Reduction Innovative
Technology Evaluation  (WRITE) Program.   This program is designed
to encourage the interaction of government and industry to
demonstrate and evaluate at least five innovative production and
recycling options for reducing waste generation.  The scope of
the evaluations includes determining the engineering
effectiveness of the technology,  measuring the reduction in waste
volume and degree of toxic hazard to all media, and assessing
economic return or payback.  A major objective is to establish
reliable performance and cost information for pollution
prevention technologies and techniques.

     HWRIC has taken a four pronged approach to identifying and
selecting industrial participants; distribution of announcements
at meetings, promotion of the Program with companies requesting
technical assistance with their waste management problems,
contacting equipment vendors, trade associations, and Governor's
Pollution Prevention Award winners that HWRIC dealt with in the
past, and soliciting proposals for appropriate projects with
matching funding available from HWRIC.   Fourteen most promising
projects were identified out of over 50 industrial contacts.
These were assessed using a worth assessment model and five were
selected for evaluation under this Program.

     The five projects include two with printers, two with
electroplaters, and one with the American Foundryman's Society.
The printing projects involve evaluation of water-based inks in
flexographic printing and soy oil-based inks in offset printing.


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The electroplating projects involve recovery and reuse of
alkaline zinc where zinc cyanide was previously used and the use
of a batch vacuum evaporative system to recover and reuse
chemicals and water in several plating lines.

     The approach used in this Program has been successful to
identify industrial participants.  All aspects of the approach
have been useful and necessary.  Some companies have been
reluctant to participate because of concern over proprietary
information about their process, unwillingness to share the
results with their competitors, and general reservations about
working with state government.  Other obstacles have included
technologies that are beyond the scope of the Program, matching
the participants timing with that of the Program, and obtaining
the information needed from the participants on their materials
and processes to perform the evaluations.  These problems can be
overcome if all Program participants are committed, the expertise
and resources needed to undertake the evaluations is available,
and the participants are flexible.

     This paper has been reviewed in accordance with the U.S.
Environmental Protection Agency's peer and administrative review
policies and approved for presentation and publication.

                           INTRODUCTION

     In June of 1989 the U. S. Environmental Protection Agency
(EPA), Office of Research and Development began a three-year
cooperative agreement with the Hazardous Waste Research and
Information Center (HWRIC) and the Institute for Environmental
Studies (IBS) of the University of Illinois (U of I)  as a part of
EPA's Waste Reduction Innovative Technology Evaluation (WRITE)
Program.  HWRIC is a unit of the nonregulatory Illinois
Department of Energy and Natural Resources and is affiliated with
the University of Illinois.

     The WRITE Program is designed to encourage the interaction
of government and industry to demonstrate and evaluate innovative
production and recycling options for reducing waste generation.
The approach of federal and state cooperative efforts to
incorporate pollution prevention technologies and practices in
industrial operations is also being developed under this Program.

     Engineering and economic evaluations of at least five waste
reduction technologies within the State will be conducted under
this cooperative agreement.  An additional aspect of the Illinois
Program is to develop a "Degree of Toxic Hazard" evaluation
technique which will be used in the evaluation of each of the
technologies.

     In this paper, the approach used to identify technologies
and industrial participants is summarized.   Each of the selected
technologies to be evaluated is then described.   This is followed
by a discussion of the results and plans for completion of the
project.


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                         PROJECT OVERVIEW

     For each technology to be evaluated a ten step approach is
being taken.  The ten steps are:
     1) select the project and obtain company commitment,
     2) determine the project requirements,
     3) prepare a draft quality assurance project plan  (QAPP),
     4) revise the QAPP per review comments,
     5) conduct field test preparations,
     6) collect in-plant measurements and economic data,
     7) evaluate and analyze the test data,
     8) prepare draft project report,
     9) conduct report review, and
     10) prepare and publish final project report.

     During the first year the major activities have been to
identify candidate technologies, contact potential cooperating
industries and technology developers, assess and select
technologies for in-plant evaluation, and develop the Degree of
Toxic Hazard evaluation system.  Steps 2 through 4 have been
undertaken for some of the projects.  Technology evaluations
(steps 5 through 7) are scheduled to be undertaken during the
second year of this Program.  Final project reports and an
overall Program report will be prepared during the third year.

     Since the start of the project, more than 50 industries,
companies, trade associations and consultants have been contacted
regarding their willingness to participate in the program.  To
make these contacts and identify potential industrial
participants, four coordinated approaches were used.

     The first approach was to prepare announcements for
distribution at various speaking engagements given by project
staff.  Presentations have been made to industry on over twenty
occasions.  For those companies that expressed interest
informational material was provided and site visits were
arranged.

     Second, companies contacting HWRIC for technical assistance
on their waste problems were also approached when their needs
were suitable.  HWRIC personnel described the WRITE Program and
arranged for meetings to explore their interest.  Meetings have
been held with personnel from more than 25 companies regarding
their participation in the project.

     The third approach used was to make contacts with various
companies and trade associations that project personnel had dealt
with in the past.  These included companies who had applied in
previous years for the Illinois Governor's Pollution Prevention
Award.  Two candidate companies were identified in this way.

     The fourth approach used was to invite companies to submit
proposals for state funding of waste reduction projects.  For the
past three years HWRIC has funded waste reduction projects with
industry with an objective similar to the WRITE Program.  This
approach was designed to use state funding to help attract


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industry to participate in this Program.   Projects currently
funded and new proposals were considered.  Three of the
participating companies plus two other appropriate companies  were
identified by this approach.

TECHNOLOGY SELECTION APPROACH

     Through these approaches, fourteen potential WRITE projects
were initially identified.  A worth assessment model evaluation
was undertaken to evaluate and rank each of the fourteen
potential waste reduction projects according to 12 technical
criteria.   The selection criteria used for choosing the waste
reduction technologies were:

     1) Type of waste-minimization technology (source
        reduction or recycling applications),
     2) Status of development or level of maturity according  to
        a maturity index (chosen technologies developed beyond
        the proof-of-concept stage to at least the pilot plant
        scale),
     3) Unique nature of the technology (not previously
        evaluated for waste reduction effectiveness),
     4) Applications for reducing priority wastes or for more
        than one process primarily in small- and medium-scale
        operations,
     5) Source-reduction-performance capability or the extent of
        waste volume or toxicity reduction expected,
     6) Extent of process modification,
     7) Cost-effectiveness of the technology,
     8) Process safety and health considerations,
     9) Cost to the EPA and U of I (HWRIC and IBS),
    10) Demonstrator's qualifications,
    11) Legal/contractual issues,  and
    12) Length of the project.

     A worth assessment model was the decision tool used.  With
this model each of the selection criteria are given a weighted
score.  The ratings are added to obtain an overall rating.
The results of this evaluation for the five selected technologies
are summarized in Table 1.   Each technology involves source
reduction or recycling, is within the prescribed maturity index
limits, and is unique in that it has not previously been
evaluated for its cost and waste reduction effectiveness.  Also,
it has been determined in discussions with each company that no
major legal or contractual issues are pending for these projects.

     After this review, five technology evaluation projects were
selected for this Program.   The selected projects and industrial
participants are:

     1) Flexographic printing with water-based inks and
        alternative cleaners (MPI  Label Systems in University
        Park, IL.),
     2) Offset printing with soy oil-based inks and alternative
        cleaners (University of Illinois,  Office of Printing
        Services in Urbana/Champaign),
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     3) Non-cyanide  zinc plating and  reuse of  recovered chemicals
        in electroplating  (P and H Plating in  Chicago),
     4) Vacuum evaporative batch recovery and  reuse  of  chromium,
        copper, nickel, cadmium, brass, and  zinc  in
        electroplating  (Graham Plating in Arlington  Heights),  and
     5) Recovery and reuse of waste zircon molding sand in  the
        investment casting (foundry)  industry  (American
        Foundryman's Society in Des Plaines).

In addition to these five projects, two other  projects  were
identified that may  be undertaken if  funding and  time permit.
These alternate projects are evaluation of citrus based cleaners
for metal parts degreasing (Lockformer Corp.,  Chicago)  and
pickle-liquor recovery and reuse in electroplating (lonsep  Corp.,
Chicago).

     The other main  task has been to  develop the  degree of  toxic
hazard reduction evaluation system to be used  for this  program.
For each waste stream to be evaluated an equivalent  toxic
concentration (Ceq)  is calculated as  follows:

     Ceq = A SUM (Ci/BiTi)         where:

     A is a constant equal to 300 which is used to allow percent
       values to be  used for Ci and to adjust  the results so that
       a reference material (100% copper sulfate  which  has  an
       oral toxicity of 300 mg/kg), achieves an equivalent
       toxicity of 100;
     SUM is the sum  of the results of the calculation in
       parenthesis for each component of the wastestream;
     Ci is the concentration of component i  as a  percent of the
       waste by weight;
     Bi is a conversion factor used to convert toxicities (Ti) to
       equivalent oral toxicities according  to (Plewa, et al.,
       1989); and
     Ti is the measure of the toxicity of component  i.

The equivalent toxic concentration is converted to a toxic
amount, M, by the following formula:

     M = S Ceq           where;

     S is the maximum size of the waste stream in kg/month.

     With these calculations a value  for the toxic amount, M, for
each waste stream is obtained.   This toxic amount accounts for
the toxicity and amount of each component in each waste
evaluated.  The number obtained for M can range from 0 to more
than 10,000.  This toxic amount can be considered as a relative
toxicity rating for each type of waste.   For the Illinois/EPA
WRITE Program a toxic amount will be calculated for each waste
produced before and after the waste reduction technologies are
implemented.  In this way the change in the relative toxicity of
the wastes produced can be evaluated along with measured changes
in waste volume.


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     During the first year of this Program the software
computational system has been restructured to make it more
efficient and the toxicity database has been expanded for
chemicals that are expected to be found in the waste streams.  A
necessary task has been to obtain information on the chemical
make-up of each of the waste streams to be evaluated.  This
information has been difficult to obtain for some of the
commercial products used by the participating companies.  In most
cases chemical analysis of the wastes will be undertaken to
determine constituents and their concentrations for the degree of
toxic hazard evaluations.

     The first year of this project has been successful in that
at least five candidate projects have been selected and all
maintaining the project schedules.  Considerable effort has been
required to identify potential participants, to evaluate each
candidate technology, and to select those most beneficial.  State
funding has been used to assist with three of the projects and
cooperative agreements have been reached with the other two.  One
draft QA Project Plan was reviewed by EPA and is being revised.
Two other QA Project Plans are being prepared by Program staff.
Preliminary results have been obtained from three of the
projects.

               ENGINEERING AND ECONOMIC EVALUATIONS

     It is anticipated that each evaluation will be completed
during the second year of this Program.   This evaluation involves
an in-depth study of the process, a literature review, material
and energy balance computations, a field demonstration, and cost
estimation.  The short time involved in conducting the evaluation
of a technology precludes examination of long-term operating data
for evaluation of life-cycle costs and long-term operating
problems.  The scope of the project also limits the extent of the
evaluation.

     Once a technology or technique has been selected for
demonstration, a site specific Quality Assurance Project Plan
will be prepared.  This plan will address sampling locations,
types of analysis to be performed, data handling procedures, etc.
specific to a given technology evaluation.  Although the content
of each plan will vary depending on the technology studied and
the extent of the engineering and analytical evaluation, the
following items will be common to each QA Project Plan:

     1)  Testing program duration and schedule,
     2)  Development of detailed evaluation design,
     3)  Sampling and analytical procedures, and
     4)  Health and safety concerns.

PROJECT DESCRIPTIONS

     Descriptions of the activities to be undertaken for each of
the five selected project are provided below.  Included in the
description of each project is the technology or technique to be
evaluated.


                               428

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I.   MPI Label Systems - flexographic printing with water-based
     inks and alternative cleaners.

     MPI Label Systems of University Park, XL is a small
label-printing firm which uses narrow-web, multi-color
flexographic presses.  A recent management decision mandates that
they use materials that are least  toxic  to individuals and
are not hazardous to the environment.  As a result they converted
to the exclusive use of water-based inks and are evaluating the
use of alkaline and citrus-based  cleaners.  Prior to the change,
their inks and cleaners were compounded with alcohol solvents.

          The water-based inks contain only about 5% alcohol.  A
full line of 720 different colors are available with the new inks
and their print quality is at least equal to their predecessors.
Disposal of small quantities from clean-up into the sanitary
sewer is acceptable to most treatment plants.  Larger quantities
are filtered to remove the organic pigments.  The latter material
is then sent to a landfill.

     The citrus-extract cleaning agent appears to perform
satisfactorily.  The other new cleaning agent is composed of
non-halogenated organic compounds which remove spills of plastic
label coating.  Factors being evaluated include product quality,
waste minimization, employee tolerance and economic analyses.

     At least three meetings have been held with MPI Label
Systems plant staff and WRITE Program staff to establish the
scope of the evaluation to be undertaken and for project staff to
gain familiarity with MPI's operation.

 II. U of I, Office of Printing Services - offset printing with
     soy-oil based inks and alternative cleaners.

     The Office of Printing Services (OPS), University of
Illinois at Urbana-Champaign, is participating to cooperatively
evaluate the change from petroleum-based inks to soy oil-based
inks in offset printing operations.  The change is being
considered because soy oil is a renewable resource, less air
emissions may result, any ink wastes may be more degradable, and
the end products may be more easily recycled.

     A cooperative agreement was signed with OPS for this
project.  During this project, data will be collected on the
volume of inks used, the effectiveness of various press clean-up
chemicals, the amount of waste produced, and the comparable costs
of using both types of inks.  Any change in toxicity of wastes
produced by the alternative inks and cleaners will also be
determined.

     The Office of Printing Services will evaluate the use of
soy oil inks and appraise any effects on printing quality.   OPS
will also provide all necessary information on volume of
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materials used, effectiveness of alternative cleaners, material
costs, waste volumes, etc., required to make engineering and
economic evaluations of the soy oil inks.

III. P & H Plating - non-cyanide zinc plating and reuse of
     recovered chemicals in electroplating.

     P & H Plating Company is a large Chicago electroplating job
shop.  Their main plating lines include cadmium, chromium,
copper, nickel and zinc.  Of the zinc processes, there are five
plating lines — three rack lines and two barrel lines.  All the
zinc lines use zinc cyanide to plate mostly steel parts.  In the
U.S. plating industry, 85% of zinc plating is done with cyanide
baths because of the ease of maintenance, lustrous and ductile
deposits, and easy preplate cleaning requirements.

     For the current project, P & H Plating is changing one of
the zinc barrel lines to non-cyanide alkaline zinc chemistry.
This particular line has a 2500 gallon plating tank divided into
nine plating stations.  The cyanide plating bath will be replaced
by the non-cyanide alkaline zinc bath, the main component of
which is zinc hydroxide.

     The most innovative aspect of this project will be the
recovery of zinc hydroxide from the rinse water for reuse in the
plating bath.  Rinse water containing low concentrations of
plating solution will be treated by pH adjustment to precipitate
the zinc hydroxide.  This will be filtered, monitored as to
suitability for reuse, and its chemistry adjusted as needed
before being returned to the plating bath.  The filtrate will be
recirculated and reused as rinse water.  Some dilution with fresh
water may be necessary*

     Under the WRITE project the capital cost of the changeover,
reduction in sludge volume and toxicity waste,  reduction in
volume of cyanide bearing waste water, reduction in rinse water
use, reduction in operating costs,  and plating quality before and
after the change will be evaluated.  This project is being
undertaken cooperatively with a consultant, the Center for
Neighborhood Technology (CNT), with State funding from HWRIC.
CNT has collected some samples of the zinc plating line prior to
installation of the new equipment.   Since then the new equipment
for recovery and reuse of the zinc hydroxide has been installed.
Evaluation of this equipment and the technology change is
scheduled for July and August.

IV.  Graham Plating - vacuum evaporative batch recovery of
     chromium,  copper, nickel, cadmium, brass and zinc in
     electroplating.

     Graham Plating Company is a medium-size plating job shop.
Their major plating lines are chromium, copper,  nickel,  cadmium,
brass and zinc.  The company recently moved to a new facility in
Arlington Heights, northwest of Chicago.   The new plant is
designed to be a zero-discharge facility producing no waste water
or sludge.   It is the company's goal to recover and reuse all


                               430

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plating chemicals.  The main waste reduction  feature of the  new
plant will be a Vacuum Evaporative System  (VES).  Rinse waters
containing low concentrations of plating solutions  from each line
will be collected in separate storage tanks and  fed to the VES
and reused for rinsing and other operations.  The concentrate
containing plating chemicals from that VES will  be  monitored as
to suitability for reuse in the plating bath, its chemistry  will
be readjusted, if needed, and pumped back to  the plating tank for
reuse.  The entire system will be automated.

V.   American Foundryman's Society - recovery and reuse of waste
     zircon molding sand in the investment casting  (foundry)
     industry.
     State funding has also been given to the American
Foundrymen's Society (AFS), headquartered in  Des Plaines, IL, to
develop a solution to one of the investment casting industry's
waste management problems.  Zircon silicate,  which  is a strategic
and costly sand, is one of the aggregates utilized  in the high
quality investment casting process to form a  mold.  Currently
there is no way to reuse the zircon constituent  of the spent mold
materials; it is discarded and sent to a landfill.  Sometimes the
sand contains significant quantities of metal contaminants.

     Investment casting in the U.S. is a $3 billion industry.
There are 14 foundries in Illinois employing  approximately 1,400
people.  From these foundries over 5,000 tons of mold material  is
disposed of each year at an approximate cost  of  $175,000.
Typical tipping fees are $15-20/ton with transportation costs at
least equal to the tipping fees.

     The goal of this project is to develop a practical and
economical approach to reclaiming and reusing the used zircon
sand.  Currently, AFS is evaluating candidate technologies for
recovery of the sand.  By the end of the summer of 1990 the most
promising technology will be selected and the project
requirements determined.   Mechanical and thermal reclamation
techniques will be investigated.  Potential uses of the reclaimed
zircon include reuse in the foundry,  production of zirconium and
production of base ceramic products for other industries.   Pilot
scale testing of the reclamation and reuse process which is
developed will be performed in six Illinois investment foundries.
The project is expected to result in an economical use for what
is currently a waste, will save valuable landfill space,  and
money for the foundry.

DISCUSSION

     The four pronged approach used to identify industrial
project participants and appropriate technologies has proven
successful.  It is helpful that HWRIC and the University of
Illinois are not regulatory agencies.   The experience that HWRIC
has had in the past five years of working with companies has also
been a benefit.   For some participants the availability of state
funding to cover a portion of the cost of the project was
necessary for them to undertake the project and to share the
results.  Since HWRIC had sponsored the Governor's Pollution


                               431

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Prevention awards for the past  four years, this positive
recognition was an inducement for  other companies to consider
participation.

     Barriers to this Program include the need that most
companies have to protect proprietary information on their
processes and equipment.  In most  cases an evaluation can be
performed without using that information but in some cases this
issue is insurmountable.  The past experience some companies have
had working with government agencies  has a strong influence on
their willingness to participate.   Small to medium-sized
companies are generally more interested in obtaining assistance
with these types of projects.   Large  companies have the necessary
resources and staff to undertake these projects.   The main interest
of large companies, as stated by several  approached by HWRIC, is often to be
given favorable publicity about what they are doing to reduce their wastes
and be good corporate citizens.

     The scope of the evaluations  undertaken on this Program is
generally limited to a month or less  of in-plant sample collection
of a few key parameters.   There usually is not enough time
to evaluate the technologies under all operating conditions over
a  long  period of time.  Some industrial waste reduction projects
are on  a very tight time  schedule  that leaves little time for
collection of samples before the new  technology is installed.  It
is often necessary to adjust the project schedule or scope to fit
within  the production schedules and business plans of the
industries.  Considerable difficulties have also been encountered
in obtaining adequate information  about the materials used and
the costs that  a company  has for production and waste management.

     With persistence and by contacting enough prospective
participants, enough willing companies can be found to undertake
these  cooperative technology evaluations.  Expertise and
familiarity is  needed about the industrial processes and waste
reduction technologies being evaluated so that an adequate
evaluation plan can be devised. This requires close coordination
between the evaluation team and the industry.  The results of
these  evaluations are of  great  interest to many other companies
and this is a worthwhile  approach  to evaluating waste reduction
technologies.

                            REFERENCES

1. Plewa, M., Minear, R., Ades-Mclnerney, D., and Wagner, E.
Refining the  Degree  of Hazard  Ranking Methodology for Illinois
Industrial Waste Streams.  HWRIC RR-029, Hazardous Waste Research
and Information Center,  champaign, Illinois, 1989, 99 pp.
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  Table 1.  WORTH ASSESSMENT MODEL EVALUATION - ILLINOIS/EPA  WRITE.PROJECTS
Criteria Weight
Status of Development 5
Applications 20
Priority Waste
Range of other applications
Size of Industry
Source Reduction Performance 20
Extent of Process/Equip. Modifications 10
Cost-Effectiveness of Technology 15
Safety & Health Considerations 5
Cost to EPA £, local governments 5
Demonstrator's Qualifications 10
Legal/Contractual Issues 5
Length of Evaluation 5
TOTALS 100
Score - Rating
MPI
2.5
13
3
4
6
20
10
7.5
5
2.5
10
5
5
65.5
AFS
0
10.6
0.6
4
6
10
5
7.5
2.5
2.5
10
5
0.5
43.6
P S. H
0.5
13
6
4
6
20
5
15
5
5.5
10
5
5
61
Grahm
2.5
13
6
4
6
20
1
15
5
2.5
10
5
0.5
63. S
UI/OPS
2.5
13
3
4
6
10
10
7.5
5 1
2.5 |
10
5
5
50.5 1
MPI = MPI Label Systems, Inc.
AFS = American Foundrymen's Association
P8.H = P & H Plating, Inc.
Grahm = Graham Plating Works
UI/OPS « University of Illinois/Office of Printing Services
                             433

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     POLLUTION PREVENTION IN THE ELECTRIC UTILITY INDUSTRY

            by:   Michael J. Miller
                 Electric Power Research Institute
                 Palo Alto, CA 94303

                               ABSTRACT

INTRODUCTION
The electric utility industry generates several types of waste by-products as a result
of electricity production. These by-products vary in composition, frequency of
generation, and quantity.  Management practices include landfills, ponds,
incineration or evaporation, reuse/recycle and source reduction. Examples of
waste by-products include coal ash, FGD system by-product, metal cleaning wastes,
solvents, runoff from coal piles and various blowdown streams.

METHODS
The Electric Power Research Institute (EPRI) and individual utilities have been
involved in a number of activities aimed at cost-effective by-product
management.  Studies have included construction of highways using coal ash,
substituting coal ash for cement and aggregate in concrete and testing uses for
waste streams such as boiler chemical cleaning wastes.  Further, several guideline
manuals on options for waste management have been prepared for such wastes as
antifreeze, asbestos, petroleum contaminated  soils, batteries and various
wastewaters.

RESULTS
These studies have shown that, in general, electric utility wastes are non-toxic and
non-hazardous. Several management options currently exist for many wastes;
however the actual costs and applicability are dependent on the regulatory and
environmental climate where the waste is generated.  In some cases, the options
available are quite limited and thus management costs  could be relatively high.
Research by EPRI, the federal government and private industry is rapidly
expanding the management options available. Databases have been established to
track emerging technologies and currently available techniques (including waste
minimization opportunities) are documented in published reports.

CONCLUSIONS
The activities described in the paper are multi-media in perspective. The  electric
utility industry's continuing goal is to design  and operate power plants in a
manner which poses minimal environmental risk while at the same time taking
an integrated and innovative perspective to waste management.
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       POLLUTION PREVENTION IN THE ELECTRIC UTILITY INDUSTRY
                              INTRODUCTION

     The electric utility industry produces many and varied by-products in the
process of generating and distributing electricity and in servicing its customers.
These by-products span a wide range in terms of volume and rate of generation,
chemical and physical form (solids, liquids, gases), and management methods.  In
general, the industry does not use or dispose of many by-products which carry a
toxic or hazardous designation under  RCRA  (characteristic or listed), the  Clean
Water Act, Clean Air Act or other Federal or individual state laws and regulations.
For example, EPA's Report to Congress "Wastes From The Combustion of Coal By
Electric Utility Power  Plants" recommended that  high volume coal combustion
residues-fly ash, bottom ash, boiler slag, and flue gas desulfurization(FGD) sludge--
not be regulated as "hazardous waste" under Subtitle C of RCRA (1).  In fact, the
Report encouraged utilization of these combustion by-products in commerce.

     By-products from the  generation and  distribution of  electricity and  other
associated activities will be categorized into three general types for the purposes of
this paper. High volume by-products are fly ash, bottom ash, FGD by-product, and
boiler slag. Currently the industry produces approximately 90 million tons per year
of this material  (2).  The second category is low volume/noncombustion wastes.
This category spans virtually every other liquid and solid by-product stream.  Here
the volumes can range from ounces to tons per year.  Examples include liquid filled
fuses, asbestos, solvents, paint sludges, boiler cleaning wastes, various blowdown
streams and ash pond discharges.

     The final category,  gaseous emissions, represents the source of  the high
volume solid by-products generated by utilities. This situation begins to get at the
heart of pollution prevention as a regulatory philosophy.  That is, in cleaning the
air of particulates and sulfur oxides, the burden is shifted to the land and water
environment. As discussed below, the challenge for utilities is to find uses for this
by-product material rather than simply transfer chemicals among media.

     The electric utility industry has historically relied on landfills and ponds as its
primary solid and liquid waste management strategy.  However, as will be noted in
this  paper, the  industry is increasingly pursuing markets for its by-products
through brokers, waste exchanges, recycling/reuse; by generating less material; or by
using more environmentally compatible materials.   This  paper will  provide
                                     435

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several examples of pollution prevention as applied by the electric utility industry
and  describe  the role of the Electric Power Research Institute  and  others in
furthering that objective.

CASE STUDIES OF UTILITY POLLUTION PREVENTION

     The discussions given in the remainder of this paper are not intended to be all
inclusive but rather provide a glimpse of how the electric utility industry is being
innovative in effectively managing  its by-products.   The intent is to share
experiences so others may learn  from our  experiences and to  adopt effective
strategies employed by others.  Most of the examples  cited are  individual case
studies and should not necessarily be construed as being widely applied.

HIGH VOLUME BY-PRODUCTS.

     As noted  above, high volume  by-products are generated as a result of the air
emissions control system at a power plant—electrostatic precipitators, baghouses or
flue  gas desulfurization systems.  Currently, the industry  produces about 90 million
tons  per year of coal ash and FGD by-product- enough to fill a football stadium to a
height of nine miles.  Given projections that coal use in  the US may double in the
next 10 to 15 years, and the growth anticipated for flue  gas desulfurization (FGD)
systems because of new Clean Air Act legislation, the  challenge to manage this
increasingly large volume of material will grow substantially.

     Currently, about 20% of electric utility industry high volume by-products are
used in  commerce. The  primary use is fly ash as a  substitute for  cement in
concrete.  Figure 1 shows that utilization trends have remained relatively constant
over the last several years.   Although there  are many uses for coal ash given its
pozzolanic and, in some cases cementitious properties, most potential markets are
relatively small.  The examples cited below will focus on some potentially large and
innovative markets for coal ash that are relatively new.

Highway Construction

     Highway construction  represents  a  major  potential market for coal
combustion by-products, but use to date has been limited. This is due primarily to
the unfamiliarity that state highway departments and contractors have with coal
ash  in these applications.  In addition, state environmental  permitting agencies
need information on the potential impacts of the ash constituents on groundwater.
Finally, the materials that coal ash  would replace-cement, sand, soil and aggregate
are typically locally available at relatively low cost and the suppliers are structured
as vertically integrated  industries.  Thus, coal combustion  by-products have a
difficult time in cracking the market unless there is a strong cost advantage.
                                      436

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    In the State of Kansas, the Kansas Electric Utilities Research Program (a
consortium of Kansas utilities) sponsored a program  to  use coal  ash in the
renovation of secondary roads. The concept involved spreading 3 to 4 inches of dry
ash on the existing surface.  The surface was then pulverized to a depth of 6 to 8
inches.  Water was added during the pulverizing process to allow cementitious
reactions to occur and the mixture subsequently compacted.  A top coat of sealant
was applied as the final step.  This project used a Type C or cementitious ash which
is typical when burning low sulfur western coals. The test sections in Kansas  were
only two  miles in length.  However, the success of this project has  resulted in
repavement of over 400 miles of secondary roads in Oklahoma.  It should be
applicable almost anywhere in the US, especially in rural areas where Type C coal
ash is locally available.

    The Electric Power Research  Institute (EPRI)  and several of its member
utilities have sponsored six highway demonstration projects in  the US using coal
ash in  several different applications  such  as  road  subbase, base  course,
embankments and as a high cement replacement in  concrete.  The projects  were
structured to show the technical acceptability of ash in these applications as well as
examine any short-term effects on groundwater.  One utility in Pennsylvania  used
coal ash and stabilized FGD by-product rather than conventional  fill materials  in an
embankment for an interstate highway. They documented savings of over $600,000
for a 1500 foot highway section where 353,000 tons of coal ash  were used. These
demonstration projects  have  served as  test cases for highway  design and
construction manuals using coal ash (3,4).

Aggregate Production

    Although the largest use of coal ash is as a substitute for cement  in concrete,
concrete contains only about 20% cement.  Most of the remainder is aggregate and
water.  Therefore, manufacture of aggregate from coal ash would represent  a much
larger market in the concrete industry.  An example of a recent entry into this
market is the  Aardalite process. It consists of  mixing coal ash, water, lime and
additives and passing the resulting mixture through a rotating disc pelletizer which
forms pebble type material which can be sized according to the need.  A 24  hour
steam cure is  necessary to produce the final product.  A full-scale plant is currently
in operation in Florida and uses about 150,000 tons of coal ash  a year. A similar
facility, referred to as Agg Lite, recently started operation in Virginia.  The  process
uses cement rather than lime to produce the aggregate.

Other Uses of High Volume Coal Combustion By-Products
                                     437

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    Electric  utility  coal combustion by-products have  been used in over 50
different applications (5). Examples are listed in Table 1.  However, many of these
uses have limited market  volumes  and  given the large volume  of material
produced each year, new markets are  always needed.  Some new applications
currently in the research stage that appear promising are as filler materials for
plastics and metals. Not only could these materials be produced more cheaply, the
ash would add improved properties to the final product.  In aluminum,  the ash
adds improved machining and sound damping characteristics to the metal, making
it a good candidate for engine casings.  In plastics, the ash could reduce the need for
expensive matrix components such as resins or reduce the amount of elastomers in
rubber.

    The electric  utility industry  and EPRI are aggressively  pursuing existing
markets for coal ash and investigating new opportunities through research. While
no national goal for coal ash use has been established by the industry, the American
Coal  Ash Association  and the Edison Electric Institute have been active in
promoting coal ash as  a by-product and  in attempting  to remove institutional
barriers to its use (6).

LOW VOLUME/NONCOMBUSTION WASTES

    The following discussion will illustrate several innovative means by which
the electric utility  industry is pursuing options for reducing disposal  volume for a
variety of other waste  materials generated as part of electricity production and
distribution.  The major motivation for these new approaches is cost.   Many states
have designated a  wide variety of waste materials hazardous; thus, costs of landfill
have increased substantially and potential long-term liability remains an issue for
wastes which require disposal.

Antifreeze (Ethylene Glycol)

    Electric utilities  have large  vehicle  fleets  for servicing their customer
territories.  A large EPRI member utility initiated a recycling program for its
antifreeze and now saves about $90,000 annually. The spent antifreeze is  shipped
over 400 miles for redistillation and reconstitution back into antifreeze at a cost of
$1.50  per gallon versus replacing it at a cost of $8 per gallon.  Further cost savings
(not quantified) were realized from avoided disposal.

Boiler Chemical Cleaning Waste

    Electric utility boiler tubes must be cleaned periodically to remove iron and
copper deposits that form on interior surfaces and impede heat  transfer  and
diminish efficiency.  There are five common types of solutions commonly used to
                                      438

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clean boiler tubes which are generally acidic in nature (e.g., hydrochloric acid).
Utilities  typically clean their boiler  tubes  every 1 to 5 years.  The volume of
undiluted cleaning waste is usually around  125 gallons per megawatt. When this
material  is combined with several boiler volumes of rinse water, the total volume
can add up to several hundred thousand gallons for a large power plant. Although
on an annual basis this represents less than a gallon  per minute, in practice the
material  is generated in a short time and therefore  must be handled in large
volumes.

     Some of these  cleaning  wastes  have exhibited RCRA hazardous waste
characteristics because of pH or chromium  considerably increasing disposal costs
(7).  Thus, from a pollution prevention point of view, options that minimize waste
production, such as source reduction, substitution or recycling are preferred.   The
following discussion will illustrate examples of how the electric utility industry is
applying such approaches.

     One innovative electric utility  company  has initiated a program which
eliminates disposal of the cleaning wastes and provides a useful product to another
industry.  The utility treats the metal  bearing solution  with lime to precipitate the
metals in solution, primarily copper and iron.  The clean liquid is then returned to
the municipal wastewater system and the  resulting sludge is sent  to a  copper
smelter in Arizona.  The smelter recovers the copper value and uses the lime as a
flux  in the smelting process.  The utility has estimated savings of approximately
$400,000 per year in avoided treatment and disposal costs.

     Other utilities have reduced their frequency  of cleaning which is a  form of
source reduction.  Further, careful control of boiler  cycle water chemistry  can
reduce the amount of deposition in boiler tubes and therefore reduce  the need for
cleaning.  Another option that appears promising is reuse of the  solution in the
flue gas desulfurization system. Lab tests have shown that chemical cleaning waste
addition  slightly improves SO2 removal and increases limestone utilization.

Asbestos  Cages

     Asbestos has historically been used by the electric utility industry in three
forms: (1) in insulation around equipment, piping and  cables, (2) in surfacing
materials used during construction of  utility facilities, and (3) in a variety of other
products such as pump and valve packings, piping and equipment gaskets, floor
and ceiling tiles, and brake linings for company vehicles. Because various diseases
have been linked to industrial exposure to airborne asbestos, its use, handling and
disposal is strictly regulated by the Environmental Protection Agency (EPA) and the
Occupational Safety and Health Administration (OSHA).
                                     439

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    As long as asbestos  containing materials remain in  good,  non-friable
condition, abatement actions such  as repair, removal and encapsulation are not
required.  Once damaged or otherwise rendered friable, however, abatement action
is necessary to protect workers  from airborne fibers.  In areas of high maintenance
such as around valves and flanges, several utilities have constructed asbestos cages
which can be quickly snapped on  and off for easy  access.  This reduces worker
exposure to asbestos and reduces the amount of asbestos that must be disposed.

Petroleum Contaminated Soil Reuse

    Petroleum contaminated soils  are produced as a result of leaks from above
ground and underground storage tanks. The typical means of managing such spills
is removal of the contaminated soil and transfer to  a secure landfill.  One utility
has found that rather than send the  material to landfill, the soil can be incorporated
into asphalt to pave light-duty roads in the vicinity of its facilities. This practice has
saved $350 per cubic yard in treatment costs for the contaminated soil or between
$270,000 and $385,000 per year assuming paving of one road per year.

Spent Solvent Waste Management

    Utilities generate  small quantities of spent solvent wastes  from routine
operations such as  parts cleaning, paint stripping and vehicle maintenance. Since
solvent wastes are typically classified as  hazardous, management practices are
costly.

    Many utilities  have already initiated solvent minimization programs. Typical
steps include source reduction (i.e., use less  solvent),  substitution of less toxic
materials and recycling of used materials. Table 2 illustrates examples of frequently
applied techniques and some of the issues associated with each (8).  In terms of
waste reduction, using less solvent is the simplest and often least expensive option.
Worker training and good housekeeping have been shown to be effective methods.
Limiting availability of solvents at facilities  is another way to reduce usage.  Several
utilities  have  experimented with a  single  universal  solvent,  typically either
mineral spirits or TCA (1,1,1-trichloroethane) to replace a wide variety of products.

     A variety of non-traditional substitutes are available to  replace halogenated
organic solvents.   Alternatives include sodium carbonate or sodium phosphate
solutions, emulsion cleaners such as mineral spirits and organic cleaners such as
citrus based D-limonene.  Substitutes are generally less toxic, but are generally less
effective, especially in electrical contact cleaning.  Mechanical cleaning can, in many
instances, be substituted for chemical cleaners.  Extra "elbow grease" is an effective
substitute as is sand or bead blasting.  Mechanical  cleaning works  well for paint
                                      440

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stripping but is less satisfactory for degreasing and use on sensitive materials such
as wood, plastic or soft metal.

     A survey conducted by EPRI indicated that that 46% of respondents employ
some type of solvent recycling. Figure 2 shows the comparative costs for several
recycling options. In most cases, recycling is less expensive than spent solvent
disposal as a hazardous waste.

CONCLUSIONS AND FUTURE DIRECTIONS

     This paper has provided limited examples of how the electric utility industry
is applying the concept of pollution prevention in  its operations.  Studies have
shown that, in general, utility industry by-products are non-hazardous and non-
toxic.  Nevertheless,  landfill  costs are  increasing and those  wastes which are
hazardous or toxic and require disposal pose potential long-term liability. Thus,
the industry, through EPRI,  EEI, ACAA and the Utility Solid Waste Activities
Group (USWAG)  have together devoted increasing attention to the issue.

     EEI  and USWAG have focused on improving the legislative and regulatory
climate for flexibility in  managing  utility by-products  in  an environmentally
compatible manner.  ACAA has focused primarily on improving markets for the
high volume by-products through its efforts with the ash marketers and end-users
such as highway departments and contractors.

     EPRI research supports the activities of these organizations noted above and
its  member utility companies through  investigating new uses and devising
innovative management practices at both laboratory and field scale.  Reference
manuals have been produced to assist utilities  in effectively managing by-products
(9,10,11).  An emerging technologies database is tracking new developments in
more cost-effective by-product management methods. EPRI is also looking into
integrated waste  management concepts  which would examine the entire power
generation  cycle for  opportunities to reuse, recycle or  reduce generation of
residues, market those residues to others or combine waste management strategies
for similar waste materials.

     The  electric utility industry is supportive of the pollution prevention  concept
and continues to put new management practices in place that will further  this
objective. The electric utility industry's continuing goal is to operate its facilities in
a manner that poses minimal  environmental risk.  This drive for new solutions
for integrated waste management will involve not only technical innovations, but
also institutional and regulatory changes that view pollution control from a multi-
media perspective.
                                    441

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 Ash Utilization Rates in the US from 1980 through 1988
     80%
_N

t?

JC
w
 o
o
O
s?
                                                             % Fly Ash Used
                                                             % Bottom Ash Used
                                                             % Boiler Slag Used
                                                             % Total Ash Used
                                                          Data from the American
                                                          Coal Ash Association
                                                          Annual Survey
          1980  1981  1982 1983 1984 1985  1986  1987  1988

                             Year


                                FIGURE 1
                                    TABLE 1
                     COAL ASH UTILIZATION APPLICATIONS
•Replacement for Cement in Concrete
•Raw Material in Brick Manufacture
•Trench Backfills
•Area Fills/Landscaping Berms
•Structural Fill or Embankment
•Mineral Filler in Asphalt Paving
•Grouting
•Pozzolonic Base Course
•Aggregate in Bituminous Paving
•Railroad Ballast
•Mineral Wool Insulation Manufacture
•Source of Cenoshperes for Insulation
•Molding Sand Flowability Agent
•Roofing Granules in Asphalt Shingles
•Oil Spill Absorbent Material
•Sewage Sludge Dewatering Absorbent
•Sanitary Landfill Cover
•Abandoned Strip Mine  Reclamation
•Water Treatment Filtering Medium
•Revegetation Aid
•Aggregate in Lightweight Concrete Block
•Cement-Stabilized Bases and Subbases
•Fighting Mine Fires and Controlling Subsidence
•Cement Replacement in Precast Concrete Manufacture
•Structural Fills for Housing and Business/Industrial Parks
                                                    •Ingredient in Grouting
                                                    •Flowable Fly Ash Fills
                                                    •Fills for Dams and Dikes
                                                    •Large Fills (e.g., parks)
                                                    •Pozzolonic Base Course
                                                    •Soil Stabilization
                                                    •Aggregate Base Course
                                                    •Cement Stabilized Base
                                                    •Drainage and Backfill
                                                    •Roofing Felt Ingredient
                                                    •Metal Reclamation
                                                    •Wallboard Manufacture
                                                    •Filler Material in Plastics
                                                    •Soil Amelioration
                                                    •Oil Spill Filtering Medium
                                                    •Sulfate Sludge Fixation
                                                    •Sand Blasting Grit
                                                    •Ice Covered Road Grit
                                                    •Agricultural Fertilizer
                                                    •Artificial Reef Construction
                                                    •Portland Cement Manufacture
                                     442

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                                     TABLE 2
    Options to Reduce or Manage Solvent Wastes.  The waste reduction options at
    the top of the table are preferred; disposal is used to eliminate residual wastes.
Waste Management Options
                           Example*
                             Key Issues/Potential Problems
      >£-. — »
Reduce, Solvent U:
     __ >,  v»—  __ -/
I      II
u-

                              -
                           Add covers* to parts' cleaners
                         - ThitajreBBntercuTfeni. T     "|
                             multl**iage>«J«anerr	
                            ae su
                           !  Usual!
Recycle; Spent So vent
t	-1 r	\
i      I
!	-|
  ilvent and parts cleaner
—Contract services
   •site recycling
  r-slte (commercial) recycling

Hazardous waste Incineration
Waste derived fuel and
  fuel blending
Burn waste In utility boiler
Usually Inexpensive
"Re'q'uireFbpVratoFlnd worker
-  InvoiyemenfalKMralnirig	'
                                                        Aqueous substitutes less costly,
                                                        '"-. organic substitutes more costly
                                                        -Substitutes may not perform as
                                                          well as traditional solvents

                                                        Recycling appears cost effective
                                                        Solvent contract services
                                                          minimize utility Involvement
                                                        On-slte recycling requires
                                                          large volumes to be economic
                                                        May be only alternative for
                                                          some waste materials
                                                        Regulatory uncertainty about
                                                          burning as fuel
               Parts Cleaner
               Service Contract
                                                    dous Waste Incineration
                     200           400            600            800
                   Amount of Waste Solvent Generated (gallons/month)
                                                                                1000
                                      FIGURE 2

                     Comparative Costs for Waste Solvent Recycling
                                       443

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REFERENCES

 1.  Report of the United States Environmental Protection Agency to Congress on
    "Wastes From the Combustion of Coal by Electric Utility Power Plants," ICF
    Incorporated, February 1988.

 2.  Coal Combustion By-Products-Production and Consumption, American Coal
    Ash Association, 1988.

 3.  Brendel, G., DiGioia, A., Dry Fly Ash Design Manual for Highway and Site
    Applications, EPRI Report CS-4419, Vol 1, March 1986.

 4.  Brendel, G., et.al., Fly Ash Construction Manual for Road and Site
    Applications, EPRI Report CS-5981, September 1988.

 5.  Patelunas, G. M., High Volume Fly Ash Utilization Projects in the United
    States and Canada, EPRI Report CS-4446, Second Ed., May 1988.

 6.  Parks, D., editor, Coal Ash, American Coal Ash Association and Edison Electric
    Institute.

 7.  Lott, T., Micheletti, W., Holcombe. L., Boiler Chemical Cleaning Waste
    Treatment and Disposal Options, Paper presented at the 50th Annual Meeting
    of the International Water Conference, Pittsburgh, PA, October 23-25, 1989.

 8.  Lott, T., Managing Spent  Solvent Wastes, EPRI Journal, September 1989.

 9.  Options For Handling Noncombustion Wastes, EPRI Draft Report, Prepared by
    Mittelhauser Corporation and Roy F. Weston, Inc.

10.  Preslo, L., et. al., Remedial Technologies for Leaking Underground Storage
    Tanks, EPRI Report CS-5261, July 1987.

11.  Dawson G., et. al., Utilization Potential of Advanced SO2 Control  By-Products,
    EPRI Report CS-5269, June 1987.
                                     444

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                             COAL REFUSE TO ENERGY

                            by:  Ronald D.  Neufeld
                        Professor of Civil Engineering
                           University of Pittsburgh
                             Pittsburgh, PA  15261
                                   Abstract

The  objective of  this  research  is to  develop basic  energy production  and
environmental  information  for the  in-situ combustion  of  coal refuse  piles.
Laboratory pilot  system results  show exhaust  gas  temperatures from  in-situ
combustion of over 1,000°C, with 65%  to 96% utilization of the original calorific
content of the pile.   The relative quantity of fines has great influence on gas
permeability  of  refuse,  and operational  efficiency  of combustion.   EPA-TCLP
leachates  of  "post  burn"  coal  refuse  are  nonhazardous  under current  RCRA
regulations.    Combustion volatilized significant quantities  of Al, Pb, Zn, Hg,
and  Cd,  and  removed 40%  to  99%  of the  original   pyritic sulfur,  thereby
attenuating acid mine drainage potentials.


KEYWORDS:   Coal    refuse;    waste-to-energy;    combustion;     leachates;
            coal preparation plants; trace metals;
                COAL REFUSE PILES:  NATURE,  LOCATION, SAMPLING

      Coal refuse piles originate from the coal preparation plant waste residuals
of yesterday.  'It is estimated that about 40% of the volume of all coal mined
in the U.S. since the 18th century has been discarded as waste,  covering about
177,400 acres of land throughout the coal producing regions of the U.S.  Today,
coal preparation plants are somewhat more efficient and produce waste at the rate
of about 25% by volume of coal feed (1,2,3).

      Coal refuse piles contain coal,  carbonaceous shales,  and  pyrites.   Some
piles  are  on  fire,   and  pose  inherent safety  hazards;  acid  mine  drainage
conditions are also common resulting in environmental blights on the landscape.
Little data is available characterizing the physical and chemical properties of
coal refuse piles.

      Pennsylvania  Department  of   Environmental  Resources   (DER)   provided
topographic maps with locations of all known coal  refuse piles within the State.
Using this data, a sampling protocol was developed,  and 9 different sites were
evaluated within the Western Pennsylvania region.
                                     445

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COAL REFUSE ANALYSIS

      Samples from each site were  crushed and riffled to assure samples  were
representative for analysis.  Coal refuse and ashed refuse samples were digested
with HC1 and HF in teflon lined vessels for subsequent metal analysis.   Details
of analytical techniques may be  found in Schmidt(4).

      Table 1 is a summary of analysis conducted on 9 different coal refuse  pile
sites in Western Pennsylvania.  Results of the 9 sites show a sample mean value
of 4,923 BTU/lb dry weight  (with a range of 2,328 BTU/lb  to  7,187 BTU/lb).


                                  TABLE  1

                ANALYSIS WESTERN PENNSYLVANIA COAL REFUSE PILES
            Site
            Banning
            Brownstown
            Cramer
            Export
            Homer City
            Mather
            Nemacolin
            Revloc
            Ebenezer

            Ranee	
       BTU/LB.   % ASH   % VOLATILES  %FIXED CARBON
      4,380
      7,178
      6,467
      3,665
      5,844
      3,117
      2,328
      6,518
      4,8710
         .6
         ,2
         ,6
         .4
65,
48,
53,
68.
57.4
71.9
76.5
51.1
63.0
18.7
23.4
19.9
17.4
18.9
17.6
17.1
18.6
21.5
15.8
  .3
  .6
28,
26,
14.2
23.6
10.5
 6.4
30.3
15.5
    2.328  -  7.178  48.2-76.5  17.1-23.4  6.4-30.3
      Table 2  is  a summary of sulfur  forms  in coal refuse.    Note that  the
average total sulfur content is 1.08% (with a  range of 0.58% to 3.04%).   Further
elemental characterization data is provided by Neufeld  (5).

                                  TABLE  2
           SULFUR FORMS IN WESTERN PENNSYLVANIAN COAL REFUSE PILES
                                (% BY WEIGHT)
      Site
      Banning
      Brownstown
      Cramer
      Export
      Homer City
      Mather
      Nemacolin
      Revloc
      Ebenezer

      Ranee	
  Total  -   Organic
                  Pvritic
                       Sulfate
.60
3.04
1.11
.61
.79
.97
1.59
.91
.58
.32
1.32
.64
.36
.39
.24
.17
.37
.30
.06
1.20
.13
.06
.09
.07
.12
.05
.09
.22
.52
.34
.19
.31
.66
1.30
.49
.19
.58-3.04
.17-3.02
       .05-1.20
       .19-1.30
                                     446

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COAL REFUSE RECYCLING

      Coal refuse is attractive for recycling due  to  its BTU value.  Currently,
modular coal preparation type plants using "float/sink" technology are reclaiming
some coal refuse sites.  Using such technology, a high BTU value coal product may
be "mined" for blending with the coal feed to local utility plants.  Wastes from
such systems are simply returned to the refuse pile.   Alternatively, coal refuse
may be combusted in bulk for energy production.  Two techniques  for direct firing
include fluidized bed combustion, and in-situ combustion  (4,5,6).

Insitu Combustion:  Experimental Procedure      Figure 1  is  a  diagram  of the
University of Pittsburgh in-situ combustion system  capable  of handling a 25 pound
charge of coal refuse.  The combustor exhaust pipe was connected through a gas
cooling system, to an exhaust fan capable of pulling 75 cfm at a water head of
50 inches.  The purpose of  the coolers were NOT to  generate steam, but  rather to
cool gases  sufficiently  to assure the integrity  of  down  stream air pollution
sampling equipment, and the air moving fan.

                                    RESULTS

      Figure 2 is an example of data from  the in-situ combustion of coal refuse
from the "Cramer" site.  Note exhaust gas temperatures rapidly  reached  a maximum
of 946°C before  it  declined due  to completion of  combustion.   The temperature
profile of the exhaust gas and the lower elevation of the reactor  follows similar
trends.  Further data of a  series of runs comparing refuse of high and low ash
contents  shows  that high ash content material could also achieve substantial
exhaust gas temperatures and energy production, and therefore should not be ruled
out for commercial considerations  (4).

GAS PERMEABILITY/PARTICLE SIZE

      The particle size distribution of the refuse influenced permeability, which
in turn influenced time for startup, and fraction  of calorific value  recovered
during  a  run.   Summary  data of  runs from all locations shows that start-up
periods appears to fairly constant at permeability values greater than  about 300
Darcys, with  drastically increased values at smaller permeabilities.   Further
analysis shows that permeability  and start-up period increase drastically as the
"D-90" particle size (ie..  the effective diameter  at  which 90% of all particles
are larger  than)  falls below 0.6 nun.    Higher permeability allows more air to
flow into the fire zone, which, in turn,  feeds more  oxygen to the  fire and avoids
pyrolysis conditions.

Gaseous Pollutant Concerns

      An air pollution sampling train was installed to monitor  on-line  S02, NOX,
combustion  gases,  and  total hydrocarbons.   In  general, the  nature  of air
emissions is  a  function  of the  type of  combustor  used.  In this case, in-situ
combustion  is by nature a fuel rich system,  with operator  control only with the
exhaust air fan.   Summary data shows  a  sharp increase  in  Total Hydrocarbons in
the exhaust gas as  its temperature decreases below 600°C.   Similar data for CO
illustrates  the same critical temperature.   Operation at  lower  temperatures
resulted  in pyrolysis conditions,  and emission of  tars and oil that coated the
fan impeller blade.  Maintenance of exhaust gas temperatures over 600°C allowed
for relatively  clean burning of  coal refuse with no noticeable hydrocarbons.


                                     447

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Similarly,   noticeable   levels    of   HoS   were    liberated   under   lower
temperature/pyrolysis  conditions  with  SG^   being  liberated  at  elevated
temperatures.  Analysis shows some sulfur oxide controls would be necessary for
commercial scale in-situ  coal  refuse  combustors.

Trace Metals:

      Material  balances  conducted for  trace  metals shows  that significant
fractions of Cd,  Pb,  Hg,  Al,  S,  and Zn appear to  be volatilized during coal
combustion:   the data for the significant fractions  volatilized  is presented  in
Table 3.


                                 TABLE  3

                  ELEMENTS VOLATILIZING  DURING  COAL REFUSE COMBUSTION
                               "Percent  Volatilized"
Site
Banning
Browns town
Cramer
Export
Homer City
Mather
Nemacolin
Revloc
Ebenezer
Range
Cd
75.0
28.6
66.7
0
50.0
53.8
12.5
50.0
78.1
0-78
Pb
79.3
81.1
72.0
73.2
59.6
91.7
91.7
87.2
85.7
60-92
Hg
71.7
83.8
92.4
76.6
72.7
68.8
81.3
81.8
40.7
69-96
Al
0
4.8
0
33.3
25.3
21.8
23.3
21.2
22.2
0-33
S
83.3
71.4
76.6
82.0
77.2
76.3
57.9
65.9
75.9
58-83
Zn
69.9
39.4
20.0
0
41.7
10.6
0
0
33.9
0-70
      Normalizing quantities of metals released to energy production, Table 4
shows calculated air emission potentials  for  key volatilized trace metals as
follows:

                              TABLE 4

                  AIR EMISSION POTENTIALS  FOR
            	Al.  Cd. He.  Pb.  and Zn	
            Element                 Range
                              (Ibs.  of metal/100 MW day)

            Al                      0-407,500
            Cd                      0-2.3
            Hg                      1.0-10.1
            Pb                      150-395
            Zn                      0-516
      Similarly,  elements Ba, Fe, Mn,  Ca,  and Mg appears to be retained strongly
in the combustion ash.   Results  of  a  mass balance showing  "percent retained in
ash" of these elements  is  given  on  a  site-by-site basis on Table 5.  This data
                                     448

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was developed by acid solubilization of aliquots of pre and post burn coal refuse
samples, followed by AA analysis for metals of concern.

                              TABLE  5

            ELEMENTS RETAINED IN COAL REFUSE COMBUSTION ASH
                        "Percent Retained in Ash"
Site
Banning
Browns town
Cramer
Export
Homer City
Mather
Nemacolin
Revloc
Ebenezer
Ba
100
100
100
96.1
99.5
97.5
100
100
92.1
Fe
100
100
100
91.5
76.8
95.0
83.7
94.7
84.2
Mn
100
100
100
100
100
100
100
100
100
Ca
100
78.3
100
80.0
100
89.4
100
60
55
Mg
93.3
92.3
100
96.3
86.0
91.4
94.1
100
86.7
            Range       92-10  84-100  100   53-100   87-100
LEACHATES and ACID MINE DRAINAGE POTENTIALS:

      Pre-burn and post burn coal refuse samples were leached in accord with both
the ASTM distilled water,  and EPA-EP acetic acid based techniques.  In addition,
measures of pH,  Hot Acidity, and major anion and cation species were made on the
distilled water leachates.  Heavy metal based "EP-toxicity"  appears not be an
issue.  Other data, however show that on the average the pH of leachate solutions
changed from  clustering about pH -  3.4 to  clustering about pH - 7.2.   This is
significant, since it indicates that one beneficial environmental effect of coal
refuse  combustion is  to  cause  drainages  to  go from  the  acid  range,  to  the
neutral/slightly  alkaline  range.   This is a  particular  advantage  for in-situ
combustion where  the refuse is not moved.

      A better measure of  attenuation abilities of acid mine drainage potentials
is  the  "net alkalinity",   (Net Alkalinity  - Alkalinity  -  Hot Acidity) ,  which
accounts  for the ultimate  oxidation of inorganic  species.   Distilled water
leachates from combusted coal refuse ash confirm that relatively acidic leachates
are  converted into  a  neutral leachates,   with  concurrent  small increases in
solubilization of K, Mg, and Na.

      A summary compositional analysis of  all  pre and post burn coal refuse ash
is developed  for  all sites, and is available from Neufeld (5).
                                      449

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                                CONCLUSIONS:
1.     Coal refuse originated as reject material produced during  the mining or
      beneficiation of coal.  These wastes pose potentially major environmental
      problems in  the form  of fire potentials,  and producers  of acid  mine
      drainage.      Structural  weaknesses  in  coal refuse  banks  have  led  to
      landslides  leading to loss of human  life.   In addition,  burning refuse
      piles  contribute significantly  to  potentially  serious  air pollution
      problems, and may cause additional underground coal fires within the coal
      mining regions of the U.S.

2.     One approach  for the simultaneous  generation of energy,  remediation of
      serious environmental problems,  and recycling of  resources is combustion
      of coal refuse via fluidized bed reactors, or via an in-situ technique.

3.     Using a bench  scaled in-situ combustion technique, Exhaust temperatures in
      excess  of  1,300  °C  were easily  achievable,  however,   overall  energy
      utilization efficiencies  were  achievable only when piles did not  contain
      excessive quantities  of "fines.  Particle size and the permeability of the
      refuse  are  significant  variables  that  influence  "extractability",  or
      energy utilization (% of  the  original BTUs utilized)  of a pile.   Below a
      D90 particle  size of 0.50 mm (ie..90%  by weight  of coal refuse  has a
      particle size > the D90  size),   the energy  utilization  of  the  burn
      decreases from 90+ % to  less  than 65%.   Particle size  is  related to gas
      flow permeability.  In a similar manner,  at gas flow permeabilities of 200
      Darcys  or  less,  the energy utilization of the  burn follows a  similar
      trend.

4.     Leachates produced by the residual material remaining after combustion do
      not contain metal concentrations in excess of 100 times the drinking water
      standard and  therefore  the residual  ash material from Burnout  Control
      would be non-hazardous under RCRA regulations.   Pre-burn   coal    refuse
      material exhibited tendencies  to acid mine drainage formation as  measured
      by "net alkalinities" (net alkalinity - alkalinity - hot acidity).  These
      tendencies  were  usually  confirmed  by visual observation at  the  time of
      sampling  by   the  Principal  Investigator  and   research  team.     Net
      alkalinities of pre-burn materials ranged from  -524 mg/L as CaCO^ to -14
      mg/L  as  CaCO-j.      Leachates  from  post  combustion  residuals  were
      characterized by a net  alkalinity range of -12 mg/L as CaCOg  to 36 mg/L as
      CaCO-j and a pH range of 4.8 to 10.1.

5.     Based on the  results  of mass balances, fractions of Al,  Cd, Hg, Pb, and Zn
      are volatilized  during coal refuse  combustion.   Up  to  33%  of  the solid
      phase aluminum volatilized, aluminum being present in the solid phase from
      6.3% to 9.1%  by weight.   Cd, Hg, Pb,  and Zn were found to volatilize to as
      high as 70% by weight, however,  in the solid phase Cd,  Hg, Pb and Zn are
      present at <.01% by weight.
                                     450

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                                 REFERENCES
1.    Heaton, R.C.,  Thode,  E.F.,  and Wagner,  P., Trace Element Recovery  from
      Coal Preparation Wastes.  Los Alamos National Laboratory, Los Alamos, NM,
      LA-9175-MS, 1982,

2.    Cavalet, J.R.  "Coal Cleaning Plant Refuse Characterization"   EPRI report
      # CS-4095  June, 1985

3.    McGown, Frank.,  and Gillespie, Barry, L. ,  Management  of Coal Waste by
      Energy Recovery:  Mild Gasification/Flash  Pvrolysis  of Coal Preparation
      Wastes. DOE/MC/21108, (1985)

4.    Schmidt, K. "Leachate  Properties and Mass  Balances Resulting from 'Burnout
      Control'  of  Coal  Refuse  Piles"    MS   Thesis,   Department  of  Civil
      Engineering, School of Engineering, University of Pittsburgh, 1989

5.    Neufeld, R. D.  et al "Burnout  Control and Energy Production  from  Coal
      Refuse  Piles"    final report   to  the Pennsylvania  Energy  Development
      Authority  under  contract ME 486-004, December  31,  1989  (University of
      Pittsburgh Research in Civil Engineering  series report CE/EE-02)

6.    Chaiken, Robert F.,  Method for  Controlled Burnout of Abandoned Coal Mines
      and Waste Banks. U.S. Patent No. 4,387,655 (1983).
      This project, entitled BURNOUT  CONTROL  AND  ENERGY PRODUCTION FROM
      COAL  REFUSE  PILES.   was   supported  by the  Pennsylvania  Energy
      Development Authority award number ME 486-004, to  the University of
      Pittsburgh, Dr.  Ronald D.  Neufeld, Principal Investigator.
                                     451

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tn
ro
                      COLD WATER
                      INLET   -""""
                     HEATED WATER
                     OUTLET
                                                FIREBRICK pEACTOR
                                        — <4	 THERMOCOUPLE (TO MEASURE EXHAUST TEMP)
1
                                                    DURING NORMAL OPERATION, EXHAUST TEMP
                                                    RANGE FROM 500 T01000 DEG C
                                               WATER-COOLED
                                               CCNDENSOR
DILUTION
AIR INLET
                                                                                       REGENERATIVE
                                                                                       VACUUM BLOWER
                                                TYPICAL FLOW RATE - 20 CFM |

                                                           FLOW RATE
                                                                                /^VACUUM GAUGE
                                                           THERMOCOUPLE         ^	
                                                         DROPOUTTANK      I  TYPICAL VACUUM PRESSURE - 35 • H20   I
                                                         Y^               	'

                                                BURNOUT CONTROL SYSTEM
                                                         FIGURE 1
                                                                                                      EXHAUST TO ATMOSPHERE

-------
in
CO
      o.

      Ul
      CE
      CC
      UJ
      CL
              1200
              1000 -
               800 -
               600 -
               400 -
               200
-O- EXHAUST

•*- Upper Plane

-o- Lower Plane
                                         TIME (hrs)



                            FIGURE  2 TEMPERATURE PROFILE


                                           CRAMER PR-301

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    SANDIA'S SEARCH FOR ENVIRONMENTALLY  SOUND GLEAMING PROCESSES
            FOR THE MANUFACTURE OF E-LF.CVTROHTC
                    AND PRECISION MACHINED PARTS
               M.  C. Oborny,  E.  P.  Lopez,  D.  R.  Frear
                    Sandia National Laboratories
                       Albuquerque, NM  87185

                          M. G. Benkovich
                 Allied Signal-Kansas City Division
                       Kansas City, MO  64141

                   R. F. Salerno,  J. V. Dichiaro
                  EG&G Mound Applied Technologies
                       Miamisburg,  OH  45343

                  D.  R.  Ostheim,  R. Waterbury,  Jr.
            General Electric Neutron Devices Department
                          Largo,  FL  34643
                              ABSTRACT

     As part of the DOE's commitment  to minimizing waste  at  the
national laboratories and its production agencies, Sandia has
embarked on a program to reduce, and where feasible, eliminate
hazardous liquid waste by-products of cleaning processes used in
the manufacture of electronic assemblies and precision machined
parts.  The program is being carried out in conjunction with three
DOE production agencies:  Allied Signal-Kansas City Division, EG&G
Mound Applied Technologies,  and General Electric Neutron Devices
Department.  We will discuss the methodology used to coordinate
such a program across the DOE complex, involving, as it does,
hundreds of components and thousands of DOE-specified cleaning
processes.

     We will also discuss three specific projects to replace
chlorinated solvents in cleaning manufacturing processes:
1) alternative solvents used to remove solder flux residues during
electronics assembly manufacture,  2)  alternative solvents used in
ceramic header fabrication,  and 3)  alternative manufacturing
processes that eliminate the need for solvent cleaning of
precision optical components prior to mounting.
                                454

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                            INTRODUCTION

     Chlorofluorocarbon and chlorinated hydrocarbon solvents are
widely used throughout the Department of Energy (DOE)  weapons
complex for cleaning processes.  However,  due to a variety of
environmental, safety, and health concerns, increasing numbers of
regulations are being issued by federal,  state, and local
regulatory agencies to ban, or to place more stringent controls
on, the production, use, and disposal of these materials.  Since
November 1986, DOE/Albuquerque Operations Office (DOE/AL) has been
concerned about the use of these solvents within the DOE weapons
complex.  At that time, R. G. Romatowski,  Manager,  DOE/AL, drafted
a memo to all weapons design laboratories and production agencies
requesting that they identify and qualify alternate materials to
replace the chlorofluorocarbons (CFCs) and chlorinated hydrocarbon
solvents (CHCs) then in use.[l]  As a result of this request, the
design laboratories and production agencies have initiated studies
to reduce and eventually eliminate the use of these materials.
Sandia National Laboratories (SNL) in conjunction with three DOE
production agencies [Allied Signal-Kansas City Division  (AS-KCD),
EG&G Mound Applied Technologies (EG&G Mound), and General Electric
Neutron Devices Department  (GENDD)] has embarked on a program to
eliminate these materials from cleaning processes used in the
manufacture of electronic assemblies and precision mechanical
parts.  This program represents an enormous undertaking as it will
require changes in cleaning processes for hundreds of DOE
components.


        DOE/AL CHLORINATED  HYDROCARBON SOLVENTS  COORDINATING
                             COMMITTEE

     In response to the Romatowski memo of November 1986, the
Chlorinated Hydrocarbon Solvents Coordinating Committee  (CHSCC)
was created under the auspices of DOE/AL to coordinate solvent
substitution efforts,  for chlorinated hydrocarbons and
chlorofluorocarbons, within the weapons complex.  In the three and
a half years that this committee has been in existence, there have
been significant decreases in the use of these materials in the
weapons complex.  These decreases have occurred primarily in the
area of "non-specified" cleaning processes.  Non-specified
cleaning processes are those cleaning processes that are not
controlled by design laboratory QA specifications and as such are
the province of the production agencies.   In contrast to non-
specified cleaning processes, specified cleaning processes are
defined by the responsible design laboratory to ensure that the
final product meets or exceeds required performance
characteristics.
                                455

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         FIRST INTEGRATION WORKSHOP ON WASTE MINIMIZATION:
                      NON-NUCLEAR  COMPONENTS

     Realizing that solvent substitution in specified cleaning
processes and a number of other waste minimization issues would
require a much closer collaboration among the design laboratories
and production agencies, SNL hosted the First Integration Workshop
on Waste Minimization:  Non-Nuclear Components in September 1989.
This workshop specifically addressed waste minimization issues
affecting non-nuclear components since SNL component design
responsibilities lie almost exclusively within the non-nuclear
area.  During this workshop, working sessions were held which
addressed the following areas:  1)  Encapsulants; 2) Halogenated
and Flammable Solvents; 3) Volatile Organic Compounds (VOCs);
4) Electroplating; and 5) Reliability Assurance  (i.e., the need to
assure long-term reliability while implementing changes in the
four materials areas).  The joint SNL/production agency solvent
substitution programs that will be discussed here shortly were, in
part, an outgrowth of this workshop.
                  SOLVENT  SUBSTITUTION METHODOLOGY

     As with any technical endeavor, an organized approach is
necessary in order to assure any kind of success.  The methodology
that we have used in our solvent substitution efforts consists of
the following six steps:   (1) Survey and periodically update
solvent usage;  (2) Identify and prioritize user locations and
programs; (3) Identify, evaluate, and develop substitute
materials/processes;  (4) Determine the effects of substitute
materials/processes on components and production process;
(5) Review proposed material/process changes with the appropriate
design and production departments;  (6)  Implement material/process
changes.


        SNL/PRODUCTION AGENCY SOLVENT SUBSTITUTION PROGRAMS

     In establishing  joint solvent  substitution programs between
SNL and the various production agencies, it was decided that the
production agency having primary responsibility in a given
component area would be the focus for efforts within that area.
Based upon this premise, we have divided up the component areas as
follows:  1) Electronic assemblies - AS-KCD; 2) Precision
mechanical assemblies - AS-KCD and GENDD; 3) Glass and ceramic
components - Mound and GENDD; and 4) Optical components - GENDD.
In addition to the above  joint SNL/production agency programs, we
also have a program with Babcock, Inc.  (Orange, CA), a relay
manufacturer, and are preparing a joint program with Raymond
Engineering  (Cromwell, CT), a manufacturer of inertial switches.
Both of these companies are small vendors who do not have the
resources necessary to undertake these solvent substitution
                                456

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studies on their own.  The successful completion of these programs
will represent a transfer of technology from DOE to these two
companies in the private sector.  Three joint SNL/production
agency solvent substitution programs for the cleaning  of
electronic assemblies  (AS-KCD), ceramic components (Mound), and
optical components  (GENDD) will now be discussed.
       SOLVENT SUBSTITUTION STUDIES FOR ELECTRONICS ASSEMBLY
                         CLEANING AT AS-KCD

     At this time, SNL and AS-KCD are involved in a joint solvent
substitution study to replace trichloroethylene  (TCE)  in the
cleaning of electronics assemblies at AS-KCD.  Figure 1 shows a
typical electronics assembly that illustrates the potential size
and complexity of the assemblies that must be cleaned.
              Figure 1.   AS-KCD electronics assembly.
     This study is focussed on a system that contains eight major
electronics assembly modules.   Production of this system requires
49 separate solvent cleaning steps using TCE.  These cleaning
steps are primarily for in-process rosin flux removal,  cleaning of
completed subassembly and assembly modules prior to foam
encapsulation, and post-encapsulation cleaning of silicone mold
release from encapsulated units.
                               457

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     In this study five substitute cleaning materials; a terpene,
decyl acetate, two proprietary aqueous cleaners, and isopropyl
alcohol, are being evaluated as potential replacements for TCE.
This study has been divided into two phases: Phase 1 is an initial
screening process to narrow down the list of substitutes to one or
two cleaners; Phase 2 is further evaluation and process
development studies of the cleaner or cleaners that successfully
pass Phase 1 evaluation testing.  After successful completion of
the Phase 2 studies, a substitute material will be qualified to
replace TCE in production cleaning processes.

   At this time, Phase 1 testing has been completed.  Evaluation
criteria that were used in the Phase 1 screening process were:
ES&H impact at AS-KCD, cleaning efficacy, cleaner corrosivity,
bondability of cleaned surfaces, and high voltage breakdown
resistance of high voltage assemblies after cleaning.  The
bondability and high voltage breakdown resistance testing were
necessary due to specific issues related to the production and
function of this particular system.

   An ES&H impact assessment was done by environmental, fire
safety, and industrial hygiene personnel at AS-KCD.  This
assessment indicated that,  properly used, none of the five
substitute materials would present a significant ES&H problem with
either current or anticipated near term regulations.

     Cleaning studies were carried out at both SNL and AS-KCD.
The SNL studies were primarily focussed on the removal of solder
flux and silicone mold release agent from four substrate materials
common to the electronics system being cleaned.  These materials
were: bare copper,  bare copper which had been fluxed and  Sn/Pb
solder dipped,  17-4 PH stainless steel,  and E-glass/polyimide
printed wiring board material.  The bare copper and solder dipped
copper substrates were used to simulate electronics materials
before and after soldering.   The 17-4 PH stainless steel is used
as the structural housing material for the electronics assemblies
and the E-glass/polyimide printed wiring board material is used in
all of the electronics assemblies in the system.

     In this study, coupons of the four substrate materials were
contaminated with each of the two contaminants; the mildly
activated solder flux and the silicone mold release agent.  These
coupons were then cleaned using TCE,  to provide baseline
information,  and the five substitute cleaning materials.  After
cleaning,  the coupons were analyzed to determine cleaner efficacy
for each combination of substrate, contaminant, and cleaner.

     Solder flux contaminated coupons were analyzed visually and
with Auger electron spectroscopy (AES)  or x-ray photoelectron
spectroscopy (XPS)  to identify and quantify surface contaminants.
An additional set of solder dipped copper coupons were analyzed
using an Omegameter to measure residual ionic contamination
                               458

-------
levels.  All silicone mold release contaminated coupons were
analyzed visually and with AES or XPS.  In addition, goniometer
water drop contact angle measurements were made and used to
determine relative surface cleanliness levels.

     In addition to the above SNL cleaning study, cleaning studies
were also carried out at both AS-KCD and SNL to determine the
effectiveness of the TCE and substitute cleaners in removing some
of the general contaminants present in the production area.  These
studies were done on bare copper, bare aluminum, and solder dipped
copper substrates using various oils, greases, mold release and
body oils.  Cleaning efficacy in these studies was determined
visually, by weight loss measurements, MESERAN  (Measurement and
Evaluation of Surfaces by Evaporative Rate Analysis) values, water
drop contact angle measurements, and Grazing Angle Reflectance-
Fourier Transform Infrared Spectroscopy.

   Analysis of data from all the SNL and AS-KCD cleaning studies
indicated that, of the five substitute cleaners, the decyl acetate
and terpene cleaner were the most effective in removing the solder
flux, mold release agent and other contaminants that were studied.
This data also showed that the decyl acetate and terpene cleaner
both cleaned as well as TCE in these studies.

      Two types of tests were conducted at SNL to evaluate the
relative corrosivity of the substitute cleaners and TCE.  The
first of these tests was an immersion test to determine the
aggressive nature of each of the cleaning solutions.  In this
test, preweighed coupons of copper and Sn/Pb solder were immersed
in each of the cleaners for one week, at ambient temperature.  At
the end of this time, the coupons were removed, rinsed, dried, and
reweighed.  Relative changes in the weight of the coupons, before
and after immersion, provided an indication of the aggressiveness
of each cleaner.

     The second part of the corrosion evaluation testing was
designed to assess potential long-term corrosion problems due to
cleaner residues left from incomplete rinsing after cleaning.  In
this test bare copper and Sn/Pb solder coupons were prepared under
no rinse, partial rinse, and full rinse conditions for each of the
cleaners.  These coupons were then placed in an environmental
chamber and aged for 30 days at 40°C, 70% relative humidity.  At
the end of this time, the coupons were removed and a visual
assessment was made of the relative amounts of corrosion present.
Results of both the immersion and cleaning residue tests indicated
that all five substitute materials were acceptable from a
corrosion standpoint.

     Post-cleaning bondability of materials was investigated at
SNL.  In these studies adhesive shear strengths were measured
between an encapsulating resin and coupons of solder dipped
copper, 17-4 PH stainless steel, and E-glass/polyimide printed
                                459

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wiring board material.  In these tests thin-wall steel cylinders
were bonded to the cleaned substrates with an encapsulating resin
and torqued to failure.  Within experimental scatter, TCE and the
five substitute cleaners all yielded the same short-term adhesive
shear strength.  These tests were deemed necessary due to the
large number of bonding and encapsulation processes which occur
during production of the system.

     The final evaluation testing in Phase 1 involved high voltage
breakdown testing at AS-KCD.  High voltages are present in several
modules in the system under study and previous experience had
shown that high voltage breakdown problems are often the first
indication of incomplete cleaning and/or contamination of these
modules.  High voltage breakdown testing was done using a high
voltage test assembly that had been cleaned using each of the
cleaners.  After cleaning, the test assembly was subjected to a
high voltage stress test to determine breakdown behavior.  Results
of this testing indicated no significant high voltage breakdown
failures due to the use of any of the cleaners.

     Based upon all Phase 1 testing, the decyl acetate and terpene
cleaner were selected for further evaluation in Phase 2 of the
solvent substitution program.  The main issues to be addressed in
Phase 2 are materials compatibility and the determination of
process parameters to be used in production at AS-KCD.  These
studies are now underway.  If either of the substitute cleaners
successfully passes the Phase 2 evaluation process, TCE will be
replaced with a substitute cleaner.
        EG&G-MOUND  INVESTIGATION  OF  SUBSTITUTE  CLEANING  AGENTS
            FOR METHYLENE  CHLORIDE  IN  HEADER  SUBASSEMBLIES

     A cleaning process for the production of header subassemblies
at EG&G-Mound utilizes methylene chloride in conjunction with a
specified "four step" cleaning solution.

     In an effort to eliminate the use of methylene chloride from
this cleaning process, four non-chlorinated solvents,  N-
methylpyrrolidone (NMP),  Arco Solv DPM,  Bioact EC-7,  and ethyl
lactate, were evaluated as potential substitutes.    Cleaning tests
of the four substitute solvents,  along with methylene chloride,
were conducted using component parts and built-up  header
subassemblies in the actual production environment.   The header
subassembly selected for this evaluation is shown  in Figure 2.
The component parts of this subassembly are:   an Inconel 718
shell,  two Kovar or Hastelloy 276 pins,  and an S-glass preform.

     In these tests, groups of fifty parts were processed with
each solvent using the "four step"  cleaning process.   The
components and resultant subassemblies were analyzed by Auger
                               460

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               Figure  2.  Mound header subassembly.
electron spectroscopy (AES) and x-ray photoelectron spectroscopy
(XPS) after six different production process cleaning steps.  The
cleaning effectiveness of each solvent was determined by comparing
the levels of carbon residues measured on the surface of the
components and subassemblies before and after the "four step"
cleaning.  These carbon residue levels, which indicate the amount
of organic surface contamination,  were assumed to be residual
contaminants from the air, contaminants generated during
processing, and residues from the cleaning solvents.  The data
from each group of fifty parts was averaged for each of the six
production process cleaning steps.  These average values were then
used in determining the relative cleaning effectiveness of the
methylene chloride and the substitute solvents at each of the six
steps.

     To illustrate this, Table 1 shows the average carbon levels
on glass preforms as received and after "four step" cleaning using
the methylene chloride and substitute solvents.  The carbon atom
percent values listed were reproducible within ±5% of the average
value listed, and differences of more than 5 at% are considered
significant with respect to residual contamination.  Additional
data from this study is available in a formal report.[2]
                                461

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             TABLE 1 - AVERAGE  CARBON  LEVELS  OF  GLASS  PREFORMS

                                                   Carbon
                  Glass Preform Sample             (at.%}

             As received                            36.0
             Methylene chloride/4-step cleaning     27.0
             EC-7/4-step cleaning                   15.7
             NMP/4-step cleaning                    14.7
             DPM/4-step cleaning                    38.4
             Ethyl  lactate/4-step cleaning          20.0


     An analysis of the glass preform data shown in Table 1, along
with the data for the other five production process cleaning steps
indicated that,  overall,  NMP and Bioact EC-7  were superior to
methylene chloride for the production cleaning of this header
subassembly.  At the present time,   Bioact EC-7 is undergoing
additional evaluation studies at EG&G-Mound.
             ELIMINATION OF SOLVENT CLEANING  IN OPTICAL
                    COMPONENT SOLDERING AT GENDD

     A critical process in producing an optical assembly at GENDD
involves soldering a cylindrical shaped,  borosilicate glass lens
into a Kovar housing using 63Sn-37Pb solder.   This lens has a
diameter of approximately 1 mm and fits into a correspondingly
small cavity in the housing.   Figure 3 shows the housing, lens,
and solder preform that is used in the soldering process.  A
critical feature of the lens is a brittle anti-reflective (AR)
coating present on both ends of the lens.  The outer body of the
lens is gold coated, using a Cr/Pt/Au metallization process, to
provide a solderable surface.  The Kovar housing is also nickel
plated for this same reason.

     Initially, joining of the lens to the housing was performed
by using an activated rosin flux with the solder preform.
Although this process produced acceptable solder joints, all flux
residue had to be removed after soldering to eliminate the
possibility of subsequent corrosion.  To remove the solder flux
residue, the soldered assemblies were ultrasonically cleaned for
10 minutes in trichloroethylene followed by 10 minutes in
isopropyl alcohol.  In evaluating this cleaning process, there was
a concern that the small size and complicated geometry of the
housing might provide "hideouts" where flux could become entrapped
and not be removed by the cleaning process.

     In order to overcome this concern, an alternative soldering
process that substitutes a reactive gas for the activated rosin
flux was developed.  Pure hydrogen was chosen as the reactive gas
and the process that was developed is detailed below.  First, the
                                462

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                Figure  3.  GENDD optical assembly.


nickel-plated Kovar housing is placed in a dry hydrogen furnace at
975°C for 20 minutes to reduce the  surface oxides on the nickel.
After treatment, the housings are stored in a dry environment and
are to be soldered within 24 hours  to ensure that excessive
reoxidation of the nickel surface has not occurred.  In
preparation for soldering, the lens and a solder preform are
inserted into the housing on fixtures.  The housing/lens assembly
is then placed in a hydrogen retort furnace where the assembly is
heated at 250°C for 20 minutes in hydrogen.  At this low
temperature; the hydrogen atmosphere provides some additional
oxide reduction.  Since the gold surface on the lens is not
oxidized to begin with, the solder  wets the lens well.  The
cleaned nickel layer on the housing also wets well and the solder
easily flows between the lens and the housing via capillary
action.  The soldering temperature of 250°C is an increase over
the 210°C soldering temperature that was used in joining fluxed
parts.  This temperature increase was necessary to achieve
adequate capillary flow and is in no way detrimental to the lens,
the AR coatings, or any optical performance.

     Optical metallographic analysis of solder joints produced
using the reactive hydrogen gas process indicate that these solder
joints are as good as those obtained using an activated rosin
flux.  As an added benefit, the elimination of solder flux from
this production process also eliminated the need for solvent
cleaning with trichloroethylene and isopropyl alcohol.
                                463

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                              SUMMARY

     Sandia and its production agencies are committed to waste
minimization.  As a part of this commitment,  joint SNL/production
agency programs have been and are now underway to reduce and
eventually eliminate CFCs and chlorinated hydrocarbon solvents
from production cleaning processes in the DOE weapons complex.
These efforts have already been successful in decreasing the
amounts of these materials being used and will continue.  The
desired end result of these efforts will be the elimination of the
use of these hazardous materials in the weapons complex while
maintaining the same levels of weapons safety and reliability that
have been historically achieved.

                          ACKNOWLEDGEMENT

     The authors would like to acknowledge the efforts of numerous
individuals at Sandia National Laboratories,  Allied Signal-Kansas
City Division, EG&G Mound Applied Technologies and General
Electric Neutron Devices Department.  Their dedication and efforts
are appreciated.  This work was supported by the U.S. Department
of Energy.

                            REFERENCES

 1.  Memo, R. G. Romatowski, POD, to Distribution,  dtd 11/17/86,
    subject: Chlorinated Hydrocarbon Solvents

 2.  R.  F. Salerno, J. V. Dichiaro, E. E. Egleston and J. W. Koons,
    "An Investigation of Nonchlorinated Substitute Cleaning Agents
    for Methylene Chloride," MLM-3621, EG&G Mound Applied
    Technologies, 1990.
                                464

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                      RECOVERING VALUE FROM PROCESS WASTES
                    F. T. Osborne*, C. T. Chi, J. H. Lester,
                                Monsanto Company
                                 F. 0. Box 12830
                               Pensacola, FL   32575
                                  Prepared For:
                International Conference on Pollution Prevention:
                      Clean Technologies and Clean Products
                                Washington, D.C.
                                June  10-13, 1990
                                    ^Speaker
                                   ABSTRACT
     By-products produced  in the manufacture  of Nylon  6-6  Intermediates
are considered  valuable chemicals  to  be recycled,  purified for  sale  or
used  as  specialty fuels.    Three  case studies  illustrating  differing
technical  approaches,   obstacles   and  commercial  resolution   will  be
presented.  Propionitrile produced  during  the  electrohydrodimerization of
acrylonitrile  to  adiponitrile  is   isolated,  refined  and sold  as a raw
material useful  in the production of di-n-propyl amine.   Tricyanohexane,
the trimer of  acrylonitrile,  is produced in the same  process.   Isolation
of  this high boiler  is  straight-forward  enough but  purification is  so
difficult as to preclude chemical feedstock uses and relegate it to use as
fuel in a hydrogen reformer.  High boiling residues from the air oxidation
of  cyclohexane  to  cyclohexanol are  a  prohibitively  complex mixture  of
closely related compounds.  The  oily mixture is extracted with an aqueous
process stream to remove ash forming metals and produce clean boiler fuel.
                                      465

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                                INTRODUCTION
     The United States Chemical Industry is currently experiencing profound
change.  Motive forces for the current change are a complex blend of  social
and  economic  circumstances.   Almost  two  decades  ago,  Alvin  Toffler  (1)
warned  of  such an  extraordinary  impending transformation.   Toffler  urged
creation  of   refuges  to  shelter   against   such  perilous   inconstancy.
Unfortunately, our  industry has found no sanctuary for retreat from  either
the previously unprecedented  international competition   or the rising tide
of public expectations which characterized the last decade.

     Corporate policies often resist change;  our policy is to minimize this
resistance.    Our  CEO  is  a  proponent of sweeping  change.   Our corporation
has  recently  adopted a  broad  policy  committing  to  significantly  reduce
process  wastes   and  to  demonstrate   "exemplary  performance   in   all
environmental responsibilities."   Working toward an  ultimate  goal of zero
discharge worldwide,   our  company has  set a target  of  70%  reduction  in
organic  and  toxic inorganic wastes  by  the end of  1995.   Recovering  value
from these process wastes is an essential part of  implementing  this policy.

     Effective utilization  of chemical  byproducts is also  an appropriate
response to  the  resource conservation,  social  responsibility and economic
pressures  which  beleaguer   our   industry.     Utilizing    byproducts   is
recovering  "value"  from  process   waste.    Adding value   is  what chemical
processing is all about.  Today I  will  share  some  experiences in  recovering
value  from  byproducts  produced   in the  manufacture  of  nylon,  or  more
specifically, the manufacture of  nylon 6-6 salt.   The reported results  are
consequences  of  group   effort   by  many  people  and  are  not  personal
achievements  of  myself  or  of  the  other   authors.     Indeed,  byproduct
utilization seems always  the result  of  protracted, complex and  interrelated
activities   by   many  different   individuals.      Such   processes   seem
characteristic of our time.

     Experience  leads us  to propose  some  heuristic rules  to  guide  the
search   for value (Figure 1).  Certainly the easiest way to handle
byproducts is  to  avoid making them.   Many of us  have  done  this for  years
and  called it  "yield  improvement."    Unfortunately  many of  our  chemical
processes  are rather mature and have  had  much  of the  achievable  yield
improvement  quite literally  "squeezed  out of them."   If all  else  fails,
the  only  acceptable   alternative  is  responsible  disposal.    I   emphasize
"responsible"; our  society will tolerate nothing less.
                                     466

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                                                     PREFERENCE

     •  AVOID  CREATION


     •  INTERNAL UTILIZATION


     •  EXTERNAL UTILIZATION -  SALE


     •  USE AS FUEL


     »  RESPONSIBLE DISPOSAL
       Figure 1.   Hierarchy of Waste Minimization Procedures
     Between  the  extremes  of  avoidance  and  disposal  we  must  define
efficacious alternatives  from  for implementation.  The alternatives should
be considered quite broadly.  Internal use is  usually preferable to
external use.  This policy conserves resources;  it reduces product
development, technical service and other marketing costs.   Several nylon
intermediates byproducts  are profitably sold,  worldwide,  in "as  produced,"
purified and derivatized forms.  In general, we recommend limiting
byproduct processing to the extent essential for profitable use.
Derivitivization  usually  requires  intensive  processing  and  is normally
justifiable only if the derivative can be internally utilized.

     The  principal products   and  the  process  itself   sometimes  suggest
possibilities.   Our process for producing nylon intermediates is shown in
Figure 2.   We start with cyclohexane  and acrylonitrile  to produce adipic
acid, hexamethylenediamine and nylon  salt together with several byproducts.
While this  process has  unique features, both  Monsanto  and our  principal
domestic  competitor, DuPont,  produce and sell, three directly  comparable
byproduct materials.  These are byproduct dibasic acids from adipic
                                  467

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manufacture,   shown   here  as   "ACS",   residues  from   the  refining   of
hexamethylenediamine,  shown here  as  "BHMT",  and the associated  low  boiling
diamine  impurities  shown as  "Amine  Heads."   In  addition to "as  produced"
forms, DuPont markets derivatives of the dibasic acids.  Development of
applications for these byproducts has been previously  discussed  (2,3).   The
three byproducts which I will discuss are two produced in the
electrohydrodimerization  of   acrylonitrile   to  adiponitrile,   a  process
developed by Monsanto, and a  byproduct  stream produced by the air  oxidation
of cyclohexane to cyclohexanol.
      Cyclohexane
                                                     ->*AGS
                   CUan BoiUr Fu*l
                                    Waste
                       AN Trlm.r
         Acrylonitrile
                          Adipic
                          Sales
                                                                   . Nylon
                                                                    Salt
                           HMD
                           Sales
                          • Proplonltril*
BHMT-«
Amin*
Heads
                        Burned
            	Sold
               Figure 2.   Nylon Intermediates  Byproducts
                                     468

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                         UTILIZATION OF PROPIONITR.ILE
     Propionitrile  is  one  of   two   major  byproducts  produced  in  the
hydrodimerization of acrylonitrile (Figure 3).  It is readily isolated from
the  reaction mixture  and purified  by  distillation.    Dehydrogenation of
byproduct  propionitrile  to  acrylonitrile  is a  logical route  to internal
utilization which has been studied in some detail.   Unfortunately,  the
selectivity  of  dehydrogenation  declines with  conversion.  To  obtain high
yield,  the  desired   acrylonitrile   product must  be  recovered  from  a
substantial quantity of unreacted propionitrile  and the boiling points are
relatively close.   Economics of  this  alternative have not been attractive.
Hydrogenation to  the primary  amine,  n-propylamine,  using  an  extension of
our hexamethylenediamine technology was  simple enough.  Unfortunately there
is virtually no market for  this  material!   The  market is for the secondary
amine, di-n-propylamine,  analogous to the undesired byproduct  BHMT  in the
HMD process!
           2= CH-CN
         Acrylonitrile
    Internal Utilization
       n- Propylamlne
        Sale
                              Purify  |  Sale
                                    Y
                                  Customer
- - -*-{CH3-CH2-CH2 )2-NH
       Dl-n-propylamine
       Figure  3.   Alternatives  for  Propionitrile Utilization
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     The conventional  route  to di-n-propylamine  is  by reacting  n-propanol
with  ammonia.    The  hydrogenation  of  propionitrile had potential   raw
material  cost   advantages   over   the  conventional  route,  but   required
different reaction conditions  and even  the  preferred reactor  design  was
considerably  different.    Protracted cooperative  efforts  with  potential
customers well  established in the alkylamine  business were  required  before
profitable sale of this byproduct was achieved.
                           UTILIZATION OF AN TRIMER
     The other major byproduct from the AN hydrodimerization  is  the  trimer,
which  we  call tricyanohexane  (Fitgure  4).    Both  cracking to  adiponitrile
and hydrogenation  to the triamine have  been extensively  investigated  both
by  Monsanto and by Asahi,  a Japanese  practitioner  of  hydrodimerization.
The  triamine,  in particular,  shows  considerable promise as  a  high-value,
trifunctional  crosslinking  agent.   Unfortunately  either  reaction  requires
purified feedstock; herein lies the problem.  The very  low vapor  pressure of
the   trinitrile   prohibits   economic   distillation  and  no   satisfactory
alternative purification process has been developed.
            CH-CN   NC-(CH2U-CN
        Acrylonltrlle     Adiponitrile
                     ^V
                        ^Cracking

              Internal Utilization
                               NCHCH2)2-C-(CH2)3-CN
                                       C'N
                                   AN Trimer
                               Tricyanohexane
Triamine or Trlacid
  x
                                                       *Boiling Point
                                                      255°C @ 2mm Hg
                                 Hydrogen Reformer
     Figure  4.  Alternatives for utilization of  Tricyanohexane
                                     470

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     The initial  suggestion  of using this  byproduct  as reformer  fuel  was
greeted with strident skepticism!  (Figure 5).   Our reformer was designed to
use clean, expensive natural  gas  as  fuel.   To many the  idea  of using this
thick,   black,    "pitchlike"   residue   seemed   irrational.      Technical
consideration further  deprecated  the  idea.   This  material   contains  25%
organic  nitrogen  which many  thought would produce  copious  NOX  fumes  and
cracking experiments had previously shown hydrogen cyanide  as  a degradation
product.   It also  contained  solid  particles  to  plug  control valves  and
burner  orifices.    The  most  serviceable  feature was   reasonable  heating
value.
                       Tricyanohexane Characteristics
                             Black Viscous Residue
                             25% Nitrogen - Solids
                          Heating Value - 13,800 BTU/lb

          Concern                                   Resolution
        Incomplete Combustion                    Stack Gas Analysis
          Toxic Stack                            No HCN or Organics
                                                Acceptable NO
                                                             A
        Corrosion                                Replaced  25  Cr/20 Ni
                                                with 28 Cr/48 Ni Tubes

        Fuel Flow Control                         Filtered Fuel
                                                Heated Lines
                                                Resized Valves
            Figure  5.  Tricyanohexane Utilization Issues
     Despite the  skepticism,  off-plant burner trials  were conducted.   To
the  amazement  of some,  even  the  most careful stack gas  analysis  revealed
absolutely no HCN or other toxic organics.   Under limited oxygen conditions
needed for  the high-temperature reformer, very little  of  the  fuel  nitrogen
was  converted  to NOX.   Subsequently  it  was  learned that  another  Monsanto
scientist (4) had previously investigated combustion of high nitrogen fuels
with  similar  results.   Because  of modest corrosion  after two years,  the
very  old,   somewhat  outdated  reformer  tubes were  replaced  with  higher
performance, higher nickel alloy.  Conventional engineering  design changes
successfully adapted the system to this alternative fuel.   Following almost
seven years of successful  operation,  the  burning  of high nitrogen organics
                                    471

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as fuel has been expanded to the boilerhouse using a combination of waste
with  pulverized coal.   Extensive  stack gas  sampling has  established  no
increase in NO. levels and appropriate air quality regulatory agencies  have
approved the practice.

                             UTILIZATION OF KATT
     The  final example  illustrates  beneficial utilization  of  two  waste
streams from different manufacturing  areas.   One is a distillation  residue
from refining  of cyclohexanol and  the other stream a  dilute waste  liquor
from crystallization  of  adipic acids.   Sources of both these purge  streams
are shown in Figure 6.   The high boiling residue from this  refining  process
is called  KA Topper  Tails, or KATT.    Some  characteristics of this  stream
are shown.  One important characteristic is  its complexity.  Unlike  the  two
adiponitrile  process  streams  in  which one byproduct  predominates, KATT
contains  more  than  thirty different  organic  compounds.   Most  are  high-
boiling esters of  cyclohexanol or  cyclohexane diol but no  single  component
or group  of components  is  present at  sufficient  concentration to  justify
separation.
                         Characteristics of KATT
              Extremely Complex Mixture ( > 30 components)
              High Boiling Esters
              Contains Sodium,  Boric Acid,  Aqueous Phase
         KATT
Organic Residue
Inorganic Salts
Aqueous Phase
     Powerhouse
                 Clean Flitl
                                          Aqueous Liquor
                                                         Dibasic
                                                          Acids
                                          Metals Free
                                                      AGS
                                    Inorganics to
                                      Waste
          Figure 6.   One Byproduct Stream  Upgrades Another
                                     472

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     Despite  its  high  organic  content,   as  produced,   this   residue   is
unsuitable  as   fuel   due   to  variable  water  content  and  high   metals
concentration.   In addition to water dissolved  in the  oil phase,  the  stream
contains a  separate aqueous phase  amounting to  as much as 50% of  the total
weight.  The  density  differential between  the  two  phases is small,  making
consistent  phase separation  difficult.    Even  with phase  separation,  the
high  sodium  and  boron content   of  the  oil  phase  would  create   boiler
corrosion and tube fouling problems if burned in the plant boilers.

     A development program was undertaken  to find ways  to overcome  these
difficulties.     Laboratory  screening identified  waste liquor  from  Adipic
Manufacturing  as  having  favorable  characteristics  for  consistent   phase
separation,  good  metals  removal,  and  minimum  loss  of  organics  to  the
extractant.  This waste stream is a dilute form of the commercial byproduct
ACS.  It is a metal-free,  aqueous  waste  stream  with  an appropriate density.
Batch  simulation  of  2-stage  continuous  countercurrent  extraction with
simultaneous  phase separation was conducted.   Data  from  the  column test
were  used  for  scale  up  to  a  full-scale  installation.   A   patent  was
subsequently  granted  (5) .   A centrifugal extractor was  used in  the  plant
installation to  shorten contact time and minimize chemical  reaction between
the two streams.

     Washed KATT is  a clean  fuel.   Because  of  the  relatively low heating
value  of  the  highly  oxygenated  organics,  primary fuel  is  always   fired
simultaneously  to  ensure flame  stability.   Because of the corrosive  nature
of  this  byproduct fuel, special  stainless steel burner  guns and tips  are
used in this boiler.

     This byproduct utilization process has been in operation for  more than
six  years,  saving  fuel and  reducing waste  every year.   Value  has been
created by  combining two almost useless  materials in a creative way;  "value
added manufacturing" in every way!
                                   SUMMARY
     It is risky  to  generalize  from such disparate examples.  Certainly  in
knowledge there is power.  It pays  to know  all you can about everything you
make, both composition and volume.   Imaginative comparison of what  you make
with what you  buy and sell often suggests byproduct streams  as  alternative
materials.  Cost savings are often a consequence.   Dedicated, persistent
effort  is  a  routine  requirement.    It  helps  to  remember Ralph Waldo
Emerson's remark  "nothing  great is  achieved without enthusiasm."   Early  in
this century  the  American Meatpacking Industry developed a  reputation for
their effective use of all parts of  a pig.   It is  widely  reported that they
use all the parts except the squeal.  We're  not down to the  squeal  yet, but
were listening for it!
                                     473

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                                 REFEREMCES
1.    Toffler,  Alvin,  "Future  Shock",  Random House  (1970).

2.    Chi,  C.  T.  and J.  H.  Lester,  Jr.,  "Byproduct Utilization  in
     Adipic Acid  Manufacture",  paper  presented  at CMA  Waste Minimization
     Workshop,  New Orleans, November  11-13, 1987.

3.    Downing,  R.  G.,  "Marketing  Waste Byproducts as  Reusable Feedstock",
     paper presented AIChE Annual  Meeting, Washington,  November, 1988.

4.    Walker,  H. M. ,  "NO, Formation During the  Incineration of Nitrogeneous
     Residues",  paper  presented  at  Symposium,  "Clean-Up  of Plant Waste
     Streams",  AIChE National Meeting,  New Orleans, March 12,  1973.

5.    Chi,   C.   T.   and  J.  H.   Lester,  Jr.,   "Decontamination  of   KA  Oil
     Refinement Waste Streams",  U.S.  Patent 4450291  (1981).
                                     474

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          DESIGN FOR THE ENTIRE LIFE CYCLE:  A NEW PARADIGM?

                              Dr. Chuck Overby

                Industrial & Systems Engineering Department
                    Ohio University, Athens, Ohio  45701
                     (614) 593-1543  FAX (614) 593-4684

   "The natural sciences are concerned with  how things are. .  .   Design, on
the other hand, is concerned with how things ought to be, with devising
artifacts to attain goals."  Simon, H.A.,  The Sciences of the Artificial.
MIT Press, 1969.  (1)

     "Design should not merely meet environmental regulations;  environmental
elegance should be part of the culture of engineering education and prac-
tice.  Selection and design of manufacturing processes and products* should
incorporate environmental constraints and objectives at the outset, along
with thermodynamic and economic factors".

                                 National Academy of Engineering, 1989.  (2)
                                                       *0verby's underlining

                            ABSTRACT

     This paper explores the idea of design for the entire life cycle --in-
cluding the disposal phase of a product's life.  It is postulated that there
are environmental, consumer, legislative,  competitiveness issues, and a
changing world in the technology of design -- such that we need to look at
things in a new light (a new paradigm) relative to the way that we create
and get rid of the material "things" of life.  This paper briefly touches on
each of the above ideas as a path to get to asking:  What might be done in
engineering education and in engineering practice so that design consider-
ations for disposal get factored into the design process at the very begin-
ning of that process? More broadly we might ask, how can we get to the point
where "environmental elegance" becomes an integral part of the culture of
engineering education and practice.  The paper outlines a few ideas for some
soon to begin research along these lines at the School of Engineering, Grand
Valley State University (GVSU), Grand Rapids, Michigan.  This research is to
be funded through the Michigan Quality of Life Bond Fund, Michigan Depart-
ment of Natural Resources.
     Much credit must be given to Dean Kindschi (GVSU) for his role in
rekindling my dormant interest in this challenging area of concern, and for
his considerable effort in getting us to this point.  Credit is also due to
Assistant Dean Larson, and to Shelley Padnos for their major contributions,
and to colleagues, Shirley Fleischmann, and Paul Johnson for their willing-
ness to professionally join this undertaking.

     The views here expressed are the views of the author and do not reflect
those of any other person or institution.

         	                      475

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     THIS IS AN EXTREMELY ABBREVIATED VERSION OF A PAPER WITH THE SAME TITLE
THAT WILL BE GIVEN TO THE "DESIGN ENGINEERING DIVISION MEETING" AT THE AMER-
ICAN SOCIETY FOR ENGINEERING EDUCATION (ASEE) ANNUAL CONFERENCE IN TORONTO,
CANADA ON JUNE 25TH, 1990.  READERS OF THIS MATERIAL WHO WOULD LIKE TO SEE
THE ENTIRE ORIGINAL PAPER SHOULD SEE THE 1990 ASEE ANNUAL CONFERENCE PRO-
CEEDINGS . PAGES 552 -- 563, OR CONTACT THE AUTHOR AT THE ADDRESS GIVEN ON
THE TITLE PAGE.

                                INTRODUCTION

     People all over this land are becoming concerned with the continuously
growing waste stream resulting from the affluent life styles lived by the
majority of us, and at the negative environmental impacts that result from
disposing of these wastes.  These concerns, along with a decline in low cost
disposal options are causing people to ask if it might be possible to gain
some control over these problems by "minimizing the waste stream at its
source".  Among the many possibilities for "source reduction" are ideas
about designing products with concerns for "disposal" considered at the very
beginning of the design process.  If we include "design criteria" for dispo-
sability in our product designs, the resulting products might become more
easily recyclable as products,  or to basic materials.  They might become
products that have much less waste to be "disposed of".  Or, if their dis-
posal problem appeared to be overwhelming, then they might never "see the
light of day" as things for our consumption.   In short, we might call them
"earth friendly products".  Following is an exploration of some of these
issues in the context of "design for the entire life cycle".

     Engineering design textbooks sometimes mention the need to be con-
cerned, at the beginning of the design process, with the entire life cycle
of the product or system, including its disposal.  For those authors who do
mention it (and many do not),  other than a few words or a brief paragraph or
two early in the book, nothing more is heard of the "disposal phase" for the
rest of the book.

     This paper, in part, arises out of some of my past work in resource
conservation, solid waste, and related environmental issue areas.  (3), (4),
(5), (6).  I intend the paper as an "exploratory vehicle" with which to
provoke responses from and for interaction with (A) designers and creators
of products and systems, (B) engineering educators, and (C) "interested
others" --on the idea of "Design for the Entire Life Cycle:  My specific
focus will be on the neglected "disposal phase" of the cycle.

     The words "A New Paradigm", with a question mark, appears in the title
because it seems to me that several things are "working" out there in the
world of legislative affairs,  environmental concern, international competi-
tion, and with the "technology of design" itself, such that engineers and
other creators of new products and systems, in the future, may well find
their concepts of "design" stretched to include the entire life cycle of
their creations (including disposal) much more often than has been the case
in the past.  If this is true,  then we might well think of it as a "new
paradigm", a new way of seeing things, a new model or pattern for organizing
ourselves in the production of the goods for our affluent life styles.  If
                                     476

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we in the developed world can do this,  we may even be able to present the
developing countries of the world (with their masses of drooling prospective
consumers) with a new model so that they might also enjoy some of the
"goodies" without completely sacking the world environment.

                OBJECTIVES AND LIMITS OF THE ORIGINAL PAPER

     In the original paper I (A) first defined and briefly elaborated on the
concept of "design for the entire life cycle", pointing out how very impor-
tant the designer is in determining the "downstream" consequences of his or
her creations -- life cycle costs etc.  (B) discussed some of the flux of
things happening "out there" by touching on (a) some contemporary environ-
mental, (b) international competitiveness, and (c) design technology issues
all of which I think might in some ways be relevant to the topic; (C) high-
lighted the focus of our proposed research at GVSU, and finally; (D) raised
some questions as to what we might do in the education of engineers so that
"design criteria for disposability",  "design criteria for recyclability",
"design criteria for waste reduction and minimization" and more broadly, so
that "environmental design requirements" might become a more important part
of ALL engineering curricula--not just the specialized curricula for so-
called environmental engineers.  The original paper did not concern itself
with public policy measures for stimulating "design for the entire life
cycle".

     In order to meet proceedings publication deadlines, and to conform to
space limitations, I have excised most of the original paper, leaving only
the outline of our proposed research at Grand Valley State University,  and
the questions as to what we might do in the education of engineers for
"environmental elegance".  The following original paper headings have been
left out of this version:  "Design for the entire life cycle"; "Environmen-
tal concerns and adaptations";  Professional concerns for the environment";
"Industrial concerns for the environment"; Grassroots concerns for the
environment"; "Spiritual concerns for the environment";  "Governmental con-
cerns for the environment"; "Changes  in the field of design"; "Legislatively
driven design change";  "Competitiveness driven design change"; "Quality
function deployment"; "Taguchi philosophy -- quality is the loss a product
causes to society after being shipped..."; "Design principles";  "Expert
systems in design";  "Design data bases  and information systems".

            HIGHLIGHTS OF OUR PROPOSED  GVSU RESEARCH*

     We propose to carry out the following tasks and activities in our
research at Grand Valley State University on this topic.  (9)

     (A) Identify and build a database  for several contemporary products
that create environmental and/or recycling problems at the time of their
disposal.

     (B) Select a sample from this database and carry out a design assess-
ment for these products so as to identify design changes that, had they been

*I have agreed to be Project Director for this research.
                                     477

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made, could have improved the environmental impact and or recyclability
-- design changes that could have made the products more "earth friendly".

     (C) In parallel with (A) and (B) above, we will be doing research on
ways, short of public policy measures, by which it might be possible to make
it easier for engineers and others responsible for design to include design
considerations for disposability at the very beginning of the design pro-
cess .  We will explore many of the things presently happening in the field
of design in an attempt to identify how it might be possible to use some
dimensions of this present "dynamism in design" to help "stretch" the
designer's perspective to include more of the life cycle of the product.
Preliminary ideas along these lines have been presented in this paper, (the
original paper) Included in these explorations will be concepts of "expert
systems", "quality function deployment" (QFD), "Taguchi ideas", "design
engineering databases", "concurrent or simultaneous engineering", and other
aspects yet to be identified as the research progresses.

     (D) In parallel with (A) through (C) above, we will be hosting a series
of seminars with visiting experts on topics related to "design for recy-
clability", "design for the entire life cycle", "design of earth friendly,
clean, or green products", "design itself" and selected concepts from our
research in (C) above.  These seminars will be designed to both inform us,
and to provide a forum for discussion with practicing engineers, academi-
cians, consumers, environmentalists, managers and other interested persons.
The seminars and individual interviews with the "experts" will be video
taped for possible later use as educational material.

     (E) Drawing on all of the above, we intend to prepare academic materi-
als for two different groups of engineering students -- one at the freshman
level, and one for students at the senior design "capstone" course level.
We presently envisage these materials as having at least two dimensions --a
set of readings that relate to (a) environment and engineering, technology,
design etc., and (b) a set of case studies and/or design projects that will
serve to educate with respect to "environmental design concerns" as well as
"engineering functional" and "economic" concerns in engineering design.

     (F) Finally, we intend to write and present papers at appropriate tech-
nical and other meetings on various dimensions of this research so as to
further its dissemination as broadly as possible in engineering education
and engineering practice.

             IMPLICATIONS FOR ENGINEERING EDUCATION

     I began this paper with the following quote from a new National Academy
of Engineering publication.

     "Design should not merely meet environmental regulations;  environmental
elegance should be part of the culture of engineering education and prac-
tice.  Selection and design of manufacturing processes and products should
                                     478

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incorporate environmental constraints and objectives at the outset, along
with thermodynamic and economic factors."  (2)

     I now end it with the question -- How do we translate the "shoulds" in
this quote into reality in engineering education so that environmental ele-
gance, including design for the entire life cycle, does in fact become a
part of the culture of engineering education and practice?


     Some think that this will happen naturally as legislation finds ways to
connect the producer with his or her products for their entire life cycle.
But, can we not see some possibilities outside of governmental action, that
might help to make it easier for engineers to factor "environmental require-
ments" as well as "functional requirements", and "economic requirements"
into the design process at its very beginning?

     If public environmental concerns continue to grow, might it become
possible for the Acreditation Board for Engineering and Technology (ABET) to
find a way to "require" engineering curricula for ALL engineering disci-
plines to reflect "environmental elegance" in their curricula?  Perhaps this
is not such a wild idea.  Recently we see discussion about requiring a cer-
tain course for all engineering students so that our engineering graduates
can be more effective and productive in their work, and thus help this
nation get back into the ballgame in international competition.  I am speak-
ing of proposals to require an appropriate kind of "statistics--experimental
design" course for all engineering students.  (43)  Incidentally, some of
the driving function for the above discussion partially arises from the
popularization of Taguchi's ideas of experimental design as a very important
engineering data gathering and decision making tool.

     Might not the "enlightened self interest" expressed by various compa-
nies and industrial trade associations in this era of "new paradigms" pre-
sent opportunities for us to demonstrate to engineering students the fact of
"environmental elegance" in places where they will work? (23) (19)

     Hopefully, the development of "readings" and "case studies" and/or
"design projects" such as proposed as one of our research outcomes, might
have some small continuous improvement impact in the creation of "environ-
mental elegance" as an appropriate engineering "mind set".

     If an "expert system" were developed with paths that required consider-
ation of the disposal phase (or other environmental concerns) at the begin-
ning of the design process -- might not the use of this "expert system" as a
tutorial device to train fledgling engineers in the design process, help
make a small contribution toward "environmental elegance" as an appropriate
engineering attitude?

     If an engineering design database were augmented with health and envi-
ronmental impact information in relationship to various materials and pro-
cesses choices to be made by the designer, might this be of some help in
achieving "environmental elegance" as a stronger dimension of engineering
education and practice?  	  What suggestions have you?
                                     479

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                     BIBLIOGRAPHY OF THE ORIGINAL PAPER

1)   Rychener, Michael D.,  (ed) Expert Systems for Engineering Design. Aca-
demic Press, 1988.

2)   Ausubel, J.H., and Sladovich, H.E., Technology and Environment.
National Academy of Engineering, National Academy Press, Washington, D.C.,
1989
3)   Overby, C.M., "Product Design for a Sustainable Future:   A Matter of
Ethics?, Proceedings. 1980 ASEE Annual Conference.

4)   Overby, C.M., "Product Design for Recyclability and Life Extension",
Proceedings. 1979 ASEE Annual Conference.

5)   Overby, C.M., "A Preliminary Technology Assessment of Product Recycling
(Remanufacturing) as a Conservation Option",  American Society of Mechanical
Engineering (ASME), Winter Annual Meeting, Paper No. 79-WA/TS-8, New York,
1979.

6)   Hill, Poulton, Overby, & Ford, Materials and Energy From Municipal
Waste. Congress of the USA, Office of Technology Assessment,  Washington,
D.C., 1979.

7)   Henstock, M.E., Design for Recyclability. Published by the Institute of
Metals, on behalf of The Materials Forum, London, UK, 1988.

8)   ISRI, "It's Time to Design Our Manufactured Products for Recycling",
Phoenix Quarterly. Vol.  21,  No. 1, Winter 1989, Institute of Scrap Recyc-
ling Industries, Inc., (ISRI).

9)   GVSU, "Design for Recycling:  Solving Tomorrow's Problems Today", A
Waste Reduction and Research and Demonstration Proposal, Submitted to the
Michigan Department of Natural Resources, Quality of Life Bond Program
(QLB), by the School of Engineering, Grand Valley State University, Grand
Rapids, Michigan, October 1989.

10)  Dieter, G.E., Engineering Design:  A Materials and Processing Approach.
McGraw-Hill, N.Y., 1983

11)  Fabrycky, Wolter, J.,  "Designing for the Life Cycle", Mechanical Engi-
neering. January 1987.

12)  Fabrycky, Wolter, J.,  "Ramcad and Concurrent Engineering Design
Research at Virginia Tech." for the Fifth Annual RAMCAD Technical Inter-
change Meeting, San Diego,  CA., April 11, 1989

13)  Taguchi, Genichi, Introduction to Quality Engineering:  Designing
Quality into Products and Processes. Asian Productivity Organization, UNI-
PUB, 1986.

14)  Taguchi, G., Edsayed,  E., and Hsiang, T., Quality Engineering in Pro-
duction Systems. McGraw-Hill, 1989.
                                     480

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15)  Kuhn, Thomas, S., The Structure of Scientific Revolutions. Second
Edition Enlarged, University of Chicago Press, 1970.

16)  UCLA, Workshop on Pollution Prevention Design:  Challenge for the
1990's, University of California, Los Angeles, September 21, 1989--
Cosponsored by UCLA's NSF Engineering Research Center (ERC) for Hazardous
Substances Control, and Carnegie Mellon's ERC for Engineering Design.

17)  Purcell, A., "The Third Dimension of Waste Minimization", Opinion and
Comment Page, Chemical Engineering Progress. June 1989.

18)  SA, "Managing Planet Earth", Scientific American. Special Issue,
September 1989.

19)  NAM, "Waste Minimization:  Manufacturers' Strategies for Success".
National Association of Manufacturers (NAM), 1989, prepared by ENSR Consult-
ing and Engineering.

20)  Dr. Lori Ramonas, Director of the Chemical Manufacturers' Association
(CMA),  Responsible Care Program, personal communication 3/26/90.

21)  CMA, "Handle With 'responsible' Care", Two page advertisement in the
Christian Science Monitor. Wednesday, April 4, 1990, pages 10 & 11.

22)  CSM, "Lawmakers Propose 'Enviro-Taxes' To Boost Conservation, Raise
Cash",  Christian Science Monitor. 27 March 1990.

23)  Sherman, S.P., "Trashing a $150 Billion Business",  Fortune.  August 28,
1989.

24)  Carlson, Barbara, "The Grass is Always Greener on the Socially Con-
scious Side", New England Business. January 1990.

25)  Cairncross, Frances, "Demands to 'Go Green' Challenge Best European
Firms", Financier. December 1989.

26)  Freeman, Laurie, "The 'Greening' of America II", Advertising Age.
November 13, 1989.

27)  Foster, Anna, "Decent, Clean, and True", Management Today. UK, February
1989.

28)  Hamilton, Pat, W., "Emptying the Trash" D & B Reports. Nov/Dec 1989.

29)  McCamus, David, "A Revolution in Management Thinking", Business Otrly.
(Canada) Autum 1989.

30)  ANON, "The Perils of Greening Business", Economist. UK, October 14,
1989.
                                     481

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31)  Au Sable Institute of Environmental Studies, Mancelona, Michigan,
49659, DeWitt, C.B., Director.

32)  EPA, U.S. EPA's "Pollution Prevention Research Plan", Draft Report to
the Congress, U.S.  Environmental Protection Agency, April 28, 1989.

33)  Freeman, H.M. and Bridges,  J., Pollution Prevention Research, U.S. EPA,
Cincinnati, Ohio, personal communication, 1 February 1990.

34)  CONEG, Coalition of Northeastern Governors, Source Reduction Council,
1989.

35)  JAPAN, Self Evaluation By Business of the Difficulty of Waste Disposal.
1988 Japanese publication, 209 pages--limited parts translated into English
as of March 1990.

36)  Winner, Pennell, Bertrand,  and Slusarczuk,  The Role of Concurrent
Engineering in Weapons Systems Acquisition.  IDA Report R-338, Institute for
Defense Analysis, Alexandria, Va.,  22311, December 1988.

37)  Fritsch, Charles,  "Information Dynamics for Computer Integrated Product
Realization", published in Advanced Information Technology for Industrial
Material Flow Systems.  S.Y. Nof and C.L. Moodie, Editors, Springer-Verlag,
Berlin, 1989.

38)  Suh, Nam P., The Principles of Design.  Oxford University Press, 1990.

39)  Hirschhorn,  Oldenburg, & Finnemore, Serious Reduction of Hazardous
Waste:  For Pollution Prevention and Industrial Efficiency, Congress of the
USA, Office of Technology Assessment, Washington, D.C., 1986.

40)  Freeman, Harry, (ed), Hazardous Waste Minimization. McGraw-Hill,  1990.

41)  ASI, Quality Function Deployment:   Implementation Manual. Version 3.2,
American Supplier Institute,  Detroit, MI, 1989.

42)  Mandell, John, Professor of Chemical Engineering Department, Montana
State University, Bozeman, Montana, personal communication, Fall 1989.

43)  Penzias, Arno, "Teaching Statistics to Engineers" (Editorial) Science.
Vol. 244, No. 4908, 2 June 1989, pg. 1025.
    Thanks to Pat and Kay.
                                     482

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          WASTE REDUCTION AT A PRINTED CIRCUIT BOARD MANUFACTURING
                FACILITY USING MODIFIED RINSING TECHNOLOGIES

                 by:  Paul Pagel
                      Minnesota Technical Assistance Program
                      Minneapolis, MN  55455
                                  ABSTRACT
      The Minnesota Technical Assistance Program (MnTAP) and the U.S. EPA
began this program to assess waste reduction achievable for rinses on two
processes at Micom, Inc., a printed circuit board manufacturer.  Baseline
measurements for wastewater volume and copper concentration, the waste
parameters of interest, were taken along with measurements for drag out and
rinsing effectiveness.  Candidate rinsing modifications include:  slowing
the rate of withdrawal, increasing the drain time, reducing the rinse flow
with restrictors, and controlling the rinse flow with conductivity meters.
The most promising modifications will be implemented.  Follow-up sampling
will be performed to evaluate the effect of rinsing modifications on
wastewater volume and copper concentrations.  Rinsing effectiveness and
drag out were assessed in baseline sampling and will be assessed following
each modification.

      This study is being conducted as part of the U.S. EPA's Waste
Reduction Innovative Technology Evaluation (WRITE) Program, which was
funded by a cooperative agreement between the EPA and the University of
Minnesota, Minnesota Technical Assistance Program (MnTAP).*
*The Minnesota Technical Assistance Program (MnTAP) is supported with a
 grant from the Minnesota Office of Waste Management (OWM) to the
 University of Minnesota, School of Public Health
                                   483

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                                INTRODUCTION
      The Minnesota Technical Assistance Program (MnTAP) has allocated a
considerable amount of its resources to providing waste reduction
assistance to the metal finishing industry in Minnesota over the last five
years under the support of the Minnesota Office of Waste Management (OWM).
More recently, MnTAP has been working cooperatively with the U.S. EPA Risk
Reduction Engineering Laboratory under the Waste Reduction Innovative
Technology Evaluation (WRITE) Program to assist metal finishing companies
in achieving waste reduction by modifying rinsing techniques.

      A number of large electronics and computer manufacturing firms are
based or located in Minnesota.  As a result,  approximately 200 small and
medium-sized job shops, printed circuit board shops, and other
electroplating/metal finishing operations exist in Minnesota to support the
larger companies.  The metal-containing sludges, solutions,  and rinsewaters
from these shops comprise 19 percent of the hazardous waste  stream
generated in Minnesota.

      Solicitation of metal plating companies for participation in the
WRITE Program began in early 1989 through newsletter articles,  metal
finishing association presentations, and by direct mailings.   Approximately
20 companies responded with interest in evaluating source reduction
opportunities via rinsing modifications.  Once the WRITE engineer began
work in mid-August 1989, site visits were conducted to assess each
company's interest and applicability to the project.  A total of thirteen
shops were visited, six printed circuit board shops and seven job shops,
primarily rack and barrel electroplating shops.  Companies are evaluated
for inclusion in the WRITE Program on the basis of a number  of criteria
which include potential for pollution prevention, willingness to make
modifications, willingness to share information, production  variability,
and a measurable quantity/concentration of contaminant to be reduced.

                              PROJECT OVERVIEW
      The overall objective of the Minnesota/EPA WRITE Program is to
implement and document source reduction practices to reduce waste
generation by modifying rinsing techniques as part of the plating process.
However, a number of more specific objectives exist.  The two most
effective methods for reducing wastes as a part of the rinsing process are
reducing dragout or carryover of metals from the plating bath and
practicing water conservation methods.   This project focuses on evaluating
rinsing modifications on a single plating line.   These modifications,  once
evaluated, could then be transferred to other lines within the facility.
The impact on downstream treatment or recovery technologies will also  be
examined, as it is believed that the combination of reduced drag out and
reduced water use should reduce treatment needs and associated costs.

      The first WRITE company, Micom Inc., was selected largely because of
their willingness to make changes and because of their relatively stable
                                   484

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production.  Micom is a medium-sized job shop in New Brighton,  Minnesota,
employing approximately 240 people.   The company manufactures printed
circuit boards under a number of military and other contracts.   A
production day consists of two eight-hour shifts with a current work load
of 1,000-1,200 square feet of panel per day.   The WRITE project is
concentrating on the counter current rinses which follow the micro-etch
bath, and the counter current rinses which follow the electroless copper
bath.  The waste water from these rinses is currently being treated by ion
exchange for copper recovery.

      MnTAP is obtaining data from these lines both before and after
rinsing modifications are made.  A baseline of waste generation has been
established by measuring rinse flows, copper concentration in the rinses,
and other parameters such as process solution copper concentrations, drain
time, carry over of process solution (dragout),  and production throughput.
The same information will be collected after each modification.  In this
way, a baseline of rinsing effectiveness can be established by measuring
residual copper concentration on the printed circuit boards after rinsing.
This baseline of rinsing effectiveness can be used for comparison following
each rinsing modification to ensure that product quality is not being
interfered with.  Armed with this information, the company can be convinced
that the rinsing modifications are worth pursuing and will not compromise
product quality.

                   MICOM PROJECT PURPOSES AND OBJECTIVES
      The two major objectives of the Micom project are to reduce the
copper discharged in the rinsewaters from the sensitize line,  and to reduce
rinsewater volumes in that same line.  In the case of reducing copper
discharge, at least three benefits are possible.   If copper discharge is
reduced by capturing process solution before rinsing, raw material costs
may be reduced, since the need for chemical additions could be reduced by
returning process solution to the bath.  Treatment costs may also be
reduced, especially in the case of Micom, which uses ion exchange to
capture copper from the rinsewaters.  In addition, reducing copper
discharge by capturing process solution can also reduce the amount of water
needed for rinsing, since less residue requiring dilution (rinsing) will be
present.

      Reducing rinsewater volumes will be possible both because of the
previously mentioned reduction of residue needing rinsing, and also because
it may be possible to improve rinsing efficiency.  Improving rinsing
efficiency, which implies using less water to achieve the same rinsing
effect, can have at least two benefits.  Using less water will decrease
water and sewer charges,  especially important at Micom where incoming water
must be softened, at additional cost, before use on the sensitize line.
Decreased rinsewater volumes may also reduce treatment costs,  both by
improving the efficiency with which the ion exchange system at Micom is
able to remove copper from rinsewater, and also by reducing the amount of
water which must, pass the resin beds.
                                   485

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      For the Micom project, not only is the work focused on one process
line, but also further narrowed to focus on two process steps within that
line, the micro-etch and the electroless copper plating solution (explained
in more detail in the next section).   The reason for that focus was first a
matter of economics, since only a certain amount of time and money can be
spent on evaluation in any one shop.   Another reason is that these two
processes are the most concentrated copper sources on the process line.
The focus is also part of a larger philosophy, one which MnTAP calls
"planting seeds."  The hope is that if rinsing process modifications are
demonstrated to be successful in one location in a plating operation, plant
management will be more likely to attempt similar modifications on that
process line, or even on other process lines.  Rather than attempting
plant-wide modifications, or changes applied to large, aggregated waste
streams, a staged approach is not only more manageable, but may be more
accurate in the assessment of costs,  product quality, and other advantages.

      Besides the two major objectives of reducing copper discharge and
water use, MnTAP hopes to develop and test a procedure for evaluating and
modifying rinsing processes which will be transferable to and useful with
other operations.  This procedure would address such imperatives as
protecting product quality while simultaneously modifying the production
process, evaluating the impact of modifications on production throughput,
and providing a "rule-of-thumb" for such decisions as number of samples
required for evaluation.  MnTAP believes this procedure to be a very
important transferable product of the project.

                            MICOM PLANT DETAILS
      Micom manufactures double-sided and multilayered printed circuit
boards.  Printed circuit boards are produced by depositing and etching
metal from a fiberglass sheet (board).  The steps in this process include:
cutting the boards to size, coating the boards with a photosensitive
material (resist), developing the resist, drilling holes, deburring,
cleaning, etching, plating the inside of the holes (using an electroless
plating process), plating the board, and inspecting at many points along
the way.  Water rinses follow many of these steps.

      All printed circuit boards at Micom pass through the sensitize line
(Figure 1).   This line is used to plate copper onto the inside of the
circuit board holes and is composed of micro-etch, activator,  accelerator,
electroless copper and rinse tanks.   Micom is interested in changes to the
micro-etch and electroless copper plating and rinsing processes as these
are significant contributors of copper to their wastewater treatment system
(currently ion exchange).   The copper bearing countercurrent rinses are
made up of softened water with restricted flow of 3 gpm per set of tanks.
These water flows are piped to the copper ion exchange system and then
sewered.

      The printed circuit boards enter the line in racks holding 24 boards.
The boards range in sizes up to 18 inches by 24 inches.   The racks are 34
inches by 19.5 inches by 13 inches and are transported by a hoist from tank
                                   486

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Soft Water

-^*
*
*
HI*-

@
(Process Flow)
*
Micro-etch

@
1
@
Counter Current
Rinse

Counter Current
Rinse

@
Activator
Pre -dip
Activator
Rinses
Accelerator
Rinses
4-
@
Electroless Copper
Plating

@
1
@
Counter Current
Rinse

Counter Current
Rinse

@
Dead Rinse
-^»
->»
Copper
Ion Exchange

f ^\
* = Flow measurement
@= Sampling point
J

Figure 1   Micom Sensitize Line
                   487

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to tank.  The operator controls the hoist and allows the rack to drain 3-5
seconds before proceeding to the next tank.   The approximate residence time
in the micro-etch bath is 75 seconds, the electroless copper bath is 30
minutes, and each rinse bath is 2 to 3 minutes.   The electroless copper
plating is the rate determining step for production throughput.

      MnTAP intends to maintain or improve the current rinsing
effectiveness.  This is monitored by checking the amount of copper build-up
in the non-flowing process tank which follows the countercurrent rinses.
An objective of the company is to maintain the current production
throughput rate.

                       GENERAL RINSING MODIFICATIONS
      Although there are numerous modifications to rinsing operations which
can reduce rinsewater volumes while preserving rinsing effectiveness, a
number of these techniques are particularly attractive at an installation
such as Micom's.  These techniques can be broken down into three
categories:  procedural, systems, and controls.

Procedural techniques in rinsing refer to work flow,  operator routines, and
work practices.   Several procedures can be used to reduce dragout in a
plating shop:

      Improved work flow in a plating shop refers to  the most direct route
      a part can take from the time a part enters the shop to the time a
      part leaves a shop.

      Proper racking of parts affects the way in which solution drains off
      the part.

      Increased hanp times allow solutions to drip back into the process
      tank, thus conserving process solutions and reducing dragout.


      A number of other methods exist which can be practiced by operators
to help reduce dragout:

      Slower withdrawal rate of parts from the plating tank or rinse
      enhances return of solution to the process tank

      Longer rinse times allow for better rinsing

      Use of wetting agents reduces surface tension of process solution

      Operating the plating bath as hot as possible decreases solution
      viscosity

      Minimizing the concentration of dissolved materials in the plating
      bath minimizes the concentration of metal in the dragout
                                   488

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 Systems which  facilitate  improved rinsing techniques involve modifications
 to  the rinsing tank design or  the set-up itself.  Proper use of the
 following  systems can  result in reduced dragout of process solution  into
 the rinse  tanks, concentration of solutions for reuse, and generally more
 efficient  rinsing.

      Dragout  tanks function not only to save water, but also as a basic
      component of the rinse line to allow for chemical recovery and return
      to the process tank.

      Spray rinsing of parts can be an effective rinse technique because
      even with a small volume of water, the contaminant on the surface of
      the  part can be  diluted  enough to make the rinsing effective.

      Agitation is more commonly used in rinse systems to increase the
      efficiency of the rinses so that water use can be minimized.   Two
      primary  types of agitation are used:  air agitation (sparging) and
      mechanical agitation.

      Countercurrent rinsing refers to a system in which clean water enters
      the  last rinse in a line (cleanest) and works its way through  each of
      the  first rinses (dirtiest) in the system.  Each additional rinse
      results  in an approximately eight to ten-fold reduction in water use.
A number of control techniques may be used in rinsing systems to reduce
water usage.  These are best implemented after earlier modifications have
been implemented, and water needs to be reduced.

      Conductivity controllers measure the amount of dissolved solids in
      the rinse.  When the level reaches a preset minimum, it shuts off a
      valve, interrupting the continuous fresh water feed to the rinse.
      When the concentration of dissolved solids reaches the maximum
      allowable level, the cell opens the valve.

      Flow regulators are another water saving device which can be used to
      control the fresh water feed within a narrow range.   These devices
      eliminate the need to reset the flow each time the valve is closed.

                      SPECIFIC MODIFICATIONS  FOR MICOM
      At Micom, the process of selecting implementable rinsing process
modifications has focused on:  available equipment, impact of a
modification on process solutions, product quality, and effect on
throughput.  Production objectives (quality and throughput) are paramount,
as might be expected.  As it happens, the project is structured so that
these objectives are implicitly considered in decision making, so the
question actually becomes one of implementation.

      The first option that will be implemented at Micom is extended
withdrawal rate from the process solutions, accomplished by slowing the
                                   489

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motor on the hoist used for raising, lowering and transporting racks of
circuit boards.  The literature suggests that this option has the largest
potential for reduction (up to 60%) of dragout, and also combines the
effects of solution viscosity aiding solution removal and extended drain
time (since the parts are necessarily drained longer while being withdrawn
more slowly).  In both cases, the effect on process solutions is an
important consideration.  Retaining  process solution which was formally
lost to dragout often means the solutions must be replaced more often.
MnTAP believes that managing the concentrated waste stream resulting from
bath dumps is preferable to managing diluted rinsewaters.   Opportunities
for metals recovery are improved if the wastestream is concentrated.  The
treatment of a dilute wastestream generates more sludge than a concentrated
wastestream.

      After reducing the amount of copper reaching the rinsewater by
extending withdrawal rates, rinsewater use will be reduced by installing
"needle" valves and throttling the flow.  When the baseline concentration
(measure of rinsing effectiveness) is again reached, the volume and/or
distribution of air in the currently installed air agitation system will be
modified in an attempt to increase rinsing efficiency and thereby
potentially further reduce water needs.   While the literature does not
indicate optimal air volumes or distributor designs, visual inspection of
Micom's rinse system reveals the air agitation is "gentle", rather than
"vigorous."  Vigorous agitation has the potential to significantly improve
the dynamics of dilution which lead to efficient rinsing.

                        BASELINE MEASUREMENT METHODS

      To properly evaluate the modifications of the rinsing process, MnTAP
established a baseline for copper dragout, water use, and rinsing
effectiveness for the Micom project.

      To measure the dragout from the process solution,  the incoming
softened water flow to the rinse tanks was temporarily shut off.  The first
and second rinse tanks were sampled (Figure 1) before and after a known
quantity of printed circuit boards were rinsed (one or two racks of 24
boards).  The process bath solution was also sampled immediately after a
rack of boards was removed.  The change in the copper concentration in the
rinses was analytically determined by atomic absorption.  The area of the
printed circuit boards,  which were rinsed during the sample period,  was
calculated to enable a comparison based on square footage  of production.
The dragout can be calculated by dividing the change in copper
concentration in the rinses by the concentration of the process solution
and then normalizing the result by dividing by the surface area of the
boards processed.

           (change in copper
           concentration in rinses) X  (volume of rinses)
Dragout - 	  [ml/sq.  ft.]

           (copper concentration         (surface area
            in process solution)    X       of boards)
                                   490

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      The water flow rate was calculated by measuring the time it takes to
fill a five gallon container from the rinse tank discharge.  The rinsewater
flow rate can be expressed in gallons per minute.  Rinsing effectiveness
was determined by measuring the residual quantity of copper on the printed
circuit boards after they have been rinsed.  This was done by analyzing for
the build up of copper in a non-flowing tank immediately following the
counter current rinses.   The build up was measured over the period of a
shift by taking two samples,  one at the beginning and one at the end of the
shift.

                      RESULTS OF BASELINE CALCULATIONS
      One hundred thirty-six samples were analyzed to determine the volume
of dragout from the micro-etch and the electroless copper baths for twelve
pairs of racks over a two week period.

      Dragout from the micro-etch =10.8 ml/sq ft
               Standard deviation =3.5
               Range              = 7.6 to 14. 5

      Dragout from the electroless copper =6.1 ml/sq ft
                       Standard deviation =1.3
                       Range              = 4.7 to 8.7

      The flow rates of the rinses following the micro-etch and electroless
copper baths were sampled twelve times over two days.

      Flow rate from micro-etch - 2.6 gallons/minute
             Standard deviation = .04
             Range              = 2.5 - 2.7

      Flow rate from electroless copper rinse =3.3 gallons/minute
                           Standard deviation = .05
                           Range              - 3.2 - 3.3

      Forty samples were analyzed to determine the rinsing effectiveness.
The build-up following the micro-etch rinses was less than 10 mg/1 per
shift.  The build-up following the electroless copper rinse was less than
0.1 mg/1 per shift.

      MnTAP is currently in the process of implementing the first
modifications, slowing the rate of withdrawal and extending the drain time.
The procedure is to determine the effect these modifications have on copper
dragout and rinsing effectiveness, and then continue with other/additional
modifications such as lowering the rinsewater flow rate.   The modifications
will be evaluated and the results presented to the management at Micom.
Micom will decide which modifications will be permanently put into place.
All modifications will be tested to ensure rinsing which is at least as
effective as what is currently in place.
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                                  SUMMARY

      The MnTAP/EPA WRITE project at Micom,  Inc.  has been designed to
evaluate rinsing process modifications which may reduce copper
concentration in rinsewater and reduce water use.  A baseline has been
established for flow rates and drag out volumes of process solution.  The
plating process has proven to be inherently difficult to characterize,
primarily because of variability due to operators,  solution concentrations,
and production change.  Future work includes implementing at least two
modifications,  with goals of 30% reduction in copper loading and 20%
reduction in water use, while maintaining production quality and
throughput.

                                 REFERENCES
Nunno,  T.,  et. al.  Toxic Waste Minimization in the Printed Circuit Board
      Industry, Noyes.

Kushner, Joseph B.  Water and Waste Control for the Plating Shop.
      Gardner Publications.

Cushnie, George C., Jr.  Electroplating Wastewater Pollution Control
      Technology.   Noyes.

Durney, Lawrence Jr., ed.   Electroplating Engineering Handbook.
      Van Nostrand Reinhold.

Control and Treatment Technology for the Metal Finishing Industry -
      In-Plant Changes.  EPA 625/8-82-08.

Environmental Pollution Control Alternatives -- Reducing Water Pollution
      Control Costs in the Electroplating Industry.  EPA 625/5-85-016.

In-Process Pollution Assessment:  Upgrading Metal-Finishing Facilities to
      Reduce Pollution. EPA 625/3-73-546.

Lowenheim,  Frederick.  Modern Electroplating.   Wiley Interscience.

Meltzer, Michael,  Ph.D.  "Reducing Environmental Risk:  Source Reduction
      for the Electroplating Industry.  Dissertation, UCLA.
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                        Keynote Address
       International Conference on Pollution Prevention:
             Clean Technologies and Clean Products

              Omni Shoreham Hotel, Washington, DC
                         June 11, 1990

     DEPARTMENT OF DEFENSE POLLUTION PREVENTION INITIATIVES

                               by
                 William H.  Parker,  III,  P.E.
      Deputy Assistant Secretary of Defense (Environment)


                          Introduction

     Thank you and good morning.  We are very pleased, as part
of DoD, to be here and to contribute to this important
conference.  I wish you well over the next three days.

     I am especially pleased to be here because:
     1.  DoD is an international organization, and we do have
concerns that go much beyond the boundaries of the United
States, and
     2.  This is the last major speech that I will be giving at
DoD, because I am leaving to go back into the private sector at
the end of this month.

     It just so happens that my pet program is pollution
prevention.-  This is a terrific way for me to, one last time,
talk about the program that I think has the most potential and
makes the most sense for all of us to comply with.

     There is a difficulty in coming up with terms, so I would
like to define mine before we get started.  First of all is
"waste treatment" or "end of pipe."  Second is "hazardous waste
minimization," which I refer to as the "ex poste" problem, or
big problems that already exist that have big payoffs if there
are solutions.  The third term is "pollution prevention."  I
refer to this as "ex ante."  It covers all areas.  It is to
proactively prevent pollution.  I believe at DoD we have made
outstanding progress in dealing with all of these problems and
in preventing future problems.  I truly do believe that we are
learning from the past.
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     Topics that I am going to cover with you this morning in
order to give you an idea of how we are dealing with our
problems are:
     1.  DoD environmental policy.
     2.  DoD operations and pollution potential.
     3.  Environmental leadership program.
     4.  Hazardous waste minimization efforts.
     5.  Pollution prevention initiatives.

     During the next three days our experts will be covering
with you how they implement many of the programs that I am
talking about with you this morning.  I won't get into the vast
details of these programs because of the fact that they can
cover it much better than I can in separate sessions.

                           DoD Policy

     First, I would like to cover DoD policy.  As I talk this
morning I am going to focus primarily on the policy that
relates to what we call CONUS  (Continental United States),
including all fifty states and the U.S. territories.

     First of all, our policy states that we will comply with
all applicable Federal, State and local laws and regulations.
Secondly, we require analyses of environmental consequences of
proposed actions.  In other words, we follow NEPA.  Third, our
policy requires the minimization of environmental impacts as we
accomplish our mission.  Of course, our mission is national
defense and even though we are seeing a so-called peace
dividend, we still have the responsibility of national defense
and have to work our environmental programs into the basic
mission.  I will talk more about that in just a few moments.

     Next, our policy requires that we provide good stewardship
of natural and cultural resources.  Finally we require that the
military cooperate fully and openly with environmental
regulatory agencies.  This is a major challenge for us since we
have 900 major installations in the fifty states and
territories.  It is very tough for us to do this under a
centralized program dealing with the different nuances of the
various laws of the different states, EPA regions, and
municipalities.

             DoD Operations and Pollution Potential

     To do this brings me to the second topic, which is DoD
operations and pollution potential.  We have approximately five
million military and civilian people in the Active Service,
Reserve, and National Guard.  Of course, that number is going
down as we reduce our military obligations, but still at this
time it is about five million people.  World-wide we have major
installations totalling over 1,200 and probably two or three
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times this  in minor  installations.  Here in the United States
we are stewards  for  25 million acres of land, equal to the
state of Tennessee.  This  is one of the key issues people
sometimes don't  think about - that we are responsible for so
much land.  We do have the responsibility for biodiversity on
this land.  We do have people living and working on the
installations whose  health and safety we are concerned about.

     Our installations are diverse in nature.  We have
airports, seaports,  industrial operations, laboratories,
training ranges, and so  forth.  Also, our installations are
small cities with housing, business, industry, hospitals,
recreation  and just  about  anything else that you can think of
in communities.  The pollution potential is very large and
diverse within DoD.  We  have municipal and industrial waste,
both solid  waste and hazardous waste, as well as liquid waste,
and air emissions from mobile and stationary sources.  You
might be surprised to know that DoD is the country's largest
user of petroleum products.  Worldwide, we use approximately
350 thousand barrels per day and our consumption here in the
U.S. is equal to somewhere between one and two percent of
national daily use.  We  have point and non-point pollution from
troop training and equipment maintenance and repair.  In short,
we face the same set of  problems that EPA does.  Also like EPA,
we have to  prioritize and  look at how to best accomplish our
environmental mission with the limitations within which we have
to work.

              DoD Environmental  Leadership  Program

     This brings me  to my  third topic, which is DoD's
Environmental Leadership Program .  First of all, our direction
comes from  President Bush  and from the Secretary of Defense -
Secretary Cheney.  On October 10, 1989, the Secretary put out a
memorandum  on environmental policy.  I would like to share a
couple of paragraphs from  that memorandum with you and then
talk quickly about several of the points in this memo.   The
Secretary stated "This Administration wants the United States
to be the world  leader in  addressing environmental problems,
and I want  the Department  of Defense to be the Federal leader
in agency environmental compliance and protection."  It goes on
to lay out  the program and concludes with "We must be fully
committed to do our  part to meet the worldwide environmental
challenge,   and I know I can count on your support to ensure
that we are successful in that effort."

     His environmental memorandum laid out several points.   As
I mentioned, his first paragraph says that we are to become the
Federal agency leader.   Here he means within the regulated
community.   The second point in his memorandum is that
environmental compliance must become a command priority.
Third,  is to integrate and budget environmental considerations.
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This is the big "M" word - Money.  Money drives all Federal
programs.  It drives everything, and in order for us to be
effective in the environment, we have to budget, we have to get
the money to do the work.  The next point he made is to
communicate problems and successes.  This is the responsibility
of everyone in DoD, and it is a requirement of good leadership.
Finally, the payoff.  There has to be outside recognition of
our efforts because this is the surest way to maintain access
to air, land, and water for defense preparedness.  Therefore,
we view being a good environmental citizen as part of our
mission.

     From the Secretary's memorandum, we have prepared what we
call an Environmental Leadership Program which has six goals.
I will briefly go through those, and then I will hit on several
of the subgoals as they apply to pollution prevention.

     1.  First of all is sustainable compliance, perhaps a new
term for some of us.  It is a proactive approach.  The military
has a saying "If it ain't broke, don't fix it."  With
sustainable compliance, what we are saying is "Use it, look at
it, and if you think it's going to break, fix it before it is
broken."
     2.  Second is obtaining the resources - not only the "M"
word (Money), but also people, and provide those people with
the training that is needed at each and every level to do their
job.
     3.  Third is communication. both internally and
externally.  First of all, the good news, or if you will, our
bank deposits.  Secondly, tell the bad news because we can't
hide it.  This is our bank withdrawals.  We have to have many
more deposits than we do withdrawals in order to show that we
are serious about the environment.
     4.  Next is environmental planning and awareness under
systems acquisition.  First of all, we want to try to keep
hazardous materials out of systems.  Secondly, we want to look
at how those systems are going to operate and make sure that
wherever possible they do not affect the environment, and if
there is an effect, that the effect is minimized.
     5.  Next is pollution prevention through TQM (total
quality management) and life cycle cost analysis, which to me
as an engineer, is nothing but plain good business.
     6.  Finally, is to develop reliable measures of progress
and feedback systems.  The public demands nothing less than
that we be able to quantify what kind of progress we are
making.  In DoD, we have gotten past the stage where we are
using catchy slogans to motivate people without any way to
quantify those results.

     Now I want to touch briefly on several subissues of the
environmental leadership program which I think apply to
pollution prevention:
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     1.  First of all  is cultural change.  Number one is to
publish the Hazardous  Material Pollution Prevention Directive,
which has already been done.  Then is to integrate
environmental protection and compliance into DoD's mission -
that is, change the culture.
     2.  Second is compliance with environmental laws.  Here
one of the things that we said is "Make commanders accountable
for making it happen.  Audit requirements and track
performance."
     3.  Under people, we said  "More environmental staff,
multi-disciplined," because we also concur that solving
environmental problems is a multi-disciplinary problem.  The
second point under people is better training in environmental
programs.  We maintain that everyone in DoD who goes into any
training program should have some unit of environmental
training, and a unit that helps him do his job better.  Third
is clear accountability for DoD employees and their commanders.
We expect to hold people accountable, we expect them to know
it, and we expect them to perform it.
     4.  Next is on the budgets. •  One is to develop a master
plan and program funds to match.  Second is priorities for all
environmental funding  on a worst-first basis.
     5.  Training.  We talk about integrating applicable
environmental training in all our military and civilian
training programs.  I  mentioned that before and obviously there
is some overlap in many of these programs.
     6.  Last, under regulatory relations - establish a
partnership with EPA and the states in environmental master
planning and also proactively solicit state involvement in all
our programs.  In order to do this, we have entered into
preparation of strategic plans for the environment.  This fall
we have a DoD Environmental Forum in which we will solicit
external ideas, and we will communicate.  The output of this
will be used as some of the input to our Strategic Plan.  We
are required by Congress to submit a report on our long-range
goals by November of 1991.  All of these things together
represent the start of what we call our D&EI - our Defense and
Environmental Initiative.  Also, you may have read about the
Defense Management Review, which has been undertaken by the
Secretary.  Under that, we are consolidating environmental
directives, updating all our directives that apply to all
environmental media.

        DoD HazWaste Min & Pollution Prevention Efforts

     One of those media is the fourth item that I am going to
cover this morning - DoD's hazardous waste minimization and
pollution prevention initiatives.   In our 1985 Projects of
Excellence effort,  we  evaluated DoD industrial process changes
for hazardous waste minimization successes and failures.   We
identified major sources of hazardous waste in our industrial
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activities, which, by the way, represent about 80 percent of
the production of hazardous waste at DoD.  This includes
machining, solvent cleaning, plating, painting, and removal of
paints and coatings.  We came up with factors of success,
especially motivating production people and making
evolutionary, rather than revolutionary, changes - changes
which are elegant in their simplicity.  Or, in other words,
just plain good innovation.

     To date we have funded over $200 million in HazWaste Min
projects from the Defense Environmental Restoration Account and
from the Services budgets. We have prepared reports to Congress
on our progress.  We have put out a DoD pollution prevention
directive.  We have also entered into an extension of an
agreement on Chesapeake Bay with the EPA, signed as part of
Earth Day by Secretary Cheney and Bill Reilly.  In that, one of
the initiatives is a multi-media, model community, pollution
prevention, demonstration project on one of our bases.

     We are working on the reduction of CFCs and halons through
a DoD directive.  I think that this is also a model of how EPA,
DoD, and industry are working together to phase out the use of
CFCs and halons.  For instance, halons are very important to
us.  They are used, because they are non-toxic, as fire
suppressants in our jets, on our ships, in our tanks, and other
equipment.  You can see how important it is for us to find
suitable substitutes for these materials.

     We are developing a better hazardous waste tracking and
indexing system. I would like to give credit to the military
Components, the Joint Logistical Commanders, the Joint Depot
Maintenance Analysis Group, and the Joint Depot Environmental
Panel for the work they are doing in pollution prevention and
hazardous waste minimization.  We are working on a recycling
program.  We have one that we are just kicking off, as a matter
of fact, at the Pentagon itself.  Another major program is our
Chemical Demilitarization program.  We are just starting up
Johnson Island for the destruction of many of these weapons.
And last, it is fitting to point to CERCLA and our Installation
Restoration Program, where the remedial action preference is
for treatment to permanently and significantly reduce the
volume, toxicity or mobility of hazardous substances.  We are
spending somewhere between $600 and $800 million per year on
this particular effort.

     It wouldn't be fitting to end my remarks without quoting
from one great American group  ... from the "DENNIS THEU.MENACE1®
comic strip.  Several years ago, a "DENNIS THE MENACE1® public
service poster defined progress as follows:  "Progress  is when
everyone pushes in the same direction."  DoD's environmental
policies and pollution prevention initiatives are intended to
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get all five million people at all 1,200 bases pushing together
for a better environment.

           ["DENNIS THE MENACE1® used by permission of
          Hank Ketcham  © by North America Syndicate]

     It has been said that there is a natural bond between
those who work to protect our Nation and those who work to
protect our environment.  In order to do this we need
experienced engineers and technicians to design and implement
these programs.  I am very concerned about the potential
shortages in this area, so we have got to work smarter.  There
is a need for cultural change, because many of these things
require cultural solutions.  I believe that pollution
prevention can help conserve shrinking DoD resources.

                           Conclusion

     This morning I have briefly talked to you about our
environmental policies, our operations and pollution potential,
our leadership program, our HazWaste Min efforts, and our
pollution prevention initiatives.  Since this is my last major
speech, I would like to look into my crystal ball for just one
second and give you some observations about the key DoD issues
for the 1990s.

     First of all, I do believe that hazardous waste
minimization and pollution prevention have got to be one of the
four issues DoD has to drive.  Second, are our natural
resources programs, because we truly are stewards of major
pieces of America.  Third,  is NEPA compliance, because of it's
importance with what we do.  Finally,  the development of an
environmental strategy that integrates and implements.  The
strategy must set the goals in a public forum.  It must
dedicate the resources, it must execute, and finally, it must
communicate the results.

     Thank you very much.  I want to wish you well in the next
three days. I know that you will have a good conference, and I
hope that we will all learn very much from it.


Dr. Emir Metry, Moderator:
     Thank you very much, Mr. Parker.   I can assure you that
will not be your last major speech,  because we will be
demanding that you can come and talk to us.  It is wonderful to
see, for many of us who started in this field as engineers and
technicians ... and as poets.  What the environmental movement
needs is more poets that will tell us  where we are going,  and
the rest of us will make it happen.

                              END
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 CROP AND  PASTURE  LAND  CONVERSION OPPORTUNITIES FOR MITIGATING GLOBAL WARMING

                  by:    Peter J.  Parks
                        Center for Resource and
                          Environmental Policy Research
                        Duke University
                        Durham, NC 27706
      Land and owner characteristics are used to identify a national pool of
120.8 million acres of marginal crop and pasture land,  on which hardwood or
softwood vegetation can potentially grow.   Of the 58.0 million acres for
which consistent economic data on softwoods are available, 25.6 million acres
can be profitably converted to forests.   Establishing new forests on these
lands would require $1.58 billion, which would provide an annual merchantable
volume increment of 1.7 billion cubic feet.  Most of the lands (22.7 million
acres) are currently pasture lands with little or no potential for conversion
to cropland.  The remaining 2.9 million acres are currently used for row,
close grown, or other crops.  Factors limiting the agricultural use of these
lands include erodibility, wetness, and other soil characteristics.  Most of
the lands (15.8 million acres) are erodible.   The remaining lands (5.4
million acres and 4.3 million acres) are limited by soil characteristics, and
wetness, respectively.  Some of these limitations may also impede conversion
to forests.   Establishing forests on these lands would incorporate an average
of 0.0223 Gt of carbon per year in tree biomass if trees were grown to
economically optimal rotation lengths.   Additional changes in understory and
soil carbon would also occur.  Compared to global estimates of atmospheric
carbon increases such as 3.0 Gt/yr (1.4 ppm/yr),  establishing forests on
these lands would mitigate increases by about one percent.  This corresponds
to about two to three percent of United States emissions.  In contrast,
carbon releases of 0.4 to 4.2 Gt/yr have been attributed to global tropical
deforestation.  The full menu of policy options to mitigate climate changes
must consider not only establishing new temperate forests, but controlling
the rapid loss of existing tropical forests.
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 CROP AND PASTURE LAND CONVERSION OPPORTUNITIES  FOR MITIGATING GLOBAL WARMING
                                 INTRODUCTION
      The role of global  environmental change in policy design has
concentrated attention  on forested environments and the potential for growing
forests to mitigate atmospheric  carbon increases (e.g., 4, 10).  Large areas
of crop and pasture lands in the United States may be of limited agricultural
value due to erodibility,  wetness,  and other soil characteristics (e.g., low
moisture-holding capacity).    Converting some of these marginal lands to
forests can provide net economic gains as well as sequestering atmospheric
carbon and providing other environmental benefits.
              OPPORTUNITIES FOR CONVERTING CROP AND  PASTURE LAND
POTENTIAL ACREAGE POOL
      Land and owner characteristics  are used to identify a national pool of
120.8 million acres of marginal  crop  and pasture land, on which hardwood or
softwood vegetation can potentially grow (Figure 1).
                                            North Central 49.1
                  Northeast 24.9 \\^E	Ik     ^TF Pacific Coast 3.7
                                                    Rocky Mountains 4.6

                                      	     Southeast 15.0
                        South Central 23.4
  Figure 1.  Acreage Pool of Crop and Pasture Land by Region (Million Acres)
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      The acreage pool consists of privately-owned land,  that is not prime
farmland, and is currently used for crop or pasture.   Irrigated lands and
lands growing specialty crops (e.g.,  horticultural crops) are excluded.  Only
land in Land Capability Classes III,  IV, VI, and VII (8), and areas of the
country capable of supporting hardwood or softwood vegetation are included
(6). Most of the land is in the Northeast, North central, Southeast and South
central regions, although some lands meeting the marginal criteria are found
in the Rocky Mountain and Pacific Coast Regions.

      The acreage pool is roughly evenly divided between lands that can
potentially support softwoods and hardwoods, and between current crop and
pasture uses (Figure 2).  Most potential hardwood lands are found in the
North Central and Northeast (36.8 million acres and 13.5 million acres,
respectively) regions, particularly in Great Plains.  Potential softwood
lands are in all regions, but are particularly large in the South Central,
Southeast, North Central, and Northeast regions (18.2 million acres, 15.0
million acres, 12.4 million acres, and 11.4 million acres); 8.2 million
potential softwood acres are found in the Pacific Coast and Rocky Mountain
regions combined.
                Softwoods 65.2                         Cropland 58.2
                             Hardwoods 55.6    Pasture 62.6
                 Potential Vegetation        Land Cover
 Figure  2. Acreage  Pool  by  Potential Natural Vegetation  and Current Land Cover
                               (Million Acres).


      The acreage  pool  is  also roughly evenly divided between land currently
 used for crops and for  pasture (Figure 2).  Most of the cropland  in the
 acreage pool  (41.3 million acres) is found in the North Central and Northeast
 regions; 11.9 million acres are found in the South Central  and Southeast
 Regions.  In  contrast the  largest shares of pasture land in the acreage pool
 are found in  the South  Central (17.2 million acres) and North Central  (19.7)
                                      502

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million acres.   The Southeast and Northeast acreage pools contain  9.3
million and 13.1 million acres, respectively.  The remaining 3.2 million
acres is evenly divided between the Rocky Mountain and Pacific Coast regions.
MARGINAL CROP AND PASTURE LANDS
      Marginal lands are those lands in the acreage pool which can be
converted to forests for a net economic gain.  To identify these lands,
economic benefits from forest use were compared to those for crop and pasture
lands.  Forest data were provided by the USDA Forest Service, and consist of
yields, costs, and prices.  Yields are based on an average of management
intensities, costs and prices are similar to those used in the recent 1989
Renewable Resources Planning Act Assessment (e.g., 2).  Net crop returns per
acre were determined from data provided by the Soil Conservation Service for
each state portion of Major Land Resource Areas in the contiguous United
States.  These returns per acre are based on returns, costs, and yields for
sixteen major crops, which comprise nearly 94 percent of the cropland acreage
used.  These crop budgets are similar to those used in the Second Soil and
Water Resources Conservation Act Appraisal (9).  Pasture returns used are
annual cash rents received for pasture land by state. Returns were compared
on a state-Major Land Resource Area basis to identify marginal lands within
the acreage pool.
                  95.2
                                  Marginal
                                    25.6
Northeast 1

S Central 12.7

Pac Coast 0.9
Southeast 9.1

N Central 1.9
                     Acreage Pool     Marginal Softwood Lands
              Figure  3.  Marginal Land by Region (Million Acres).
      Of the 58.0 million acres for which consistent economic data on
softwoods are available, 25.6 million acres can be profitably converted to
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forests (Figure 3).   Most of these marginal lands are in the South Central
(12.7 million acres) and Southeast (9.1 million acres).  The North Central
Region includes 1.9 million acres of marginal softwood land, and the
remaining 1.9 million acres are roughly equally divided between the Northeast
and the Pacific Coast.

      Currently, most of the marginal lands are used for pasture that has
little or no potential for conversion to cropland (22.7 million acres), the
remaining 2.9 million acres are used for row, close grown, or other crops
(Figure 4).   No marginal crop lands are in the west (either the Rocky
Mountain or Pacific Coast regions); the majority of marginal croplands are
found in the Southeast and South central Regions (1.2 million acres and 1.5
million acres, respectively).  The Northeast and North Central regions 0.2
million acres of marginal cropland.
                Pasture
                 22.7
                                            Erosion
                                             15.8
                      Land  Cover
                                            Wetness
                                             4.3
Ag  Use Limitation
     Figure 4. Marginal Softwood Lands by Land Cover and Agricultural Use
                          Limitation  (Million Acres).
The marginal softwood lands in the west consist of 0.9 million acres  of
pasture in the Pacific Coast region.  The Northeast region also contains  0.9
million marginal pasture acres, while the North Central region (primarily in
the Lake States) has double this amount, or 1.8 million acres.  The bulk  of
the marginal pasture land is found in the South Central region (11.5  million
acres), with the remaining 7.6 million acres in the Southeast region.

      Factors limiting the agricultural use of these lands include
erodibility, wetness, and other soil characteristics.  Most of the lands
(15.8 million acres) are erodible (Figure 4).  The remaining lands (5.4
million acres and 4.3 million acres) are limited by soil characteristics,  and
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wetness, respectively.  Most of  the  land in the  two southern regions is
currently limited by past or potential  future  erosion,  although erodible
marginal land is also present  in the North Central,  Northeast,  and Pacific
Coast regions.  Lands of limited use due to soil characteristics (e.g.,
moisture holding capacity) are found about equally in the North Central,
South Central, and Southeast regions.   Soils limited by wetness are found
primarily in the Southeast.  Some of these limitations  may also impede
conversion to forests.
                 OPPORTUNITIES  FOR MITIGATING GLOBAL WARMING
      These marginal lands provide an  opportunity to  mitigate global warming
by sequestering atmospheric carbon dioxide.   The  potential mitigation
possible with land conversion must be  weighed against conversion costs, and
other mitigation options.  Establishing new  forests on these lands would
require $1.58 billion  (Figure 5).  Most of the expenditure will be required
in the South Central and Southeast regions ($0.73 and $0.51 billion,
respectively).  Establishing forests on the  North Central,  Northeast, and
Pacific Coast Regions will cost a total of $0.34  billion.   Under a proposed
$110 million for the rural tree planting  initiative in the America the
Beautiful program (7), which is to subsidize 50 percent of establishment
costs, the funding level must be maintained  for at least 7.2 years to take
pay for the opportunities shown in Figure 5.
                   Millions of Dollars
              800 -i
              600-
              400
              200-
                  /\
                  North Central  Northeast  Pacific Coast  Southeast  South Central
                                      Region
                    Figure 5. Conversion Costs by Region.
                                     505

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      Creating these forests will add new acres  to  the existing nonindustrial
forest land base (Figure 6).  The additions  are  most significant in the South
Central (11.6%) and Southeast (10.8%) regions; outside these regions, the
added lands are negligible  compared  to  existing  forest area (2).   When grown
to the economically optimal rotation length,  these  lands will provide an
annual volume increment of  1.7 billion  cubic feet.   By region, the added
volume is 22 percent of projected annual  harvests for the South,  nine percent
for the North, and three percent for the  Pacific Coast (2).  The amount of
biomass in the first generation of these  new forests is 0.568 Gt (1 Gt equals
1 billion metric tonnes).   Most of the  biomass is concentrated in the South
Central (0.256 Gt) and Southeastern  (0.193 Gt) regions.  The North Central,
Northeast, and Pacific Coast regions store 0.038 Gt, 0.018 Gt, and 0.063 Gt,
respectively.
                   Millions of Acres
                   North Central  Northeast  Pacific Coast South Central  Southeast
                                       Region

                         •^1 Existing Forest Area  IM^ Marginal Lands
      Figure 6.  Potential Afforestation Compared to Existing Forest  Land.
MITIGATION QUANTIFIED
      The  opportunities  discussed here must be placed on an annual basis  in
order to compare  them to emissions,  and to quantify the mitigation impact
(Figure 7).   The  new forests shown earlier in Figure 6 will sequester  an
average of 0.0223 Gt/yr  throughout the economic rotation.  Most of this
sequestration will be in the South Central (0.0108 Gt/yr) and Southeast
(0.00771 Gt/yr) regions.   Additional carbon will be sequestered in North
Central (0.0017 Gt/yr) Northeast, (0.000816 Gt/yr), and Pacific Coast  regions
(0.001348  Gt/yr).  These statistics consider only the carbon in tree biomass.
                                      506

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Additional changes  in understory and soil carbon would also occur.  A better
assessment of net changes  as  a  result of land conversion would require a
tally of carbon  sequestered in  crop  and pasture ecosystems, as well as non-
tree components  of  temperate  forest  ecosystems.
                     Qt/yr (Billion tonnes per Year)
                    North Central  Northeast Pacific Coast  Southeast  South Central
                                       Region
                   Figure  7.  Potential Mitigation by Region.
      Compared to global estimates  of  atmospheric  carbon increases such as
3.0 Gt/yr (1.4 ppm/yr)  (5), establishing  forests on these lands would
mitigate global increases by about  one percent.  This  corresponds to about
two to three percent of US emissions.  In contrast,  carbon releases of 0.4 to
4.2 Gt/yr (3) have been attributed  to  global  tropical  deforestation.   The
full menu of policy options to mitigate climate changes  must consider not
only establishing new temperate forests,  but  controlling the rapid loss of
existing tropical forests.

      As an aside, it should be noted  that the management of existing forests
can be changed to sequester more carbon than  they  presently do.   For example,
considerable management opportunities  exist on temperate forests in the US
(2).  These fall into two broad categories, stocking control and
regeneration.  The former requires  entry  into existing stands to adjust stand
density for greater growth.  The latter requires reestablishing stands on
existing nonstocked forest lands.   Each of these options increases annual
growth.  Figure 8 shows merchantable (cf.  total tree biomass,  Figure 7)
biomass increments that could be achieved if  all management opportunities
identified in (2) were undertaken,  as  well as the  afforestation opportunities
presented earlier in Figure 7.  Clearly,  an integrated strategy,  with
emphases on establishing new forests,  adapting the management of existing
forests, and controlling the loss of forests  has much  to recommend itself.
                                      507

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                                  CONCLUSIONS
      Converting marginal  lands  to forests may require both public  and
private funds.  The cost of land use change must include not only land
conversion costs (e.g., forest establishment)  but also opportunity  costs  of
forgoing other revenue-producing land uses when they are present.   With
perfect markets and in  the absence of risk, landowners who would be
economically better-off with forests than with crops or pasture would change
uses without a subsidy.  For example,  in the Southeast and South Central
regions, net economic gains from conversion are possible on 21.8 million
acres.  Subsidies for the  difference between forest income and agricultural
income would hypothetically be required to convert the 10.4 million acres
remaining in the Southern  marginal acreage pool.  If establishing forests is
to become a policy goal, research must now identify economically-efficient
policies for land conversion,  and evaluate these policies in the context  of
risky or imperfect markets for stocks and flows of forest benefits.   Benefits
and costs of these mitigation strategies must be compared with other policy
options to find the most efficient set of responses to climate change.
                     Qt/yr (Billions tonnes per Year)
                    North Central  Northeast  Pacific Coaat Southeast South Central
                                        Region

                    •• Afforestation  KMi Regeneration   I  I Stocking Control
                  Figure 8. Potential Integrated Mitigation.
                                      508

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                                 REFERENCES
1. Congressional Record -- Senate.  S 16313-S 16319.  Washington,  DC.  1989.

2. Haynes, R.W. An Analysis of the Timber Situation in the United States:
1989-2040.  Part II: The Future Resource Situation.   A Technical Document
Supporting the 1989 RPA Assessment, US Department of Agriculture, Forest
Service, Washington, DC. 1988.

3. Houghton, R. A., W.H. Schlesinger, S. Brown,  and J.F.  Richards. Carbon
Dioxide Exchange Between the Atmosphere and Terrestrial Ecosystems.   In J.R.
Trabalka (ed.), Atmospheric Carbon Dioxide and the Global Carbon Cycle.
DOE/ER-0239, US Department of Energy, Office of Energy Research, Office of
Basic Energy Sciences, Carbon Dioxide Research Division,  Washington, DC.
1985.

4. National Academy of Sciences, National Academy of Engineering, Institute
of Medicine.  Global Environmental Change: Recommendations for President-
Elect George Bush.  National Academy Press, Washington, DC. 1988.

5. Tans, P.P., I.Y. Fung,  and T. Takahashi. Observational Constraints on the
Global C02 Budget. Science 247: 1431-1438. 1990.

6. USDA Forest Service. A Comparison of Five National Land Classification
Maps. Agricultural Handbook 672, US Department of Agriculture, Forest
Service, Washington, DC. 1988.

7. USDA Forest Service. America the Beautiful: National Tree Planting
Initiative.  Unnumbered publication, US Department of Agriculture, Forest
Service, Washington, DC. 1990.

8. USDA Soil Conservation Service.  Basic Statistics 1982 National Resources
Inventory. Statistical Bulletin No. 756, US Department of Agriculture, Soil
Conservation Service, Washington, DC. 1987.

9. USDA Soil Conservation Service.   The Second RCA Appraisal:  Review Draft.
US Department of Agriculture, Soil Conservation Service,  Washington, DC.
1987.

10. US General Accounting Office.  Global Warming: Administration Approach
Cautious Pending Validation of Threat.  Report to the Chairman,  Subcommittee
on Oversight and Investigations, Committee on Energy and Commerce, House of
Representatives.  GAO/NSIAD-90-63,  US General Accounting Office, Washington,
DC. 1990.
                                     509

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 TOXIC WASTE TRADE IN AFRICA AND  THE  CARIBBEAN:  FROM REGULATION
                    TO POLLUTION  PREVENTION
                                BY
                 HUGH G.  PILGRIM, M.S.,  M.P.H.
Paper presented to the E.P.A.  International  Conference on Pollution
Prevention:  Clean Technologies  and  Clean  Products.
Washington, D.C.  June 11,  1990
                               510

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BACKGROUND

Industrialized countries generate  90%  of  the  total global hazardous waste
produced.  Greenpeace has verified that between 1986 and 1988, 3.17 million
metric tons of waste were shipped  from countries in the industrialized North
to poor countries in the South.  Recent proposals to ship wastes to the
countries of sub-Saharan Africa, some  17.4  metric tons per year,
approximately the total volume  produced in  the EEC, were opposed by
developing countries which  ultimately  refused to accept these exports.

The issue of transnational  toxic dumping  was  dramatized by the cargo ship,
Khian Sean which carried 14,000 tons of toxic incinerator ash from
Philadelphia to a number of  countries  in  Central America, the Caribbean,
Africa and the Indian Ocean for two years in  search of a place to dump
before leaving 3,000 to 4,000 tons on  a beach in Haiti. The manifest
described the ship's cargo  as fertilizer. The remainder was reportedly
dumped in the Indian Ocean.  These episodes reflect the effects of increased
regulation of toxic and hazardous  pollutants  in the U.S. and the high cost
of disposal. Incinerator ash may contain  high levels of dioxin and heavy
metals.

Another episode from 1988 revealed that 15  million tons of U.S. and European
pharmaceutical and tannery  wastes  were due  to be imported into Guinea Bissau
in exchange for 600 million dollars, four times the country's GNP and two
times the national debt, but proper disposal  of the same waste in the
country of its origin would have cost  from  ten to twenty times more.  These
factors provide incentives  to producers of  hazardous waste to seek disposal
in areas outside the U.S. and Europe.1

The Resource Conservation and Recovery Act  (RCRA) Section 3017 requires
documentation of wastes, notification, and  prior consent before shipment of
hazardous waste between countries  participating in the trade.  Regional
groups, such as OECD and the EEC allow shipments, and the regulations such
as the 1984 EEC directive on transfrentier  movement of wastes between member
states cover movements designed for export  outside the EEC.  However, by
1988 only three countries in the EEC had  incorporated the directive into
regulations which focus on  the  end of  the hazardous waste life-cycle.  The
regulations beg the question whether conventions on notification and prior
consent between countries,  and  documentation  of wastes can protect the
people in developing countries  from adverse health impacts and further
environmental degradation,  or whether  more  preventive measures including a
total ban on exports of countries  in the  South, is more in order.

The following sections include  a review of  domestic factors underlying toxic
dumping in Africa and the Caribbean, considering the generation and
production of wastes in the U.S. and Europe.   We explore similarities
between proposed EPA Regulations and the  Basel Convention, the social,
economic, political and environmental  consequences, and the application of
pollution prevention principles which  can achieve greater protection of
human health and the environment.

1. B. Wynne, "The Toxic Waste Trade: International Regulatory Issues and
   Options," Third World Quarterly, Vol.  11,  No.3, July 1989 p. 125
                                    511

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DOMESTIC FACTORS AN THE  INTERNATIONAL WASTE TRADE:

Industries in the U.S. generated  at  least  2,4000 Ibs wet weight per person
per year, including some non-RCRA regulated wastes  such as PCBs and
industrial scrubber sludges. This excludes  wastes from companies generating
less than 1,000 kilograms, waste  from clean-up  of Superfund sites and
hazardous waste that is nuclear,  agricultural and mining.  Overall, the U.S.
generates over 250 million metric tons per  year depending upon types of
waste included.  Waste varies  by  definition. For example, recycled oil is
not regulated as hazardous waste.  The figures  above do not include the
amount of waste handled illegally.

Most RCRA regulated wastes have been managed on land by deep well injection,
landfills and surface impoundments.   Examination of  RCRA permits indicates
a decline in land disposal of  hazardous waste with  implementation of the
Hazardous and Solid Waste Amendments (HSWA).

Disposal facilities decreased  significantly when surface impoundment was
required.  It is not clear what is happening to waste previously handled by
such waste diposal facilities.  Alternative types of capacity are also
declining with utilization of  management facilities, e.g. incinerators at
90% capacity by the end of 1985.   Current  landfill  capacity has less than
15 years remaining at current  rates  of use.  Hazardous wastes represent a
special problem arising from production of  by-products in chemical
industries, and the manufacturing processes , and the need to dispose of
these by-products.  While it is difficult  to specify the amount generate
annually, it includes:


                      (1)  cyanides
                      (2)  paint  residues
                      (3)  metal  wastes
                      (4)  organic solvents
                      (5)  material  containing  arsenic,  asbestos,
                           mercury and cadmium.


Because unsafe disposal of these  wastes can cause severe damage to human
health and the environment, industrialized  countries have regulations
governing disposal.  The long  term solution is  not  so much safe disposal as
to prevent the generation of toxic waste by changing production processes
and product design.

The international trade in hazardous waste  is a complex business.  It is
almost impossible to document  and effectively control that trade by
regulations, given the diverse agents involved  in consignments and the
nature of deals between generators,  transporters of  hazardous wastes and
receiving countries.  This situation also highlights a contradiction between
national sovereignty and the international  impact of environmental
degradation.
                                     512

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The principal causes of  the  growth  in  this  trade include increasingly
stringent regulations, public  opposition  to landfills and incinerators, and
rising costs of hazardous waste  disposal  in the industrial countries such as
the U.S and in Europe.   These  developments  have resulted in both legal and
illegal shipments of toxic waste to developing countries in Africa and the
Caribbean.

The pro-export groups argue  that a  ban on waste trading would deprive poor
countries of a means to  earn hard currency, and, that lack of clear
distinction between toxic and  raw materials,  recycled as inputs for
industrial processes would curtail  waste  management technology transfer, and
discourage industrial development.   Upon  this argument, toxic waste is like
any other commodity and  it assumes  that free markets would assure efficency
and equity.  This view fails to  address the underlying structural problems.2

For example, in the U.S. the 1984 Amendments to RCRA tightened landfill
requirements for municipal wastes and  curtailed disposal of untreated wastes
in landfills, deep well  injection,  and industrial incineration.  The cost
of hazardous waste disposal  which can  run as high as $2,400.00 per ton
in the U.S., results from expensive treatment and disposal methods, and
lack of certified hazardous  waste handling  facilities.  The generators
facing this situation can circumvent the  EPA regulations by dumping unknown
quantities of wastes in  developing  countries at prices as low as $2.50 per
ton.

The European countries,  members  of  the EEC  generate 30-40 million tons of
hazardous wastes each year,  but  only have the capacity to dispose of 10
million tons each year.  Since 1986, both the U.S. and Europe shipped
hazardous waste to countries including Brazil, Haiti, Lebanon, Mexico,
Nigeria, South Africa, Syria,  Venezuela and Zimbabwe.

The developing countries generally  lack the capacity to ensure safe handling
disposal or treatment of hazardous  wastes.   The waste imports dumped in
vulnerable countries with huge debt burdens, and poverty, reproduce  the
environmental management problems and  failures of industrialized countries.

The problem of hazardous waste exports and  toxic dumping is connected with
proverty and development at  the  national  and international level. The
general situation is exacerbated by wide  differences in the stages of
industrial development and the capacity for effective regulation of waste
exports by countries involved  in the hazardous waste trade.  In a sense, the
problem of hazardous waste disposal is the  problem of poor communities both
here and overseas, impoverished  communities whether in Alabama or Zaire.
2. B. Wynne,  Ibid  pp.  123-128.
                                     513

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The poor of urban  and  rural  areas  of  the  U.S.,  Africa, the Caribbean and
elsewhere, face environmental  abuses  caused by  failed government policies
which result in the disproportionate  exposures  to pollution and hazardous
materials.  For example,  these exposures  involve hazards such as
contaminated drinking  water  from lack of  sewerage,  human and chemical
wastes, and unknown quantities of  toxic materials from location near or in
garbage dumps, toxic dumps and hazardous  industries e.g. Bhopal.

CONSEQUENCES OF THE INTERNATIONAL  TOXIC WASTE TRADE;

Toxic dumping is thus  partly a consequence  of the policies and regulations
governing export of hazardous  wastes  and  export of  hazardous wastes and
disposal of toxic  substances.   The U.S. Office  of Science and Technology
Policy describes the regulations as a two stage process:  Stage 1 uses
facts, empirical data  and scientific  judgment to characterize human exposure
and risks.  Stage  II uses values,  social  and political judgments to decide
regulatory action  based upon significance of the risk, benefits of the agent
and cost of its control.^

In addition, current national  policies and  the  international regulatory
framework under UNEP auspices,  i.e. the Basel Convention^ allow toxic waste
trade on the basis of  a documentary system  with notification and consent.
These regulations  favoring exports might  be partly  explained by the cultural
biases of the policy actors  and interest  groups.5

The trade in hazardous waste between  industrialized and developing countries
is premised on the belief that land disposal of hazardous waste substances
is reasonably safe.  The underlying assumption  is that these wastes would
degrade into harmless  products or  stay where they are put.  These
assumptions have been  proven wrong since  many of these wastes do not
degrade, degrade very  slowly,  or degrade  into substances that are hazardous
to human health  and the environment.   The waste products can also migrate
into water or be moved by wind into storm water in  other locations, and pose
significant risks  to people's  health  long after disposal.  The risks include
3.  Alice S. Whittemore, "Facts and Values  in  Risk Analysis for
Environmental Toxicants", Risk Analysis,  Vol.  3.  No.  1,  1983,  p. 23
4.  Arts. 6-14, 20, Final Act of  the  Conference  of Plenipotentiaries
on the Global Convention of the Control of  Transboundary Movement of
Hazardous Wastes, UNEP/1G.80:.  12, 22 March,  1989.   For a critical
account of the Basel Convention and the international toxic waste
trade generally, see Wynne, "The  Toxic Waste Trade:   International
Regulatory Issues and Options", note  1, supra  pp.  120-146.  According
to Wynne, the Convention ended negotiations in 1989  in a confused and
unsatisfactory manner, leaving major  loopholes and disagreements
unresolved,  (ibid, p 122).
5.  On the relevance of cultural  theory,  and cultrual bias in
environmental management, see Susan J. Buck, "Cultural Theory  and
the Management of common Property Resources",  Human  Ecology
Vol. 17.  No. 1, 1989, pp.  101-116.
                                     514

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birth defects, cancer, genetic  damage,  neurological defects and liver and
kidney damage.6

Hazardous chemicals can  cause major  public  health consequences when
discharged into the environment,  e.g. mercury poisoning at Minamata Bay in
Japan.  Highly toxic effects  result  from low level exposure to
polychlorinated biphenyls  (PCBs)  ingested in small quantities over a period
of time7.
     Consequences of dumping  in Africa  include charges of "toxic terrorism"
by most leaders at the 1988 OAU summit  in Addis,  Ababa, Ethiopia. The Afican
leaders adopted a resolution  to further agreements on a ban and prevent any
arrangements with industrialized  countries  on dumping nuclear waste and
hazardous industrial waste.   Nigeria called the special regional summit of
West African Countries (ECOWAS) in Lome, Togo.  The West African leaders
intiated "Dumpwatch" to  monitor dumping.

     Western reaction include denials,  for  example, a May 1988 Voice of
America broadcast denied that any toxic waste from the U.S. had been
shipped to Guinea; and,  equated the  need for hard currency with the "need"
to dump toxic waste, and indicated that there is  no evidence of widespread
shipments of dangerous materials  to  poor countries**.  A number of bills
introduced in the U.S. Congress in response to the reaction to toxic
dumping, would require countries  to  manage  U.S. waste exports by U.S.
standards.  These countries would be subject to requirements in U.S.
environmental laws.  The proposed legislation would cover supposedly non-
hazardous waste including municipal  solid waste and incinerator ash. The
U.S. and importing countries  would negotiate agreements that include: prior
consent by the receiving country, exchange  of information on waste
management, and access to  foreign disposal  facilities for U.S. inspectors
to ensure proper management of  U.S.  wastes. The Bush Administration has
argued against the legislation  on foreign policy grounds^.
 6.  State  of  the  Environment:  A View towards the Nineties, Conservation
    Foundation, Washington,  D.C. p.  156

 7.   ibid,  p.  157.

 8.   See "Toxic Dumping Alarms Afica", TransAfrica Forum", Issue Brief,
     Vol.  7.   NO.  3,  Winter  1988-89, pp. 1-3.

 9.   Hazardous Waste, "House Bill Would Require Foreign Countries to Manage
     Waste  Exports  by U.S.  Standards", Environmental Reporter, 6-2-89
     See also Inside  EPA,  21 July 1989.
                                      515

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INTERNATIONAL RESPONSES  TO  THE  TOXIC WASTE TRADE:
Transboundary movements  of  hazardous  waste have spurred a number of regional
agreements to regulate the  toxic  waste  trade.   On one hand, these include
decisions by the OECD and the  EEC which permit international trade in
hazardous waste, while attempting to  regulate  it.  On the other hand, the
OAU, ECOWAS and CARICOM  and forty other countries have banned importation of
wastes.10 These divergent international responses led to the UNEP sponsored
negotiations on the global  convention mentioned above.

Further in 1988, the European  Parliament joined the African, and Caribbean
Parliamentary Association to support  a  ban on  international waste trade.11
In 1989, the 4th Lome Convention  included in its main areas of cooperation
on environmental protection, a comprehensive approach involving a ban on
moving toxic and radioactive wastes.12

However, as late as 1988, sixteen African countries were linked to toxic
dumping.  A number of individual  African states signed contracts to accept
industrial waste from Western  European  states  and the U.S.. For example,
Benin contracted to accept  industrial waste containing asbestos and cyanide.
At the same time, South  Africa accepted a shipment of New Jersey sludge
waste containing mercury.   On  the other hand,  Guinea-Bissau cancelled two
contracts that would have dumped  on  their territory 1/2 million tons of
industrial and pharmaceutical  waste  from Switzerland.

At the eleventh Session  of  the Caribbean Development and Cooperation
Committee (CDCC), the participating Governments requested that the Economic
Commission for Latin America (ECLA/CC)  present at its twelth session in 1989,
a report on the damage caused  to  the  region by the international trade in
hazardous waste.  The CDCC  resolution condemned these activities carried out
by enterprises to the detriment of the  ecological security of the region and
which adversely affect the  economic and social development of the countries
and the health of their  populations.13
10. For Instance, the Nigerian Government,  after  seizing an Italian
ship which had dumped toxic waste  in  Nigerian  territory in 1988,
broke off diplomatic relations with Italy,  and also  madated the death
penalty for those engaged in  subsequent  toxic  dumping.   See generally,
"Toxic Dumping Alarms Africa", TransAfrica  Forum,  Issue Brief,  Vol. 7.
No. 3, Winter 1988-89, p. 1,3.

H. See Wynne, note 1.  supra, p.  122.

12. For the Convention, see The ACP-EEC  Courier,  No. 120 March-April
1990.  pp. 12-19.  Arts.  4,6,14,16,  33-41.

13. Caribbean Conservation News, Vol. V.  No. 5, March 1989. p.2
                                     516

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POLLUTION PREVENTION  STRATEGIES

     The protection of  environmental  resources  in developing countries can
best be served by a total  ban  on  waste  exports  in the view of many
environmentalists.  The  reasons include:   damage to U.S.  foreign policy
interests from the issue of  toxic dumping;  crippling financial liabilities
as in the case of Union  Carbide at Bhopal  in India, and considering ozone
depletion and the greenhouse effect,  the  calls  for a halt to deforestation
in developing countries  seem hypocritical  and self-serving by countries
applying pressure, and,  which  are at  the  same time engaged in toxic waste
trade.

     Pollution prevention  strategies  have  demonstrated benefits in Europe
and the U.S.  As such,  the cooperation  between  government and industry
involves changes in government polcies, industry production methods and
manufacturing processes, as  well  as the organization of work.  Research and
development of low and non-waste  technologies,  and transfer from
industrialized countries to  developing  countries and indigenous technology
transfer from developing countries to developed countries, woul'd be more ±n
order to prevent hazards from  causing disease,  or injury to human health.
Because it is feasible  to  voluntarily reduce production of wastes in the
U.S. by current technologies and  by up  to  50 percent the next few years!4,
this approach would have major impact on  the "need" to export hazardous
wastes and products.

     Incentives for pollution  prevention  include legislation with provisions
for a total ban on export  of hazardous  waste to countries without the
capacity for handling these  wastes.   Considering U.S. expenditure of up to
$80 billion U.S. per year  on regulatory activities, and $300-500 billion for
cleaning up toxic waste  sites, countries  impacted by toxic dumping do not
have the resources or facilities  to "manage" waste imports by U.S.
standards, along with excessive debt, lack  of basic sanitation, and need for
potable water supplies.

     The integration of  pollution prevention strategies with traditional
primary public health prevention  would  combine  education and legislation
such as a ban on waste exports, and maximize source reduction.  Strategies
outlined below involve fundamental changes  in behaviour,  in the activities
of individuals, groups,  government and  industry.
14.J.S. Hirschorn, "Cutting Production  of  Hazardous  Waste,  "Technology
   Review, April 1988. p.54.
                                     517

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                      Pollution Prevention  Strategies
     Individuals:
Increase awareness of environmental hazards  and  health
effects of toxic wastes and products; understand full
costs of waste; obtain technical  information and
assistance on new technologies.
     Groups:
     Communities:
Information exchange; scientific and  technical
collaboration; promote policy changes at national
and i&ternationa,! levels-; technology development and
transfer*

Muncipal ordinances e.g. bans, restrictions  on  land  use;
integrated pest management; cooperative agreements on
pollution prevention shared technical assistance,
information resources.
     Government:   Legislation to ban waste exports  and  imports,  as
                   well as regulating toxic products  e.g.  pesticides,
                   integrated pest management  as  prority in agricultrual
                   policy;  low-input farming  to  also reduce chemical
                   fertilizer use; fund  technology development  and transfer.
     The resources for implementation of pollution  presention would be
provided by country governments, the United Nations  Environment  Program,  and
regional development banks.  The UNEP's  "Provisional  Notification Scheme
for Banned and Severely Restricted Chemicals", provides  voluntary guidelines
on notification of regulatory decisions and export  shipment  or efforts to
ban or severely restrict chemicals including pesticides.   The IDB is
creating a fund to mobilize resources for  environmental  projects in Latin
American and the Caribbean, that would finance preventive  and curative
measures.  Dr. Noel Brown, UNEP, has called for  the  establishment of an
Environmental Security Council to study environmental  problems prior to the
international conference in 1992.  These collective  measures  will enhance
pollution prevention in the 1990s.
                                     518

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CONCLUSION;

The most effective measures  for  dealing  with the international toxic waste
trade clearly involve a ban  on waste  exports,  requiring wastes to be
managed and disposed of by the producer  countries.

This position is advocated by environmentalists  who assert that some
existing conventions legitimize  the expanding  global waste trade. Under
Section 12a of the Toxic  Substances Control  Act  (TSCA) EPA can restrict
export of chemical substances if the  Administrator  finds "unreasonable"
risk of injury to health  within  the U.S.  or  the  U.S. environment.

Previously, President Carter issued an Executive Order at the end of his
term in 1981 restricting  export  of hazardous waste.  This would have
banned most exports of products  that  represent a significant threat to
human health, and safety  of  the  environment, if  exporting them would cause
clear and significant harm to American foreign policy interests.  That
Order was revoked by President Reagan shortly  after he took office.^

Full implementation of recognized pollution  prevention strategies as a
priority in the industrialized countries  would eliminate or at least
reduce the international  trade in toxic  waste.  The better approach is to
deal with the problem at  the source or sources of production, rather than
attempt to eliminate the  problem by an export  solution.  To shift
pollution elsewhere, at best delays the  fundamental changes necessary in
the organization of work, production  methods and technological innovation.
This export policy does not  resolve environmental and ecological problems
which ultimately have to  be  faced in  the  era of  the so-called "Global
Village".
15.  See note 55, Faith Halter,  "Regulating Information Exchange and
International Trade  in Pesticides  and  Other Toxic Substances to Meet
the Needs of Developing Countries",  Columbia Journal of Environmental
Law, Vol. 12.  No.  1. (reprint), p.  12.
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     INTEGRATED PERMITS AND MULTI-MEDIA POLLUTION PREVENTION

               by:  Mahesh K. Podar, Ph.D.
                    Office of Policy Analysis, PM-221
                    U.S. Environmental Protection Agency
                    Washington, D.C. 20460
ABSTRACT

     That we produce wastes is an inescapable fact of life.  How
we manage and dispose of these wastes is important, because it
affects the environment we live in.  Over the years, we have seen
the quantities of wastes generated continue to increase.  We have
also seen that to dispose of these wastes in an environmentally
safe manner is taking considerable resources.  Unless we reduce
the quantities of wastes we generate, we will devote more and
more resources to manage and dispose these wastes.

     It does then make sense to explore approaches and tools that
would reduce the quantities of wastes that are generated and
disposed.  Integrated permits is one such tool.  Briefly, an
integrated permit coordinates various media-specific requirements
for releases to air, water and land to minimize cross-media
transfers of pollutants.  Such a permit would be based on an
assessment of all releases from that plant.

     To test the feasibility of issuing an integrated permit and
to develop a broad methodology for conducting plant-wide
assessments,  EPA and Amoco have jointly initiated a project.
Under the project, we will take a wholistic look at the releases
from their refinery in Yorktown, Virginia, develop multi-media
pollution prevention and pollution control strategies for the
plant, rank these strategies using a number of criteria and
assess incentives and impediments to implementing these
strategies.  The methodologies developed in this case study will
be applicable at other refineries and other industries.
The author gratefully acknowledges the assistance of EPA/Amoco
Workgroup, including Howard Klee and Dale Ruhter as well as
Robert Greene of EPA in preparing this paper.

The views expressed here are the author's and should not be
construed as the position of the Environmental Protection Agency.
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     That we produce waste is an inescapable fact of life.  How
we manage and dispose of these wastes is important, because it
affects the environment we live in.  Over the years, we have seen
the quantities of wastes generated continue to increase.  We have
also seen that to dispose of these wastes in an environmentally
safe manner requires increasingly more care and more resources.
Unless we reduce the quantities of wastes we generate, we will
devote more and more resources to manage and dispose these
wastes.

     There is greater awareness that economic activity and
environmental protection are not mutually exclusive.  The simple
fact is that if less wastes are generated, less resources have to
be devoted to treatment prior to disposal.  Improved efficiency
of production processes can yield more product for the same units
of input, thus lowering costs of production.  However, new
technologies that can provide existing products while generating
less pollution are needed but may not be readily available for
all industries.  Developing such technologies and making them
available on a broader scale will require both resources and
time.

     In the mean time, such factors as greater public awareness
of the growing problem of waste, wider dissemination of the
production technologies that generate less waste, increasingly
higher costs of treating and disposing the wastes that are
generated, and the rising concerns over future liabilities
associated with improperly disposed wastes have spurred
activities to reduce the quantities of wastes that are generated.
These activities can be described and grouped into four broad
categories: (1) source reduction,  (2) recycle, (3) treatment, and
(4) safe disposal.  EPA has also recognized that further
improvements in environmental quality will be achieved by
following the above hierarchy of waste generation and management
—reduction in the quantities of wastes generated prior to
treatment and disposal.


HISTORY OF THE ENVIRONMENTAL LAWS

     The evolution of the environmental laws in the U.S. is well
documented.  In brief, the Environmental Protection Agency (EPA)
was created in the 1970s to implement environmental legislation
that Congress passed.  These laws were passed as the nation dealt
with one crisis at a time.  The Clean Water Act addresses the
problems of water pollution, Clean Air Act deals with air
pollution, Federal Insecticide Fungicide and Rodenticide Act
regulates the use of pesticides, Toxic Substances Control Act
controls chemical products, Safe Drinking Water Act protects
drinking water supplies, Resource Conservation and Recovery Act
                               521

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 (RCRA) deals with solid and hazardous wastes, and Superfund Act
 (CERCLA) deals with contamination from past hazardous wastes
disposal practices.

     The main focus of the three laws that address releases to
air, water and land has been command and control regulations that
rely on the end-of-pipe controls.  Regulations that implement the
requirements of the Clean Air Act regulate releases of
contaminants into air.  Regulations under the Clean Water Act
regulate discharges of contaminants into water.  Regulations
under RCRA ensure that hazardous wastes are properly managed when
they are disposed in a landfill.  By focusing on preventing the
contamination of specific media, these regulations largely
ignored the potential of transferring wastes from one media to
another.  Furthermore, we do not have sufficient data to assess
the magnitude of these inter-media shifts and the impact these
shifts may have on the environment.

     That, however, is changing too.  There is a growing
realization among regulators that the end-of-pipe focus is not
adequate.  The confluence of a number of factors is causing a
shift in thinking—it is no longer adequate to protect specific
media; we have to be concerned with the whole environment.  It is
in the best interest of the nation to reduce the quantities of
wastes we generate (improve efficiency of resources used and
lower production costs) which in turn will reduce the cost of
treatment and disposal.  Resources saved by having less wastes to
treat and dispose can be used for more productive uses elsewhere
in the economy.

     It is reasonable to ask—if source reduction and recycling
is such a good idea why have these not been implemented widely?
A number of factors can account for this seemingly lack of
interest in implementing the concept—focus on compliance with
media-specific requirements; and lack of readily available
technologies, their costs and payback period ( costs are
immediate but the payback period is long).  It is also possible
that treating end-of-pipe problems under strict compliance
schedules does not provide sufficient time (and resources may be
lacking too)  to track backwards in the production processes to
reduce pollution that is generated.

     On the other hand, such large corporations as 3M, Dow,
Chevron, Amoco Chemical and Monsanto embraced "pollution
prevention" some time ago and have been implementing source
reduction and recycling in their plants.  They have documented
successes in reducing the quantities of wastes generated and
saving money both from less resources used and from lower waste
treatment and disposal costs.  I should note that pollution
prevention has not been as easily achieved at smaller facilities
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because these facilities are constrained by limited resources.

     A number of tools can be used to implement pollution
prevention—reduce wastes generated rather than transferring them
from media to media.  One such tool is an integrated permit, also
known as a cross-media permit.  Briefly, an integrated permit
coordinates various media-specific requirements for the whole
facility to minimize cross-media transfers of pollutants.  A more
detailed definition is presented later in the paper.
INTEGRATED PERMITS

     The focal point in each of our media programs has centered
on permits and compliance with them.  EPA and state delegated
permitting programs are the key tools that are used to control
pollution across the country.  They form the critical link in the
implementation of environmental control mandated by national
legislation.

          The number of facilities that discharge wastes and the
volumes of wastes regulated under various permits is quite large.
For example:  The National Pollutant Discharge Elimination System
(NPDES) permit program governing industrial waste water
discharges regulates approximately 65,000 industrial and
municipal direct dischargers, 10,000 combined sewer overflows and
over 100,000 storm water discharges.  Approximately, 5,500
facilities subject to RCRA permitting managed 272 million metric
tons of hazardous waste in 1986.  The 1988 Toxics Release
Inventory data revealed that large manufacturing facilities
released 4.6 billion pounds of toxic chemicals to air, water and
land.  A large portion of these releases comply with legally
permitted limits set by facility-specific permits written under
the Clean Air Act, Clean Water Act, and the Solid Waste Disposal
Act  (RCRA).

     There are a large number of cases where compliance with a
media-specific requirement has resulted in increased releases to
other media.  For example:  Wet scrubbers used to comply with the
air pollution requirements generate waste water.  This waste
water must be treated prior to discharge.  In addition, sludge
generated in the waste water treatment system has to be disposed
in a landfill.  However, if the facility had complied by
installing a dry bag house, treatment would have generated only
sludge but not waste water, thus saving the cost of an additional
treatment step.

     Integrated permits could represent a huge potential for
institutionalizing pollution prevention and forcing it to happen
nationally.  The potential environmental gains are also enormous
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as pollution prevention conditions are written into permits to
reduce the amount of pollution generated.  In addition to the
inclusion of new permit conditions, the permitting processes can
be vehicles for education, stimulating development of new
technology and technology transfer, and for providing incentives
to industries and municipalities to conduct additional pollution
prevention activities.


Scope of the Examination

     Since neither government nor industry have the luxury to
stop what we are doing and design a new pollution prevention-
based permitting system, we must start by examining how to
leverage and fine tune the existing permitting systems.
Currently, the permit processes for air, water and waste function
independently and address different pollutants, time frames, and
performance criteria.  As such, they do not promote coordination
and tradeoffs between permits which might provide better
environmental results.  An integrated permit would coordinate
permitting processes of various media, and would include all
relevant media-specific requirements for the facility.  These
integrated permits may contain tradeoffs among media-specific
requirements that reduce overall pollution and would encourage
the reduction of pollution generation and subsequent release.

     The need for a studied approach for incorporating pollution
prevention into permitting arises from the complexity of the
permitting system and due to the potential for cross-media
transfers.  This approach, however, has to be flexible to account
for differences between industries and between plants within an
industry.  With both EPA regional offices and States issuing
permits  (sometimes to the same facility for the same program) to
literally thousands of facilities, and several types of permits
for a facility with different schedules, EPA will want to ensure
that it selects appropriate approaches for incorporating
pollution prevention into a facility's permit.

      EPA assessed the feasibility of issuing integrated permits
using information from Massachusetts and New Jersey.  We found
that the present permit system is designed to address
environmental threats in each media as they arise and are
quantified.  However, multi-media issues require a broader
perspective, but the media-specific data being collected does not
facilitate such a broad overview.  We did conclude that
integrated permits do represent a potentially effective way of
dealing with pollution prevention and other multi-media issues.
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CASE STUDY WITH AMOCO CORPORATION

     In November 1989, EPA and Amoco jointly initiated a project
to review pollution prevention alternatives at an industrial
facility.  Amoco offered its refinery at Yorktown, Virginia for
the case study.  The study will assess the feasibility of issuing
integrated permits as well as develop plant-wide strategies and
options for reducing pollution.  Specifically, we will (1)
inventory all current releases to the environment; (2) develop
possible multi-media pollution prevention, recycling and emission
reduction options; (3) assess relative costs, benefits and
impacts associated with different options; and (4) identify
present and potential barriers and incentives to implementing
these different pollution prevention options.

     The study will be conducted in two phases.  In Phase I,
under Amoco's lead, we will focus on data collection.
Specifically we will collect background information on the
refinery/ including process descriptions; existing permits for
air, water and solid wastes; and current treatment technologies.
We will also assemble information on the releases to the
environment, including air, surface water, solid waste and ground
water; population distribution around the plant; drinking water
sources; other industrial emissions sources and environmental
studies.  To establish a better relationship between releases to
the environment and their specific sources, Amoco will collect
additional data through sampling and monitoring.  This phase is
scheduled for completion by December 1990.

     In Phase II, we will jointly analyze the data we collected
in Phase I.  Specifically, we will develop multi-media/cross-
media pollution prevention options and strategies; define ranking
criteria for evaluating options, including such factors as
technical feasibility, exposure/impact assessment, mass
loading/release, cost/economic impact, resource utilization and
cross-media transfers; rank options and evaluate rankings;
identify the obstacles and incentives for implementing options,
including legislation, training, regulation,  worker safety,
uniqueness of the facility, timing of permits and data
availability.  We are also planning to have the project workplan
and the findings reviewed by an outside group of experts.  We
expect to complete Phase II by October 1991.


Goals of the Project

     The project has a number of goals.  We expect the case study
to specifically:

  o  Establish a decision-making framework which would address
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     how limited resources—time,  people,  and capital—can be
     focused effectively to achieve desired environmental
     results.

     -Develop a systematic, site-wide analysis of refinery
     emissions.

     -Define and rank potential options for waste reduction,
     recycling, and emission controls using a variety of ranking
     criteria.  These options will have a multi-media focus and
     would consider cross-media transfers as a factor.

     -Identify how this framework can be used by government and
     industry at other locations and facilities.

     Identify key factors—technical, legislative, regulatory and
     economic—which currently obstruct or promote pollution
     prevention.

     Evaluate current permits to identify how they discourage
     pollution prevention and develop possible alternative
     permitting approaches (including integrated permits) which
     support pollution prevention activities and discourage
     cross-media transfers.
Potential Benefits of the Pronect

     There are many potential benefits associated with this
project.  Some of these benefits are summarized below.

1.   This case study will allow us to take an integrated approach
     to a variety of environmental issues, reviewing a facility
     on a wholistic basis.  A number of piecemeal programs can be
     examined comprehensively, with the possible synergism that
     multiple view points and disciplines can provide.

2.   We will develop a methodology and data bases to assess and
     prioritize environmental issues and to facilitate long term
     capital expenditure planning on a plant-wide basis.  This is
     necessary because there are not enough resources to work on
     all the issues that arise simultaneously.  Evaluating the
     results of different strategies will allow us to focus on
     those issues first that provide the most benefits.

3.   We expect to find some emission sources for which there is
     no technically practical remedy at this time.  These will
     provide new research opportunities for both EPA and Amoco.
     One example that readily comes to mind is the effective
     elimination of oil-water emulsion which is major waste load
                               526

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     in waste water discharges but has no good solution at this
     time.

4.   We are hopeful that plant-wide assessments and data will
     identify opportunities for environmental improvements beyond
     what has been achieved under the current media-specific
     regulatory system.

5.   Integrated permits would provide opportunities for
     coordinating media-specific pollution control requirements
     and thus minimize cross-media transfers.

6.   The findings of the case study will provide information that
     could prove useful for future legislative initiatives.

     To summarize, the Amoco case study offers a unique
opportunity to take a careful look at a refinery in a wholistic
manner to identify specific emission sources, their impacts, and
evaluate possible multi-media reduction alternatives that
minimize cross-media transfers.  In addition, the case study will
produce a methodology that will have broader application and use
in future pollution control efforts.
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            POLLUTION PREVENTION IN THE 21ST CENTURY:
                       LESSONS FROM GENEVA

             by:  Arthur H.  Purcell
                 Resource Policy Institute
                 1745 Selby Avenue, #11
                 Los Angeles,  CA  90024
     The international community is in the process of developing
a multiplicity of pollution prevention policies and strategies.
In the past year a number of major global forums have helped
shape the nature of these efforts.  These have included "Waste
Minimization and Clean Technology:  Moving Toward the 21st
Century," held in Geneva; the Fourth International Conference on
Environmental Future (Budapest); and "Environment-Pollution-
Development11 (Rabat).   These forums have identified certain
commonalities in pollution prevention technology and management,
as well as some evident trends in policy development.  Prominent
among these is the evolution of pollution prevention efforts into
essentially three economic levels:  Developed, Emerging, and
Developing.

     A variety of strategies—with widely differing levels of
government/private sector interactions and transnational
cooperation—characterize pollution prevention efforts globally.

     An analysis of international efforts in the field indicates
five basic elements common to viable pollution prevention program
planning for the 90s and beyond.

     Events of the past year and a half make it clear that the
world is moving from a mode of reaction to one of prevention.   In
foreign policy and international relations, large militaries are
giving way to sizable diplomacy, aid, and assistance programs.
In economic competitiveness it has become increasingly evident
that enhanced productivity is a far more effective tool than is a
system of protective tariffs.  Global energy policy has moved
toward emphasizing increased fuel efficiency as a better way to
solve energy problems than trying to keep energy prices at
artificially low prices.  And in efforts to upgrade and protect
the biosphere, the preventive, front-end approach is now viewed
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as a much better long-range strategy than are remediation,
treatment, and end-of-pipe control efforts.

     Few people disagree on the inherent benefits of preventing
pollution.  The adage that reminds us it is better to teach
someone to fish than to give that person a supply of fish each
day is one that virtually everyone would like to apply to
environmental management:  It is better to avoid having to solve
the problems of environmental pollution instead of, every day,
having to try to manage these problems.

     The major question asked in every corner of the globe,
however, is:  Will mandating pollution prevention systems slow
economic activity?  Will pollution prevention cost more than it
is worth?

     Experience is showing that, in fact, all economies will
benefit more by practicing new prevention techniques than by
practicing business as usual in environmental management.
Pollution prevention may actually save considerable amounts of
money and increase productivity—whether on the farm or in
industry.


DEFINING POLLUTION PREVENTION

     What is pollution prevention?  Pollution prevention can be
defined as any change in an economic activity—whether
technological or management-based—that leads to the generation
of less pollutants per unit of production than generated before
the change was made.

     Pollution prevention made its international debut a decade
and a half ago.  But it was not called pollution prevention.  The
term then was non-waste technology.  The first United Nations
Economic Commission for Europe Seminar on "Principles and
Creation of Non-Waste Technology" (NWT-I), held in Paris in 1976,
laid out strategies for the development of a systems approach to
manufacturing in which resource inputs and pollutant outputs
would be minimized at each step of production.

     In the ensuing years since NWT-I several terms have been
coined to describe front-end approaches to environmental
management.  These include clean technology. low and non-waste
technology, waste reduction, source reduction, waste
minimization, and pollution prevention.  Pollution prevention
appears to be the term emerging in the 1990s to connote efforts
to prevent the generation of environmental degradation.

     At that Paris conference was a gentleman named Joseph Ling
from the 3M Company, a manufacturer with facilities in many
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countries.  Dr. Ling talked about a new program he was starting
at that time called "Pollution Prevention Pays," or 3P.  Few of
us in the conference room had much of an idea of what he was
talking about.  But we soon found out.  By 1988, the 3P program
had saved 3M Company over $800 million in worldwide operations,
and prevented the contamination of billions of gallons of water
per year.

     The 3P program has been based on technological and
management advances that a) reduced environmental emissions and
b) resulted in production costs lower than those associated with
the previous more polluting method.  It has clearly demonstrated
that through careful application of systems principles,
environmental protection and economic advances can be compatible.

     It has taken the nations of the world a long time,
generally, to work into the pollution prevention mode.  While the
UN meeting set out principles in 1976, it was not, for example,
until 1988 that the US Environmental Protection Agency
established its Pollution Prevention office, and it was not until
a few months ago that the Agency upgraded this office to a status
where pollution prevention will be substantively interjected into
environmental policy decisionmaking.

     The global pollution prevention pace is, however,
quickening, and the well-attended international forums taking
place in recent months attest to this.  The recently concluded
International Conference on Environmental Future, e.g., passed a
"Budapest Imperative" calling for accelerated efforts by
government to curtail waste and prevent it at the source.
"Environment-Development-Pollution," a unique multi-nation
colloquium spearheaded by King Hassan II of Morocco, featured
pollution prevention as an environmental policy management
strategy.  The Declaration of Chellah, emanating from this
meeting, urged accelerated prevention efforts.


WMCT-21

     In Geneva, in mid-1989, a conference on "Waste Minimization
and Clean Technology:  Moving Toward the 21st Century"  (WMCT-21)
brought together representatives of 25 nations to discuss over a
period of several days philosophies, strategies, and specifics of
pollution prevention around the world.  From WMCT-21 it was
evident that a wide spectrum of individuals and institutions now
embrace the prevention concept.  The challenge articulated in
Geneva was to shift out of first gear in international waste
minimization and pollution prevention efforts and to match
resources—human, technological, and economic—with specific
needs.
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     This resource matching will require a new generation of
efforts.  As Geneva clearly underscored, the world of
minimization and prevention is very large:  from the farmer in a
developing South Asia nation building a biomass recovery system
for animal and crop wastes; to a hamlet in Appalachia trying to
reduce costly municipal waste; to a tannery or plating shop in
Europe embarking on a wastewater cleansing program; to a large
North American industrial complex putting together a closed loop,
zero-discharge system.

     WMCT-21 defined three major categories of waste minimization
and pollution prevention needs and application potentials in
global economies:  Developing, Mature, and Advanced economies and
economic sectors.

     The scales of human, technological, and economic resource
needed to address the next century's waste minimization needs in
these categories will vary considerably.  In the first category,
basic technology will have to be meshed with often untrained
personnel and very scare capital to form a pollution prevention
matrix in developing economies and economic sectors.

     The next level up for implementing waste minimization and
pollution prevention is in mature economies and economic sectors;
here, capital for waste minimization and pollution prevention
will be in tight supply and technological challenge will be
greater, but better trained personnel will be available to
address prevention and minimization problems.

     In the third category lie advanced economies and economic
sectors, where satisfying the pollution prevention requirements
of rapidly changing technologies may well absorb the more free
flowing available capital, but where a relatively abundant supply
of trained specialists will be available to provide continuous
innovation and leadership in the field.


EMERGING ECONOMIES

     A very dynamic fourth category has come forward since WMCT-
21.  This is the set of emerging economies resulting from new
political arrangements and alliances.  Emerging economies are
those whose rapid economic growth and sociopolitical evolutions
are leading to novel efforts to integrate environmental planning
and management into all facets of their economic activities.
Democratization in Eastern Europe and the Soviet Union, the
addition of countries to the European Community, and efforts of
non-European countries to develop enviroeconomic ties with
European states have all led to the emerging economy phenomenon.
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     Emerging economies are neither fully developed nor
undeveloped.  Their delineations of government and private sector
activities are varied, and changing.  They consequently will
require special attention in government-private sector and
transnational cooperation efforts in pollution prevention.
FORMS OF POLLUTION PREVENTION

     WMCT-21 and other international efforts have amply
documented that pollution prevention takes many forms.  And this
is an essential consideration for future prevention programs in
all economies.  Pollution prevention must be defined broadly in
terms of total environmental and economic impacts,  substituting
a plentiful, locally available material for a scarcer one that
has to be imported, e.g., can be a pollution prevention measure,
as can be reducing waterborne emissions in a production process.
Effective land use planning is at least as much of a pollution
prevention strategy as is recycling of waste.

     Analysis of WMCT-21 and related proceedings indicates that
five basic elements are essential for development and execution
of national pollution prevention programs.  These are:

     o    Identifying Unique Regional and National Resources

     o    Defining Unique Environmental Constraints

     o    Delineating Particular Needs of Major Economic Sectors

     o    Calculating Pollution Prevention Payback Periods in
          Defined Sectors

     o    Embarking on Vigorous Pollution Prevention Training,
          Information Transfer, and Technology Transfer Programs.


IDENTIFICATION OF UNIQUE REGIONAL AND NATIONAL RESOURCES

     The success of pollution prevention depends on the
effectiveness of managing resources.  And each region and economy
has unique resources.  Whether energy, materials, land, or labor,
these resources must be carefully inventoried to determine their
optimal mix.  Once this inventory is made, then it is possible to
determine the best pollution prevention strategies.  Substituting
locally available materials for imported ones may be an option.
Matching available labor to recycling operations is another.
Similarly, development of locally available renewable energy
resources—e.g., sun and wind—to supplant nonrenewables presents
another set of pollution prevention options.
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DEFINING UNIQUE ENVIRONMENTAL CONSTRAINTS

     Effective pollution prevention depends on fully
understanding the relationship of pollutants to their
environment.  And every nation and region has a number of unique
environmental constraints.  In some areas, e.g., land disposal of
organic wastes could actually provide benefits through creation
of valuable compost, while in others with high water tables and
high rainfall land disposal should be avoided at all costs.  In
urban areas greater recycling and waste exchange opportunities
abound than in rural areas.  Etc.
DELINEATING PARTICULAR NEEDS OF ECONOMIC SECTORS

     Pollution prevention in an economic sector cannot be
successful unless there is a comprehensive understanding of the
technology and management systems comprising that sector.  The
theory of pollution prevention can run contrary to practices
necessary to implement it.  It is therefore necessary to examine
all economic activities in terms of their environmental
characteristics and the impact of pollution prevention on them.


CALCULATING POLLUTION PREVENTION PAYBACK PERIODS IN DEFINED
SECTORS

     This is the key to planning pollution prevention.
Traditional thinking has dictated that the period of time
(payback period) needed to recoup investments in pollution
control and prevention is very long—much too long to warrant
serious consideration, particularly in a developing economy.
Recent experience indicates, however, that this is not the case.
When a full lifecvcle cost accounting is made, there is a high
probability that the payback period may, in fact, be suprisingly
short.

     Full lifecycle cost accounting includes all costs—short-
term and long-term—associated with an economic activity.  The
costs in medical care, lost productivity, and shortened life-
span of drinking water polluted by hazardous waste are as much
parts of lifecycle costs as is the price of a piece of machinery
or a change in process design that will prevent such pollution.


EMBARKING ON VIGOROUS POLLUTION PREVENTION TRAINING, INFORMATION
TRANSFER, AND TECHNOLOGY TRANSFER PROGRAMS

     Prevention of pollution and minimizing waste will only be as
effective as the human beings who have been trained to plan,
design,  implement, and monitor pollution prevention systems.
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Considerable information now exists on how to put together
pollution prevention programs—on the farm and in the factory.
The challenge is to develop meaningful programs that will
transfer this information, in the form of education and training
to the individuals who will be needing it:  managers, executives,
and laborers.  The importance of education and training in this
field cannot be underestimated.

     The success in efficiently and effectively transferring
information and technology, within and between economic sectors,
that can enhance pollution prevention efforts will ultimately
determine the success of future pollution prevention programs.
As WMCT-21 and other forums have made clear, innovative transfer
of waste minimization technology will likely be much more
important to 21st century efforts to trim global wastes and
eliminate future pollution than will be transfer of innovative
technologies.  Similarly, development of better forms of
information transfer, vis a vis developing more information, will
be central to these efforts.
LESSONS FROM GENEVA

     If there is any one lesson from Geneva—or Budapest or Rabat
or Washington or sites of other recent major pollution prevention
symposia—it is that pollution prevention programs in the 21st
century will rely on the successful cooperation and integration
of many perspectives, institutions, disciplines, and economies.
They will have many common elements, but their particular form
will depend on a number of variables unique to the geographic and
economic issues they are addressing.

     As we approach the 21st century, pollution prevention will
move from an innovative concept to a standard approach in
resource and environmental management.  As this evolution occurs
it will be important to continually re-examine the lessons of
Geneva to determine where updating will be needed to speed up the
process.
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                     PROTOTYPE  EVALUATION  INITIATIVES  IN A
              NEW JERSEY VEHICLE MAINTENANCE AND REPAIR FACILITY
                                Paul M. Randall
                               Chemical Engineer
                     U.S. Environmental Protection Agency
                     Pollution Prevention Research Branch
                            Cincinnati, Ohio   45268
ABSTRACT

      In September 1989, the United States Environmental Protection
Agency(USEPA) and the New Jersey Department of Environmental Protection(NJDEP)
entered into a two(2) year agreement to evaluate pollution prevention
prototype technologies in the vehicle maintenance and repair industry.
Through a contractor, New Jersey Institute of Technology(NJIT), and in
cooperation with the New Jersey Department of Transportation(NJDOT)( the host
facility for this study), at least five(5) target technologies have been
identified for further evaluation.  Each of these technical initiatives will
require different evaluations and different types of measurements.  The
discussion in this paper describes the  approach to technical evaluation of
these technologies with status and preliminary results.

      This paper has been reviewed in accordance with the U.S. Environmental
Protection Agency's peer and administrative review policies and approved for
presentation and publication.  Mention of trade names or commercial products
does not constitute endorsement or recommendation for use.
INTRODUCTION

      In 1976, Congress passed the Resource Conservation and Recovery
Act(RCRA) thus directing the USEPA to develop and implement a program to
protect human health and the environment from improper hazardous waste
management practices.  The USEPA first focused on large companies which
generate the largest portion of hazardous waste.  Small businesses producing
less than 1000 kilograms of hazardous waste per month, known as small quantity
generators(SQGs) were exempt from most of these hazardous waste regulations.
In 1984, the Hazardous Solid Waste Amendments(HSWAs) to RCRA were signed into
law and this established new requirements for SQGs( businesses that generate
at least 100 kilograms but less than 1000 kilograms of hazardous waste per
month).  EPA issued final regulations for these 100 to 1000 kg/mo generators
in March 1986 with most requirements effective in September 1986.

      In coming years, SQGs may be required to reduce pollutants even further.
Currently, Congress is proposing Clean-air legislation that may require
smaller industrial sources such as auto body shops to curb chemical emissions.
To reduce these emissions, SQG's are exploring new products and processes that
are both clean and profitable.  Close examination of products and processes
are uncovering many opportunities to reduce emissions, to reduce skyrocketing
costs of waste disposal and to reduce the liabilities associated with improper


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disposal.
      A two year survey by the USEPA shows that the vehicle maintenance and
repair industry leads in numbers of generators( 82,530 of 175,000 ) and
highest in quantity of total waste produced (351,500 tons / year) for SQGs.
SQGs produce less than one-half of one percent of the hazardous waste produced
nationally, however, the sheer number of SQGs pose a threat to human health
and the environment. SQGs are discovering that pollution prevention is good
business. Recycling, material substitutions, good housekeeping, and
replacement of outdated equipment are all sound business decisions that help
reduce quantities of hazardous and non-hazardous wastes.  In this effort, the
USEPA Pollution Prevention Research Branch located in Cincinnati, Ohio has
been encouraging new designs, new products, new methods of reducing wastes at
the source or through recycling.

      Furthermore, the vehicle maintenance and repair industry uses products
that may be hazardous or non-hazardous materials.  Sometimes, the wastes
generated may also be hazardous.  For example, mechanics may use products such
as rust removers containing strong acids or alkaline solutions, carburetor
cleaners containing combustible liquids, used rags containing flammable
liquids, paints with flammable solvents or thinners, or change coolants, lube
oils, or batteries.  For this industry, the USEPA has compiled a list of
typical operations of processes which use products that may contain hazardous
materials and which probably generate hazardous waste. They are shown in Table
1.

      In New Jersey, over 15,000 businesses perform vehicle maintenance and
repair functions with environmental problems such as ethylene glycol
discharges, VOC and halogenated solvent emissions, spent waste
oils/lubricants, freon emissions, oil based lacquers, other paint wastes, and
spent acids and caustics. This project between the EPA and the state of New
Jersey will attempt to test and evaluate in a typical work place environment
examples of prototype technologies which have potential for reduction of
wastes at the source or for pollution prevention.  It will determine if the
technology has a positive effect on reducing wastes and its cost
effectiveness.

      The  NJDOT facility which will be the site of this project houses many
of the Department's functions including administrative headquarters, sign
making,  signal installation and repair, roadway maintenance, and related
activities. The specific area within the complex which will be the focus of
this project is the vehicle maintenance and repair facility.  This facility
has responsibility for keeping in effective operating condition a fleet of
several thousand cars, trucks, buses, and motorized highway and roadway
maintenance equipment.

      The first phase of the evaluation will investigate engine antifreeze
recycling and reuse, and motor vehicle air conditioning refrigerant recovery
and reuse.  Other technology evaluations will follow and are discussed in this
paper. A base line evaluation of the current waste management techniques, raw
materials, and types and volumes of waste generated at the NJDOT is in
progress and will be compared to applying equipment, material substitutions,
and other techniques to reduce wastes. This paper describes the overall plan
to evaluate these technologies.


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                               TABLE 1
 TYPICAL VEHICLE MAINTENANCE/REPAIR OPERATIONS
 WITH MATERIALS USED AND WASTE GENERATED
   PROCESS
   OPERATIONS
      TYPICAL
  MATERIALS USED
           WASTES
        GENERATED
Solution replacement
OH and grease removal
Engine, parts and
equipment cleaning
Rust removal

Paint preparations

Painting

Spray booth, spray guns,
and brush cleaning

Paint removal


Used lead acid batteries
 Antifreeze solution, CFC(R-12),
 petroleum oil

 Degreasers(gunk), carburetor
 cleaners, engine cleaners,
 solvents, varsol, acids/alkalies

 Degreasers(gunk), carburetor
 cleaners, engine cleaners,
 solvents, acids/alkalies,
 cleaning fluids

 naval Jelly, strong acids,
 strong alkalies

 paint thlnners, enamel reducers,
 white spirits

 enamels, lacquers, epoxys,
 alkyds, acrylics, primers
paint thlnners, enamel
reducers, solvents, etc

solvents, paint thlnners,
enamel reducers, white spirits

 car, truck, boat,
 motorcycle and other vehicle
 batteries
Hazardous liquid, ozone depleting,
combustible liquid

Ignltable wastes, spent solvents,
combustible solids, waste
acid/alkaline solutions

Ignltable wastes, spent solvents,
combustible solids, waste
acld/alk solutions
waste acids, waste alkalies


spent solvents, Ignltable wastes,
paint wastes with heavy metals

Ignltable paint wastes, spent
solvents, heavy metals
Ignltable paint wastes, heavy
metals, spent solvents

Ignltable paint wastes, heavy
spent solvents

used lead acid batteries, strong
acid/alkalies solutions
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POLLUTION PREVENTION PROTOTYPE TECHNOLOGIES

Antifreeze Recycling

      Used antifreeze, commonly utilized in coolant/heating systems may be
improperly disposed of into community sewage systems and waterways  during
regular service maintenance of a vehicle.  This disposal negatively effects
water quality and contributes to the contamination of waterways both of the
freshwater and marine environment with organic and inorganic(heavy metals such
as lead, arsenic, or zinc) chemical wastes.  The idea of recycling antifreeze
after appropriate physical and chemical treatment is becoming an attractive
alternative, especially in light of USEPA and various state and environmental
agencies imposing fines for improper discharges of used antifreeze to the
environment.

      The key objective in this task involves the reduction of the quantity of
waste generated during the flushing of radiator cooling systems in motor
vehicles.  The premise is that the aqueous ethylene glycol which is removed
from engines does not have to be discarded, rather, it can be regenerated by
filtration and addition of specialty chemicals to impart corrosion resistance
and then recycled back to an engine.

      The system to be evaluated at the NJDOT garage is available through FPPF
CHEMICAL COMPANY.  Conceptually, the system is relatively simple. It consists
of a 100 gallon polyethylene tank, a self-priming pump, a series of three
filters, and an additive tank.  The process involves removing the coolant from
the vehicle into the tank, recirculating it through the filter system to
remove suspended particles, checking the pH of the solution and mixing in a
chemical additive if the pH is too low, and adding additional ethylene glycol
if the freezing point of the solution as estimated by refractometry is too
high.  Following these steps, the fluid  can be returned to the vehicle.

      This relatively simple concept presents some interesting chemical
questions.  There are some industry standards for acceptable performance by
antifreeze products.  The manufacturer claims that the finished product after
filtration and chemical addition meets or exceeds the ASTM-3306 standard for
this class of material.  We will evaluate claims such as this.  Also there are
some other determinations which should be made to understand more completely
the long term effect of this process.  For example, the filtration systems is
for the purpose of removing the suspended particles.  Presumably, these
particles are due to degradation or corrosion of the materials of construction
of the cooling system.  While the filtering system can remove larger
particles, smaller ones will be left in the coolant.   In fact, the
manufacturer utilizes an additive package to be a dispersant to prevent
cooling system deposits.  Appropriate tests will be done to determine the
effectiveness of the system in these areas.    Moreover, we will examine
whether there is a limit to the number of times that the coolant can be
recycled before there is a sufficient buildup of small particulates that
damage the cooling system.

      Similarly, we will investigate the necessity of adjustment of pH.  It
appears that the degradation of antifreeze produces various acids which lower
the pH of the coolant towards a pH zone that is corrosive to the metallurgy of

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the engine.  This suggests that the conditions in the cooling system are
conducive to the oxidation of the ethylene glycol to some organic acid or
acids.  The pH can be adjusted by organic salts in the coolant which could
either continue to undergo structural change or begin to deposit within the
cooling system.  Tests will be performed to investigate the increase of
organic impurities with the objective of determining if there can be an
unlimited cycle of recycling for this type of coolant fluid or if there is a
limit to the number of times the material can be reused.  Similar concerns can
arise from the other chemical additives added to the coolant.

      Our testing of this technology will evaluate the following issues:

o     Determination of the degree of reduction in the quantity of ethylene
      glycol discarded compared with the usual practice.

o     Determination of the relative cost of this technology compared with
      current practice.

o     Determination at least qualitatively of the contaminants which are
      contained in the coolant removed from the vehicle prior to
      reconditioning.

o     Any contaminants that may adversely effect the long term operation of
      the engine need to be quantified, similarly after reconditioning to
      insure that contaminate level is at acceptable levels.

o     Determination of the relative economics of this technology as compared
      with current practice.
Refrigerant Recovery and Recycling

      The pollution prevention goal of this technology involves the prevention
of the escape into the atmosphere of air conditioning refrigerants such as
Freon during the repair and maintenance of motor vehicles.  During current
operations, much of the refrigerant typically is released into the air while
repairs are made to the system.  This technological approach involves venting
the refrigerant into a holding tank which also incorporates a recovery
process.  During the recovery process, refrigerant is drawn through a heat
exchange/oil separator.  There, all oils and other condensables are removed
from the refrigerant prior to its passing into the compressor and back through
the heat exchanger where it is condensed into a liquid state for storage.  The
regenerated refrigerant can then be reintroduced into the cooling system when
appropriate repairs or maintenance has been finished.

      There are technical considerations when evaluating this technology for
its pollution prevention potential.  Areas of concern include:

o     the capability of capturing all of the refrigerant and of returning all
      of it back to the vehicle,

o     the capability of the recovery/recycle system to produce refrigerant
      which meets all of the appropriate standards of the industry,
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o     the recovery and handling of the waste streams of particulates, oil, and
      water produced as a result of the recovery/recycling process.

o     Reliability, system maintenance, and operating costs need to be
      determined.

      In this situation, there has been a industry supported evaluation of the
technology for the purpose of providing certification that the reconditioned
refrigerant will meet the air conditioning industry standards and will not
damage the vehicle equipment.  At least one of the possible commercial units
for use in this proposed evaluation has been so certified.  In our evaluation,
consideration of the procedures carried out in this industry test could
minimize any duplication of work.

      The potential for reduction of atmospheric emissions of CFC 12 using a
capture and recycling technology depends upon several concerns.  One potential
for atmospheric loss of the material lies in the technique used by the
mechanic for checking and repairing of the air conditioning system.  Reports
indicate that in some cases, mechanics may pressurize the system with
refrigerant in order to locate a leak, release the refrigerant to the
atmosphere, repair the leak, and then repressurize the system.  Careful
observations and recording of CFC use during maintenance and repair will be
required in order to determine this potential.

      The economics study will involve some careful observation of the
individual techniques and processes used by the mechanic.  A side-by-side type
comparison of the standard A/C repair procedure and the procedure modified by
use of the recovery/recycling equipment will be made.  The actual time of the
mechanic in carrying out the steps involving the release, transfer, recycling,
and refilling of refrigerant in both cases will be recorded.  Also, carefully
weighing and recording of refrigerant quantities used in each procedure
whether it is virgin CFC or recycled material will be done.  The costs of any
maintenance or replacement part must also be tracked, estimated, and recorded.

Improved Sprav Painting Technology

      Within the NJDOT maintenance operation is a painting capability.  The
painting section has responsibility for applying coatings to various kinds of
surfaces, ranging from wooden objects to large motor vehicles.  From the
perspective of pollution prevention, the greater potential for positive
benefit would be in the area of spray painting of vehicles.  Goals are the
reduction of the total amount of paint sprayed resulting in reduced volatile
organic emissions, less overspray which needs to be collected and treated as
waste, and reduced load on air handling equipment which also results in a
waste stream.

      The approach proposed in this area is a redesigned spray system which
allows application of a paint stream under higher pressure.  A manufacturer
has expressed interest in this evaluation.  The manufacturer indicates that
with their system you can get the necessary coverage using less paint and that
the painter has better control over the work.

      This type of evaluation could be very difficult, because the decision
the painter makes about when enough paint has been sprayed onto a surface to


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provide sufficient coverage is a very subjective decision.  The painter must
decide that  it  "looks right."  Therefore, some side-by-side comparisons should
be done.   In this experimental set-up, test surfaces need to be provided and
the painter  must use both the existing technology and the improved spray
technology to coat the  surfaces until the coating is visually adequate.  At
that time, comparison of the amount of paint applied using both systems should
be made.   Similarly some objective comparison of the coating properties should
be made of the  surfaces covered with both technologies.  This should measure
at least the average coating thickness and the uniformity of the coating over
the entire surface.  There should be a comparison to an industry standard.

      This study proposes investigating other issues that include:  the ease
of clean-up  of  the equipment, particularly whether or not more solvent needs
to be used to clean the paint spray equipment as compared to the existing
system.  Also,  it should determine whether or not existing system represents
the current  industry standard, and if not then the comparison needs to be done
using the  industry standard equipment.

      Using  the improved spray technology, it may also be possible to use
coatings with a higher  solids content.  High solids solvent based coatings are
slowly replacing regular solvent based coatings.  The major advantage is the
ability to comply with  the more stringent VOC limitations while using the same
paint, equipment, and application techniques.  However, high solids coatings
usually do not  atomize  well in conventional air spray equipment due to the
higher viscosity and thus higher surface tensions.  If this technology can be
utilized,  then  the VOC  released to the air will be reduced and this
evaluation,  if  performed, should be done in cooperation with a coating
manufacturer.

      Another approach  should also be investigated. Union Carbide has begun to
market a technology under the tradename UNICARB.  This technology enables VOC
emissions  to be reduced 30 to 70 percent in applying high quality coatings by
using supercritical carbon dioxide to replace the volatile organic solvent
fraction that is used to obtain atomization viscosity.  This enables
applicators  to  reduce the VOC emissions while continuing to use high molecular
weight polymer  systems.  Supercritical carbon dioxide produces vigorous
atomization  that remedies the deficiencies of the airless spray process so
that high  quality coatings can be applied.  The technology claims to be
applicable to most spray applied coatings and demonstrated on acrylics,
polyesters,  alkyds, and commercial paints and lacquers in clear,pigmented and
metallic systems.  Because the carbon dioxide came initially from the
atmosphere,  there would be no net increase in the atmospheric carbon dioxide
level.  This evaluation could be a significant evaluation which may go beyond
the use of coating techniques in motor vehicle maintenance and repair
situations.  If evaluated, this process should be examined in regard to
coating ability as a function of quantity of coating applied and volume of
organic volatiles released.

Approaches to parts cleaning using aqueous based cleaners and ultrasonic baths

      The objective of this pollution prevention technology would be to reduce
the quantity of organic solvents used to clean vehicle parts as part of the
repair and maintenance activity or to make possible the use of some organic
solvent which has reduced toxicity compared to the currently used material.


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Even though the facility is using SAFETY-KLEEN cleaning technology, currently
there is some organic materials evaporating into the atmosphere from the
cleaning containers and as "drag out" with the parts.  Therefore, alternative
cleaning techniques will have a favorable pollution prevention impact.

      The use of ultrasonics can improve the cleaning ability of most solvents
by providing a pathway to transmit energy directly to the interface between
the surface to be cleaned and the contaminant on the surface.  This energy
transfer is accomplished by a process called cavitation.  Ultrasound waves are
transmitted through a medium as an alternating series of high density bands
and low density bands.  Within the low density bands, localized areas of
vacuum are formed.  These areas collapse within themselves,  or implode, when
compression increased immediately after the low density band impinges upon a
hard surface.  This implosion stage releases energy which can serve the
purpose, in this application, of "scrubbing" the surface.

      Aqueous based cleaners and ultrasonic bath equipment will be supplied by
vendors. Ultrasonic baths may be applied in combination with vapor degreasing
apparatus.  This approach could be useful for heavily greased parts, among
other applications.  The aqueous approach is claimed to be most useful for
plastics, optics, metal parts, wire, and radiators, among other things.  The
ultrasonic vapor degreaser approach is claimed to be most useful for
applications such as ball and roller bearings, electronic assemblies,
mechanical assemblies, and machined parts.

      For this proposed evaluation, effectiveness, reliability and relative
economics will be compared to current practice.  Any additional waste streams
produced from the ultrasonic approach should be evaluated.  Presumably there
could be contaminated liquids, either water based or solvent based.  Solvent
based materials can be recycled with the equivalency of still bottoms.  These
materials may be recycled offsite by the solvent recovery service provided by
SAFETY-KLEEN.

      As in the case of the spray painting evaluation, there is a degree of
subjectiveness in this type of evaluation.  Generally, in this type of
environment, items are cleaned until they look clean or until the operator
feels they have been cleaned long enough.  To carry out an appropriate
evaluation, it will be necessary to develop a standard "dirty" item and then
clean it by current technology and all of those to be evaluated.  There must
also be determined a measurement for "cleanliness" of the item which will
provide an indication of the degree of cleaning.  The situation becomes
complicated when different types of items are cleaned in a given industrial
situation.  For this NJDOT facility, it may be necessary to determine what
parts are most often cleaned and then to identify industry or accepted
standards for cleanliness.  If none exist, some will need to be devised.

      Because part of the potential benefit of this cleaning approach is the
reduction of the amount of emissions of volatile organic compounds from
cleaning tanks, it will be necessary to take air samples in the vicinity of
the operations and to determine the levels of the cleaning solvent in the air.
If there is also a possibility of risk reduction by use of a less toxic
solvent, then some calculations of relative risk of the two approaches, taking
into consideration exposure time, toxicity levels, and exposure levels. The
plan to evaluate this technology could be particularly complicated.


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Oil Life Extension by laboratory analysis and filtration technology

      The goal is to reduce the volume of waste motor oil produced as a result
of vehicle maintenance operations.  This goal is achieved, in theory, by
conducting an oil testing program that establishes the proper oil drain
interval.  This prevents premature oil changes or increased wear caused by
over-extended drain intervals.  Oil analysis can provide an early warning of
diagnosis of problems before large scale damage occurs.  There are several
companies that supply this service.

      Moreover, this approach may be combined with another operational
approach, that is evaluating the effectiveness of bypass filters ( sometimes
referred to as Dual Filtration) .  This bypass filter may be installed on an
engine in combination with performing regular lab tests to measure the
condition of the oil over time and may further lengthen the time necessary
between oil changes.

      Standard oil analysis includes:

      o     analysis of all significant wear metals sometimes up to seventeen
            elements by spectrography

      o     viscosity with SAE weight and comparison to new oil

      o     an infrared scan for determination of soot, additive depletion and
            contaminants,

      o      water contamination, glycol contamination

      o     TEN(total base number) .

      Loss of alkalinity, TEN, is due to the formation of acids from sulfur
blow-by in the combustion process.  When sulfur particles combine with
moisture in the crankcase oil, acid is formed which in turn reduces the TBN.
Bypass filter manufacturers claim that water is absorbed by these filters and
limits the acid buildup in the engine oil.  This should be verified in the
evaluation.

      The question arises whether installation of bypass filters and extended
drain intervals will affect the engine warranty.  This is a concern and
specific acknowledgement will need to be received by engine manufacturers that
add-on devices such as bypass filters will not affect warranties.

      Also, there should be  an independent confirmation that the properties
selected by the company as indicative of properly performing oil are valid.
Literature search should be done from independent sources to confirm this
approach.  The bypass filtration system could be evaluated independently from
the oil analysis approach such as the effectiveness of the system to remove
particulates and other contaminants from the oil. For a vehicle maintenance
operation cleanup of other fluids such as transmission fluid or brake fluid
might be considered, if practical.

      Also, ideally, in an experimental situation,  the study should be run
long enough with enough vehicles involved to determine whether statistically


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significant reduction in waste oil generation is achievable.  This may require
a longer study than is practicable under this program.

Future Plans

      The proposed techniques and technologies under this program appear
promising for evaluation and the contractor, NJIT, is preparing a more
detailed work plan to evaluate two approaches first, that is, anti-freeze
recycling and the A/C refrigerant recovery and recycle methods.  NJIT is close
to completing the draft plan for approval by the EPA.

      The spray painting technology will probably require a much different set
of evaluation procedures depending on the direction that we select.  It will
be necessary to define carefully the scope of the project.  Different
procedures will be required if the focus is only redesigned spray heads and
improving the spray painting transfer efficiency than if it were to include
high solids coatings formulations or the UNICARB system.

      Similarly, the ultra-sonic cleaning technology will be reviewed further.
The evaluation and requirements will depend heavily on decisions made
regarding what parts cleaning operations are to be used for this study.
Further we will review  options to determine whether both aqueous-base
cleaning and vapor degreasing should be evaluated.

      The oil life extension study should be done.  It should be determined if
a  statistically significant study can be carried out.  The dual filtration
evaluation , evaluated independently or simultaneous, could provide
significantly useful information to reduce motor oil generation throughout the
U.S.

ACKNOWLEDGEMENT

I would like to acknowledge the New Jersey Institute of Technology and the New
Jersey Department of Environmental Protection for their assistance in this
paper.

GENERAL REFERENCES

1.    Survey of Small Quantity Generators,  U.S.  Environmental Protection
      Agency, Office of Solid Waste and Emergency Response,  Washington DC,
      1985.

2.    Waste Audit Study on Automotive Repairs,  California Department of Health
      Services, Toxic Substances Control Division, Sacramento,  CA.,  1987.

3.    W.  Toy, Waste Minimization in the Automotive Repair Industry,  JAPCA (38)
      1988,  pp. 1422-1426.

4.    Hazardous Waste Minimization Manual For Pennsylvania's Vehicle
      Maintenance Industry, Center for Hazardous Materials Research,
      University of Pittsburgh Applied Research Center,  Pittsburgh,  PA.
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                    SHORT-ROTATION WOODY CROP OPPORTUNITIES
                      TO MITIGATE CARBON DIOXIDE  BUILDUP*
                  by:   L. L. Wright1
                        R. L. Graham1
                        A. F. Turhollow2
                        Environmental Sciences Division1
                        Energy Division2
                        Oak Ridge National Laboratory
                        Oak Ridge, TN 37831
                                   ABSTRACT
      Short-rotation woody crops (SRWC) have a significant potential for
permanently mitigating carbon dioxide buildup in the atmosphere.  Like other
forestry options, SRWC can provide a fiber source for many wood products that
store carbon for short to long time intervals.  However, the greatest benefit
can be derived from growing large amounts of woody crops dedicated to
substitute for fossil energy resources.  To determine how much fossil fuel
that SRWC could reasonably displace in the United States requires making a
series of assumptions.  Assumptions include net SRWC biomass yields per acre
(after losses), amount of land available and suitable for SRWC, wood
conversion efficiencies to electricity and liquid fuels, the energy
substitution properties of various fuels, and the amount of fossil fuel used
in the process of growing, harvesting, transporting and converting SRWC
biomass.  Assuming current production and conversion technologies and a
conservative estimate of the viable U.S. land base (35 million acres), SRWC
energy could displace 34 to 67 million tons of fossil carbon releases, 3 to 5%
of current annual U.S. emissions.  The carbon mitigation potential per unit of
land is larger with the substitution of SRWC for coal-based electricity
production than for the substitution of SRWC-derived ethanol for gasoline.
Assuming predicted technology advancements (higher conversion efficiencies and
net SRWC biomass yields of 10 dry tons/acre) and a high estimate of the U.S.
land base available for SRWC (103 million acres),  SRWC energy could displace
272 to 470 million tons of annual fossil fuel carbon releases.  The carbon
mitigation potential of SRWC-based electricity production would be equivalent
to about 7.5% of current global fossil fuel emissions and 35% of current total
U.S. fossil fuel emissions.
     *Research sponsored by the Biofuels and Municipal Waste Technology
Division, U.S. Department of Energy, under contract DE-AC05-840R21400 with
Martin Marietta Energy Systems, Inc.  Environmental Sciences Division
Publication number
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                                 INTRODUCTION
      Forestry can mitigate carbon dioxide buildup in the atmosphere today
through several strategies.  These strategies include (1) planting new trees
to sequester carbon already in the atmosphere;  (2) managing understocked, poor
quality and immature forests to increase forest carbon storage; (3) improving
forest utilization to maximize carbon storage in forest products;  (4) planting
trees in urban areas to aid in energy conservation; and (5) using wood as a
renewable energy source to displace fossil fuels.

      The first three strategies, relating to carbon sequestering or storage,
are effective midterm solutions for carbon dioxide mitigation but not
permanent solutions unless the new or additional forest production is
eventually used as an energy source substituting for fossil fuels.  In
contrast the latter two strategies offer permanent mechanisms for mitigating
buildup of carbon dioxide in the atmosphere by reducing the level of fossil
fuel emissions.  This paper addresses the last strategy and short-rotation
woody crop technology (SRWC) to mitigate atmospheric carbon increases.

      SRWC technology involves techniques to promote very rapid juvenile
growth rates in selected species achieving maximum mean annual growth rate in
4 to 8 years depending on initial spacing, species and climate.  These stands,
averaging a production rate of 5-10 tons biomass/acre/year, are harvested at
rotation age (4 to 8 years) in winter after leaf fall.  Hardwoods are
preferred, since they offer the advantage of resprouting from stumps.  Some
softwoods also benefit from SRWC technology and are more appropriate for some
site conditions.

      The cycle of growing wood for energy production affects atmospheric
carbon emissions in a very different way than does the planting of forests for
carbon storage.   Forests and SRWC that are never harvested remove and store a
fixed maximum amount of atmospheric carbon which varies greatly with forest
type.  The utilization of forests and SRWC for the production of wood products
may raise or lower the maximum amount of carbon stored per acre in a given
forest type (Harmon et al. 1990).  Forests and SRWC planted and harvested
specifically for energy provide some carbon storage in the average inventory
of standing trees but, more importantly, provide an essentially permanent
carbon mitigation benefit when the wood displaces fossil fuels for energy
production.  For a simple comparison, consider the example of putting an acre
of north central cropland into SRWC production specifically for energy
production versus planting the same acre to a longer rotation pine forest
strictly for carbon storage.  Over the next 100 years the planted forest acre
would accumulate aboveground carbon until it had stored about 150 tons of
carbon/acre1 (Birdsey 1990).  Unless that forest acre is utilized for wood
products or energy products, the maximum benefit to the atmosphere of that
acre stops at approximately 150 tons of carbon mitigation  (Figure 1).  Compare
that to an acre of SRWC established specifically for providing an alternative
to coal for electric generation.  That given acre is assumed to be harvested
     1Soil carbon accretion is not included in this value as such accretion would
also occur with SRWC harvested for energy.
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for energy production once each 6 years thus resulting in the step-like curve
shown in Figure 1.  Depending on whether present or future production and
combustion technologies are assumed, the net benefit to the atmosphere over
100 years of burning SRWC instead of coal for electric generation would be 215
or 487 tons/acre, respectively, of permanent carbon mitigation.2

      But what is the real potential in the United States for SRWC to reduce
carbon emissions and provide energy?  To answer this question, a series of
linked pieces of information are required.  They include the amount of
feedstock that can be produced, the quantity of electricity or fuel the
feedstock can produce, and the quantity of fossil fuel and carbon displaced.
The remainder of the paper discusses these.

                             AMOUNT OF FEEDSTOCK
      To determine biomass energy feedstock availability, it is necessary to
know the biomass yield per acre of SRWC and the amount of land available and
suitable for SRWC.  Yields and land availability are addressed separately.

YIELD POTENTIALS

      SRWC yields have risen steadily over the past 12 years as SRWC
technology has improved.  Yields in the range of 4 to 7 dry tons harvestable
woody biomass/acre/year are now common in production research trials.3  If a
concerted research effort is maintained, yields of 7 to 13 dry tons/acre/year
are believed attainable by the year 2010 on moderate-to-good cropland.  To
date, the maximum observed experimental yield from a temperate climate SRWC is
19.3 tons/acre/year (Table 1), so the targeted yield goals would seem
realistic with adequate research effort (Wright and Ehrenshaft, in press).
   TABLE 1.  SHORT ROTATION WOODY CROP YIELDS BY REGION; CURRENT AND FUTURE
    EXPECTED YIELDS  FOR OPERATIONAL CONDITIONS AND  MAXIMUM  OBSERVED  VALUES
Region                        Yields (dry tons/acre/year)
                      Current            Goal          Maximum observed
Northeast
South/Southeast
Midwest/Lake
Northwest
Subtropics
4
4
5
7
7
7
8
9
13
13
7
7
7
19.3
12.3
     Assumptions and calculations are provided later in the text.

     3Yield is the standing aboveground woody biomass of the SRWC crop divided
by the crop's  age,  analogous to the forestry  term  "Mean Annual  Increment" or
"MAI."
                                   547

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      To ensure that SRWC energy feedstock are competitive with other energy
sources such as gas, oil, and coal, the U.S.  Department of Energy has
established a cost goal for delivered SRWC energy feedstock at $2.00/MMBtu
($34/dry ton).4  This translates to a yield of roughly 7  to 10 dry
tons/acre/year on sites with moderate annual  land rents ($40 to $60/acre).
Current delivered SRWC costs are estimated to be in the range of $2.00 to
$3.00/MMBtu ($34 to $51/dry ton) where relatively good cropland can be used,
moisture is not limiting, and best available  SRWC techniques are practiced5
(Wright and Ehrenshaft, in press). This may,  however,  represent a relatively
small proportion of the available acreage.

      SRWC yields are function of genotype, cultural practices, and site
quality.  Short-rotation species showing the  most success under agricultural
conditions exhibit a combination of rapid juvenile growth, good stress
tolerance, good coppice growth, and disease resistance.  Silver maple (Acer
sac char inum) ,  sweetgum (Liquidamber styraciflua) ,  sycamore (Platanus
occidentalis),  black locust (Robinia pseudoacacia),  poplars (Populus spp. and
hybrids), and eucalypts (Eucalyptus spp.) have been identified as potential
genotypes for SRWC in the U.S. and are currently under SRWC research.  Other
genera such are also potential candidates for SRWC.   Although poplars  have
dominated research, alternative species are important if SRWC technology is to
exploit wetter, drier, or more nutrient-poor  sites than poplars would
tolerate.  Exploitation of poorer sites is essential for expanding the land
base suitable for SRWC.  New and innovative cultural practices must match
species and site conditions to attain future  higher yields.

      Harvesting and handling technology can  affect both net yield (after
losses) from the site and feedstock costs.   SRWC harvest and transport costs
are presently $24/dry ton with several tons/acre being lost in the harvesting
and transport process.  Lighter, more specialized equipment prototypes may be
able to reduce costs by 35%, but substantial  engineering research is still
needed to accomplish this.  Energy needs at this stage of the production
process are large and must enter into carbon  balance equations.

      To obtain high juvenile yields at reasonable costs, research has clearly
shown that only land in USDA cropland classes IV or better will be suitable
for SRWC.  Moderate to good cropland (land classes II and III) that have some
erodibility problems would be quite satisfactory from the stand point of
production, economic and environmental considerations.  Establishment of SRWC
crops on cutover forested sites has been tested and is not presently
recommended.  Results have shown relatively poor growth compared to cropland
under cultivation or recently abandoned cropland (Wright et al., in press).
     *This goal was based on the assumption that there would be no change in the
current prices  of fossil fuels.   Taxes on fossil-carbon-emitting  sources  or
increases in oil import prices would likely improve the competitiveness of SRWC
as a energy source.

     5These cost figures assume chips are used as the raw feedstock.  If whole
trees could be  burned  as has  been  proposed  (Ostlie  1989),  the feedstock costs
would be significantly less.
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LAND AVAILABILITY

      Land availability is a function of land quality, agricultural product
demands, U.S. agricultural policy, and environmental considerations.  Of these
four factors the one that can be discussed with most certainty is the first.
Within the United States there are about 400 million acres of non-federal land
classified as cropland, and roughly 184 million of those acres have suitable,
fertility, rainfall and slope characteristics (<8%) for SRWC (USDA/SCS,  1989).
About 100 million acres of U.S. land currently in range and pasture is
classified as having moderate to good potential for conversion to cropland
(USDA/SCS, 1987).  Of this "potential" cropland about 50 million acres may be
suitable for conversion to SRWC production.  All cropland and "potential"
cropland in the Great Plains and further west was arbitrarily excluded from
this estimate of suitability for SRWC due to presumed moisture and slope
limitations.  Additionally the use of more drought-adapted herbaceous species
would offer additional opportunities to expand the suitable land base.  The
suitable land base has numerous competing uses and thus cannot necessarily be
assumed to be available for SRWC production.

      Projections of land needed for current and future food production in the
United States have changed considerably in the last decade, allowing the
possibility of putting cropland into energy-crop production.  In 1982, 153
million acres of the approximately 500 million acres potentially suitable for
crop production were not used for that purpose.  In addition to the land
normally used for range and pasture, varying amounts of productive cropland
are idled each year.  For any one year during the 1980s, 11 to 78 million
acres of productive cropland were idle.  To exploit this land base and
revitalize U.S. agriculture, a Task Force Report requested by the Secretary of
Agriculture (New Farm and Forest Products Task Force, 1987) proposed a
national goal of "developing and commercializing within 25 years, an array of
new farm and forest products, utilizing at least 150 million acres of
productive capacity, to meet market needs representing net new demand for
agriculture and forestry production."  However agricultural policy changes are
needed to put energy crops on "level ground" with other crop programs.

      Changes in U.S. farm policies are beginning to occur.  In 1985 the Food
Security Act incorporated provisions of the type needed to begin establishment
of wood energy crops.  The Act initiated the Conservation Reserve Program
which targeted 40 million acres of highly erodible land for long-term
retirement from food crop production.  As of 1989, 30 million acres had been
set aside under this program.  SRWC grown on 9- to 12-year rotations would
appear to an ideal crop for some of these lands because the establishment of
SRWC accomplishes the goal of reducing soil erosion, yet it is also not as
permanent a land-use conversion as conventional forestry.

      A low estimate of potential land availability for SRWC was taken to be
about 35 million acres or approximately the amount of land eligible for the
Conservation Reserve Program in the eastern part of the United States.  This
includes acres in the following USDA regions: Corn Belt (16.4 million),  Lake
states (5.7 million), Southeast (2.7 million), Appalachian (4.7 million),
Delta States (2.1 million) and the Northeast (3.0 million) (USDA/ERS 1989).  A
high estimate of potential land availability for SRWC was taken to be about
103 million acres.  This includes the 35 million acres previously described,
                                   549

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the 50 million acres of "potential" cropland with moderate to good conversion
potential in the same regions of the United States,  plus about 10% of the
current land base in active crop production in the same region (18 million
acres).  This high estimate is an optimistic but not unreasonable future land
base.6

      The environmental impact of SRWC production technology should be
considered in light of current land use.  If SRWC are established on cropland,
SRWC should result in a 50 to 75% reduction in use of pesticides, herbicides,
and fertilizers as well as decreases in erosion.  The wildlife impact has not
been examined.  Since SRWC is rarely economically feasible on anything but
cropland or recently abandoned cropland and because of the increasing value of
conserving forest ecosystems for multiple uses, it is unlikely that SRWC will
displace forests.  The overall environmental impact of SRWC production is
likely to be benign if not positive, particularly if environmentally suitable
sites are selected for conversion to SRWC.
                               ENERGY PRODUCTION

      To determine the amount of energy in the form of electricity or fuel
that can be produced from an acre of land or a ton of biomass feedstock, it is
necessary to understand the status of conversion technologies, particularly
the efficiency of conversion.  Conventional wood-to-electricity generating
plants (10 to 50 MWe)  have an energy conversion efficiency of about 25%,
largely because of high moisture content of the wood feedstock.  Ostlie (1989)
proposes a whole-tree burner technology which promises a conversion efficiency
of 33%.  Larson and Williams (1990) and Larson and Svenningsson (1990) have
proposed the use of aeroderivitive gas turbines [steam-injected gas turbines
(STIG) and intercooled steam-injected gas turbines (ISTIG)] coupled with
biomass gasifiers to generate electricity.  Efficiencies for STIG and ISTIG,
using coal as the feedstock, have been documented at 35.6 and 42.1%,
respectively.  Conversion efficiencies using biomass as the feedstock have
been lower in experiments using currently available gasifiers designed for
coal.  Because biomass should gasify more easily than coal, Larson and
Svenningsson (1990) feel that biomass should have at least as high an overall
cycle efficiency as does coal.  Using gasifiers specifically designed for
biomass will be necessary to obtain maximum conversion efficiency.

      It is currently estimated that a dry ton of wood can produce 83 gallons
of ethanol, with a conversion process efficiency of 39%.  This estimate is
based on an ethanol conversion facility model developed at the Solar Energy
Research Institute and used for analysis at Oak Ridge National Laboratory.
The model shows that an exogenous energy input of 81 kWh of electricity is
required in addition to conversion facility energy requirements met by
utilizing the unfermented portions of the wood.  With improvements in
     6To put this acreage  into  perspective,  soybean is a crop  which occupied
virtually no U.S.  land in the  first half of this century and now occupies about
60 million acres.  Thus land conversions of the magnitude considered under this
scenario have occurred within this century (New Farm  and  Forest Products Task
Force, 1987).
                                   550

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feedstock composition and the conversion process (e.g., enzymes used for
hydrolysis of cellulose, fermentation efficiencies) a dry ton of wood could
produce 108 gallons of ethanol and also a surplus of 91 kWh of electricity.
This would represent a wood-to-ethanol conversion process efficiency of 59%.

                           FOSSIL FUEL DISPLACEMENT


The relative amount of electricity produced per dry ton of wood or coal
feedstock is a function of the process conversion efficiency (previously
discussed) and the relative Btu content of the two feedstocks.  The energy
content of both wood and coal per unit of delivered weight varies
considerably.  The estimate used for average energy content of wood is 8500
Btu/dry Ib or 17 x 106 Btu/dry ton.   The average energy content of coal is
taken to be about 23.5 x 106 Btu/ton as delivered.   These values,  together
with the assumed conversion efficiencies of wood and coal combustion,
determine the relative raw Btu levels of each feedstock required to produce
the equivalent kWh of electricity.  The raw Btu levels of wood and coal
required to produce a kWh of electricity are obviously the same if the
conversion efficiencies are the same.  Once the Btu level of the coal
equivalent (to the wood burned) is determined, the calculation of carbon
offset (as shown in Figure 1) is straightforward since the carbon content of
coal per Btu is nearly constant over a wide range of coal types.  That level
in coal is 56.24 Ib C/MMBtu (24.12 kg C/GJ) if carbon released in the mining
and transportation of coal is not considered and 57.48 Ib C/MMBtu (24.65 kg
C/Gj) if the additional carbon emissions are considered  (Marland 1983).  We
used the latter.

      The calculation of fossil fuel displacement in the wood-to-ethanol fuel
pathway includes consideration of the relative substitution rates of ethanol
for gasoline and consideration of any carbon released in operation of the
conversion facility.  Liquid fuels derived from biomass do not necessarily
substitute for conventional fuels on a one-to-one energy content basis.  It is
assumed that even though a gallon of ethanol contains only about two-thirds
the energy content of a gallon of gasoline, it can be burned more efficiently.
Therefore a gallon of ethanol can substitute for 0.8 gallons of gasoline.
Much of the energy in the wood used to produce ethanol is needed to provide
process energy, and thus is not available to displace gasoline.  Consequently
it takes about two units of wood energy to displace one unit of energy in
gasoline (actually 2.75 and 1.74 wood energy units per gasoline energy unit
for present and advanced technologies respectively).  This is in contrast to
coal displacement where similar amounts of wood energy substitute for coal
energy.

                             NET CARBON BENEFITS
      The combustion of wood or ethanol does emit carbon into the atmosphere.
However, those emissions  are balanced by the carbon taken up by the SRWC
energy plantations.  However,  fossil-carbon inputs are presently required in
the production, harvesting, and transportation of SRWC feedstocks.  These
inputs are  relatively  small and may be balanced, at least initially, by carbon
sequestering occurring in the  soil and the unharvested root systems.  However,
                                   551

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data to document the level of sequestering in soil and roots are not yet
available, the sequestering does not continue indefinitely, and the stored
carbon might be released if the site was converted back to food crop
production.  Therefore, for purposes of this analysis all carbon inputs to the
production, harvesting, and transportation are assumed to be carbon emissions
that reduce the net benefit derived from fossil-fuel displacement.  The
following discussion will describe the types and levels of carbon inputs and
calculate, by conversion technology, the net benefit derived from displacement
of fossil-carbon feedstocks with SRWC.

CARBON INPUTS TO SRWC FEEDSTOCK PRODUCTION

      To determine the carbon inputs to the production, harvest, and delivery
of short-rotation wood feedstocks, a series of assumptions is made for present
SRWC technology.  First, energy requirements for each operation (site
preparation, weed control, fertilizer, pesticides, harvest, transport, and
storage) are estimated by fuel type (diesel as a proxy for all petroleum
liquids, natural gas, and electricity) and then converted to carbon
equivalents.  Electricity is assumed to be generated 75% from coal and 25%
from nonfossil sources.  Average annual yield (after accounting for harvest
and storage losses) is 6 dry tons/acre.  Harvest occurs on a 6-year cycle,
with two coppice harvests, for a stand life of 18 years.  Average annual
fertilizer applications are nitrogen, 45 Ib/acre; phosphorus (as P205) ,  13
Ib/acre; and potassium (as K20) ,  13 Ib/acre.   Weed control is  used in the
first and second years of each harvest cycle.  Pesticides are assumed to be
applied annually for this calculation, but pest resistant trees and integrated
pest management techniques should be developed that will not require nearly as
much pesticide use as is assumed here.  Harvest, transport, and storage
operations are assumed to require 0.92 million Btu/dry ton.  For advanced
production technology no change in input requirements is assumed,  but average
annual (after loss) yield is assumed to increase to 10 dry tons/acre.

      With present technology, production of an average annual (after loss)
yield of 6 dry tons/acre requires per acre inputs of 45.7 gallons of diesel,
2110 cubic feet of natural gas,  and 84.3 kWh of electricity, which results in
carbon emissions of about 0.22 tons C/acre/year.  With advanced technology,
production of an average annual (after loss) biomass yield of 10 dry tons/acre
requires per acre inputs of 72.0 gallons of diesel, 2110 cubic feet of natural
gas, and 84.3 kWh of electricity, which contributes emissions of about 0.31
tons C/acre/year.  The difference in diesel usage results from more wood per
acre being harvested, transported, and stored.

NET BENEFIT FROM CONVERSION OF WOOD TO ELECTRICITY

      The net carbon mitigation benefit obtained by displacing coal with wood
in electricity generation increases dramatically with advanced SRWC production
and combustion technologies.  With present technology a wood-to-electricity
efficiency of 25% and a coal-to-electricity efficiency of 34% are assumed.
With advanced technology the two conversion efficiencies are assumed to be
equal at 42%.   These and other important assumptions are listed in Table 2.
By substituting wood for coal, about 2.16 and 4.87 tons C/acre/year are offset
for present and advanced technologies, respectively.  After subtraction of the
carbon emissions associated with SRWC production, harvesting and
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TABLE 2.  ANNUAL CARBON OFFSET PER ACRE BY ELECTRICITY PRODUCED FROM SRWC
Assumptions and Results                                Technology Status—
                                                      present     advanced
Biomass Yield (after losses) dry tons/acre/year
Conversion Efficiencies assumed
wood-to-electricity (%)
coal -to -electricity (%)
Electricity Production (MWh/acre/year)
Net carbon emissions (tons/acre/year)*
Production
Conversion
total carbon emitted
Carbon offset by fuel substitution (tons/acre/year)
NET CARBON OFFSET (tons/acre/year)
6

25
34
7.47

0.22
0
0.22
2.16
1.94
10

42
42
20.93

0.31
0
0.31
4.87
4.56
*Assumes electricity generated 25% from nonfossil fuel and 75% from coal at
 the conversion efficiencies for present and advanced as shown in table.

transportation, the net offset of carbon is about 1.94 and 4.56 tons C/acre
for present and advanced technology, respectively.

NET BENEFIT FROM CONVERSION OF WOOD TO ETHANOL

      Wood is assumed  to be converted into ethanol by a simultaneous
saccharification and fermentation (SSF) process  (Wright 1989).  For purposes
of this paper this is  assumed to include a dilute acid pretreatment,
fermentation of xylose, enzymatic hydrolysis of  cellulose, and fermentation of
glucose.  With present technology, conversion of the wood to  ethanol requires
0.975 kWh/gallon of additional energy input, which contributes carbon
emissions of 0.11 tons C/acre (0.38 Ib C/gallon).  For each acre of SRWC wood
converted to ethanol,  total production and conversion carbon  emissions amount
to about 0.32 tons C (1.30 Ib C/gallon) (Table 3).

      With anticipated advances in technology, conversion of  the wood to
ethanol generates a surplus of electricity of 0.84 kWh/gallon, which would
have required 0.16 tons C/acre/year to generate.  After subtracting out the
carbon required for the conversion process, total production  and conversion
emissions are reduced  to about 0.15 tons C/acre  (0.28 Ib C/gallon) (Table 3).

      The net carbon offset by conversion of SRWC to ethanol  which is used for
gasoline substitution  amounts to about 0.97 and  2.65 tons C/acre assuming
present and advanced technology respectively (Table 3).  Note that the offset
of carbon is about twice as high for electricity from SRWC as it is for
ethanol from SRWC.
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     TABLE 3.   ANNUAL CARBON OFFSET  PER ACRE BY ETHANOL PRODUCED  FROM  SRWC
Assumptions and Results                                Technology Status
                                                      present     advanced
Biomass yield (after losses) dry tons/acre/year
Wood- to -ethanol conversion efficiency (%)
Ethanol yield: gallons/dry ton
gallons/acre
6
39%
83.3
500
10
59%
108.2
1082
Net carbon emissions (tons/acre/year)*
Production
Conversion
Total carbon emitted
Carbon offset by fuel substitution (tons/acre/year)
NET CARBON OFFSET (tons/acre/year)
0.22
0.11
0.32
1.29
0.97b
0.31
-0.16
0.15
2.80
2.65
'Assumes electricity generated 25% from nonfossil  fuel  and 75%  from coal at
 the conversion efficiencies for present and advanced are 34 and 42%.

                      NATIONAL CARBON AND ENERGY BENEFIT
      The potential carbon mitigation and energy supply benefits of SRWC are a
function of the acreage dedicated to the production of SRWC crops and the
advancement of SRWC and associated energy conversion technologies.  To
evaluate the U.S. potential two SRWC adoption scenarios are considered.

      The first scenario is a "current conditions" scenario.   Table 4 gives
the assumptions on land base and yield used in this scenario.   Under these
assumptions, the annual carbon offset by SRWC-based energy production is 2.16
tons C/acre/year if the wood is used to produce electricity and 0.97 tons
C/acre/year if the wood is used for ethanol production.  Table 4 shows the
national carbon mitigation benefits and ethanol or electricity production that
would be expected.  Even under this fairly conservative scenario, SRWC energy
technology could produce a significant fraction of either the U.S.
transportation fuel or electricity needs.

      The second scenario is a "future" scenario.   Under this scenario, the
total U.S. carbon benefit would be 272 million tons carbon offset/year
assuming ethanol production or 470 million tons carbon offset/year assuming
combustion and electricity generation (Table 4).   This is about 20 or 35 % of
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    TABLE 4.   SRWC PRODUCTION SCENARIOS—LAND AND YIELD ASSUMPTIONS: CARBON
   OFFSET, ETHANOL, AND ELECTRICITY GENERATION; COMPARISON TO U.S. FUEL AND
       ELECTRICITY CONSUMPTION;  AND COMPARISON  TO U.S. AND  GLOBAL CARBON
                          EMISSION FROM FOSSIL FUEL
                                 SRWC Energy Scenarios
                       Current     Current     Future      Future
                       Ethanol    Electricity  Ethanol   Electricity
Yield (tons/acre/yr)           6           6           10          10
Land base (106 acres)         34.6        34.6        103         103
Carbon offset                 34          67          272         470
 (millions tons C/yr)
Ethanol generated             17.3        -           111.4
 (109 gallons/yr)
Electricity generated         -            0.26         0.09        2.16
 (109 MWh)

Percent of Current            12%          -           79%
 U.S. gasoline consumption
Percent of U.S. Electric      -           10%           3%         78%
 power consumption

Percent of U.S. fossil         3%          5%          20%         35%*
 fuel carbon emissions
Percent of world fossil        0.5%        1.1%         4.4%        7.5%
 fuel carbon emissions
*This estimate of future carbon offset is greater that the amount of carbon
 now released by coal-fired electric generation in this country.

the current U.S. fossil fuel carbon emissions and 4.4 or 7.5 % of global
fossil fuel carbon emissions7.

      As Table 4 reveals, SRWC has a real and significant potential to offset
fossil fuel carbon emissions with a permanent effect.  That potential however,
will not be realized under current agricultural policy which strongly
encourages the status quo.  Nor will it be realized without a concerted,
stable research effort for the next 20 years.  Nonetheless, the potential for
SRWC has been well demonstrated and the carbon mitigation benefits are there
if we, as a nation, decide to go after them.
     7The estimate of future carbon offset resulting from substitution of SRWC
for coal  in electricity generation is  greater  than the amount  of  carbon now
released by coal-fired electric generation in this country.
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                                ACKNOWLEDGMENTS
      The  careful  reviews by Greg Marland and Bob Cushman in the Carbon
Dioxide  Program  at Oak Ridge National Laboratory contributed significantly
toward the accuracy of the  information in this paper.

                                  REFERENCES


Birdsey, R. A.   1990.  Carbon yields for softwood forest types in the United
States.  Proceedings of North American Conference on Forestry Responses to
Climate  Change (in press).

Harmon,  M.E., W.K. Ferrell, J.F. Franklin.  1990.  Effects on carbon storage
of conversion of old-growth forests to young forests.  Science 247:699-702.

Ostlie,  L.D.  1989.  The whole tree burner:  A new technology in power
generation.  Biologue 5 (3):7-9.

Larson,  E.D. and R.H. Williams.  1990.  Biomass-fired steam-injected gas
turbine  cogeneration.  Biologue 6 (5):12-19.

Larson,  E.D. and P. Svenningsson.  1990.  Development of biomass gasification
systems  for gas  turbine power generation.  Paper presented at Energy from
Biomass  Wastes XIV, January 29-February 2, 1990, Lake Buena Vista, Florida.

Marland, G. 1983.  Carbon Dioxide emission rates for conventional and
synthetic  fuels.    Energy 8(12):981-992.

New Farm and Forest Task Force.  1987.  New farm and forest products,
responses  to the challenges and opportunities facing American agriculture.  A
report to  the Secretary, U.S. Department of Agriculture.  U.S. Government
Printing office  1987 - 721-254 - 1302/60251,  Washington,  D.C.

USDA/ERS.  1989.   Agricultural resources:  Cropland,  water and conservation,
situation  and outlook report.  AR-16,  September 1989.  USDA Economic Research
Service, Resource and Technology Division, Washington,  D.C.

USDA/SCS.  1987.   Basic Statistics,  1982 National Resource Inventory.
Statistical Bulletin Number 756.  USDA Soil Conservation Service, Resource
Inventory  Division, Washington, D.C.

USDA/SCS.  1989.   Summary Report, 1987 National Resource  Inventory.   Iowa
State Statistical Laboratory.  Statistical Bulletin 790.   USDA Soil
Conservation Service,  Resource Inventory Division,  Washington,  D.C.

Wright,  J.D.  1989.  Evaluation of enzymatic hydrolysis processes.   In:   D. L.
Klass (ed), Energy from Biomass and Wastes XII.   Institute  of Gas Technology,
Chicago,  pp. 1247-1276.
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Wright, L.L., T. W. Doyle, P.A. Layton, J. W. Ranney.  Short Rotation Woody
Crops Program:  Annual Progress Report for 1988.  ORNL-6594.  Oak Ridge
National Laboratory.  Oak Ridge, TN.

Wright, L.L., and Ehrenshaft, A.   Short Rotation Woody Crops Program:  Annual
Progress Report for 1989.  Oak Ridge National Laboratory.  Oak Ridge, TN (in
press).
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              CORPORATE TRANSITION TO MULTIMEDIA WASTE REDUCTION

                    by:  D. B.  Redington
                         Monsanto Company
                         800 N. Lindbergh Boulevard
                         St. Louis, MO  63131
     The traditional approach to waste reduction at a major corporation was
formulated in the early 1980's as a response to the emerging realities of
CERCLA and RCRA requirements.  The program targeted reduction of hazardous
waste generation, increased recycling of wastes and treatment of remaining
residuals.  Major progress was achieved over 5 years, but by early 1988 it
was apparent that results were diminishing.  Public attitudes and expecta-
tions, accelerated by SARA 313 reporting, pressed for attention to minimi-
zation of all wastes in all media.  Over a transitional year, the corporation
overhauled its program to achieve these ends and is putting in place program
elements to pursue aggressive multi-media goals.
                                    558

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     Thank you Mr. Chairman, Ladies and Gentlemen:

     As you heard in the opening remarks, the objective of this session is to
explore the impediments to industrial approaches to Pollution Prevention, and
the solutions we can bring to bear to overcome these impediments.  Before I
do that, though, I want to make some brief remarks on motivation.  That is,
why should those of us who represent corporations be interested in devoting
resources to Pollution Prevention?

     Let's look at some statistics:

     o    In the last 20 years, world population has increased by 40% or 1.6
          billion souls, to 5.3 billion people.

     o    In this decade, we will add 1 billion more, and by the year 2030
          population will double to over ten (10) billion.  That's beyond my
          lifetime, but my new granddaughter will be just forty (40) years
          old then.  Ten (10) billion people will generate a lot of waste.

     o    The WorldWatch Institute reports that, over the last 20 years, 500
          million acres of forest have been lost worldwide — an area equi-
          valent to the Eastern half of the United States.

     o    More locally, in St. Louis County where I live we generate six (6)
          pounds of trash per person per day — three (3) from industry and
          three (3) from households.  Only a dozen of the 90 suburbs have
          tried curb-side recycling — and our landfills have only six (6)
          years of permitted capacity remaining.

     When industry people hear statistics like those, there may be a quiet
sigh of relief by some, saying, "well at least those are issues, I don't
have to worry about."  But in a broader sense we do.  Our actions, particu-
larly in leadership roles, in our communities, our states and at the national
level will be collectively very important if societal issues are to be
successfully addressed.

     Let's look at some other statistics:

     o    We continue to generate 250-300 million annual tons of hazardous
          waste in the United States, in spite of efforts aimed at reduc-
          tion.  EPA in fact estimates that the total is growing by 7.5% per
          year.

     o    The new Toxicity Characteristic under RCRA, when it becomes effec-
          tive in September, will expand the world of hazardous wastes, in-
          creasing it by a factor variously estimated between four (4) and
          six (6)  times.  The 250 million ton figure becomes a billion tons
          per year.

     o    In April, EPA announced the totals for the Toxic Release Inventory,
          reported under SARA 313 for 1988.   While reported releases were
          down 9% from 1987, we are still looking at 4.6 billion Ibs. per
          year in the U.S.,  and,  of this, 2.4 billion are releases to air.
                                    559

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     So industry does have an issue, and a very important role to play in
Pollution Prevention.  While we may be convinced that these releases do not
constitute a threat to our employees or our communities, the public expecta-
tion is clear.  We must do all that we can to pursue a goal of no releases,
achieve results, and involve our communities in the effort.  Ultimately these
communities grant to us the right to operate in their midst, but condition
that right with an expectation we will not operate at the expense of community
health and safety.

     Separately, the operations of our plants almost inevitably consume non-
renewable resources, so that we have a vital economic interest to reduce our
losses of raw materials to wastes or the environment.
     My narrower focus in these remarks, though, is on one corporation's
experience in making the transition to a multi-media database.

     In the 1982-1988 timeframe, our organized effort on waste reduction
focused on hazardous wastes generated by our plants.  That program replaced
prior efforts and derived from a Waste Management Study done in 1981-82 which
concluded several things:

     o    Past land based management practices were not necessarily protec-
          tive, as evidenced by our increased involvement as PRPs at Superfund
          sites.

     o    Emerging public altitudes cried for reduction and more responsible
          management of hazardous wastes — and RCRA was being put into place
          to drive toward more protective facilities.

     o    And, finally, the economics available to drive a waste reduction
          effort had improved, not only in the rising costs of raw materials,
          but also in the skyrocketing costs for waste treatment and disposal
          under RCRA.

     The stated corporate policy captured the now-familiar hierarchy of
management practices, giving greatest preference to source reduction, least
to land disposal of treatment residues or other wastes.  To minimize our
dependence on landfills, two mandates were put into place:

     o    By January, 1984, all acutely hazardous wastes were incinerated.

     o    Then, by January, 1986, all incinerable hazardous wastes were in
          fact incinerated rather than landfilled.

     This requirement included many wastes which are non-hazardous under
the rules, but which we have elected to manage as hazardous.

     Our program also requires that all non-hazardous wastes land disposed in
Subtitle D units be reviewed again to further guarantee against future Super-
fund involvement, an activity that is still progressing.  The 1982 policy also
mandated the setting of annual reduction goals by plants and divisions, annual
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review of progress by our manufacturing council and by our corporate Environ-
mental Safety and Health Committee.  Waste reduction coordinators were assign-
ed at each plant site, and a newsletter was put in place — and is still
active — to facilitate a sharing of waste or release reduction ideas.

     Very importantly, one effort was unified at the corporate-level.  We
established a single database, under a single well-documented set of rules,
to keep track of our progress.  Such a database is vital to any pollution
prevention effort.  Features included:

     o    Hazardous and non-hazardous wastes, including wastewaters

     o    Base year 1982

     o    39 U.S. plants

     o    Multiple reports generated

     At this point then, I want to reflect on some of the observations we
made in early 1988 when we took a critical look at our effort:

     o    97% of our hazardous wastes are waste waters.  Under RCRA's mixture
          rule, the entire stream is a hazardous waste, but there is little
          financial or environmental incentive to drive reduction of the
          actual water content of these wastes.

     o    As we look forward to the effective date of the new Toxicity
          Characteristic under RCRA, we anticipate that our inventory of
          hazardous wastes will "jump" by a factor as high as six (6).

     o    By 1987, we had reduced waste generation by about 50% against the
          1982 base.  But it was increasingly obvious in 1986 and 1987 that
          the achievement was increasingly the result of "down sizing", that
          is, the termination or sale of businesses.  It was equally apparent
          that this trend would not continue.

     And so we found ourselves in early 1988 looking at the prospect of
flattening performance from our program.  At the same time, public expectations
were broadening to encompass all wastes generated — hazardous, non-hazardous
and trash.  Further, the release of the Toxics Release Inventory for 1987
(and now for 1988) has worked to increase public awareness of chemical
releases to the environment — and public concern that these releases be
controlled and eliminated.  That concern is multi-media in scope, covering
releases to air, water and the land.

     Our historic program was not multi-media in scope (no air emissions
included) and did not focus crisply on releases to the environment.
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     1988, then, was a year of introspection and redirection.  In April, 1988
Mr. Earle Harbison, President and Chief Operating Officer, directed the
Operating Companies to re-examine our waste reduction effort, waste-by-waste,
and to develop an entirely new effort based on multi-media releases to the
environment.  Mr. Harbison noted that "no rationale exists for ignoring Title
III, Section 313 emission data when considering our total toxic waste produc-
tion."

     The challenge was sharpened in July of 1988 when Mr. Richard Mahoney,
Chairman and Chief Executive Officer, announced the corporate intent to
pursue elimination of SARA 313 air emissions, with the goal of achieving a
90% reduction in 5 years — by the end of 1992.

     The Operating Unit programs emerged out of this planning effort in late
1988.  The two major divisions — Monsanto Chemical Company and Monsanto
Agriculture Company — derived identical programs which included top-down
directions:

     o    Focus on all non-water releases to the environment, multi-media

     o    Databases which target a broad spectrum of chemical releases,
          beyond SARA 313

     o    1987 base year

     o    Stated goals ranging from 50 to 70% reduction over 5 to 8 years

     The separate 90% SARA air emission reduction goal is integrated into the
effort.

     Each of the divisions was encouraged to work independently in the evolu-
tion of this redirection, and multiple databases have resulted.  We are now in
the process of forming up a corporate-level consolidation — drawing in some
of the smaller operating units — so that we can track overall corporate
progress.  A high level of activity was required also in  1988 with plant and
divisional project teams to conceive of and list the projects required to
achieve the goals.  Some of these projects will require technical break-
throughs, so that over 50 research people have been reassigned to focus on the
program.  Priority is given in this effort to technologies that will eliminate
wastes at the source, but the overall achievement of goals will inevitably
require source reduction, new chemistry, recycling, reuse and treatment.

     Through 1988, Monsanto personnel achieved a first year  17% reduction
towards the 90%  air emission goal.  The second year, 1989, brought that
achievement to 36-38% vs.  1987.  We have to expect that progress will
become more difficult as we advance, but remain confident that the goal is
achievable.
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           PESTICIDE APPLICATION EQUIPMENT RINSE WATER RECYCLING

              by:   Darryl Rester, Specialist  (Engineering)
                   Louisiana Cooperative  Extension  Service
                   Louisiana State  University Agricultural  Center
                   Baton Rouge,  Louisiana 70803
                                  ABSTRACT
     The  Louisiana   Department  of  Agricultural   began  enforcement   of
pesticide  waste   disposal  regulations   on  January   1,   1985.      These
regulations,  which were  adopted in 1984;  apply to all  commercial  pesticide
applicators and  require  that they  adopt  procedures  and  install  facilities
to clean  the  equipment spray system,  mixing tanks and  pesticide  containers
without contaminating the soil, water or air.

     After evaluation  of various pesticide  waste disposal techniques,  60%
of Louisiana's 180 commercial aerial applicators  elected to use waste  water
recycling to dispose of aircraft spray system wash water.

     Waste water  recycling  involves collecting the aircraft wash  water  and
storing the water in tanks  for  use  as a diluent on future application  jobs.
Three  to  five,  250  to 500  gallon  tanks  are normally  used  to store  waste
from   various  pesticides   thus   preventing  label   violations   and   the
possibility of  crop  damage.  Thirty percent of  the applicators rinsed  the
aircraft  over the field being  treated.   Ten percent modified the aircraft
or used other waste disposal techniques.

     During the past  four years,  several applicators have been  interviewed
to  determine  the  cost   of constructing  and  operating  the  waste  water
recycling systems as well as information on problems.

     Most aerial  applicators used a 50 X  50' or 50 X 60'  concrete  wash area
and  three to five 250 to  500  gallon  tanks.  Most  systems  cost  $8,000  to
$12,000 with  a range of  $3,000  to  $15,000.   Very  few problems  were reported
and there were  no reported incidences  of crop damage from adding  low  rates
of wash water to  the pesticide mix.
INTRODUCTION
     During  1981 and  1982,  discussions were  held between  leaders of  the
Louisiana  Agricultural  Aviation  Association,  members  of  the  Louisiana
                                    563

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Cooperative  Extension  Service  (LCES)   and  the  Louisiana  Department  of
Agriculture.  These  discussions  covered techniques required to comply  with
proposed  Louisiana  Department  of  Agriculture  pesticide  waste   disposal
regulations (1,2,3).

     It was  generally agreed that pesticide  containers could be  converted
from pesticide  waste to  solid waste via  triple rinsing  (4).   Mixing  and
loading equipment  could be  washed and  the wash water  used for  dilution.
Based on EPA regulations, containment of water  used to  wash the exterior of
the aircraft  is not  required  (5).   However,  the applicator is ultimately
responsible for any  soil contamination.  Water  used to  wash the interior of
the spray  system must be  contained  and disposed of  in an environmentally
safe manner.

     Current research,  state of the art  technology  and other factors  were
reviewed.   It appeared that  commercial  aerial  applicators  had the  following
options for disposal  of pesticide waste:

    1.    Move off-site  for  treatment  or  disposal  at  a hazardous
         waste disposal facility.

    2.    Store on-site.

    3.    Treat on-site.

    4.    Recycle.

    5.    Modify equipment to clean in-flight.

     A  recent review of  current  technology indicates  that  during  the past 8
years  advances  have been made  in  several areas.   However,  the  cost of
collection and  transportation for off-site treatment or  disposal  is still
too  costly for most commercial  aerial applicators.    However,  this waste
disposal technique will be essential in special situations.

     On-site  storage or  treatment will require  collection and  containment
facilities plus the  treating  equipment.   Applicators who  plan to use  long
term storage  or treatment will usually be  required to  obtain a  permit  from
a regulatory  agency.  Engineering fees, legal fees,  insurance or bond costs
plus the  cost of the facilities will be very  expensive.   In addition,  very
few  commercial  applicators have time to operate such facilities  and comply
with ever  changing  regulations.

     It was decided that an  affordable,  environmentally  safe  system  must
consider  the  following factors (1,2,3,6).

1. The commercial  aerial applicators  must be able  to  install  and  operate
    the  waste   disposal  facilities   and  still provide  quality  aerial
    application at an affordable price.

2. The  applicator,  pilots  and/or  loading crew members   must  be  able to
    operate the system with  minimal training.
                                    564

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3.  The  system must be compatible with normal operations and not require  a
    lot  of management time or additional  labor.

4.  The  system must be designed to eliminate the storage of pesticide waste
    during the off season, thus  eliminating the  need for permits, additional
    insurance and record keeping.

5.  The  system must  dispose of  the  pesticide  waste  without  requiring  the
    transport of  waste to a hazardous waste disposal site.

     After  further  research in  1982,  it  was decided  that  waste water
recycling,  rinsing the  aircraft  over the  treated field  or  modifying  the
aircraft  for cleaning in flight would meet  these  five objectives.  It  was
felt that rinsing over the  field would  be feasible for aerial  applicators
who flew  less than 300 hours per year.   However, it would be  too costly  for
larger aerial applicators  (2).

     Engineers from  the  Louisiana Cooperative Extension Service designed a
waste water recycling  system  for applicators  with two  to  five  aircraft.
This system  was  evaluated on a  limited scale in 1982  and  1983.   Regulations
adopted  in 1984  by  the  Louisiana Department of Agriculture  legalized  the
use of  this  system (1,4).  Enforcement of the  regulations began on January
1, 1985.

     During  1982  - 1986  Louisiana Cooperative Extension Service  Specialists
and County Agents held annual  training  meetings in eight locations around
the state.   The  training meetings were usually attended by 20 to  40 aerial
applicators.  At each of these meetings detailed information and   handouts
were  provided on  the regulations  as well  as  techniques  for  compliance.
Ample  time  was  provided  for  questions.   Enforcement officials  from  the
Louisiana Department of  Agriculture  as  well as officers  of the  Louisiana
Agricultural  Aviation  Association   also  participated   in   each   training
session.     These   training  sessions  were   very  helpful   in   reducing
construction costs  for  the waste  water  recycling facilities  as well  as
enhancing compliance with the regulations  (2) .

     During  1985,  several  commercial  aerial  applicators  built  and used
waste water  recycling systems,  others rinsed the  aircraft over  the treated
field and a  few  applicators modified  the aircraft (3).
AIRCRAFT MODIFICATIONS
     Agricultural aircraft are equipped with  150  to  600  gallon spray tanks.
After the  completion of a spray job,  6  to  10 gallons of spray mix  will  be
left in the spray system.  Three to  five  gallons  of  this mix will be in the
bottom of  the spray  tank  and  three to  five  gallons will  remain in the spray
pump, spray booms,  and connecting  lines.   In addition,  residue will remain
on the inside walls  of the spray tank  (9).
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                          AIRCRAFT SPRAY TANK
Figure 1.  Aircraft spray tank illustrating location of various components
           and remaining 3 to 5 gallons of spray mix.

     As shown in Figure 2, a  simple  device  can be added to the pump intake
to remove 2  to  4 gallons  of pesticide.   This  pump  intake extension is now
commercially  available  at  a  reasonable  cost.   This  simple  device  will
reduce pesticide  waste  by  30 to 40%.    In  addition,  installing  a   check
valve in the loader line will eliminate contamination of this  area.
                           AIRCRAFT SPRAY TANK
                  CHECK
                  VALVE
EXTENDED PUMP INTAKE J  FRONT
Figure 2.  Aircraft  spray tank illustrating installation of pump  intake
           extension and loader line check valve.
                                   566

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     Commercial  firms now offer  on-board washout  systems.   These  systems
consist  of a 15  to 20  gallon  reservoir, a  pump  with a  D.C.  motor and  a
cluster  of nozzles  inside the spray tank.   The  reservoir can be a  tank or
collapsible bag  inside the  spray  tank.   The  reservoir  can be  filled  with
clean  water  for the  last  load  of  a  spray job.   After  exhausting  the
pesticide  the sides of the spray tank  can be  washed with  8 to  10 gallons of
water.   This water  is  then sprayed  onto  the  treated area.   the  sides of the
spray  tank are  then  washed a  second  time with  8 to 10  gallons of water
which  is then sprayed on the treated  area.   If required, the  aircraft can
return to  the loading area  where the  washout reservoir  is refilled and 20
to 30 gallons of water added to the spray tank.  This water  is  then sprayed
on the previously treated area to thoroughly clean the entire spray  system.

     On-board  purging or  wash-out  systems  eliminate  the  need for costly
containment  or  recycling  systems.    In  addition,  these  systems  are  very
convenient for use on remote sites.
WASTE WATER RECYCLING SYSTEM
     The waste water recycling system designed by  the  LCES  consists  of a 50
X  50'  to 50 X  60'  wash area, a  sump  to contain  the  waste water,  a  pump,
connecting  lines  and 3  to  5 holding tanks  with a capacity  of 250 to  500
gallons each (7).

     Cost varied  from  $1.50  to  $2.50 per square foot  depending on the site
preparation  required,  fill material required,  thickness of concrete,  type
of underliner,  amount of  steel  used for reinforcement and other factors.
As expected, applicators who did  most  or all of their own  construction had
the lowest  cost  (9).   Specifications for the wash area, sump and  tanks  are
contained  in  the  Louisiana  Department  of  Agriculture   pesticide  waste
disposal regulations (4,7).

     Louisiana regulations require elevation of  the pesticide waste  storage
tanks  so  leaks will  be readily  apparent.   Also,  a  secondary containment
structure  capable of  holding 110%  of  the  volume  of  the  largest  tank  is
normally required (4).

     The number and  size of  tanks depends on the size  of the operation and
the  variety  of  pesticides  used.     Under  Louisiana  conditions,   most
applicators  will  have three  to  five tanks with a capacity of 250  to  500
gallons each.   The  pesticide waste  water must  be  segregated and  stored  in
separate  tanks  to   avoid  label  violations and  the  possibility  of  crop
damage.

     Tank cost varied depending on tank  size, type of  tank, and whether new
or used.  A typical waste water recycling system is shown in Figure 3.

Data for construction  cost is shown  in  Table 1 and data for operating cost
is shown in Table 2.  This  data  is  based on a  system for  3  to 5 aircraft
with each aircraft flying 400 to 700 hours per year (9).
                                   567

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                                                              FERTILIZER
                                                              STORAGE
                                                        RINSATE
                                                        STORGAE
Figure 3. Typical waste water  recycling system.   Number and size  of  wash
          water or rinsate storage  tanks  can be  varied as required.
     TABLE 1. CONSTRUCTION COST FOR WASTE WATER RECYCLING  SYSTEMS
         50 X 60' Concrete Wash Area
         Five Tanks (500 Gallons Each)
         Plumbing and Electrical
         Pump (2 HP, 2" Capacity)
         Labor
                                    $   6,000
                                       3,000
                                       1,000
                                       1,000
                                       1,500
TOTAL
Range    $3,000 - $15,000
                                                 $  12,500
    TABLE 2.  ANNUAL OPERATING  COST FOR WASTE WATER RECYCLING SYSTEMS
         Depreciation (10 year life)              $   1,250
         Interest on Investment (12% Interest)         800
         Maintenance                                   600
         Labor (75 Hours @ $8.00)                      600

              TOTAL$3,250
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    The  concrete wash area can be used to  mix and load pesticides  as well  as
service  the  aircraft.    Therefore,   a portion  of  these  costs  should  be
attributed to other phases of the operation.
OPERATING PROCEDURES
     The applicator  must first decide what  pesticide  waste will be  stored
in each  tank.   Waste  from various pesticides must  be segregated to  avoid
label violations  and compatibility problems.  Each  tank should be  labeled
so that all pilots and loading crew members  will always  know what  is  stored
in each tank.   This  will reduce  the possibility of errors  in utilizing  the
waste as  a dilution agent  on  future  application jobs.   An example of  how
the tanks  can  be utilized  is  shown  in Table 3.   The  type waste stored in
the various  tanks will vary from  area to  area  within Louisiana as well as
from year to year.

     In  this  example,   the  pesticide waste generated  from  cleaning  the
aircraft  after applying  soybean pre-emerge  herbicides  will be  stored  in
tank number  one.   Most soybean  pre-emerge  herbicides will be applied  in
April -  May.   Therefore,  this tank can be cleaned and utilized to  store
soybean fungicide and insecticide waste during July - September.
    TABLE 3.   EXAMPLE OF WASTE WATER CONTAINMENT TANK UTILIZATION
TANK     TANK                 	TYPE OF WASTE WATER	
 NO.     SIZE                 EARLY SEASON               LATE SEASON

  1     250 Gal.            Soybean Pre-emerge        Soybean Fungicides
                            Herbicides                and Insecticides

  2     400 Gal.            Soybean Post-emerge       Soybean Defoliants
                            Herbicides

  3     500 Gal.            Cotton Pre-emerge         Cotton Insecticides
                            Herbicides

  4     500 Gal.            Cotton Post-emerge        Cotton Defoliants
                            Herbicides

  5     300 Gal.            Rice Herbicides           Rice Fungicides
                                                      and Insecticides
   NOTE: The number and size of tanks can be  varied to  meet  the  needs  of the
         applicator.   Pesticide waste water  from post-emerge herbicides can
         be applied  with pre-emerge  herbicides.  However,  waste  from  pre-
         emerge  herbicides  should   never   be  applied  with  post-emerge
         herbicides.
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    Waste water should be recycled by mixing one part pesticide waste  water
with four parts fresh water for dilution of the pesticide.

    The second step in utilizing  the  waste water recycling system  requires
that the applicator decide whether or not to wash the aircraft between
spray  jobs.    As  an  example,  when  changing  from  soybean  fungicides  to
soybean  post-emerge  herbicides  to  soybean  insecticides  it  will  not  be
necessary to wash  the aircraft.   All three types of pesticides are labeled
for application on  soybeans.  Therefore, phytotoxicity and label  violations
will not be a problem.

    The applicator  should use his  experience,  judgement  and knowledge  of
various  pesticides to  schedule  application  jobs  and aircraft  washing  to
minimize the volume of pesticide waste.

    The applicator should never store  pesticide waste  unless  he knows  of a
future  job  where  this waste  can be  added  to the pesticide  mixture  and
promptly applied.   Ideally,  this waste should  be  used within two  to  three
weeks.

     The  aircraft  should  be  rinsed  over  the  field being treated if  the
applicator is  uncertain  about how or when he  can  recycle  the waste.   This
is especially true  if the pesticide is seldom used in his operation.

     Rinsing  the  aircraft over  the treated  field can be  costly  and time
consuming.  However,  this may not be as costly  as  transporting the  waste to
an approved disposal  site or other types of on-site treatment.
 COLLECTION PROCEDURES
     The  applicator  can use two  techniques  to collect the pesticide  waste
water when washing the  aircraft  spray  system.   The  first  technique involves
dumping  the  waste on the concrete wash  area.   The second  technique  allows
pumping  the pesticide waste and wash water directly from the aircraft.

     If  the  first  technique  is  used,  the wash  area should  be washed  to
remove  all  soil particles  and  other debris.   The  aircraft is  then  taxied
onto  the  concrete  wash  area.    After  dumping  the  waste  pesticide,  the
aircraft  spray  system  is  thoroughly  washed.    This  includes washing  the
spray  tank  and purging  the  spray  booms,  spray  pump and all  connecting
lines.

     The  waste pesticide, spray  system wash water  and water  used  to  again
wash the  concrete wash  area drains  into  a sump located adjacent to the wash
area.

     The  waste pesticide and wash  water is then  filtered to  remove  trash
and  pumped  into the   storage  tank designated for  storage   of this  type
pesticide waste.
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     The  second  technique   requires   connecting   hoses   with  appropriate
adopters  to  the  outer  end  of each  spray boom  or  a  fitting  and  valve
installed on the  bottom of  the aircraft spray  tank.   The spray  system is
washed as previously described.  The waste  pesticide  and  wash water is then
pumped into  the storage tank.

     Use of  this  technique is recommended because  it  reduces contamination
problems  that could cause nozzle plugging as  well  as  contamination with
other pesticides.

     The use of flexible hoses to transfer the waste from the  aircraft to
the  containment tanks  is  recommended.   After  cleaning  the   aircraft,  the
hose  is  always flushed with clean water to  remove all  pesticide  residue.
This practice eliminates  cross contamination and possible  label  violations
as well as crop damage.  In  addition,  physically connecting the  hose to the
proper  storage tanks  assures that the wash water  will  be  stored in  the
proper tank.   This practice  also  holds true when removing pesticide  waste
water from the tanks.

     Applicators  report that  it  requires  at  least  80  to  100  gallons  of
water to thoroughly wash the  aircraft  spray system  (9).   The  aircraft  spray
system will  normally  contain 4 to 7  gallons  of  field  strength  pesticide
waste.   Therefore,  the pesticide  waste water  stored in the  containment
tanks will have a  pesticide  concentration of less than 10% of normal  field
strength (9).

     One part pesticide waste water should be  mixed with four parts  fresh
water when  using the  waste   for pesticide  dilution.   The resulting  spray
mixture will  contain a maximum of  2%  additional pesticide.   This  low  level
of  additional  pesticide  reduces   the  probability  of  label  violations,
illegal  residue  or  crop  damage  should an  error  be made   in  mixing  or
loading.
SUMMARY
     Interviews with  Louisiana aerial  applicators  after the completion  of
the 1989 spray season indicates that problems have  been  minimal.   Pesticide
waste water  can be  disposed of by  rinsing the  aircraft  over the  treated
field or recycling.  There were no reports  of illegal  crop  residues  or crop
damage caused by recycling of pesticide waste water (3).

     Aerial  applicators  flying  less  than 300  hours per  year  felt  that
rinsing the  aircraft  over the field costs less than constructing  pesticide
waste water  recycling  systems.   Larger applicators felt that the use  of  a
recycling system consisting  of three  to five  250 to 500 gallon tanks  and  a
50  X  50'   to  50  X   60'   concrete  wash  area  was  a good  investment.
Construction cost  ranged from $3,000  - $15,000  with  most  systems  costing
$8,000 - $12,000.   Annual operating cost was about $3,000  - $4,000 for  an
applicator with three to  five aircraft with each  aircraft flying 400 to 700
hours per year.
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                                REFERENCES
 1. Unpublished  Minutes  of  Pesticide  Revue Commission.  (1983  and 1984).
   Louisiana Department  of Agriculture, Baton Rouge, Louisiana.

 2. Unpublished  Minutes  of  the  Louisiana  Cooperative  Extension  Service
   Aerial  Applicators   Advisory  Committee.  (1981  -  1988).    Louisiana
   Cooperative  Extension Service,  Louisiana State University, Baton Rouge,
   Louisiana.

 3. Calhoun, H.  F., Elledge, Ken, and Impson, Dr. John, Louisiana Department
   of  Agriculture,  Baton Rouge, Louisiana, Personal  Communication (1981  -
   1989).

 4. LSA  3:3201   -   3280.  Section  1.0  -   31.0  Louisiana  Department  of
   Agriculture, Baton Rouge, Louisiana.

 5. Skinner,  Director,   Office  of  Solid  Waste   (WH-562A)  United  States
   Environmental  Protection Agency, Washington, D.C.  20460,  Memorandum on
   Regulation  Interpretation of Pesticide Applicator  Washing Rinse Water.
   July  22, 1985.

 6. A Guide  to  Minimizing Problems of Pesticide  Waste Management.  Illinois
   Pesticide Waste Management Task  Force, July 1,  1982.

 7. Noyes,   R.   T. ,   1989.    Modular  Concrete   Wash/Containment  Pad   for
   Agricultural Chemicals.   ASAE  Paper No.  891613.   American  Society of
   Agricultural Engineers.   St. Joseph, Michigan.

 8. Taylor,  A.  G., Agricultural Advisor,  Illinois Environmental Protection
   Agency,  Personal  Communication,  1985 and 1986.

 9. Louisiana Aerial  Applicators,  Personal Communication (1981-1989).

10 Rester,  Darryl,  1986.  Waste Water Recycling,  Paper No. AA86-001,  1986
   Joint Technical  Session  of  National Agricultural  Aviation Association
   and American Society  of Agricultural Engineers, Acapulco, Mexico.
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          POLLUTION PREVENTION IN TEXTILE WET PROCESSING
                   AN APPROACH AND CASE STUDIES

               by:     Stephanie  Richardson
                N.C. Pollution Prevention Program
                        Raleigh,  NC  27611
                             Abstract

                           INTRODUCTION
     Environmental concerns of the textile wet processing industry,
once limited to effluent discharge requirements, have expanded .to
include pretreatment specifications, aquatic toxicity, color, air
emissions, and restricted  landfill  availability.   Additionaly, a
more aware and  environmentally sensitive public  has  even forced
textile public relations into the environmental arena.

     Ever-rising costs of potable, process-quality water, coupled
with wastewater  treatment,  has  put to  death  the  theory  that
"dilution is  the solution  to  pollution."   Plant  management has
finally  come  to the  realization that  there  is  often  a direct
relationship between pollution and profits.  Increased pollution,
resulting  from  wasteful   handling  of   dyestuffs,   chemicals,
commodities,  excessive water use, improper inventory control, and
lax maintenance  programs,   produces  higher  wastewater  treatment
cost,  increased chemical cost,  higher water cost, and ultimately
leads to reduced profit margins.

                             METHODS

     Taking a "fresh look" at a facility, its  operating procedures,
the products used in processing, and the waste produced, can lead
to a combination of approaches resulting in waste  reduction.   A
"fresh look"  is accomplished by someone with  no preconceived ideas
or answers in hand—someone  who will ask  why without  the fear of
repercussions or ridicule.   A plant walk-through approach will be
outlined with areas to pinpoint for closer examination.

     This action, followed  by a detailed review  of the material
safety data  sheet  information,  inventory QA/QC    practices  and
processes, can lead to explanations for aquatic toxicity problems
and other non-compliance problems.  Information on environmentally
harmful  dyestuffs,   commodities  and  chemicals,  with  possible
substitutes,  will be presented along with explanations of process
modifications which have been successful in the past.
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                     RESULTS AND CONCLUSIONS


    Actual case  summaries  of  successful approaches used by North
Carolina textile mills,  ranging from simple inventory control to
equipment modification to  equipment replacement,  will be used to
demonstrate that pollution prevention does pay.  It pays in dollars
for industry and in the environment  for the public.

                   BASIC  APPROACH - WASTE AUDIT


     As is the case with most manufacturing facilites, waste in a
textile wet processing  facility is  found in  four basic arenas—
waterborne, airborne, hazardous and solid.  Each waste stream comes
with its own unique management problems; however, the  initial steps
taken to deal with these wastes should be the same—elimination and
reduction.  The best first step toward proper waste management is
a waste audit.

     A  waste   audit  not  only  identifies  and quantifies  waste
streams, but it  further  identifies the practices, procedures and
processes which result in waste generation.  Further, it provides
the basis  for  the collection  and  evaluation of technical  and
economic data necessary to select appropriate waste reduction and
management techniques (1).  Using six basic steps beginning with
1)  developing a  written  corporate waste  reduction  policy  and
progressing through, 2) audit  team selection,  to  3)  gathering of
all available  background  data, to  4) developing  a  plant  flow
diagram and conducting an in-plant  survey to, 5) performing a mass
materials balance for each process, and finally to, 6) the
technical and  economic evaluation of waste reduction alternatives,
the waste  audit  approach can  become a simple tool  used to help
construct the  waste reduction plan  (2).

     As is apparent  by the  first step  in  the waste  audit,  the
development of a waste reduction plan must begin with  true and real
corporate commitment which is easily identified and understood by
all employees.  Employees will rise to or fall to whatever level is
expected of them; therefore it  is essential that the commitment to
waste reduction is made apparent and the  goals of expectation be
set at achievable levels.   Employees are the first line of defense
against waste  generation;  therefore  they are  the key  to  waste
reduction.  Proper education of employees as to what a waste is,
where it comes  from,  the effect it has on the environment,  the
effect it  has  on  profitability  and ultimately their job stability,
can help assure that the waste reduction alternatives adopted in
step six will  be properly implemented and maintained.
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                     APPLICATION TO TEXTILES

     Traditional  areas  of  concern when  dealing  with  textile
effluents have  been BOD, COD,  TSS  and oils.   These parameters,
though still  important,  have recently been  overshadowed  by such
issues as aquatic toxicity, color, and metals  and chloride effluent
limitations.

     The best approach to dealing with all  these  concerns is the
examination and evaluation of all products used  in a facility.  By
insisting that chemical and dye  vendors provide  information on BOD
and COD  as well as other essential data  found on  the Material
Safety Data Sheets  (MSDS), educated decisions can be made regarding
appropriate  substitutions which can  reduce effluent  pollutant
loadings.  Additionally  prescreening of  all  products used in the
facility and testing of incoming ingredients can provide valuable
information on pollutants which may be introduced indirectly (5).

CHEMICAL CONSERVATION

     Many  textile  mills  use  excessive  and  even  unnecessary
chemicals. Often chemicals are added to a dye recipe to counteract
a negative side effect of another ingredient instead of finding a
substitute for the  offending chemical.  This  approach can result in
a series  of unnecessary chemical additions which  negatively affects
effluent quality and processing costs  (5).

     All processing recipes should be reviewed and reduced to their
original base state.  If a problem arises from the base state then
chemical  substitutions  should be considered in lieu of chemical
additions.

     Excess  chemical usage  also results  from lack of  precise
measurement techniques.   These  techniques range from the "scoop"
method of chemical addition  to  lack  of specifics  on  filling  of
machines  with water, finishes  or  other mixtures.   By providing
specific  instructions and metering/measurement equipment,  both
chemical and water usage can be reduced.

     Another simple approach is  to use  available data to formulate
only the quantities of finishes  needed. If data is not available,
then a data base should be established  which  will eliminate excess
quantities from been washed down the drain.

METALS LOADINGS

     When  attempting to  isolate and  reduce metals  loadings  in
textile effluents,  all aspects of plant operation must be examined
because  metals sources  can  be  found  from incoming  water  to
maintenance chemicals.
                               575

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Water Supplies

     Water supplies, in particular well water, can contain elevated
metals  levels;  therefor,  incoming  water  should  be  tested  to
determine  the  base level  from which  to  work.   Additionally,
seasonal  water evaluation is  recommended as water  treatment is
often adjusted seasonaly.

   Incoming  water  has  in  some cases  contained  metals  loading
exceeding  required  effluent limits. It  is not  uncommon  to find
significant  levels  (>lppm)  of  zinc,  copper, and  iron  in public
water supplies (4).

Incoming Fibers

     Incoming fibers often contain metals, both naturally occurring
and added.   Natural fibers such as  cotton adsorb metals from the
environment  during growth.   The   addition  of  antistatic  and
antifungal treatments often result in manmade (and natural)
fibers arriving with elevated  metals  loadings.   Other sources of
metals contamination of  incoming fibers  include warp  sizes and
machinery  oils as  well  as polymerization catalysts in  manmade
fibers (4).

Oxidation/Reducing Agents and After Treatments

     Oxidizing/reducing   agents  and   after   treatments   have
traditionally  contained metals.   Although the  use  of dichromate
oxidizers has basically been replaced with periodate, bromate and
peroxide oxidizers,  they are still used in many laboratory cleaning
chemicals.  Examination of all laboratory testing and cleaning
chemicals  is therefor  recommended.   If the  use  of  dichromate or
other metal-bearing solution is to continue in the laboratory, an
alternate method of disposal should be established.

     Examination  of reducing  agents  may  identify  metal-bearing
solutions which can be replaced with nonmetal-bearing treatments.
An example would be  the use of  sodium hydrosulf ite in lieu of zinc
stabilized sulfoxylate (5).  Copper sulfate is still being used as
an aftertreatment for direct dyes, but is  being replaced by organic
resinous fixatives.   This eliminates the metal contributions, but
increases the BOD and nitrogen loadings in the effluent.  The use
of epsom  salts  as   an  antimigrant  until the  application  of  a
fixative from a continuous resin finish formulation can reduce the
BOD,  nitrogen and metals  loadings (5).
     Metals can be expected to occur in certain dye classes.  This
data has been published by the American Dyestuff Manufacturers
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 Institute  (5).   Most of these dyes are green or blue and usually
 occur  in the  74000 series  of chemical  constitutions  which are
 phthalocyanine dyes  and pigments  (4).  The  first and most obvious
 approach to this source is the total replacement of the metalized
 dye;  the second  approach is  to  use  a  metalized dye  only when
 specific contracts mandate their useage;  the third  approach  is the
 replacement of only a portion of the metalized dye thereby reducing
 but  not eliminating  the  metals;   and,  the final  approach  is to
 assure complete exhaustion of the  dye onto the fabric.   This  can be
 accomplished   by    adjusting   time,   pH,   temperature,   salt
 concentration, fixatives  and other parameters.

 Finishes and Repair  Procedures

     Tin, antimony and  zinc can be found  in water repellant, flame
 retardant, antifungal and antiodor finishes.  Reduction in metals
 from  these  sources  involves the  formulation of only  the volume
 needed and collection and storage of excess for future use.

     Repair procedures may involve the use of stripping ingredients
 such as zinc sulfoxylate-formaldehyde,  permangenate or dichromate.
 An  evaluation  as  to  the   need   of   these  activities  and  the
 ingredients used should be conducted.

 Miscellaneous/Less Obvious Sources

     Metals contamination of effluents can also be traced to less
 obvious sources.  Examples include zinc contamination of salts used
 in processing, metal-containing biocides used in cooling towers and
 air-wash systems, and  photographic processing activites  used for
 screen making. Additional sources include herbacides, pesticides,
 maintenance chemicals,  lubricating oils and needle oils.  A review
 of MSDS information should provide data on the type  and quantity of
 metal contained in each product.

 AQUATIC TOXICITY

     With the enforcement of  EPA regulations regarding the aquatic
 toxicity of effluents,  the  textile industry  has an  entirely new
 environmental problem  to address.   Determining the cause  of  an
 aquatically toxic effluent can be  extremely difficult as it may be
 a result of a single ingredient, a combination of ingredients, or
 other existing conditions. Further complicating the problem is the
 fact that toxicity problems sometimes appear and disappear for no
 apparent reason.

Metals

     Compliance  with effluent limits  has  lulled many  textile
 facilities into a false  sense of security.  Many  textile mills are
                               577

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in  full  complianace  with  discharge permits  with  exception of
toxicity.   Compliance  with metals  limits does  not necessarily
translate to compliance with toxicity limits.  For this reason it
is important to eliminate the use of  as many metalized ingredients
as possible.  If toxicity is sporadic then  examination of cleaning
or maintenance routines that occur infrequently is in order.

Salt

     The  traditional  approach  to aquatic toxicity problems in
textile mills has  been  a reduction in salt usage.   It is easily
understood that freshwater organisms  cannot survive in a saltwater
discharge.  More often than not, salt removal has not resulted in
toxicity  compliance.    This  is  not  intended to   downplay  the
seriousness of  over use of  salt in  the textile  industry  or the
problems faced by mills  in trying to comply  with chloride discharge
limits  of 230 mg/1 or  less.   It is  intended to point  out the
reality that there  are many other contributors  to aquatic toxicity
and  the seriousness  of  this issue.    Elimination of  salt usage
should  therefore  not  be  expected to immediately  solve toxicity
noncompliance problems.

Surfactants

     Surfactants,   detergents,   emulsifiers   and   dispersants
frequently  contribute to the  aquatic  toxicity faced  by textile
mills.  The action  of  a  surfactant is to lower interfacial tension
of water  and other materials  at  phase  boundaries.   This helps to
insure  even,   thorough   and  rapid wetting  and  penetration  of
processing  solutions  into  the  textile  substrates.     This
unfortunately is the same feature that causes toxicity to aquatic
life (4).

     There  is  ongoing research  into  the  relative  toxicities of
surfactants.  Results  indicate that there is considerable variance
in toxicities even  between similar types  of surfactants.   There
seems to be a general trend that,  all  other  factors being equal,
surfactants which  contain more hydrophyllic groups  (higher HLB)
have  lower  toxicity.    Another  approach is  to  consider  the
biodegradability of the  surfactant.  A surfactant with a moderate-
to- low toxicity that  will not degrade will produce  a  more toxic
waste stream that  a surfactant with  a higher  toxicity that will
easily degrade (4).

     One approach taken  for toxicity reduction  in wastewater is to
substitute LAE for  ethyoxylated octyl or nonyl pnenol(AP) wherever
possible. Though reducing toxicity, this substitution can increase
BOD (4).
                               578

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     Some rules of  thumb to remember in considering toxicity and
degradability of surfactants:
     -the more linear the molecule, the more degradable the
     molecule
     -branched hydrophobes are less degradable than linear and
      aromatic are the least degradable
     -BOD:COD ratios in  a textile mill usually range from 2.5:1
      to 5:1.  A very high ratio, >5:1, indicated poor
      biodegradability (4).

Quaternary Amine Compounds

     Quaternary Amine Compounds, "quats" are found in a variety
of uses throughout textile wet processing.  One major use is as a
softener or  finish  for  fleece  products.   Although this treatment
does provide a high  quality product, it can be the cause or a major
cause of aquatic toxicity noncompliance.


     The use of "quats" can be determined once again by a review of
MSDS information.  This  compound,  if  an ingredient in a product,
will be listed on the MSDS.   A  close review  should be conducted to
determine the  need  of any product containing  a quaternary amine
compound.  If the use is  necessary, then some form of waste stream
segregation  or other  method  of catching  the  waste  should  be
investigated.

Solvents

     Typical solvent emulsions  include use  as  scouring agents or
dye  carriers for synthetic  fibers.    Typically  these  materials
exhaust into the fiber and are later driven off as airborne waste
during drying.  Solvent emulsions can however become a part of the
wastewater stream through spills, leaks, drum washing activities,
batch chemical dumps and poor housekeeping.

     Objectionable chlorinated materials used  in scouring  can be
replaced  with  non-chlorinated  materials  such  as  xylene  for
chlorotoluene.  Solvents use in non-aqueous applications such as
machine cleaners or laboratory uses can be recovered for reuse or
pickup and disposal.   Solvents should be segregated by  type and
should not be disposed of via sanitary sewer (4).

                    CASE SUMMARIES
PROCESS MODIFICATION

     The  J.  P.  Stevens  Co.,  Lincolnton,  North Carolina,  used
biocides in the air washer in an attempt to control algae growth.
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The basic  "blow down"  and periodic cleaning from this system was
discharged  to  a  small stream.   Following stream analysis, which
indicated the discharge to be aquatically toxic, the North Carolina
Division of Environmental Management revoked the discharge permit.
When the city refused to allow the discharge into the  sewer system,
J.  P.  Stevens was  faced  with a  serious  problem.   The  air wash
system  was  necessary  for  the   carding,  spinning   and  winding
operations  and some form  of  disinfection was required to control
algae growth within the system.

     After  a review of available options, a decision was reached
to  install an ultraviolet  disinfection  system on the  air wash
system.   This closed-loop system  would solve  two problems.   It
would eliminate the discharge and the use of the biocides.

     The system installed,  provided by Hydro  Systems,  Inc.,  was
capable of  disinfecting 100 gpm of air washer cooling water.  As
can be  seen below, the payback  period was  less  than two years,
after which the company can show an annual cost savings of $2,578
(6).

             Capital cost	$4,560
             Annual Operating Cost	$  872
             Annual Biocide Cost	$3,450
             Difference in Annual Costs	$2,578
             Pay Back Period = 1.77 yr.
CHEMICAL SUBSTITUTION

     United Piece Dye Works located in Edenton, North Carolina was
faced with reducing the phosphorous in their effluent from 7.7 mg/1
to 1 mg/1.  Instead  of building  an expensive treatment system, a
decision was  reached to  approach  the  problem  through chemical
substitution.   Through a detailed analysis of prodution processes,
process  chemistry,  and  the  chemicals  being used,  sources  of
phosphorous were identified.   Chemical  susbstitution  and process
modifcations  were  made to allow  for  the  use  of  non-phosphate
chemicals.      Examples   include   the   reduction   in  use   of
hexametaphosphorous and the elimination  of  the use  of phosphoric
acid.  The  results are  environmental compliance with no capital
expenditures (7).

INVENTORY CONTROL

     West Point  Pepperell  in  Robeson County  in North Carolina
undertook a  program to evaluate all chemicals, dyes and commodities
used within their  facility.  A committee of employees was  set up
and  evaluations  took place based  on safety,  fire  potential  and
environmental  hazard of  each chemical.   Areas such as
                               580

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biodegradability, metal content and toxicity were considered.
By evaluating all chemicals  and  eliminating those not necessary,
and finding substitutes for those of a hazardous nature, West Point
Pepperell has greatly reduced their waste management cost as well
as reducing chemical costs.   Some examples of changes made include
the substitution of  a  water-based  cleaner  for  an organic solvent
cleaner, the rejection of dicholorbenzine dyes due to the benzine
base and the rejection  of a chloride catalyst for  resins due to its
association with bis-(cholormethyl) ether.

      The committee continues its work by evaluating all
chemicals proposed  for use  in the facility and  by  working with
vendors to assure that  the chemicals specified are environmentally
sound (7).

                           REFERENCES
1.  Kennedy, Bingham.  The Need for Environmental Audits.  In;
    Pollution Engineering.  July 1982.  pp 28-30.

2.  Richardson, Stephanie.  Waste Audit—A Self Help Approach to
    Waste Reduction.  In;  Proceedings of the 1989 Food
    Processing Conference. Georgia Institute of Technology,
    Atlanta, Georgia. 1989. p. 48.

3.  Developing and Implementing a Waste Reduction Plan.
    Pollution Prevention Pays Program, Raleigh, NC, 1988. 13pp.

4.  Smith, Brent. A Workbook for Pollution Prevention by Source
    Source Reduction In Textile Wet Processing.  Pollution
    Prevention Pays Program, Raleigh, NC, 1988.

5.  Smith, Brent.  Identification and Reduction of Pollution
    Sources in Textile Wet Processing.  Pollution Prevention Pays
    Program, Raleigh, NC, 1988.

6.  Smith, Edward J. and Whisnant, Ralph B.  Evaluation of A
    Teflon-Based Ultraviolet Light System On the Disinfection
    of Water in a Textile Air Washer.  Pollution Prevention Pays
    Program, Raleigh, NC, 1987.

7.  Case Summaries of Waste Reduction by Industries in the
    Southeast.  Waste Reduction Resource Center for the
    Southeast.  Raleigh, NC.  1989.
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                     THE BUSINESS COUNCIL OF ALABAMA
                      WASTE MINIMIZATION INITIATIVE

                         by:  David L.  Roberson
                              Alabama Power Company
                              Birmingham, AL  35291
    First  of all, I want to  thank you for the opportunity  to speak and
share  some information  about  the Business Council  of Alabama and  its
member  interest  and  efforts  in  the  area  of waste  minimization.  I
appreciate   the   Environmental   Protection   Agency   (EPA)  including
representatives  from  Alabama  businesses  in  the  information  sharing
process  and I  hope  to add to  the information already  provided by the
other speakers from Alabama.

        The  Business Council of Alabama  (BCA) is an organization  which
was  established in 1985 through the merger  of the Associated Industries
of  Alabama (AIA) and the State Chambers of Commerce.  The organization's
function  is  to  present  business  and industry  views and  concerns to
governmental  officials on the  State and Federal  levels to promote  the
business  climate  in  Alabama.  BCA  is composed  of approximately  2200
business  and industry  members  located throughout Alabama  in virtually
every  type  commercial  operation  from  small to  large scales.   These
members represent over 60 standard industrial codes.

    BCA  has developed standing committees to follow State, Federal, and,
on  occasion, local initiatives in several  areas, such as environmental,
industrial  relations,  governmental  affairs, and  health benefits,  and
advise  the membership of any potential  impact(s).  The committees, such
as  the Environmental  Resources  Committee, may form  subcommittees or a
task  force in  order  to expedite review  and reporting on  issues.  The
potential  resources  of  the  BCA  membership is  unlimited in  terms of
technical knowledge and information available by industry type.

    It  was a BCA task force, composed  of eighteen BCA member companies,
that  began working  with Mr.  Dan Cooper  of the  Alabama Department  of
Environmental  Management (ADEM) in 1988 to  address pollution prevention
and waste minimization issues.  We felt the time was right to implement a
program  to educate the  public and make  a concerted effort  to minimize
waste  at  all  levels of  our society.   There have  been numerous  news
stories  of mismanaged wastes  and we would  like to show  that reputable
companies can do the job right.

        The first step in our plan was to have the Governor call together
the  top corporate  executives from  around the  State and  urge them  to
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participate  in a  voluntary  effort to minimize  waste generation.  This
came  to fruition on November 17, 1988, when approximately 100 executives
came  together in Birmingham to hear from the Governor, the Region IV EPA
Administrator,  the ADEM Director, and  an executive from the  Ciba-Geigy
Corporation as they discussed the problems, the needs, and the challenges
which lay ahead in the area of wastes and their disposal.  The Ciba-Geigy
representative  gave an  excellent  presentation on the  efforts of their
Corporation  to reduce waste  by going to  process changes, raw  material
changes,  etc.

    The  BCA task force next  recommended that the original  committee be
expanded   to  include  other  groups,  such  as  education,  government,
environmental,  and the general  public.  On May  31, 1989, such  a group
came together for the first time, known as the Alabama Waste Minimization
Advisory Committee.  The Committee consisted of the Alabama Department of
Education,  the Alabama Department of Economic and Community Affairs, the
Association  of County Commissioners,  the League of  Municipalities, the
Business  Council of Alabama, the  Alabama Chemical Association, and  the
Alabama Department of Environmental Management.  Two representatives from
the  public at  large  were also included.   The goal statement  for this
group included the development of voluntary programs for the minimization
of  wastes  generated  in Alabama  and the  dissemination of  appropriate
information  to  affected  groups.   Activities  thus  far  have included
working with the Department of Education to include waste minimization in
school  curriculums and the development of a speaker's bureau and program
to  provide talks at  civic club meetings,  etc., on minimization.   As a
group,   we  have  also  provided  written  comments  on  proposed  State
legislation on recycling.

    Besides  serving on the advisory  committee, BCA members have  worked
with  the  Hazardous  Material Management  And Resource  Recovery Program
(HAMMARR)  at  the  University of  Alabama and  have invited  the HAMMARR
Program  Directors  to  make presentations  to BCA's  members on  several
occasions   regarding  the  programs  available  for   industry  and  the
possibility .  of  having  joint  seminars  around   the  State  on  waste
minimization and regulatory compliance.  We have taken an active part in,
as  a co-sponsor for the Auburn University Engineering Extension Service,
an annual conference on hazardous waste and waste minimization, providing
speakers  from our membership to address case studies and other technical
information.

    Why  do we  want to  make the  effort to  encourage waste  reduction?
Let's  look at  a  slide that shows  what industry faces  in making waste
management  decisions today and then let's look at  why we want to make a
more concerted effort.

    It  is to industries'  advantage to look  for ways to  minimize their
solid  and hazardous wastes, as well as any  other potential for waste at
their  facility,   such  as in  water use.   When you  consider that  most
households  can place their solid waste at the curb and have it picked up
and  worry no  more  and yet industry  must provide for  treatment and/or
                                   583

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disposal,  either on-site or  off-site at ofttimes  considerable expense,
common  sense prompts  the question,  "Why pay  if you  can eliminate  or
reduce?"   This represents both sound waste management and good financial
sense.   It  makes  sense  to  allow  groups  such  as  the  Bicentennial
Volunteers,  Incorporated  (BVI),   or  Shoals,  Inc.,   groups  of retired
engineers  and scientists working in Tennessee and  Alabama to go through
facilities  and  perform  non-regulatory waste  minimization assessments,
because those of us who work in the same production environment daily may
overlook   the  obvious  while  an  experienced   newcomer  in  the  same
environment may identify a major savings.

    We  (BCA) held our first Environmental Conference in February of this
year in Montgomery and had representatives from the Alabama Department of
Environmental  Management and Region IV  EPA discuss their programs.   We
provided  case studies and research  literature from the Waste  Reduction
Resource  Center,  the  Chemical  Manufacturers  Association, and  EPA to
members and there was a lot of information sharing between members, which
was  the purpose of the meeting.  We had over ninety participants at this
first  conference with a lot of interest  shown in continuing the efforts
within BCA.  We also provide information on our programs and of available
information  through the  monthly  BCA newsletter which  goes to all  the
member companies.

        This  year  we  plan  to  provide,  within  the  BCA  membership,
roundtable   discussions   at   various  locations   in  the   State  for
environmental  problems and issues which  members may share with  others.
Many  people tend to  think  they are the only  company with a particular
problem,  but  in  sharing information  we feel  a teamwork  will develop
further  to solve some of these problems.   We see having a cross-section
of industries at each of the meetings should provide for more information
being  shared.   We  are also  requesting that  industries write  up case
summaries  of  minimization  efforts  in  the  same  format  of  those in
literature  from  the  Waste  Reduction  Resource Center  to provide  our
members  with guidance  and contacts  for their  own particular  facility
efforts.

        I  work  for  a  utility  and  we  encounter problems  that other
companies  also have and I will go  through  a few slides and address some
of  the issues.  There have  been major savings from  doing simple things
like  segregating waste streams better, something that in the past was not
done.

    I  hope that I have given you an  idea of the interest and activities
within  BCA  and  again, thank  you for  your time  and if  you have  any
questions, I will be glad to try to answer them.
                                    584

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       WASTEWATER RECYCLE FACILITY AT IBM EAST FISHKILL
             BY: James G. Sales
                 Mgr., Material Specification and Assurance
                 International Business Machines, Corp.
                 Hopewell Jet., New York 12533
                           ABSTRACT
     IBM East Fishkill is a semiconductor manufacturer located in New
York's Hudson Valley. Continued growth on the site has increased water
and wastewater demands significantly.
     To meet these increased demands, a recycle facility was built to
treat relatively dilute inorganic industrial wastewaters and use them as
cooling tower feedwater. Because the recycle system consumes relatively
"clean" waste streams, the available dilution at the final effluent
discharge was reduced. This has resulted in a fluoride removal step being
added to the wastewater treatment process.
     The Wastewater Recycle Facility thus integrates two distinct
operations. The first is a highly automated, monitored and controlled 1.2
million gallons per day process, which segregates and treats industrial
wastewater for reuse.  The second is a polishing process which reduces
lime precipitated Fluoride and Heavy Metals Treatment Facility effluent
fluoride levels via a phosphoric acid addition process. A 90-95% removal
efficiency is achieved.
     This integrated recycle concept has allowed the site to reuse
millions of gallons of wastewater with no detrimental effects to the
cooling system nor final effluent discharge quality. In fact, fluoride
levels in the effluent have been lowered since the recycle system has
been operational.
                                    585

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                         INTRODUCTION
     IBM East Fishkill is a semiconductor manufacturing facility located
in New York's Hudson Valley. Continued growth at the facility has
increased our resource demands over the last two decades. This growth has
created projected shortfalls in both the site's water supply and
wastewater treatment capacities.  To meet these shortfalls, a wastewater
recycle facility was constructed.
     The Wastewater Recycle Facility treats relatively dilute inorganic
industrial wastewater for use as cooling tower feedwater. Several major
benefits occur from the switch from potable water to recycled wastewater
feedwater. Water supply requirements are reduced with the substitution of
wastewater for potable water. Wastewater treatment requirements are also
reduced through the evaporation of the wastewater from the cooling towers
and the elimination of wastewater associated with producing potable water
from well water. The net effect is less water supply required and
wastewater discharged.
     Several factors weighed in determining the components that make up
the system. First, IBM East Fishkill is independent in its water supply
and wastewater treatment.  Water is supplied to the site from numerous
on- and off-site production wells. Suitable new well locations were at a
minimum several miles away, making future well water supply less
desirable, not only from a control stand point but from a cost one as
well. Treated wastewater, industrial and sanitary, is discharged into a
New York State class C(T) trout stream.  Final effluent discharge limits
are stringent because of the stream's designation and the discharge flow
in relation to the stream flow. A number of treatment facilities treat
the various segregated industrial and subsequently combined industrial
and sanitary wastewaters to meet those limits.
     Second, the wastewater was to be used as feedwater to the site
cooling loop recirculation system. The feedwater is used to replenish
cooling water that has evaporated. The water is sprayed countercurrent to
airflow, in the cooling tower, where evaporation cools down the remaining
water. This cooled water provides the temperature differential in the
condenser tube, where it is heated, then recirculated to the cooling
tower. This cycle continues until the water in the loop's concentration
exceeds tolerable limits. Then a portion of the cooling water is bled
from the system as blowdown. An important factor is controlling the
equilibrium of the system, such as, corrosion, fouling and scaling. Any
increase in any of these factors could result in loss of efficiency or
shutdown of the chilled water system. This is accomplished using
treatment chemicals and filtration.
     The last factor is a result of the first two. Because the recycle
system utilizes relatively "clean" industrial waste streams, the
available dilution at the effluent discharge is reduced. Meeting the
stringent permit limits became a major concern.
                                    586

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     A two year feasibility/pilot study was undertaken. The results
addressed the chemical nature of the dilute inorganic industrial
wastewater, its projected effects on the cooling water system, the effect
of increase chemical constituent concentration on the effluent discharge
limits and the system design parameters. The program was a success and a
two phase facility was constructed. The major portion of the facility is
utilized to recycle the wastewater. The other phase is to reduce the
final effluent discharge fluoride concentration.
     This paper will describe both of these systems and the results
achieved by their implementation.
                 WASTEWATER RECYCLE FACILITY
     The Wastewater Recycle Facility is an integrated system that either
has constructed new facilities or has enhanced existing systems.  It is,
as will be shown, a complex system which depends on continuous chemical
monitoring for its control. The strategy behind the facility was to be
totally automated, monitor and control feedwater quality versus treat and
utilize all dilute inorganic industrial wastewater, operate 24 hours per
day and meet or exceed all regulatory requirements. This section
describes both the wastewater recycle system and the enhanced fluoride
removal system.
INORGANIC INDUSTRIAL WASTEWATER RECYCLE
     The recycle facility was designed to minimize the treatment required
to allow recycling of the wastewater.  It has a design capacity of 1.2
million gallons per day. The facility has five main components:
monitoring and control, neutralization, disinfection, filtration and
storage ( See figure !.)•  Enhancements to cooling water system were also
implemented.  They were: adding side stream filtration to eliminate
suspended solids and precipitated metals; changing cooling water
treatment chemistry and adding automated feed systems to prevent
corrosion, fouling and scaling; and adding covers on the cooling towers
to prevent biological growth (these will not be discussed in any detail).
     The monitoring and control system is critical to the success of the
facility. Five individual wastewater streams and a mixing tank are
automatically monitored on a continuous basis for six constituents
(copper, chrome, ammonia, fluoride, phosphate and pH).  These
constituents were chosen based on their potential detrimental effects on
the cooling loop system as well as their variability during the pilot
study.  Each had a risk of exceeding cooling tower feed water limits.
Limits have been set for the individual wastewater streams as well as the
mixing tank. If exceeded, that stream or the mixing tank will be diverted
to the Industrial Waste Treatment Facility until it recovers.
                                    587

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     The incoming pH is highly variable  (pH from 2-13) and requires
neutralization.  A two step neutralization  is carried out. A rough
adjustment is done in the mixing  tank at the Industrial Wastewater
Treatment Facility and a further  polishing is carried out downstream
prior to filtration.  Cooling water  limits are pH 6.5 - 7.5.
           WELL
           WATER
          SUPPLY
 POTABLE'
L"
WATER
             DILUTE   '
            INORGANIC
           INDUSTRIAL I
          .WASTEWATER!
...i    ~\J
                                 OOOUNO
                                 TOWER
                                                    RECYCLE SYSTEM
                         EFFLUENT DISCHARGE
     Figure 1.  Wastewater Recycle System's  Integration
                into the Cooling Tower Feedwater  System.
     Disinfection is accomplished utilizing  sodium hypochlorite prior to
the filtration step. Disinfection prior to the  filters keeps them free of
any biological growth.  Residual chlorine level is controlled before
storage to 0.7 ppm free and 1.0 ppm total chlorine.  The variability of
the wastewater and the conditions and length of storage make control of
residual chlorine extremely difficult.  This  is  one area in which recycled
wastewater has a disadvantage over the extremely stable potable water.
     The wastewater is filtered to remove any residual particles
including any post precipitation occurring from neutralizing a normally
acid wastewater stream.  Three multimedia sand  filters are utilized and
feature automatic backwashing based on pressure differential. These were
designed to remove ninety five percent of the incoming particles greater
than 2 microns.
                                    588

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     The recycle system depends on the quantity of wastewater produced by
the manufacturing operations. This can be highly variable depending on
time of day, day of week, etc. Storage of the raw (after rough
neutralization) smooths out this variation and allows sizing of treatment
equipment for somewhat less than peak conditions. Cooling tower feedwater
demand is also highly variable, particularly time of year and time of
day. An 100,000 and 200,000 gallons storage tanks handle the raw
wastewater and recycle product, respectively.  When the quantity of
recycled wastewater cannot meet feedwater demand, potable water is added
to the recycle product tank.
FLUORIDE REMOVAL PROCESS

     The reduction in the available dilution at the effluent discharge
was predicted to have caused the effluent fluoride concentration to be
above the State Pollution Discharge Elimination System (SPDES) permit
limit of 1.5 ppm average and 2.5 ppm maximum. Thus, the requirement was
placed on the Wastewater Recycle Facility to reduce the fluoride
concentration in the site's final effluent discharge. Several wastewater
streams were evaluated for further treatment. The Fluoride/Heavy Metals
Treatment Facility effluent was chosen because of its relatively low flow
and high concentration compared to the other streams.
     This facility treats concentrated wastewater primarily from
manufacturing first rinses and has a capacity of 250 gallons per minute.
Fluoride and heavy metals concentrations are reduced by utilizing a cold
lime process.  Lime is added to precipitate fluoride as calcium fluoride
and metals as metal hydroxides.  A flocculant is added, and the
wastewater is clarified. The sludge is dewatered and sent to a cement
kiln as a raw material. The clarifier overflow (Fluoride/Heavy Metals
Treatment Facility effluent) fluoride concentration is further reduced in
the Recycle Facility's fluoride removal process.
     Tricalcium phosphate had been successfully utilized to remove
fluoride spikes in the site's Industrial Wastewater Treatment Facility.
The fluoride reduction process is based upon the chemistry of the
tricalcium phosphate - fluoride interaction.  Research was done in the
potable water treatment field to produce tricalcium phosphate by adding
phosphoric acid to a lime slurry. (1,2) The clarifier overflow
characteristics, high pH (11-12) and calcium concentration ( 1400 ppm),
allowed this concept to be utilized. The Fluoride/Heavy Metals Treatment
Facility's reduction process (clarifier overflow) is now followed by the
addition of phosphoric acid. The wastewater is agitated and an insoluble
fluoroapatite is formed which is then settled in a clarifier. The
resultant sludge is mixed with the lime sludge and dewatered. Figure 2
illustrates the fluoride removal process.
                                    589

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                 i      !
            njuonoe
           r
  FLUORIDE
HEAVY METALS
  REDUCTION
                PHOSPHORIC
                ACID
         F - 10-U ppm
         pH - 11.4
         Ca B 1400 ppm
                             FLUORIDE
                             REMOVAL
                                                        f
                          CLARIFICATION
                        ^IDEWATERING;
            SYSTEM
      1
           F < 1 ppm

FURTHER TREATMENT
RAW MATERIAL
   FOR
CEMENT KILN
         Figure 2.  Fluoride Removal Process Utilizing
                   Phosphoric Acid.
                          RESULTS
     Both the wastewater recycle and the fluoride removal systems  have
exceeded their goals. Expansion of well water supply and wastewater
treatment systems  have  been minimized.  Capital expenditures based on
implementing the Wastewater Recycle Facility have been cut by fifty
percent and operating costs lowered. The final effluent is well  within
the permit limits  and fluoride concentration has in fact been lowered.
                                   590

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WASTEWATER RECYCLE  FACILITY
     The facility  has  fed the cooling towers for several years. Water
savings for  1989 have  reached approximately 200 million gallons (over
500,000 gallons per  day  average).  This is 86% of the total cooling tower
feed water.  The savings  remain seasonal ( see figure 3), only limited by
the dilute inorganic industrial wastewater's quantity and quality.
   a
   o
1.1



0.9

o.a

0.7

0.6

0.5

O.4

0.3

0.2

0.1

0.0
                 JFMAMJJASONDJFM

                                                 1990
                                1989
                                RECYCLE
                                           POTABLE
          Figure 3. Cooling  Tower  Feedwater Sources
     The recycled wastewater  is  superior to potable water in that its
total dissolved solids  (a measure  of  recirculation cycles) is less than
potable water. Cooling  loop cycles of concentration are averaging from 5-
7, the same as with potable water.  Variability in recycled wastewater
characteristics does require  more  frequent  adjustment of cooling loop
treatment chemistries than does  potable  water.   No detrimental effects,
however, such as corrosion, scaling or fouling have been caused by
utilizing the recycled  wastewater.
                                     591

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FLUORIDE REMOVAL  PROCESS
     The goal of this  process was to reduce the fluoride concentration in
the Fluoride/Heavy Metals  Treatment Facility effluent so that the SPDES
permit limit of 1.5  ppm would be met.  This goal was exceeded in that the
effluent discharge concentration has been reduced 50% since 1986 (before
the Recycle Facility).  For comparison another effluent constituent,
copper, shows stability over  the period (see figure A) although no steps
were taken to reduce its concentration.
          1.4

          1.3

          1.2

          1.1

           1

          0.9

          0.8

          0.7

          0.6

          0.5

          0.4

          0.3

          0.2 f-

          0.1 -

           0
-t-K
          ,4s
                 1986
              -» I •! I I I I I
                             1987

                            D  FLUORIDE
     1988


     +   COPPER
1989
           Figure 4. Final Effluent Discharge
                     Fluoride\Copper  Concentration.
     The effluent from the fluoride  removal  process has averaged 1 ppm.
This is over a 90% reduction.  Fluoride  concentration is controlled by
adjusting the phosphoric acid dosage.  Phosphate concentration in the
process effluent could be detrimental  to subsequent treatment facilities.
The sanitary facility could be especially effected because it is a
biological treatment facility. Phosphate levels have been controlled by
controlling the dosage rate of phosphoric acid.   Correlation between acid
dosage and effluent concentration  is excellent  - 0.9.
                                     592

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                           SUMMARY
     The Wastewater Recycle System has met all its objectives. The system
has reduced well water supply consumption by approximately 500,000
gallons per day in 1989.  On a peak day its saved well over a million
gallons.  Fluorides in the final effluent discharge to a class C(T) trout
stream have not only met the limit, but have been reduced by 50%. This is
from an average of 1.15 ppm in 1986 to 0.57 ppm in 1989.

     Both well water supply and wastewater treatment system expansions
have been minimized by reducing the quantity of flow required.
Expansions of approximately one million gallons per day would have been
required to keep up with peak monthly flows. A precious natural community
resource, water, was saved.
     Capital and operating costs were avoided by utilizing the Wastewater
Recycle Facility. Capital cost avoidance amounted to 50%.  Therefore,
recycling makes good business sense.
                          REFERENCES
1. Adler, H. and Klein, G;  Removal of Fluorides from Potable Water by
   Tricalcium Phosphate. Industrial and Engineering Chemistry. 40: 163,
   1938.

2. O'Brien, W.J.  Control Options for Nitrates and Fluorides.
   Water/Engineering and Management.  130: 37, 1983.
                       ACKNOWLEDGEMENT
     I would like to thank Robert Dennis for his help in supplying
current data for the Recycle Facility.
                                    593

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               State Mandated Pollution Prevention -
     Legislative and Regulatory Initiatives to Compel Reduction
                   of Use of Hazardous Chemicals
                   John H. Scagnelli, Esq.
                      WHITMAN & RANSOM1
I.   INTRODUCTION.

          There  has been  a  growing trend  at  the State  level
toward the  enactment  and consideration of legislative  bills and
regulatory programs to  require companies to  reduce their use of
hazardous  chemicals  in manufacturing  processes.    This  paper
explains  current   legislative   and   regulatory  initiatives  in
several  states  and  distills  the  state  approaches  with  the
objective of  suggesting a  uniform model state  approach towards
pollution  prevention.  A  uniform  state  approach  is  urgently
needed, particularly  for companies with  multi-state facilities.
Without a uniform  approach,  states will create disincentives and
obstacles to the development of pollution prevention.


II.  CURRENT STATE REGULATORY AND LEGISLATIVE INITIATIVES.

     1.  California.

     In  1989,  California enacted  the Hazardous  Waste  Reduction
and  Management Review  Act.   The  Act requires  industries  which
     ^•Partner in Charge  of  Environmental  Practice Group; Whitman
&  Ransom,  One  Gateway  Center,  Newark,  New Jersey  07102-5398;
Telephone: 201-621-2230; Telecopier: 201-643-4640
                             594

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generate 12,000 kilograms or more of hazardous wastes annually to
review their operations for potential measures for reducing waste
generation  and  to   prepare   plans  showing  an  implementation
schedule for  selected source  reduction  measures.   The  Act also
requires these  generators to  submit a  performance  report which
presents the results of their waste reduction planning efforts.

          The  Act  is administered  under  the California  Waste
Reduction  Program  with  other  waste  reduction programs.   These
programs  cover  several  areas,   all  directed to  prevent  land
disposal of hazardous waste and,  ultimately, its generation.  The
Hazardous  Waste  Reduction  Grant  Program  provides  funding  to
universities, governmental agencies and private organizations for
the  research  and  development  of  hazardous  waste  reduction,
recycling  and treatment  technologies.   The Waste  Audits Program
encompasses  facility  site  visits  to  identify hazardous  waste
generated  and current waste  management practices.   The  Waste
Exchange Program publishes a  directory of  industrial  recycling
operations  and  assists  hazardous waste generators  in  locating
operations  which can  use their waste  streams for  feed stocks.
The   Technology   Transfer  Program,   finally,   develops  and
disseminates  information  on  waste  reduction,   recycling  and
treatment  technologies  and  develops  strategies  to  encourage
industry  to  eliminate  or  reduce  the  volume and  toxicity  of
hazardous waste.2
          2.  Florida.

          The  Florida  Department  of  Environmental  Regulation
(FDER)  has  received one  of  fourteen  Integrated  Training  and
Technical Assistance  (RITTA)  grants to develop  a  State Training
Action  Plan  (STAP)  for  Florida state  personnel  and  hazardous
waste  generators.    The  STAP  Program  is directed  toward  the
objective of  reducing solid  waste,  including  hazardous waste, by
30%  by  1994  and significantly  reducing  the  number  of  small
quantity  hazardous  waste  generators  not  in  compliance  with
hazardous  waste  management  rules.    The  Program has  identified
deficiencies  in  Florida's system  for developing and  delivering
compliance oriented RCRA  training  and technical  assistance.   The
STAP  Program  has  recommended that Florida's  solid and hazardous
waste training and technical assistance programs be organized and
administered  as  a formal  consortium  of  State  universities  and
community colleges to provide training and technical  assistance
through  six  regional  training   centers,  called  the  Florida
     2Information  provide  by Alternative  Technology  Division,
Toxic  Substances  Control  Program,  State  of California,  Health
and  Welfare Agency,  Department  of  Health  Services,  714-744  P
Street,  P.   0.  Box  942732,  Sacramento,  California  94234-7320;
Telephone No. (916)322-3670.


                             595

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Environmental Training  and  Technical Assistance Network  (FETTA-
NET) .

          FDER   has  primary  responsibility  for  providing
technical assistance through its waste management program offices
and the Waste Reduction Assistance Program (WRAP) .-*

          3.  Illinois.

          The 1989  Illinois Toxic  Pollution  Prevention Act,  SB
1044, established  the Toxic Pollution Prevention  Program  within
the  Illinois Environmental  Protection Agency  ("Agency").    The
Program consisted of  identifying  federal  and  state laws relating
to  waste   disposal   and  toxic  substances   release,   promoting
increased coordination of efforts to administer and enforce those
laws, and determining how Agency programs should  be coordinated
or modified to  promote  toxic pollution prevention.   The  Program
is required under the Act to develop a toxic  pollution prevention
manual  for   Agency  inspectors  and  permit  reviewers,  establish
procedures  for   expediting  permit  application  reviews,  and  to
develop a list  of toxic substances  for priority toxic pollution
prevention  consideration,  based upon examination of toxic release
inventory reports filed under  the Federal Emergency Planning and
Community Right to Know Act of 1986.

          The Act  also  established a  Toxic Pollution Prevention
Assistance   Program  at  the  Hazardous  Waste   Research  and
Information  Center.   The  Program  established  at   the  Hazardous
Waste  Research   and   Information  Center  (HWRIC)   under  the  Act
increases the Center's  waste reduction work.    The Center  exists
within  the  Illinois  Department  of Energy and  Natural  Resources
(ENR) and promotes waste  reduction through a  series of programs.
The  Industrial  and Technical  Assistance  (ITA)  Program  provides
direct  technical assistance  to state industries, communities and
citizens with hazardous waste management problems and administers
the annual  Governor's Pollution Prevention Awards  to recognizing
efforts to  reduce  hazardous  and non-hazardous waste.  The Center
has  established  cooperative  college  and   university  programs
designed to augment  the implementation of the  Program,  and can,
if  it  chooses,   set  financial  charges  for  participation  in the
Program with the  resulting  monies  to be deposited in a  Toxic
Pollution Prevention Fund.

          Beginning January 1, 1990, any person may submit to the
     3June 5,  1990  Final Draft Report,  "A  State  Training Action
Plan  For Waste  Management",  prepared by  the Waste  Management
Training  and Technical  Assistance  Council,  in conjunction with
the  University  of  Florida  Center  for Training,  Research  and
Education  for  Environmental  Occupations,  3900  Southwest  63rd
Boulevard, Gainesville, Florida 32608-3848,  Contract No. HW113.


                             596

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Agency  toxic  pollution prevention  plans  involving  innovative
production  processes or  new  applications  of  technology.    The
Agency must  approve  proposed plans if  feasible  under applicable
law and consistent with prudent environmental practices.   Agency
approval  may  include  expedited coordination  and processing  of
applicable  permit applications,  cooperation  with requests  for
applicable  variances,  adjusted  standard   or  site  specific
standards and appropriate technical assistance.


          Illinois,  working  with  other  States  and  USEPA,  has
developed  the  Waste  Reduction  Advisory  System  (WRAS)   which
provides waste generators with options for reducing and recycling
industrial waste.   WRAS has  two components:   a Waste Reduction
Audit  Checklist  (WRAC)  and  the  Waste  Reduction  Information
Bibliography  (WRIB).   Illinois has  received  one of the  RCRA
Integrated Training  and Technical  Assistance  (RITTA)  Grants from
USEPA.  The  Agency and  HWRIC are working together to  develop and
implement  a  five  year  State  Training  Action  Plan   (STAP),  to
expand  the  RCRA Hazardous  Waste  Training  Program  for  Agency
personnel,  for  others  providing technical  assistance,  and for
generators,   and  to   develop   and   implement  pilot  technical
assistance projects focusing on waste reduction.

          Illinois is  also one  of  six  states selected by  USEPA
to implement a national research demonstration program called the
Waste   Reduction  Innovative   Technology   Evaluation   (WRITE)
Program.   The WRITE Program  is designed to evaluate  the use  of
innovative engineering  and  scientific technologies to reduce the
volume  and/or toxicity of  waste produced  from  the  manufacture,
processing and use of materials.4


          4.  Louisiana.

          In   1987,   Louisiana  enacted   the  Louisiana   Waste
Reduction Law, Act No.  657,  requiring  every  Louisiana generator
of  waste  to provide a report  to the  Louisiana Department  of
Environmental Quality regarding that  generator's waste reduction
efforts.  Generators must use data in their reports sufficient to
convey  an   accurate analysis   of  waste  reduction   previously
accomplished or  to be accomplished in the  future.   The data must
be  given  on an  output  production basis  and  give a  final  waste
reduction percentage based upon waste  generation  and production
data, not  based  solely upon  changes  in the  absolute  amounts  of
waste generated.
     4Illinois Hazardous  Waste Research  and Information  Center
Annual Report, July 1, 1988 - June 30,  1989,  submitted to the ENR
Board  of  Natural  Resources  and  Conservation,  February  1990,
HWRIC AD 89-014.


                              597

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          Louisiana in 1984 enacted Act No. 803 which  required a
research  and development  fee to  be  charged for  all  permits,
licenses,  registrations   or  variances  under  the  environmental
laws.    The  fees,  set by  formula,  are  designed  to  encourage
alternative  and  environmentally  sound  methods  of destroying,
recycling and neutralizing hazardous  waste.   The fees  generated
fund   the  Louisiana  Alternative   Technologies   Research   and
Development Trust Fund.5

          5.  Minnesota.

          In 1990, Minnesota  passed the Minnesota  Toxic Pollution
Prevention Act6.  The  Act establishes toxic pollution  prevention
as state  policy through several mechanisms.   The  Act expands  the
responsibilities  and  staff  of the  existing Minnesota  Technical
Assistance Program (MnTAP) which  assists companies in  identifying
and implementing pollution prevention measures.  In  addition,  the
Act  provides $150,000 in  grants  for projects  to  assess  the
feasibility of pollution  prevention technologies  and establishes
a  Governor's  Annual  Program  for  excellence   in   pollution
prevention.  Each facility which reports  toxic chemical releases
under  the Community  Right  to Know  Act  must  develop a  toxic
pollution  prevention   plan  establishing  goals  for reducing  or
eliminating  toxic   pollutant   releases.     The  plans   are
confidential but  each facility  must submit  an  annual  progress
report  based  upon the plan  to the  Minnesota Pollution  Control
Agency  (MPCA).    The  progress  report  is available  for  public
review.   If  the MPCA  determines that a report does not  contain
the  required  information,   the  company  may  be subject   to
enforcement action, following  a  public meeting in  the  community
where  the  facility  is   located.     Citizens  are  permitted  to
petition the MPCA to review deficiencies in a  report.

          The Minnesota  Office of  Waste  Management   (OWM) must
submit  annual  progress  reports   to   the  state  legislature
commencing January  1,  1991,  assessing the regulatory,  economic,
educational and  institutional  barriers to pollution prevention.
The OWM must also prepare a report to the legislature  by January
1,  1993  evaluating whether  to  require  companies  to   report  on
their use of toxic chemicals.

          Facilities required by the  Community Right to Know  Act
to report toxic chemical  releases must pay an annual fee  of  $150
for  each  toxic  pollutant released.   In addition,  each facility
that  releases  more  than 25,000   pounds  of toxic   pollutants
annually  must pay $.02 per  pound  not to exceed  $30,000, and  a
     5Act No. 803 (1984),  §§1065,  1065.2

     6Chapter 115D,  Minnesota Statutes.
                             598

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facility that  releases  less than 25,000 pounds per year must pay
a  $500 fee.   Large  quality generators  of hazardous  waste not
required  to report  releases under  the Community Right  to Know
Act must pay a fee of $500.  The first  fees are due on January 1,
1991 and are expected to raise approximately $1.2 million.

          6.  New Jersey.

          The  New  Jersey  legislature  is now  considering the
Pollution Prevention  Act,  Senate No.  2220.   The Act establishes
an Office of Pollution Prevention in the New Jersey Department of
Environmental Protection and a State-wide goal of a 50% reduction
in the use  or  discharge of hazardous substances over five years.
The Act also establishes a Pollution Prevention Advisory Council
in  the Department  responsible  for  reviewing  implementation  of
the Act and the  Department's criteria  for pollution prevention
plans.  Every  owner and operator of an industrial facility must
prepare a hazardous  substance  inventory and  certain facilities
must  submit pollution prevention plans to the  Department.   The
Act applies to industrial  facilities in the manufacturing sector
employing more  than 10 full-time employees,  and at which 25,000
pounds  or more of a hazardous substance are  manufactured,  or at
which  10,000 pounds or more of  a hazardous  substance  are used.
The substances  required to be inventoried, and  the use of which
is required to be reduced, are the hazardous substances regulated
under  the New Jersey Worker and  Community Right  to Know Act.  Of
the  facilities  submitting  inventories,  the  Department  would
select  between 10  and  15  facilities during  the  first  year  to
submit pollution  prevention plans,  with  each  year the  number of
facilities required to submit such plans increased by 50%.

          7.  Ohio.

          In 1979,  Ohio  established  the Ohio Technology Transfer
Organization (OTTO)  to  address energy  conservation  and to serve
as  an industrial  extension service  for business  and  industry.
OTTO  agents provide free  technical  assistance  to  Ohio business
and  industry  and  are  located  at  32  state  supported  two  year
technical  and  community  colleges  and  universities.   In  1986,
Governor Celeste named  OTTO to spearhead Ohio waste minimization
activities  and also  created  a  Waste  Minimization Task  Force
(WMTF)  including  representatives from  industry,  environmental
groups, state personnel and academia.

          Battelle  Memorial Institute,  under  contract with the
Ohio   Department  of  Development,   has  prepared   a  report  on
hazardous waste minimization identifying lack of information and
lack  of  technical  assistance  from  the  regulatory  and  non-
regulatory  community  as  the  principal  reasons  for  lack  of
progress  in waste  minimization  in  industry.   The  Fisher/Troy
Toxic Use Bill, introduced in the Ohio legislature,  would assess
a  $.10 per pound  fee  for hazardous  waste  disposal  with  the


                              599

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revenue  to  go  (i)  to  a  hazardous  waste  technical  assistance
center,  (ii)  to  increased technical  assistance,  and (iii)  to
increased regulatory control.

          Ohio  has  also  received one of  the  RCRA  Integrated
Training and Technical Assistance (RITTA)  grants  from USEPA'.
          8.  Oregon.

          In  1989  Oregon  passed  the Toxic  Use  Reduction  and
Hazardous  Waste Reduction Act  which  required  covered  Oregon
businesses  to  submit toxic waste  reduction and hazardous  waste
pollution  plans.8    The  plans   must   contain  written  policy
statements  articulating  upper management  and corporate  support
for  the  planning  process,  a  written statement  of plan  goals,
scope and  objectives, numeric reduction  goals for  certain  toxic
substances  and  hazardous waste  streams  and  analysis  of  toxics
use  and  hazardous  waste  streams.    The  development  of  cost
identifying  accounting  systems,   the identification   of  waste
reduction  opportunities   and   implementation   strategies,
establishment of employee awareness and training  programs and the
implementation  of  technically and economically practical  toxics
use  reduction  and  hazardous  waste  reduction options  are  also
required.  Annual progress reports in implementing the  plans must
be  submitted  to the  Oregon  Department  of  Environmental  Quality
(DEQ).

          Businesses  covered  by  the Act  include:  large  users,
those  users  of toxic chemicals   required  to report  under  the
Federal   Community  Right  to  Know Program;   fully   regulated
hazardous waste generators, those generators generating more than
2200 pounds per month of hazardous waste, or more than  2.2 pounds
per  month of   acutely  hazardous  waste;   and   small   quantity
hazardous  waste  generators,   those  generators   which  generate
between   220-2,200   pounds  per   month  of  hazardous  waste.
Conditionally  exempt  generators  of  hazardous   waste  are  not
required  to  develop  plans,   although  they  are  eligible  for
technical  assistance  under the program.    Large  users  and  fully
regulated  generators must file   their  plans with the  DEQ  by
September  1,  1991.   For small quality generators,  initial  plans
are due by September 1,  1992.   Progress reports must be submitted
     7June  5,   1990  Memorandum  on Waste  Minimization in  Ohio,
Prepared by  Dawn  Palmieri,  Ohio Technology Transfer Organization
(OTTO).

     8House Bill No. 3515.
                             600

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to the Oregon DEQ each year thereafter.

          The  Oregon  approach  thus  covers  three  areas:    (1)
providing  technical   assistance  to   affected  industries;  (2)
monitoring  the  use   of   toxic  substances  and  generation  of
hazardous waste; and  (3)  requiring  affected industries to engage
in comprehensive  planning and to develop  measurable performance
goals.

          9.  Tennessee.

          In March 1990, Tennessee passed the Tennessee Hazardous
Waste Reduction Act  of 1990.9  The Act  requires hazardous waste
generators  to  submit hazardous  waste  reduction plans  to  the
Tennessee  Department  of  Health  and  Environmental  (DHE).    The
plans  must   describe  how  the  generators  will  reduce  their
hazardous  waste  generation  by  25%  by  June  30,  1995.    Large
quantity generators,  defined  as generators generating 2.2 pounds
of acutely  hazardous  waste or 2,200  pounds  or more  of hazardous
waste in  any month,  have  until January  1,  1992  to  submit their
plans.     Small  quantity  generators,  defined  as  generators
generating not more than  220  and 2,200 pounds of hazardous waste
in any month, must submit their plans by January 1, 1994.

          The  hazardous  waste  reduction  plans  must contain  a
dated and signed policy articulating management support for waste
reduction, and a specification of scope and objectives, including
evaluation  of technologies,  procedures and  personnel  training
programs.    Specific  goals   must  be set  for  hazardous  waste
reduction  with a description  of  technically  and  economically
practical hazardous  waste reduction  options and  a  schedule for
implementation,  a  description  of  hazardous  waste  accounting
systems with  specific source  reduction  goals,  a  description of
employee  awareness  and training  programs, and  a  description of
how  the  plan has  been or will be incorporated into management
practices and procedures.   All generators  must annually review
their waste reduction plans  and submit hazardous waste reduction
progress  reports  to  DHE.    Generators  failing  to  file  the
required reports  are  subject  to civil penalties of up to $10,000
per day.


III.   DISTILLING  THE  VARYING  STATE APPROACHES  -  DEVELOPMENT OF
A UNIFORM MODEL COST EFFICIENT APPROACH TO STATE POLLUTION
PREVENTION.

          The varying state approaches illustrated by these state
waste  minimization  programs present significant problems  for
     9Tennessee Hazardous Waste Reduction Act of 1990, House Bill
No. 2217.


                             601

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industry, particularly  manufacturing companies with  multi-state
facilities.    Complying with  different  state waste  minimization
requirements can prevent companies from adopting a cost-efficient
and uniform approach to  reduction  of  their industrial  process
waste streams,  particularly  where reductions are  dependent  upon
capital  equipment expenditures  and  long-range engineering  and
planning requirements.  The development of  a uniform model cost-
efficient approach to pollution prevention  on the state level is
urgently needed.   If  a model uniform  approach is not adopted,
the  ensuing  confusion  and  divergence in  pollution  prevention
approaches   could   significantly   hinder   waste  minimization
progress.

          Certain  fundamental  elements  from   different  State
approaches  can  be distilled  to create a uniform  model approach.
First, the identification of goals or targets for hazardous waste
generation  for  all  industries should be  pursued but  such goals
should   be   simply   that—goals  rather   than  statutorily  or
regulatory  mandated  targets.   Common goals of  25% reduction of
hazardous waste generation by the year  1995 and 50%  reduction by
the year 2,000  have  been  identified  in  some states and can serve
as useful guideposts  for  industry.   Programs for hazardous waste
minimization  should  require reduction  from a  facility specific
baseline.  Baselines should be identified  through use of existing
environmental reporting mechanisms.   The  federal Right  to  Know
legislation now requires companies to report annual manufacturing
and use  of  toxic chemicals on an annual  basis.   Those reported
inventories  should   serve  as  the   basis   for  required  waste
reduction  plans  to   be submitted  every  three years to  state
environmental protection  agencies with annual  required progress
reports.  The agencies should be  directed  to review the submitted
plans against the general  goals of 25%  reduction  by the  year
1995  and 50% reduction by the  year 2,000,  but  the  reductions
should not  be mandatory  for  each facility.  Instead,  the state
agencies  should  be   empowered  to  require   each  facility  which
submits a plan  to document  its progress against the  target goals
based upon  best  available  waste  reduction  technology available
for manufacturing progress within its industry.  Deviations from
the 25% and 50% goals of reduction therefore, are permitted based
upon  the available  technology and  the circumstances  within the
industry,  permitting market  and  economic  consideration to  be
factored in.

          The  model  uniform  approach  requires  each state  to
establish grant programs  to  fund  waste  reduction programs and to
provide  special  technical  assistance  in  waste minimization,
including training using  the  resources  of  colleges,  universities
and engineering schools.   Each state would  also  be  required to
establish information clearing houses to  facilitate  the transfer
of technology for hazardous waste reduction.

          Fees  for hazardous waste disposal on  a per pound basis


                             602

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should be established to fund the state technical assistance and
information clearing  house  programs,  and  to provide  a  further
financial incentive for hazardous waste reduction.

          The model uniform state approach suggested here is but
one of several  possible  scenarios,  but  the fundamental point is
clear  -  a  uniform state model  approach  is  critically  needed.
Serious consideration should be given to establishing a national
state   hazardous   waste  minimization   congress,  with
representatives of the  environmental  protection  agencies of the
fifty  states  invited  to prepare  a model  uniform state  waste
minimization bill.
                             603

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                       THE LINEAR TUBULAR REACTOR

        A NEW PROCESS FOR RECLAIMING USED OILS AND  DECONTAMINATING

        OTHER HAZARDOUS WASTES VIA MOLECULAR THRESHOLD DISTILLATION

                       AND MOLECULAR CONDENSATION


                                  by

                    Christian Schoen, Dipl.-Ingenieur

                    ENTRA Ingenieur- und Handels GmbH

             Roemerstrasse 1, D-7590 Achern 18, West-Germany
                                Summary

A patented  linear tubular process  is  applied to reclaim  liquid waste
materials,  especially used oil, by means  of a total vacuum distillation
within the critical energy level of  the molecular stability followed by
subsequent  fractionated condensation.  The simple assembly of the reactor
enables trouble free operation with locally trained personnel.

The automatic control of the operation is tuned so precisely that the
retention time of molecules at the desired energy level can  be adjusted to
within milliseconds.  Also, thermal energy adjustment is possible to within
0.2 degrees  C,  even for large flow rates.  The use of non-conventional
energies  is under trial  at present, showing  even better control
possibilities.

A pilot plant has been operating since September, 1988, with a throughput of
400 kg/hr. It is constructed of standard machine parts made from  plain
carbon steel. This plant was sponsored by the German government.

For used oils,  the yield  is  around  95$  depending on  the volume of
contamination.  By means of the linear tubular process, hazardous compounds
of  the used  oils are largely  removed:  chlorine,  sulphur,  lead,
polychlorinated biphenils (PCB's), and polychlorinated hydrocarbons (PAH's).
All residual  contamination can be removed with a modest treatment of  0.4$
sodium,  or stoichiometric amounts of hydrogen.
                                   604

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The residue sludge contains  only environmentally  irrelevant compounds
because heavy metals and the original additives are  chemically bound.  The
sludge can  be used  as fuel in smelters or in the cement industry.  A
conversion into recycled products  is also possible by adding other  residual
materials,  e.g.  ash from combustion processes, lime products, salts from gas
flue cleaning devices, or bituminous road binders.

The exhaust gases of the vacuum pumps are recycled into the process in such
a way that there is no detectable  odor around the  reactor. They are fed into
the combustion air of  the  burners  after scrubbing by absorption to waste
oil. Noxious substances of the flue gases (CO, S02, NOx, dust ingredients)
from the burners are 20$ below the limits of the German Regulatory Rules.

A tubular reactor with a capacity  of 50,000 tons  annual throughput  can be
installed  for  about $ 8.8 million. The operating costs are $ 38.20 per ton
of waste oil, compared to $ 97.00  for the customary sulphuric acid/Fullers
earth  process. These savings in operating costs  alone  will pay for the
capital costs of the reactor within two years.

The success of this project  prompted the German  government to sponsor
additional research valued at $ 11.7 million.
                               Background

The reclamation of used lube oils  is gaining importance for environmental
protection and preservation of non-renewable resources.

The annual amount of waste  oil  in  the Federal Republic of Germany has
reached  500,000  tons, of which  330,000 tons were  reclaimed in 1985.  The
established sulphuric acid/Fullers earth refining process results in  22  kg
of additional hazardous waste per  100 kg of used oil.  The resulting acid  tar
and oil-charged  Fullers earth represent complex and costly  disposal
problems.

In addition to  the high costs of the sulphuric acid/Fullers earth process
itself and the  disposal costs of the resulting  special waste, further
problems  arise: risks for the environment during the  transport and utiliza-
tion of these special wastes,  expensive waste water treatment, necessity  for
stainless  steel, etc.

The linear tubular reactor developed by ENTRA has the  advantage that it does
not create any  additional wastes. It simply  separates the oil from  the
contaminating materials. The output is clean oil,  and  waste in the form of
sludge.  There is no more sludge than was already present in  the input oil.

In other  words,  the recovery process causes a complete separation of  the
waste oil  into valuable compounds as  distillate,  and  trashy products  as
residue,  without  the addition of major amounts  of auxiliary materials.
During the distillation process, some chemical  agents can be added  to
accomplish a total elimination of residues of chlorine,  sulphur, nitrogen,
polycyclic aromatics, or PCB's.
                                    605

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Attracted by  the advantages  of this  novel  application of  physical
separation, the Ministry of Research and Technology of the German Federal
Government supplied  grants for the operation  of a pilot plant at ENTRA
within the program "Environmental Research  and Development."

ENTRA has received  two patents on  its work, namely, DE 3638606  and
DE 3640978, together with the corresponding foreign patents. Further patent
applications are pending.
                  Description of Process and Equipment

Based on years of research  and experience in the field of high  temperature
processing of organic substances, ENTRA engineers thought that oil molecules
could be made  to drop hetero atoms  before being destroyed (cracked) by
thermal energy.  Experiments applying thermal and non-conventional energies
confirmed the hypothesis.

By means of precisely controlled levels  of energy and retention time for
each molecule, specific conditions can be maintained which lead  to  dropping
the hetero atoms but not to cracking of the carbon chain. A newly developed
control technique allows keeping the retention time within milliseconds, and
maintaining the temperature within 0.2 degrees C of the desired  level.

The tubular reactor used for this process consists of a single tube in which
a liquid product stream is continuously transferred into steam by means of
increasing temperature,  followed  by fractionated  condensation.  The
evaporation  process  or  the chemical reactions take place during the
controlled flow through exactly tempered zones  of the tubular reactor at
relatively high velocities.

The  small flux of  materials  enables rapid  changes  of pressure and
temperature, and  thus instantaneous  adaptation to the  different  bonding
energies of the substances to be treated.  Desired chemical reaction can be
achieved at points of the tubular reactor with the corresponding  level of
activating energy by the dosage of auxiliary process aids.

With the help of  a specially developed measuring and control technique, a
process  sensitivity can  be reached  which is  unmatched by other
installations,  such as autoclaves,  fractionating  columns, or other
reclaiming units.

During continuous operation, yields of up to 97% can be reached, depending
on the quality of the used oil and  the efforts for after-treatment. All
impurities remain almost quantitatively in the residue which can be produced
either tarry or as granulate. A coking oven designed by ENTRA can be used to
convert the granulate into  petrol coke. It contains all solid waste, such as
soot,  heavy metals, and   other impurities.  Sulphur and  chlorine  become
available as  inorganic  salts. A  complete dechlorination of used  oil,
including  the removal of all PCB's, can be achieved with metallic  sodium.
During this  process,  all chlorine  compounds  are converted  into sodium
chloride.
                                    606

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                                Results

Table 1  contains the costs for a  plant with a capacity of 60,000 tons per
annum using  the ENTRA process, as  well as comparative  costs of the well-
known sulphuric acid/Fullers earth process.

At ENTRA,  the prototype plant has been in operation since 1988 with varying
parameters. The following results have been obtained:

Treating used oils with chlorine  contents between 0.8$ and 2.0%, and sulphur
contents of about 0.8%, a reduction of the chlorine and sulphur levels  by
30%  to  10% could be achieved without  the addition of  auxiliary chemical
agents.  The yield exceeded 95$. The residues  amounted  to less than 5$.
Chlorine  and sulphur compounds react with the metals from the additives for
wear to  form  salts which are concentrated in the residues.

All  valuable long-chained hydrocarbons come as a result of  the distillation
as distillates after a fractionated condensation. Aging or cracking  of the
distillates could not be detected.

The  fractions  required  only a modest after-treatment for brightening
purposes with 0.4% sulphuric acid and 0.1% Fullers earth, or with 0.4%
sodium,  or with stoichiometric amounts of hydrogen. In the later case,
hazardous substances, such as chlorine, sulphur, and PCB's are removed below
detection levels. The  percentage of PAH's declines to 30 - 40%  of the
original value.

The resulting residue only contains environmentally irrelevant compounds.  It
could be  used  as fuel  for industrial purposes  without any problems.  A
conversion into easily disposable  or recyclable products is possible  by
adding other  residual materials,  e.g., ashes, lime products, salts from gas
flue cleaning devices, bituminous road binders.

Thermal treatment of the residue at 500 to 600  degrees C leads to a solid
bottom of coke,  and salt compounds from chlorine and sulphur. The
simultaneously developing gases could be scrubbed by absorption to waste oil
in a gas-washer  and thus fed back into the process.

The  exhaust  gases from the vacuum  generators with possibly hazardous
substances (e.g., mercaptanes) are disposed  of by feeding back into the
combustion air for  the  burners after scrubbing by waste oil. Using this
method,  no molestation by odor was  observed.

Harmful substances of  the flue gases from the  burners are negligible.
Noxious compounds of the flue gases  (CO, S02, NOx,  dust ingredients) are 20%
below the limits of the regulations of the German authorities.

The  quality of the  resulting product is  completely in line with  the
requirements  of  the market.  In Table  2, comparative data is  given using  the
specifications of a  major lube oil manufacturer for a solvent neutral
ISO VG 32 versus independent test results for ENTRA oil. It  can be seen that
all values meet  the requirements.
                                    607

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                                                    TABLE   1
       Comparison of the Sulphuric Acid/Bleaching Earth (S/B) Process with the ENTRA Linear Tubular Process
                                (does not include Gate Delivery Costs for  Used Oil)
Process                    INPUT                                    OUTPUT
I 	
Haste Oil

S/B t 60,000
Other Parts 107
Value $/t
Profit/Loss
(Hi 11 ion $)
ENTRA t 60,000
Other Parts 107
Value $/t
Profit/Loss
(Million $)
Auxiliary Process
Agents Costs
6,168
II2
(48.50) (97.00)
(0.3) (5.8)

240^
0.4
(2,353.00) (38.20)
(0.6) (2.3)

	 j
Total
Input
66,168
118

(6.1)

60,240
107.4

(2.9)

L 	
Base
Stock
48,787
87
176.50
8.6

52,685
94
176.50
9.3

Solvents

3,925
7
58.50
0.2

3,925
7
58.80
0.2

	 j
Losses Haste Total
Residuals Output
1,120 12,336 66,168
2 22 118
(88. 25)4
(0.1) 1.0 7.8

600 60,240
1 107.4

9.5

Balance




1.7




6.6

Notes:      1.  Containing 5X contamination
            2.  6.6 parts Sulphuric Acid plus 4.4 parts Bleaching Earth - $48.50/ton
            3.  15 parts Acid Tar plus 7 parts Oil Soaked Earth
            4.  Disposal Costs $88.25/ton
            5.  Sodiui, calculated at $2,353/ton
            6.  (  ) indicates profits or losses in Million *
                                                      603

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                             TABLE   2
Typical Values of a Reclaimed Base Stock According to the ENTRA-Process
              Compared with the Specifications of a Major
                Lube Oil Producer for a Solvent Neutral
ISO VG 32
Method Dimension
Appearance

Density
Color
Flashpoint o.c.
Viscosity at 40 C
Viscosity at 100 C
Viscosity Index
Pour Point
Conradson Residue
Ash Content
Neutralization No.
Aromatic Content
Sulphur Content
Chlorine Content
Calcium Content
Zinc Content
Water Content
Demulsifying Property
Evaporation Loss


DIN 51757
ISO 2049
ISO 2592
DIN 51562
DIN 51562
ISO 2909
ISO 3016
DIN 51551
EN 7
DIN 51558
DIN 51378
DIN 51400
DIN 51557
DIN 51391
DIN 51391
DIN 51777
ASTM D1401
DIN 51581


kg/m3

degree C
mm2/s
mm2/s

degree C
wt %
wt %
mg KOH/g
wt %
wt %
mg/kg
mg/kg
mg/kg
mg/kg
ml
wt %
ENTRA
Reclaimed
Bases took
bright,
clear
870
1.5
220
31.0
5.2
97
-14
0.01
<0.001
0.03
ca. 7.0
<0.04
<5.0
35
<20
<2.0
30-30-0
12
Standard
Specifications
Solvent /Neutral
bright, clear

865
max.
min.
29.0
5.0
min.
max.
max
max.
max.
max.
max.
max.
max.
max.
max.

- 875
1.5
210
- 32.5
- 5.4
95
-9
0.02
0.01
0.05
8.0
0.8
20
50
50
50
40-40-0
max.
15
                                   609

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                          Operating Cost Estimates
Based on  the experience gained so far with the  pilot plant,  the design of
the plant results in a high degree of reliability due to simple construction
and the use of standard components. These features lead to easy maintenance,
and extended meantime between failure.

Cost estimates for a plant having a capacity of 50,000 tons annually are as
follows:
Total capital investment
    $ 8.8 million
Heating oil consumption
:    230 to 250 kg/hr (light  oil  can  be  used)
Electric power consumption    :    180 to 220 kw/hr
Revolving water circulation
    30 to  40 cubic  meters/hr, with  an  inlet
    temperature  of  25  to  30  degrees C.
Exhaust gases
    Only  flue  gases  from  the  oil burners,
    within the limits  of  German regulations.
Residue
    To  be  used  as primary  fuel after
    congealing,  or reprocessing for metal or
    cement industry.
Staffing
    1  foreman and 2 craftsmen  (locksmith,
    electrician) on an on-call baais aa the
    unit works fully automatically and stops
    in case  of failure.
Materials
   Constructed of low carbon structural
   steel  (easily available in all countries).
Total operating costs
   $  38 per ton of input waste oil.
Recovery
   Depending on condition of input oil,
   around 95% oil and 5% sludge.
                                     610

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               Previous Production Units Designed by ENTRA

For the  construction of the  linear tubular reactor for reclaiming waste oil,
ENTRA relied  on  its experience gained from constructing other commercial
production units designed for  carbon compounds:

1976   Development  and construction of a pollution free plant to  integrate
electrode carbon  on a commercial scale for Vereinigte  Aluminium Werke.
During  the  process, bitumen,  pitch,  and oils are heated  far above the
cracking limits without decomposition.

1984    The  first  linear  tubular  reactor for commercial scale coal
liquefication was installed  for  Salzgitter AG. Applying a  novel energy and
controlling concept,  temperatures  up to 530 degrees C are  applied at a
pressure of  1,500 bar.  This  plant was sponsored by the German government
with DM  320  million.

1985   ENTRA succeeded in  binding solid particles in the micrometer range,
as well  as liquid and gaseous organic  compounds, e.g.,  pitch vapors,  to
water without any chemical  or auxiliary substances. An exhaust gas cleaning
unit using this process was  developed and supplied to Sigri AG.

1986   Important parameters  of molecular  bonding forces of petrochemical
products and their influence on  other chemical compounds (e.g., used oil and
additives) could be calculated.

1988   A pilot plant  for reclaiming used oil with a capacity of  400 kg/hr
went into operation in cooperation with Suedoel AG. This  company  has
refined  waste oil for about  90 years, and gained comprehensive experience in
this field.  The pilot plant was supported by the German government with
DM 2.5 million.

Other  research  and  development  problems solved by ENTRA include the
construction of fans for continuous operation at 1,400 degrees C, and mixer
and kneading machines for 700  degrees C at 50,000 Nm torque.

Based on the experience gained with new designs over many  years, expertise
is at hand  for the safe layout of a linear tubular reactor for reclaiming
used oil.

Purposely designed for simple operation and maintenance,  locally trained
operators and maintenance personnel  can  be used.  Low  operating  and
maintenance  costs are expected.

Following the successful operation of the pilot plant, a production unit
having  a capacity  of 50,000 tons per annum is now under  construction.
Quotations for other capacities  are available.
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                        Future Research at ENTRA

The following  research and development  is planned:

Omission  of  the after-treatment  with sulphuric acid and activated clay by
adding sodium  or other harmless products, such as, red mud from  the aluminum
industry.  Trials indicate  that water white and  clear fractions  can be
obtained without further after-treatment.

Further reduction or complete removal of PAH's by more precise tuning of the
conditions of reaction, or  the application of auxiliary agents,  e.g.,
hydrogen.

Further reduction of  the  chlorine and sulphur  contents via  catalytic
reactions  with safe rest products not controlled by waste legislation.

Enlarging the spectrum of  input materials to chlorinated  hydrocarbon
solvents and other substances like  PCS, polychlorinated dioxines and furanes
with the goal  of an economic and environmentally safe disposal possibility.

Since 100$ of  the PCB's in the waste oil is  removed with the  addition of
small  amounts of sodium, the German government is now sponsoring  additional
research work  to remove PCB's from other wastes by the ENTRA  method.
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       APPROACHES TO REDUCING ENVIRONMENTAL RISK
              THROUGH POLLUTION PREVENTION
                J.J. Segna, P.E. and R. K. Raghavan
 Environmental Resources Management - Program Management Corp.
                7926 Jones Branch Drive, Suite 210
                       McLean, VA 22102

Introduction
Much of what has occurred in our recent environmental  history has
led to the concept  of "pollution  prevention".   In fact,  the  U.S.
Environmental Protection Agency (EPA) Administrator, William Reilly,
has summed up  Pollution Prevention as the environmental goal for the
1990's (Reilly, 1990).  However,  as we presently look at pollution
prevention or waste minimization there is  another basic fundamental
question that needs  to be answered.  How does pollution prevention
reduce environmental risk?

It would seem to many of us  that a reduction in waste would have a
direct correlation  with  a reduction in environmental and  human
health risks.  However,  the pollution prevention approach does not
bring into the picture  the concept of risk  assessment  and  risk
management as part  of the overall decision-making process.  Industrial
efforts  have  focused largely on  the end-of-pipe technologies to
minimize waste that  may not  necessarily reduce risk but only transfer
pollutant problems from one media to another. This is not to say that
risk assessment be  the driving force behind waste  minimization
decisions, but rather be utilized as  a  tool along with  economic and
technical consideration  to  give the  decision  maker an overall
understanding of the problem.

It  is the effort of this paper to demonstrate that risk  assessment
should  be considered an  important step in pollution  prevention.
Techniques  using data bases  and computer programs  are already
available that can connect risk management and pollution prevention
as part of the overall strategy to reduce hazardous waste.

Waste Minimization
Major environmental  disasters, such as Love Canal in New York State
and the dioxin sites  in Missouri have sparked national attention and
focused public and private interest  on the problems of uncontrolled
and improper waste  disposal.  The need to control hazardous waste
led to the understanding that it is  more difficult to clean  up a spill
then to prevent it from occurring.  Cleanups are always difficult,  many
times ineffective, time consuming and  always expensive.  The initial
response  to  environmental  disasters was to prevent  them  from
occurring by controlling pollution,  and led to  the creation of the
Resources Conservation and Recovery Act (RCRA).  RCRA  significantly
                                613

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broadened  the  federal mandate  for overseeing  the generation,
treatment and disposal of hazardous waste.

While the development  of RCRA was  clearly desirable, the impact of
hazardous waste generation remained  to be largely undefined.  Trends
in waste generation were inconsistent making  decisions on costs and
potential for waste reduction almost impossible.  The development of
the Hazardous and Solid Waste Amendment (HSWA) of RCRA in  1984
changed this problem forever.

Waste Minimization was, in fact, first introduced as a national policy in
the HSWA.  The EPA elaborated on the concept in its 1986 Report to
Congress (EPA,  1986), stating that waste minimization is:

     "The reduction  to the  extent feasible, of hazardous
     waste  that is  generated or subsequently treated,
     stored or  disposed of.   It  includes  any source
     reduction  or  recycling  activity undertaken by a
     generator that results  in either  (1) the reduction of
     total volume or quantity of hazardous waste, or (2)
     the reduction of toxicity of hazardous waste, or both,
     so long as such reduction is consistent with the goal
     of minimizing present  and future threats to human
     health and the environment."

At present,  there are three formal statutory requirements relating to
waste  minimization, all of  them enacted  as part  of  the  1984
amendments.

1.  Section  3002 (b)  of  HSWA requires generators to certify on  their
   waste manifests (mandated under Section 3002 (a))  that they have
   in place a program "to reduce the volume or quantity and toxicity of
   such waste to the  degree determined by the generator to be
   economically practicable."

2. Section   3005(h)  of HSWA requires  the  same  certification in
   relation  to any new permit  issued  for  treatment, storage, or
   disposal of hazardous waste.

3. Section 3002(a) (6) of HSWA requires,  as part of any generator's
   biennial  report to EPA. that the  generator  describe "the efforts
   undertaken during the year to reduce the  volume and  toxicity of
   waste generated" as well as "changes in volume and toxicity of waste
   actually achieved  during the year in question in comparison with
   previous years, to the extent such information is available for years
   prior to enactment of HSWA."
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These formal statutory requirements provide us with the data bases
that are necessary to study  trends  and requirements to  reducing
waste.  Still risk is not considered in the process. For example, EPA's
Waste  Minimization Opportunity  Assessment Manual  (EPA,  1988)
outlines this fact rather clearly.  Table 1 provides a list of the key
elements for a successful pollution prevention program.  Where in the
frame work should risk be addressed or is it really necessary?

 Table 1.  Key Elements of an Effective Pollution Prevention Program

                   Top Management Support
                   Explicit Program Scope and Objectives
                   Accurate Waste Accounting
                   Accurate Cost Accounting
                   Pervasive Waste Minimization Philosophy
                   Technology Transfer

While the reporting requirements under HSWA have greatly  increased
our understanding  of waste minimization activities,  this information
does not  necessarily show the path  towards  additional  pollution
prevention.   In the meantime,  Section 313  of Title III  of the
Superfund Amendments and Reauthorization Act (SARA) of  1986 has
made available  new  information  related to the environment from
certain  manufacturing facilities.   Also known  as  The  Emergency
Planning and Community-Right-to-Know Act of 1986, this law requires
manufacturers  to  submit chemical-specific  information on different
types of environmental  releases.   Optional  information on  waste
minimization actions taken to reduce  these  releases  is also being
required.  The rest of this paper shows how this type of information
can  help  us to assess  the risk  reduction associated with  waste
minimization.

Risk Assessment
Risk Assessments have become important to risk  managers,  policy
makers, and the public in that they  often offer a range of options, each
having  a  specific cost  and  benefit.   Properly  conducted risk
assessments have received fairly broad acceptance,  in part because
they put Into  perspective the  terms:   toxic, hazard,   and risk
(Paustenback, 1989).  In  pollution prevention,  reduction  in  waste
streams must be coupled with estimate of the magnitude and  nature of
the risks each stream imposes to health and the environment.  If risk
can  be estimated, they  can then be incorporated  into  the cost
comparisons of different proposals  to reduce waste.  Without a good
measure of risk, it is difficult  to judge just exactly what benefits are
received for the  costs.  In particular,  it would be difficult to balance
waste disposal options against waste stream reduction options. (Hahn,
1988).
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In general, risk assessment has emerged as a major analytical tool In
supporting environmental decision-making within EPA (North and
Yosle, 1987).  The growth In the use of risk assessment has resulted
from EPA's need of increased sophistication in developing regulations
mandated by laws, and improved way to  communicate the scientific
basis for decisions to the public.  Risk assessment may be  defined as
the characterization of potential adverse effects to humans and the
ecosystem resulting from  exposure  to environmental hazards.  What
risk assessment provides Is an orderly, explicit, and consistent way to
deal with scientific issues in  evaluating whether a hazard  exists and
what the magnitude of the hazard may be. (North and Yosle,  1987).

Component of Risk Assessment
Discussing risk assessment,  the National Research Council  (NRC,
1983) divided the process of risk assessment into four components.
These are:

     1. Hazard  Identification - consists of a review of
        relevant  biological  and  chemical  information
        bearing on whether or not an agent may pose a
        specific hazard.

     2. Dose-Response Assessment - involves describing
        the quantitative  relationship between the amount
        of exposure to a substance  and the extent of toxic
        injury or disease.

     3. Human Exposure Evaluation - Involves describing
        the nature and size of the population exposed to a
        substance and the  magnitude and duration of
        their exposure.   The  evaluation could  concern
        past, current, or future exposures.

     4. Risk Characterization -  generally Involves the
        integration of the data and the analysis of the first
        three components  to determine the likelihood
        that humans  will experience any of the various
        forms of toxicity associated with a substance.

The area of hazard  identification and dose-response assessment are
important components of  risk assessment but are already derived for
many of the major chemical analyzed in pollution prevention.  In most
situations It has been the toxicity  side of risk assessment that has
driven the reduction of waste  in pollution prevention.  The human
exposure evaluation and risk characterization because  of Its site
specific  nature can change from  location to  location  and  from
chemical to chemical.  It's these two components of risk that are most
important for using risk assessment in pollution prevention.
                                 616

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The assessment of human exposure involves  an estimation of the
number of people exposed and the magnitude, duration, and timing of
their exposure.  In some cases, it is straightforward to measure human
exposure  directly by measuring levels of the hazardous agent in the
ambient environment.   In most cases, however, detailed knowledge is
required  of the factors  that control human exposure, including those
factors which determine the behavior of an agent after its release into
the environment.  The  following types of information are required for
an exposure assessment:

        •  Quantities of an agent that are released and the
           location and timing of release.
        •  Factors controlling the fate of the agent in the
           environment after release, including factors
           controlling its movement, transformation, and
           degradation.
        •  Factors  controlling  human contact with  the
           agent,   including  the  size,  nature  and
           distribution of the population, and activities
           that facilitates or prevent contact.
        •  Patterns of human intakes. (EPA, 1989)

Availability of such information in many cases is limited, varies greatly
from case to case, and  may  be  difficult to accurately  predict.
Therefore, except in fortunate  circumstances in  which the behavior of
an agent in the environment is unusually simple, uncertainties arising
in exposure assessments  could  be significant.   This situation is also
different depending on whether the  assessment  is predictive or an
estimate  of risk is made on previous exposures.  Once these various
factors can be estimated, then chemical dose, its duration and timing,
and the nature and size of the population receiving it are the critical
measures of exposure for risk characterization.

The final step  in  risk assessment  involves bringing  together  the
information provided in the exposure assessment with toxicological
data to determine risk. While  the final  calculations themselves are
usually straightforward (exposure times potency or unit risk), the way
In which the  information is presented is important. For example, this
step can  be  far more complex than  indicated  here,  especially If
problems  associated with duration and/or timing of exposure  are
considered.   Also, other factors  such as  the uncertainties which are
introduced from assumptions  and extrapolations must be considered.
This discussion  is a tremendous simplification of the  risk assessment
process, but  is sufficient for the purposes here.  The  noncarcinogenic
and the carcinogenic risks are the final measures  of the possibility of
human injury or disease from a given exposure or range of exposures.
                                  617

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Risk Assessment and Waste Minimization Data
When performing risk assessments, one must understand the sources,
derive the exposure  levels,  determine human or  environmental
effects, and compute the risk.  What the risk assessment provides in a
pollution prevention setting is an orderly, explicit, and consistent way
to deal with the scientific issues in evaluating whether a hazard exists
and what will be the magnitude of hazard.

New data being made  available  to assist risk assessment includes:
details of each hazardous waste stream being generated by industries;
reports on each environmental hazardous substance  being released;
and  information on  the manufacturing  processes and pollution
prevention activities  associated  with  both  waste  generation  and
environmental release.

These data elements  provide  the "source" in the risk assessment.
Estimates  of exposure  levels (air, water  and  soil) can  then be
developed along with general or site-specific population information to
create exposure scenarios.  Appropriate toxic hazard data combined
with  the  exposure estimates  can then generate potential lifetime
excess cancer risk or chronic non-cancer toxicity.

It is  the final  coupling of the  data  base with risk assessment
techniques that will derive the  overall picture  of risk in pollution
prevention. The following section  outlines a simple approach, in most
cases to get a better handle on risk reduction more detailed analysis
should be performed.    Table  2  summarizes  the  environmental
discharge of benzene  (Ib/yr).  In this example, benzene data is
provided  for years  1987 and  1988  to  describe  the changes in
discharge from  the statewide information.  Also shown  are  the %
change in discharge loading from 1987 to 1988.

                   Table 2.  Benzene Discharge

                           dbs/yr)
Type  of Discharge	1987	1988	% change

Fugitive               502,010    320,576       -36
Stack                140,092    158,055       +13
Water                   1,620      1,520         -6
Injection                     0          0
Land                      290          0
POTW                    750      3,000       +300
Off-Site                65,903     39,350       -40
TOTAL               710,665    522,501       -26

The  constituent of concern, benzene, was selected  because  of it's
known carcinogenic properties.   As part of the human exposure
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evaluation we have  now developed a  first-cut understanding of the
quantities of an agent (Ibs) and timing of release (yr).

The  next phase  of  the risk  assessment  is to develop  the factors
controlling human contact and the patterns of human intake.  Table 3
outlines the media and important routes of  exposure of benzene.

              Table 3. Media and Routes  of Exposure

Media           Scenario                   Cancer Potency Factor
	(Routes of Exposure)	fl/mg/kg/dav)	

Groundwater     Drinking Water                  2.9 x  10'2
                 Showering                       2.9 x  10"2

Surface Water    Drinking Water                  2.9 x  10'2
                 Ingestion of Fish                  2.9 x  10'2

Soil              Inhalation of Particulates          2.9 x  10'2
                 Ingestion of Soil                  2.9 x  10'2

Air              Inhalation of Vapors              2.9 x  10'2

The  next step in the  process is to develop the  exposure scenario.
Generic  equations are  used  in  calculating the resultant subchronic
intake for inhalation and ingestion.  Because we are not dealing with
site specific information we are more interested in relative risk rather
than actual risk.  Relative risk in this case  is how much risk increases
or decreases by waste  reduction from one year to the next.  In this
case study performing  a risk assessment  using only state wide data
would give us meaningless  risk values.  The location of facilities,
population distribution potential,  human contact and  fate  of the
chemical at each site could only determine a general risk value.  By
using relative risk values we bypass  the  questions  associated with
exposure scenarios on a state wide level.

Each route of exposure has associated  with  it  an equation that
determines estimated  exposure (mg/kg/day).  Again  the discussion
presented here is a simplification of the process and only the equation
used for  inhalation is provided.

General Exposure Equation for Inhalation
Potential Inhalation  intakes  are estimated based on the  number  of
hours  in each event,  the Inhalation rate  of the  exposed individual
during the event, the concentration of compound in the air breathed,
the percentage absorbed into the bloodstream, and the body weight of
the Individual.
                                 619

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                    IEX = DxIxCxRFx 1/BW

     WHERE:  IEX =   estimated inhalation intake (mg/kg/day)

               D   =   duration (hr/day)
               I    =   alveolar air rates of exposed person (M3/hr)
               C   =   compound concentration in exposure media
                       (mg/M3)
               RF  =   % of inhaled compound absorbed into the
                       bloodstream
               BW =   body weight of exposed person (kg)

For each route of exposure a similar equation is developed that
calculates the resultant exposure.  The resultant concentration is given
in terms  of mg/kg/day, when multiplied with the cancer potency
factor (1/mg/kg/day) results in a unitless number and  risk:  If  the
result of inhalation exposure of benzene is  10-6 risk it means that  one
Individual out of 1 million will likely develop an excess cancer due to
exposure  to benzene at a  particular concentration under a unique
exposure scenario.

It is important to note that risk assessment is  not an exact science.
The numbers developed  are only estimates of what could  likely occur.
However as referenced in this paper they play  an important role for
decision making when attempting to balance cost and treatability In
waste reduction.
The results of using risk  assessment in this example are shown in
Table 4.

              Table 4  Relative Risk of Benzene 87-88

                   LOCATION	% CHANGE
                   on-site               -26
                   off-site               -3.7

The  off-site also  assumes  that all the chemical is available to  the
environment.  In most cases, off-site disposal of benzene Is handled by
incineration so in  all likelihood  the risk is significantly less than
shown.  The numbers generated from Table 3  and  4 only discusses
risk via type of discharge point.  However, when benzene is discharged
to a POTW or  off-site where does It really go?  If we examine exposure
by media assuming 90% of benzene available in the air, 9% in  the
water, and 1% In soil the following relative risk are computed In Table
5.
          Table 5. Benzene Load by Media and Relative Risk

           Media	1987	1988	% change
           WATER       7,620        5,330        -30
                                 620

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           SOIL          9,600        420          -56
           AIR           702,089     516,746      -26

Exposure by media indicates potential risk in a  different light.  In all
cases relative risk decreased, using a weighted average, by 26% from
1987 to  1988.  The difference between using type of discharge versus
media resulted in most of benzene getting into  the air and changing
the relative risk for both on-site and off-site conditions.

Combining Waste Minimization and Risk Assessment
By looking at waste minimization in terms of Table 2, pounds per year,
we are  limiting  our capabilities in  understanding  what  is  truly
occurring at a site.  In many cases, a constituent will behave differently
in different media.   For example, if we  used arsenic instead of
benzene, the cancer potency factor would  be different for inhalation
exposures versus ingestion by an order of magnitude increase.  This
would imply that an inorganic compound  such as arsenic is  more
important to reduce in air  rather than  as  a contaminant in soil or
sludge.   Relative and actual risk by media (Table 5)  would then be
significantly different.

With  the  addition  of high  powered  personal  computers  the
combination or addition  of risk assessment with waste minimization
options  is  presently  achievable.   Tools  such  as EPA's RISK *
ASSISTANT (Segna and Walentowicz, 1989) can  provide the  computer
system for conducting the exposure and risk aspects of the problem.
The  whole Idea is to eventually combine risk, cost, and  technical
capabilities in a computerized format that will not only generate waste
reduction but more important risk reduction as well.

Figure 1  illustrates the point in  simplistic fashion.  An industrial
facility has a number of chemicals it must attempt to reduce as waste.

In the past, cost was the  driving force  in getting most  removal
(regardless  of  media)  to   meet  State  requirements  for waste
minimization.  With the use of a data base  system coupling cost and
treatment considerations one can get a first cut in reduction In waste.
The next step is to add a risk assessment module to understand what
benefits can be achieved under that particular scenario. By adjusting
cost and treatment one can see if risk also changes significantly. It
can be quite possible that total % reduction  in waste does not equal an
equivalent reduction in risk.
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                            Chemical of Concern
                             Discharge Point
                              Reduction hi
                                Waste
                                 Risk
                              Assessment
                              Final Waste
                              Minimization
                              Technology
                               Figure 1
                                                   Cost
                                                Considerations
Conclusion
Pollution prevention based solely on economic, technical or regulatory
decisions could be misleading.  Approaches that tie-in risk reduction
to pollutant prevention must be considered in any decision making
process.  The approaches discussed in the paper could provide a user
and decision-maker with the tools  they need in determining  pollution
prevention  technologies.
                                    622

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References
    Newton, J.,  (1990).  Setting up a Waste Minimization Program,
    Pollution Engineering, p 75-80, April 1990.

    National Research Council (NRC) (1983).  Risk assessment in the
    federal government:   Managing the process.   Washington  D.C.
    National Academy Press.

    North, W. and Yosie, T.F. (1987).  Risk Assessment:  What It Is;
    How It Works, EPA Journal, Volume 13, No. 9, U.S. Environmental
    Protection Agency,  Office of Public Affairs, Washington D.C.  p!3-
    15, November  1987.

    Paustenbach, D.J.  (1989).  A Survey of Health Risk Assessment,
    McLaren  Environmental  Engineering,  Chem  Risk Division,
    Alameda, California.

    Reilly, W.K. (1990).  Pollution Prevention:  An Environmental  Goal
    for  the   1990's,  EPA Journal,  Volume  14,  No.  1,   U.S.
    Environmental  Protection  Agency,  Office  of  Public  Affairs,
    Washington D.C. p 4-7, January/February 1990.

    Segna,  J.J.  and  Walentowicz,  R.  (1989).   Performing  risk
    assessments using  Microcomputers, Proceedings of the  7th
    National Conference  on Microcomputers in civil engineering,
    American  Society of Civil Engineers, Orlando, Florida, November
    1989.

    U.S. EPA  (1986).  Minimization of Hazardous Wastes, Report to
    Congress, U.S. Environmental Protection Agency, Office  of Solid
    Waste, Washington, D.C. 530/SW-88-041A, October 1986.

    U.S. EPA (1986).   Future Risk:   Research  Strategies  for the
    1990's,  Science Advisory Board,  SAB-EC-88-040.  September
    1988.

    U.S. EPA  (1988).  Waste Minimization Opportunities Assessment
    Manual, U.S. Environmental  Protection Agency, Hazardous Waste
    Engineering Research  Laboratory,  Cincinnati,  Ohio   45268,
    EPA/625/7-88/003, July 1988.

    U.S.  EPA  (1989).    Exposure  Factors  Handbook,   U.S.
    Environmental  Protection   Agency,  Office  of  Health  and
    Environmental Assessment, Washington, D.C.  20460, EPA/600/8-
    89/043, March 1989.
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             Educational Aspects of Multimedia Pollution Prevention


                              Thomas T.  Shen,  Ph.D.
             New York State Department of Environmental Conservation
                   50 Wolf Road, Albany,  New York  12233-3259


Introduction

     Environmental quality  and natural  resources  are under  extreme stress  in
many industrialized  nations  and in virtually  every  developing nation  as  well.
Environmental pollution  is closely  related to population  density, energy  and
transportation  demand,   land  use  patterns  as well   as  industrial  and  urban
development.  The main reason for environmental pollution is the increasing rate
of waste  generation  in  terms  of quantity  and toxicity  that  has  exceeded  our
ability to properly manage it.   The other reason is the management approach that
has  focused  on  media-specific  and  "end-of-pipe"  strategies,  even  though  a
media-specific approach  has improved our  environmental  quality  to a  certain
extent.   There   is   increasing  reported   evidence  of  socio-economic   and
environmental benefits realized from  multimedia pollution prevention.   '     The
prevention of environmental pollution in the 1990s is  going to  require  not only
enforcement  of  government  regulations  and  controls,   but   also  changes  in
manufacturing processes  and products as  well as  in  lifestyles   and  behavior
throughout  our   society.   Education  is key  in  achieving  the vital  goal  of
multimedia pollution prevention.

     This  paper  presents  a  broad-based  approach  to  promote  environmental
education  and training  in  the  principle and  practice of multimedia  pollution
prevention.   It  illustrates  some significant  issues  that need to  be  addressed
including environmental problems,  the cross-media nature of  pollutants,  benefits
of  multimedia  pollution  prevention,  and  the  importance  of  education  and
training.   The   purpose  of  this  paper  is  to  stimulate  open  discussion  of
educational needs  necessary to meet  the  environmental challenge of  the  1990's
and  beyond.   The  challenge  is  how  to  integrate  air-water-land  pollution
management through waste prevention prior to  the application  of waste treatment
and disposal techniques.

Environmental Problems

     Environmental problems result from releases of wastes (gaseous, liquid, and
solid)   that  are  generated  daily  by  people  from   industrial  and  commercial
establishments,   as well  as  households.   The  lack  of consciousness  regarding
conservation  of  materials, energy,  and water has  contributed to  the  wasteful
habits  of our society.   The  rate  of waste generation has  been  increasing  in
accordance  with  the  increase  in  population  and  the   improvement  in  living
standards.    With   technological   advances  and   changes  in   lifestyle,   the
composition of waste has  likewise  changed.   Chemical  compounds  and products are
being  manufactured  in  new  forms   with different  half-lives.    It  has  been
difficult  to  manage  such compounds and products once  they  have been discarded.
As  a result, these  wastes have  caused many  treatment,  storage,  and  disposal
problems.

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     Many  environmental  problems  are  caused  by  products  that  are  either
misplaced in use  or  are  discarded without  proper concern of their environmental
impacts.  Essentially all products  are potential wastes,  and it is desirable to
develop methods  that reduce the  waste  impacts associated with  products,  or to
produce environmental  friendly products.   Environmental agencies  have  been lax
in promoting and  automating tracking  mechanisms  which identify sources and fate
of new products.

     Solving problems,  however,  can  sometimes  create  problems.   For  example,
implementation of the  Clean Air Act and Clean Water  Act  has generated billions
of tons of  sludge,  wastewater, and residue that  could  cause soil contamination
and  underground  water pollution  problems.   The  increased concern  over  cross-
media shifts of pollutants  has yet to translate  into a systematic understanding
of pollution problems and viable  changes in regulatory designs.

     Environmental  protection  efforts  have  emphasized  media-specific  waste
treatment  and  disposal  after  waste  has  already been  created.   Many of  the
pollutants which  enter the environment are  coming from "area  sources"  such as
industrial complex  and land disposal  facilities;  therefore,  they  simply  cannot
be controlled  by  the end-of-pipe  solutions.   Furthermore,  end-of-pipe  controls
tend  to  shift pollutants   from  one  medium  to  another  and  cause  secondary
pollution problems.  Therefore, for pollution  control purposes,  the environment
must be perceived as a single  integrated system  and  pollution problems  must be
viewed  holistically.   Air  quality can hardly be  improved  if  water and  land
pollution continue to occur.  Similarly,  water quality cannot be improved if the
air and land are  polluted.

     Many secondary pollution problems today can be traced in part to education,
i.e.,  the  lack of knowledge  and understanding  of  cross-media principles  for
identification and  control of  pollutants.   Neither the Clean Air Act nor  the
Clean Water Act enacted in  the early 1970's adequately addresses the cross-media
nature  of  environmental  pollutants.   More  environmental  professionals  now
realize that our  pollution  legislation is  too  fragmented  and compartmentalized.
Only  proper education and training  will  re-orient  this  situation and  will
hopefully lead  to a more  comprehensive  legislation of the  total  environmental
approach.

Multimedia Approach

     The environment is the most  important component of our life support system.
It  is  comprised  of air,  water,   soil,  and biota through  which elements  and
pollutants  cycle.  The  cycle   involves the  physical,  chemical,   or  biological
processing of  pollutants  in the  environment  as  shown in  Figure 1.   It may  be
short,  turning hazardous  into non-hazardous  substances  soon  after they  are
released;  or,  it  may  continue  indefinitely  with  pollutants posing  potential
health risks over a long  period of  time.   Physical processes  associated  with
pollutant cycling include leaching from soil to groundwater,  volatilization from
water or  land to air,  and deposition  from air to  land  and water.   Chemical
processes  include decomposition  and  reaction of pollutants  to  products  with
properties  that  are  possibly quite different   from  those  of  the  original
pollutants.   Biological processes involve  micro-organisms which can  break  down
pollutants and convert hazardous pollutants into less toxic  forms.    However,
they can also  increase the toxicity.xtf a  pollutant,  for instance, by  changing
mercury into methyl-mercury in soil.


                                      625

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     Although  pollutants  sometimes  remain  in  one medium for  a  long  time,
eventually  they will  move.   Pollutants  settled  in  river  sediments  can  be
dislodged by micro-organisms, flooding, or dredging.  Displacement  such  as  this
constituted  the  PCB problem  in the New  York State Hudson River.   Pollutants
placed   in   landfills   have  been   transferred  to  air   and  water   through
volatilization and  leaching.  About  200 hazardous chemicals have been  found in
the air, water, and soil at the Love Canal land disposal  site in New York State.
The advantages of multimedia approaches lie in their ability:   (1)  to manage the
transfer  of pollutants  so  that they will  not continue  to  cause  pollution
problems, (2)  to avoid  duplicating  efforts or conflicting  activities,  and  (3)
to  save resources  by  consolidation of environmental  regulations,  monitoring,
database management, risk assessment, permit issuance,  and field inspection.

     In  recent years,  the  concept and  goals of  multimedia  pollution prevention
have  been   adopted by  many  regulatory  and   other   governmental  agencies,
industries,  and the public in the United  States  and abroad. Multimedia efforts
in the  United  States have  been focused on by  the U.S. Environmental Protection
Agency's  (USEPA)  Pollution Prevention  Office  which helps  coordinate  pollution
prevention activities across all USEPA headquarter offices and regional offices.
The current USEPA philosophy  recognizes that multimedia  pollution  prevention is
best  achieved through  education and  technology transfer  rather   than  through
regulatory imposition of mandatory approaches.   But the progress of implementing
multimedia pollution prevention has been slow.

     Recognition of the need for multimedia pollution prevention approaches have
extended beyond  the  government,  industry,  and the  public,  to  professional
societies.  The Air Pollution Control Association (APCA)  has been renamed as the
Air  and Waste Management  Association  (AWMA)  to incorporate waste management.
The  American  Society  of Civil  Engineers (ASCE) has  established  a multimedia
management committee under the Environmental Engineering Division.   The American
Institute  of  Chemical  Engineers  (AIChE)  has   reorganized  its  Environmental
Division to  include  a  section  devoted   to  pollution  prevention.  The  Water
Pollution Control   Federal  (WPCF)  has  adopted a set  of principles addressing
pollution prevention.

Pollution Prevention

     President Bush,  in signing his  first proclamation  of the new decade  (the
20th  Anniversary  of  the  Earth  Day  Proclamation) declared,  "We must...seek
solutions  that  embrace all  sectors  of   society in  preventing pollution and
ecological  damage before they occur."   The USEPA's  Administrator William Reilly
also  said,  "We must start preventing pollution  as  the primary  means of meeting
our  environmental  objectives."   The  USEPA's  policy has  focused  on pollution
prevention  via the multimedia  reduction  of  pollutants  at the source  and the
promotion of environmentally sound  recycling.   A major  goal of Earth  Day  1990
has  been to  encourage  government   agencies  to  acknowledge  the  importance  of
pollution prevention.

      Pollution prevention  approaches for  environmental protection include:

      (1) Reducing  the  quantity and/or   toxicity  of pollutants   generated  by
          production processes  through source  reduction, waste minimization, and
          process modification.


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     (2)  Eliminating  pollutants  by  substituting  non-pollutant  chemicals  or
          products   (e.g.,   material    substitution,    changes    in   product
          specification).

     (3)  Recycling  of waste  materials   (e.g.,  tracking  by-products,  reuse,
          reclamation).

     Source reduction  is  the key  component of multimedia  pollution prevention
strategies.  It  acts  as the  first  line of defense against the ever-increasing
quantity  and  toxicity  of  waste which  poses  environmental  pollution  problems.
Source reduction is not simply  a means  of environmental protection,  but part of
the  broader   picture   of   industrial  process   and  products   improvement,
modernization,   innovation,  and  expansion.  It  is  considered  one of  the  least
costly means  of waste  management  and  also provides  one of the  best  means of
pollution control.  Source  reduction can conserve  expensive materials  and save
not only in the direct  costs of waste management (storage, transport, treatment,
and disposal)  but also in the  administrative  costs  of  regulatory  compliance,
legal  advice,   liability   insurance  of  long-term   environmental   risks  and
managerial time.  However, many available opportunities in  source reduction and
recycling have  not  been pursued, simply  because  many waste generators  are not
aware of such opportunities.  Therefore, the key to successful implementation of
pollution prevention is education and technology transfer.

     Pollution prevention design consists of several multimedia elements.  These
range  from  complex   scientific   and  technological   considerations  to  major
socio-economic  factors, public  policy  and regulatory  issues.  Waste  reduction
through a further extension of  sound operating  practice appears most promising.
It  includes,   such  techniques  as  employee  training,  management  initiatives,
inventory control,  waste  stream segregation,  scheduling and  material  handling
improvement, spillage and leakage prevention,  and preventive maintenance.

     The next promising area  for source reduction  is  technological modification
of continuous  processes that generate  large  amounts  of waste.   Input  material
substitution and new product  designs  can  be highly  effective in processes  where
impurities  constitute   a considerable faction  of  input material  or where  the
potential exists for  lowering the  toxicity of  auxiliary  raw material.   Product
substitutes to reduce waste generation  can be effective,  but it is an extremely
complex issue.   For example,  a  substitute  must  provide  the  same function as, or
a  better  function  than   the   original   product;  the  waste  characteristics
associated with the substitute's manufacture and disposal must compare with that
of  the  original  products;  and the  increased  costs   of  a  substitute   must  be
compatible with net environmental benefits and a free  market economy.

     Both  internal  and  external   influences  stimulate   the integration  of
pollution  prevention   in  corporate  management.   Internal  influences  refer  to
economic  advantages,  workers'  demands  for cutting down occupational  exposure
risk and  development   in  environmentally  acceptable  products  and  processes.
External   influences   include  regulations,  public   opinion,  concern  about
environmental  degradation,  as  well  as  technical  and  financial   assistance
programs.

     Elements of an effective pollution  prevention program for  industries  and
government  agencies   should  consist   of  goals,    organization,   commitment,
resources,  and  communication.    Success  in  pollution   prevention   requires


                                        627

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"incentives".  Waste  generators must have  economic  reasons to  implement waste
minimization and  clean technology options in their  daily  operation.   Economics
is  the driving  force  for  most  business decisions,  and pollution  prevention
should provide incentives to achieve environmental quality goals.

Education and Training

     The role  of  environmental professionals in waste management  and pollution
control  has  been  changing  significantly   in  recent  years.   Many  talented,
dedicated   environmental  professionals   in  academia,  government,   industry,
research institutions,  and  private practice  need to cope  with change,  and to
extend  their  knowledge  and  experience  from  media-specific,  "end-of-pipe",
treatment-and-   disposal   strategies    to   multimedia   pollution   prevention
management.  The  importance of this extension  and reorientation  in  education,
however, is such that the effort cannot be further delayed.   Many air pollution,
water pollution, and  solid  waste  supervisors  in government  agencies spend their
entire careers  in just one  function  because environmental  quality supervisors
usually work  in only one  of  the media  functions.   Some may  be  reluctant to
accept such an educational extension and re-orientation.   This is understandable
given the fact that such  a  re-orientation requires time and  energy to learn new
concepts and that time  is a premium for  them.   They  must,  nevertheless, support
such education and training in order to have young professionals well-trained.

     Successful implementation of multimedia pollution prevention programs will
require well-trained  environmental professionals  who are fully  prepared  in the
principles and practices of  such  programs.   The programs need  to develop  a deep
appreciation of the necessity  for multimedia pollution prevention in all  levels
of  society that  will  require a  high priority  for educational  and  training
efforts.  New instructional materials and tools are needed for incorporating new
concepts  in  the  existing  curricula  of elementary and  secondary  education,
colleges and universities,  and training  institutions.  The  use  of computerized
automation offers much  hope.   Government agencies need to conduct  a  variety of
activities to achieve three main educational objectives:

     1.   Ensure an adequate number of high-quality environmental professionals,
     2.   Encourage groups  to  undertake  careers in environmental  fields  and to
          stimulate all institutions  to  participate more  fully  in  developing
          environmental professionals,  and
     3.   Generate data based, which can  improve  the environmental  literacy of
          the general public and especially the media.

     These objectives are related to,  and reinforce,  one  another.   For example,
improving  general  environmental  literacy should  help to  expand  the pool of
environmental professionals  by increasing awareness  of the  nature  of technical
careers.   Conversely,  steps  taken  to  increase  the number  of  environmental
professionals should  also help to improve the  activities of general  groups and
institutions.   Developing an adequate  human resources base  should  be the first
priority in education.  The  training environmental professionals receive  should
be top quality.

     There is a significant  need  to provide  graduate students  with training and
experience  in  more  than one  discipline, as  many  of  the  most  important  and
interesting environmental scientific  and technological questions  increasingly
require  interdisciplinary   or  multidisciplinary   approaches.    Environmental
graduate programs must address  this  aspect.   Most practicing  environmental
professionals  face various  types of environmental problems-' that  they  have not
been taught in universities.   Therefore,  continuing  education  opportunities and
                                   628

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cross-disciplinary  training  must  be  available   for  them  to  understand  the
importance of multimedia pollution prevention principles and strategies, as well
as to carry out such principles and strategies.

     The education  and training plan of multimedia pollution  prevention may be
divided into technical and non-technical areas.  Technical areas include:

     1.   Products  --  Life  cycle analysis methods, trends-in-use  patterns,  new
          products,  product  life-span  data,  product  substitution,  and product
          applicability.   A  product's   life  cycle   includes  its   design,
          manufacture, use, maintenance and repair, and final disposal.

     2.   Processes  -- Feedstock  substitution,  waste minimization,  assessment
          procedures,  basic  unit  process  data, unit  process waste generation
          assessment  methods,  materials   handling,  cleaning,  maintenance  and
          repair.

     3.   Recycling   and   Reuse   --   Market   availability,   infrastructure
          capabilities,  new   processes and   product   technologies,  automated
          equipment  and  processes,   distribution and   marketing,   management
          strategies, automation, waste stream segregation, on-site and off-site
          reuse opportunities, waste exchange opportunities,  close-loop methods,
          waste recapture and reuse.

     Non-technical areas include:

     1.   Educational programs and dissemination of information,
     2.   Incentives and disincentives,
     3.   Economic costs and benefits,
     4.   Sociological and human behavioral trends, and
     5.   Management  strategies  including  coordination  with  various  concerned
          organizations.

     Environmental professionals dedicated  to  multimedia  pollution control also
need to have a broad education and sound understanding of:

     1.   characteristics of pollutants in waste streams;
     2.   cross-media nature  of  the movement,  distribution,  fate,  and effect of
          pollutants that have entered  the environment;
     3.   coordinated  management  of   gaseous,  liquid,   and  solid  wastes  so
          problems are not shifted unduly from one medium to another;
     4.   use of  source reduction  and recycling  prior  to waste  treatment  and
          disposal;
     5.   environmental impact and cost-effectiveness of solutions;
     6.   intelligent and automated information and data management systems;
     7.   role of ethics in decision-making;
     8.   societal system such as current environmental laws and regulation;
     9.   environmental sociology, public relations, and communications; and
    10.   use of risk assessment and management tools.

     Though  the  subject matter to  be  covered  is  broad,   the  environmental
profession will  not be  well  served by training  only generalists.   Beyond  the
basic goals  and within  specific areas listed,  it is  important that  for most
professionals   to   obtain   some  degree   of  specialization.    Environmental
professionals should  learn broadly and act specifically  with  full knowledge of
the impact of ones actions.
                                    629

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     Education and training can take many forms:  new curriculum materials in our
primary and secondary schools, new courses and degrees in our  universities,  new
business practices by our corporation,  and new local and  national legislation by
our policy-makers.  Societal change away from our current "end-of-pipe"  command-
and-control practices  and toward  a  more pollution preventive  strategies  will
only evolve through proper  education and training throughout all levels  of the
society.  The  need for educated and trained personnel in multimedia  pollution
prevention is urgent.   The lack of trained professionals  impedes the implementa-
tion of pollution prevention program.   Computer  literacy must  also  be  elevated
to transfer existing expertise for ready access by junior professionals.

     The universities and training institutes must  make  a substantial  effort to
revise their  teaching  materials  to adequately cover topics  of  great importance
to  environmental  problems   and  possible  solutions  through  waste  reduction,
recycling, and clean technologies.   Environmental  professionals in industries
and consulting  firms  are  likely  to  examine  environmental problems  that  involve
all   media.     Industrial   pollution    control   problems   typically   involve
consideration  of  liquid,  gaseous,  and solid wastes, so  excellent opportunities
exist  for both cross-media  analysis and integrated  design  of  waste  treatment
systems.   Effluent and  emission  standards  can be  related  to  toxicological
information in the environment.    Exposure  estimates,  risk  assessment,  safety,
reliability,   and  fail-safe   designs can  be  incorporated   into the  training.
Recently, training manuals have been published as a tool for the identification
and  assessment of  pollution  prevention options at  a  plant   level.   '     The
government and the educational  system must  conduct  more workshops,  seminars,
conferences,   and  outreach  efforts  as  well  as  establish  more  information
clearinghouses  on multimedia pollution  prevention with respect to methodologies
and technologies.   The teleconferences with  remote hookup  for  dialog  are also
useful in transfer of detailed information and skills.

     A  new  environmental ethic  must be  taught  in universities and continuing
education with an understanding  of the  effect  that  development of new clean
technologies  and  new products is  essential for environmental  protection.  For
example,  industrial plants have  usually been developed to maximize  reliability,
productivity,  product  quality,  and  profitability  with  chronic emissions  and
effluents, waste  treatment  and disposal being secondary  factors.  Engineers and
managers  in those plants must be educated to take a proactive role in design and
operation that produce less waste,  less  toxicity  of the waste,  and to  improve
ability  to  predict the fate  of  pollutants in  the environment after  release.
Waste  generators  must  accept the responsibility for meeting the total costs of
the production of goods  and services.   The traditional market  prices  have not
reflected subsequent costs of waste  disposal nor the uncompensated environmental
and health damages.  Thus, the responsibility of waste generators must go  beyond
those  for production and  marketing to social costs  as well.  All  waste generators
should follow  "The Valdez  Principles"  of ethical  guidelines  for protection of
the environment.

     Effective  public  education  including  media  is  essential  to  any  type of
program.   Public  opinion, public  awareness  and public  participation  will  fuel
the  entire multimedia pollution  prevention effort.   For   example, developing
public support up front will develop public demand for pollution prevention and
for  products  manufactured  via  clean  technologies.    If  products  are  not
purchased, industry will  stop producing them.   Public attitudes must be  changed
via education first.
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     Environmental  regulatory  agencies  should  support  the  development   and
implementation of education and  training  programs  that teach targeted  groups
about methods and procedures to  prevent pollution problems.  They also  should
work with private industry and universities to  incorporate environmental  studies
and training  into  academic  curricula.   Students  who study business, science,
engineering,  public policy, law, economics  and  medicine should all be  exposed to
the concept of multimedia environmental pollution and the  clean  techniques  of
pollution prevention.

Conclusions

     Industrial  and urban growth,  energy  and  transportation  demand,  land  use
patterns,  and wasteful habits have all created  environmental problems  as  well as
challenges.   Part  of  the answer to  these  challenges  lies  in  education  and
training to develop new  multimedia pollution prevention policy and legislation.
Education  and training  would  create  practical  solutions  that  would  shift
environmental  management  strategies   from passive/reactive  restoration   to
preventive  planning.    This  would  allow  sustained   economic   growth  while
minimizing environmental  damage.

     Success   of  implementing  multimedia  pollution prevention  programs will
require an adequate number  of  well-trained environmental  professionals and  a
fundamental shift  in  attitude and perception.  This  shift  is  unlikely to occur
without an aggressive and proactive  program of  education.   The  lack of well-
trained environmental  professionals  impedes  a  viable approach  to  environmental
protection via pollution  prevention as much as  funding limitations do.  Computer
science  techniques   must  be  expanded   to   include   ethical  evaluation   of
environmental costs when  evaluating the consequences  of planned activities.
                                   HAZARDOUS
                                  CONTAMINANT
                                                      J
                                                   WATER
                                                      &
                                                        •S-'
          Fig. 1    HAZARDOUS CONSTITUENT  CYCLE
                                  631

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References

1.   Chemecology, Vol.  17, No.  1,  February 1988 and Vol.  19,  No.  2,  March 1990.

2.   Schecter, R.N. and G. Hunt,  Case Summaries of Waste  Reduction by Industries
     in  the  Southeast.   Published  by  the  Waste  Reduction  Resource  Center,
     Raleigh, NC, July 1989.

3.   Shen,  T.T.,  "The  Role of Environmental  Engineers in Waste  Minimization",
     Proceedings of the First International Conference on Waste Minimization and
     Clean Technology,  in Geneva,  Switzerland,  May 29 to  June 1,  1989,  published
     by the International Solid Waste Association.

4.   USEPA, Waste Minimization:  Issues and Options.   Volume 1,  EPA/OSW&ER Report
     EPA/530-SW-S6-041, October 1986.

5.   USEPA, Review Report on Waste Minimization Strategy,  Science Advisory Board
     publication SAB-EEC-88-004,  October 1987.

6.   NYSDEC,  New York  State Hazardous Waste Reduction Manual, published by the
     Department of Environmental Conservation,  Albany, NY, 1988.

7.   USEPA, Waste Minimization Assessment Manual, EPA/625-7-88/003,  July 1988.
 (90-1-38)                               632

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              Industrialization, Development and the Environmental Crisis in
              Developing Economies of the Caribbean Basin  Region

              WHE Suite

              Faculty of Engineering, University of the West Indies, St. Augustine
              Trinidad, W.I.


Abstract

       Introduction

Fragile Caribbean island economies, struggling to modernize their largely plantation
economies and in many cases attempting to reduce their single export item dependency,
are trying to industrialize and  diversify.   Modernization and  development  have
resulted in the proliferation of sanitary landfills and waste  dumps.  The process has
resulted in increased faecal pollution of water courses, coastal wetlands and marine
preserves. Their haste to increase crop yield and reduce post harvest loses has meant a
decided and almost suicidal turn to insecticides, pesticides, fungicides and germicides.

       Methodology

Many of the older technologies such as oil extraction and refining, mining of bauxite,
manufacture of cane sugar and rum have polluted the once pristine environment, the
envy of European tourists.

Recent attempts to harness the newer technologies,  metal plating, plastics, etc.,  have
left the environment  in crisis.  Technology transfer packages with guilt edged
commitments have opened the Pandora's box.  These demands have proved too much
for the weak technology resources of these islands' economies.

New terms  loom large on the horizon as the island leaders seek to woo foreign
investors.  The seemingly attractive package includes the highly toxic industries under
containment by the US EPA and its European equivalents, looking for more favorable
industrial climate to resume operation of the latest of the growth industries, treatment
of toxic  and  hazardous waste.   To  this must be  added the  recent reports of
environmental pollution created by clandestine of hazardous chemical waste  and the
requests to develop dumping sites in these micro states. The question is how can these
island states protect themselves.  The paper reviews  the Caribbean experience and
develops a tri-partite  strategy that can be  adopted  by the coordinated efforts of
Caribbean agencies  charged with  environmental surveillance and protection, the
United Nations agencies and US EPA.

       Conclusions

The paper discusses the arguments for technology transfer which are  in  essence
contracts between unequal parties.  It concludes with a discussion on three important
concepts:

       (a)     The Technology transfer question and the "Beggar cannot
             be Chooser" concept.
       (b)     Ethics  and the International  Environmental Question.
       (c)     What can be done to help developing countries from
             destruction.
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Industrialization,  Development  and the Environmental Crisis  in Developing
Economies of the Caribbean Basin Region

Winston H.E. Suite
Faculty of Engineering

Introduction

Caribbean Island States do not now have deeply rooted Industrialized economies but
without exception have come to the realization that this is a necessary, even If belated,
path to their development.  Desperate efforts to modernize and  diversify national
economies have correctly identified strategies which call for entering new areas of
activity and thereby break the stranglehold dependence on their entrenched mono-
sectoral economies. National economic planning strategies all shared  certain common
features:

       (a)    Weak technological infrastructure
       (b)     Most of the islands can only lay claim to any technical
              experience in sugar refining and rum manufacture.  This  is with the
              exception of Jamaica with at least three (3) decades of Bauxite industry
              and Trinidad with Petroleum industry that is more than six (6) decades
              old.
       (c)     Only a recent concern with environmental issues.
       (d)    All are presently engaged in developing industrial plans and are in the
              quest for international capital to take up the leadership in
              implementing an industrialization plan.
       (e)     Most of the islands would have a very weak legal machinery
              to deal with technology, the environment or pollution
              control.

To describe their  position as vulnerable is an understatement since they  have no
alternative but to turn to foreign capital, foreign technology and to foreign advisors to
take them into the twenty-first century.

The paper will not dwell on the state of underdevelopment but will develop the basis of
the environmental crisis  as it now exists and as  it already is developing.   It will
concentrate on what the author sees as the path forward and offer  mechanisms for
dealing with the otherwise inevitable environmental degradation of the Robinson
Cruiso type islands.

Early Industrialization

Early industrialization in  rum  distillation and manufacture and sugar production
would have resulted in crop-time inconvenience occasioned by the burning of the canes
before harvesting.  The grinding of the canes and the subsequent processing would have
had to utilize a generous quality of potable water.  The waste water, the  product of
washing, would have been allowed to empty into natural streams and rivers or into the
coastal water where the refineries were situated near the coast. The product generates a
stench as well as floating scum. Because of the importance to the island economies and
the relative influence of the industry1 operation, pollution was considered a necessary
evil with which one simply had to live.  The issue may have been dismissed as suicidal
to the industry which was already struggling for survival against beat sugar, artificial
sugars, cane sugar production in areas where mechanization was well advanced and the
economies of scale provide too much for Caribbean producers.
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In the case of Trinidad, in excess of pollution from the sugar industry the economic
blessings of petroleum were accompanied by pollution of the lands as a result of
exploration and production wells.  Several streams have become biologically dead
because  of waste and spills coming form the refinery operations.  Marine exploration
which began in 1954 saw the beginning of coastal pollution and gradual destruction of
wetlands and even loss of certain beach (bathing) areas to bilge washing from boats, oil
spills and simple discharge of waste from coastal refineries and motor vehicles.

Although Trinidad and Tobago is not a producer of bauxite, a trans-shipment port has
been constructed in Trinidad to receive the bauxite from the river going boats which
come from neighboring Guyana.  The villages around the trans-ship port have
repeatedly protested about the bauxite dust that has discolored their homes and clothes
and which has posed a health risk to all residents. The problem has not yet been dealt
with.

In  a previous  document the author  (1) has discussed the  earlier stages  of
industrialization that have ocurred in Trinidad and Tobago. It was pointed out that in
the last two decades several small industrial estates have been set up with a wide range
of chemical process and manufacturing operations.  The effluent from these factories
has been allowed to enter roadside drains, streams and rivers. These ultimately pour
into the coastal areas destroying the wetlands and the life forms native to them.  The
coastal marine life forms have taken a heavy beating.

Industrialization and  urbanization have brought with them increased population
concentration and higher levels of domestic sanitation.  Central sewerage and packaged
treatment plants have virtually mushroomed in each new housing estate, in each new
industrial or manufacturing estate.  The sad fact is that inevitably the malfunction
resulting in atmospheric  pollution (stench) and faecal waste or  partially untreated
sewerage are allowed to enter water courses. Like with petroleum pollution the land
becomes polluted, the streams and coastal waters become polluted  and ultimately
gravity and percolation means that contamination enters the ground water system of
wells and aquifers.

Sanitary landfills have quietly polluted the land and with the passage  of years finally
the pathogens,  the dissolved heavy  metal and metallic salts and other chemical
pollutants have  finally appeared in the aquifers which once were the  source of pure
water.

The present interest in accelerating and deepening the industrialization process is
occurring in an environment where pollution has not been a topic for economists nor
planner,  where industrial disasters have not yet entered the planning equation.   We
have not yet learnt to treat with existing industrial pollution.  We have not set in place
the necessary legislation neither the necessary institutions (2). While we cannot hold
back the proverbial march of progress, we must now be abundantly clear that all these
must be put in place on an accelerated agenda. If we do not, new sources and new forms
of pollution will visit the  region with the inevitable new thrust in industrialization.
The question of industrial pollution  has assumed a new dimension where several
multi-nationals begin a quest for sites within the non-developing countries to dispose
of hazardous and toxic waste and in a few cases even to set up factories ostensibly to
detoxify  or neutralize  hazardous and toxic waste.  These  implications have been
discussed by the author in a previous paper (3) and will not be dealt with here.
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The Nature of the Crisis

One may begin by presenting the dilemma of the industrial planner.  It is generally felt
that industrialization holds the secret to the non-development of Caribbean countries.
some have advanced this as a strategy well worth embracing by all the non-developing
countries.  As we are no doubt wiser by  the mobilization  of the Green Peace
Organization in Europe and the green movement internationally, by the outstanding
work which emanated in the United Nations General Assembly during 1990's the
Decade of Natural Hazard Reduction, by the timely though unfortunate catastrophies of
Bhopal, Three Mile Island, Chernobyl and Exxon Valdeze by the growing awareness of
desertification and consequent famine in Sub-Sahara Africa, by the lead work of TIME
Magazine in its January 2/89 Issue -  "Endangered Earth" and its continuous articles
together with the rest of the international media on such topics as, Global Warming and
the Greenhouse Effect; Ozone Depletion, the Threat to the Tropical Rain Forest, Toxic
and Hazardous waste. Acid Rain, Sanitary Landfills and the Pollution of Aquifers and
Oil Spills and Dumping of Waste at sea. We are now fully aware of the negative impact of
industrialization on human life and the degradation of the environment.

We cannot plead but culpable ignorance.  This is the dilemma which planners face
armed with the promise of the plusses and the certainty of the minuses.  How is  he to
maximize the benefits?  In the face of this crisis several comments must be dealt with.

(i)     "Appropriate Technology is less polluting".

This would caution against too rapid an assimilation of the so called "high technology
of the developed world. The corollary must  be that high technology is inherently
polluting.  There is the danger that if for no other reason,  non-developing countries in
being relegated to low or appropriate technology will never be able to compete with the
developed countries and not only the technology gap will widen but the development gap
as well.  This thesis that high technology is necessarily more polluting will not be dealt
with here neither will the complementary  argument that so called  "appropriate
technology" is more suited to non-developed countries.  In fact the author is firmly
convinced that the non-developing countries can only enter into the development of the
twenty-first century on the work horse of technology.

(ii)    "Any attempt to formulate a serious package of laws and guidelines to treat with
industrial accidents and disaster preparedness would discourage foreign investors and
even the local ones as well".

The argument here is that to put the  necessary safe-guards, training programme and
insurance in place will increase cost to the investor.  No one points out that increase
safety and disaster preparedness will set the environment  for greater efficiency,
innovation, commitment and consequently greater productivity.  These conditions
must lead to better industrial relations, less down time, less rejects, less loss of time due
to accidents and hence higher output.  This is possibly the simple reason why proposed
improvement to the Factories Act (1950), "The Act Representing the Safety, Health and
Welfare  of all persons in relation to  the activities of industrial establishment", has
languished in the corridors of parliament and  the drafting department since 1984.  It
may indeed explain why the Public Health Act, Chapter 12 No. 4, Laws of Trinidad and
Tobago 1950 Edition, has been redrafted several times but has not yet been repealed and
replaced.
                                      636

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(ill)    "That the non-developing countries are the industrial haven for 'dirty
       technology"1.

There is much evidence that would support that  several multinationals  involved in
highly polluting, highly toxic and hazardous products have in recent years  (the decade
1980's) sought to transfer operation to several non-developing countries.  This may
explain why they have sought to clandestinely dispose or dump hazardous and toxic
waste (chemical sludge  and radioactive waste as well known) in the Caribbean Basin
Region.

It is not a haven for the regional environmental groups have already been made aware.
The population has been alerted although the risk has not disappeared.

(iv)    "The Economists have not yet addressed the environmental question".

The most glaring support of this view is that environmental impact statements are not
necessary or demanded as a necessary precondition of all industrial, commercial or
residential projects.  It is therefore reasonable  to assume that many developments
which are carried out without the benefit of environment impact assessment studies.

Regional Economists have not yet got into the  question of assessing the economic
effects of natural or man made disasters far less the environmental degradation and
pollution.  Frantic efforts are not being made to draw them into the discussion.  We
often get an accounting statement of market value for buildings and crops lost but the
analysis of the impact on the long term development has not yet begun.  Several non-
economists including the author hold the view that the destruction by natural disasters
constitute a big factor in the non-developing of the so-called non-developing countries.

(vi)    "The State should assume responsibility for effecting industrial clean up after
       disasters".

It has been argued that companies pay taxes to help defray cost of clean up and recovery,
and that the burden for clean up should be assumed not by the industrial polluters and
the author of the disaster but that the state, representing all the citizenry, should carry
financial responsibility.  The argument has been advanced that this  should  be
undertaken as a sort of incentive. Indeed one can understand the position of the state in
entering into clean up where:

(i)     An industry has been polluting an area for a long period and the clean up
       process would result in the company becoming bankrupt.  The state may assist
       in this case

(ii)    The industry that created the pollution is no longer in existence

(ill)    The particular industry is critical to the economy and does not have the
       technical or financial capacity to undertake clean up by  itself.

Industry should be encouraged by all means available to convert to clean technologies.
This could possibly generate tax relief and/or assistance to those that move to put in
place clean technologies. Incentives to clean up must be linked to incentives to convert
to clean technologies and to enter into recycling and reduction of waste.

We must also understand the  nature of the principal forces driving the crisis in non-
developing countries.
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One of the major driving forces in the quest for new parcels of arable land, in order to
support rising population and to generate surplus for export. The problem had also
been exercerbated by unscientific farming practices which have resulted in net loss and
degradation of existing agricultural land.  In the Caribbean islands hillside "slash and
bum", which has been increasing a pace, has meant loss of hillside forest cover.
Erosion has ensured that the recently exposed area will only serve for two or three years
and the farmer must move  on, "slash  and bum" more forest, increase  erosion and
flooding in the low lying areas. In rural areas where wood is used as fuel,  felling of the
forest goes on. The de-forestation process is therefore driven by the need for fuel as well
as to yield land for planting.  The consequence is not environmental pollution per se,
but environmental degradation  since both the hillsides  and the flooded areas  are
degraded and ultimately can yield less and support less life.

Another driving force in the environmental crisis is the increased use of artificial
(chemical) fertilizers, insecticides, pesticides, fungicides  and herbicides.  Driven to
obtain better yields and in many cases to  prevent dwindling yields on exhausted lands
farmers have turned to chemicals.   The results  in Trinidad  and Tobago, while
promising in volume yield have been  very discouraging in other areas.  Mounting
incidence of accidental poisoning in rural agricultural  homes  among  children,
accidental poisoning among  farmers who  are either not properly trained in the use of
the chemicals and not  aware of the toxicity risk,  a rise in disease  occasioned by
prolonged exposure to low doses of toxic chemicals. While no serious published results
of tests are available it is generally felt that the crop yield is compromised with these
poisonous chemicals which  accumulate in the human body.  The issue  has been so
serious that finally the "Pesticides and Toxic Chemicals Act, No. 42 of 1979" had to be
put on the books.

We must mention the mushrooming of industrial estates and separate  cottage type
industrial operation  since the period 1970's.  This small scale industrial effort which
began in the post independence era (1962  -) saw the proliferation of these un-monitored
or  un-controlled ventures. The 1974 rise in oil prices saw some inflow of money  and
increase in those manufacturing ventures. No one considered restraint. The Factories
Inspectorate did not increase its technical competence to monitor or regulate industry
and no one  thought this was  a  necessary function, definitely not  the industrial
planners nor the  politicians.  No legislative reform or updating took place in respect of
industrial safety or the  protection of the environment although we focused on tax
reforms. The Factories Act  saw very little reform of significance. The Public Health
Ordinance remained unchanged in spite of countless new drafts having been prepared.
Clearly this was not within the focus of the parliament or the planners.

In  recently prepared review (4) by  the  author the conclusion was made that the
legislative mechanism which dealt with industrial accidents, industrial pollution and
industrial disaster preparedness was all but dormant in the decades of 1970's  and
 1980's. Of the Bills that reached parliament only a few emerged law and of these the
necessary organizational support staff and funding were so deficient that very little was
achieved. The main legislative banner may have been the Litter Act (Chapter 30:50, Act
27 of 1973, later amended by 2 of 1976). It was an Act "respecting the littering of public
places and of premises", as the  short title reads.  The Act made provision identifying
offences and penalties  for littering.  It gave the local authorities power to  enforce
removal of litter,  power to enter and inspect premises and to remove derelect vehicles
left in any public place.  Finally it made provision for the setting up of wardens to assist
in  carrying out the functions conferred on the local authority by the Act.  It is not with
any satisfaction that one notes that the Act did not achieve what its drafters may have
intended. The problem lay more with the  commitment to enforcement and persecution.
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We must note that the environmental question was identified as an important one even
if it did not receive its due.

The previous regime did set up the Solid Waste Management Company, a State owned
company to handle the management  of garbage collection, transportation, and
disposal,  the question  of sanitary landfills and garbage dumps, the collection of
sewerage and even some industrial waste.

The Institute of Marine Affairs prepared a compilation of laws regulating the use of the
coastal environment (5).  This research report begins, "Environmental Law as a judicial
corpus or distinct branch of the Law is in its infancy in Trinidad and Tobago, indeed in
many countries of the world". The report goes on to state that, "The time is  perhaps
right therefore, to examine those laws which have the capacity to control the manner in
which we use our resources and the activities associated with this exploitation".  While
the main reason for the compilation was the Coastal Environment, it lists as well all
the laws that impact on the environment under the broad headings.

Classification:
1.     Laws
       A.    Legal
                    Administrative Law
                    Penal Law
                    Civil Law
                    International Law
       B.    Environmental
                    Water Pollution
                    Air Pollution
                    Noise Abatement
                    Waste Disposal
                    Nature Conservation
2.     Statutes
       A.    Legal
                    Constitutional Law
                    Administrative Law
                    Penal Law
                    International law
       B.    Environmental
                    Water Pollution
                    Air Pollution
                    Noise Abatement
                    Waste Disposal
                    Nature Conservation

In fact it will not be correct to say that very little legislative work was done in the last
three decades in the area of environmental control and protection.  Any serious
discussion must begin with the Town and Country Act, Chapter 35:01, previously Act 29
of 1960 (amended by  13 of 1974 and 19 of 1977).  This Act sought to "make provision for
the orderly and progressive development of land in both urban and rural areas and to
preserve and improve the amenities thereof; for the grant of permission to develop land
and for the powers of control over the use of land; to confer additional powers In respect
of the acquisition and development of land for planning; and for purposes connected
with  the matters aforesaid".

This  is the basis of all development and a guide  to all environmental protection plans.
The problem therefore is not absence of legislation but rather the will to enforce these
legislation.
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In 1986 a new government was elected and In 1987 a national clean up campaign was
launched In which attempts were made to mobilize the entire citizenry to clean up their
own premises as well as to put all the garbage and waste at the roadside. The project
also sought to stimulate people to clean up the roadsides. The effect was repeated in the
next two years but not with the success of the first year in which political supporters of
even opposition parties responded in the mutual effort.  This year 1990 the project was
led by the state company, Solid Waste Management Company.

A  separate ministry has now been set up, The  Ministry of the Environment and
National Service.  Plans are now afoot to create an Environmental Authority (a Bill has
already been drafted entitled,  "An Act  to provide for the National  Environmental
Authority, for preparation of the National Environmental Policy for the conservation,
preservation, protection, enhancement and management of the Environment and for
matters incidental thereto". The National Environmental Policy is being prepared.  In
the mean while the work of the clean up campaign has moved to a tree planting effort.

The Ministry of Environment and National Service, consistent with what it demies  as
a government  agreed policy, has spearheaded a group whose  task is  to examine the
problems Involved in initiating a clean up  of the major rivers and water ways during
1990.  The committee brings together persons representing several different ministries,
professional bodies, local authorities and the University. This Is where we are at.

It  should be  pointed  out that the question of  environmental pollution and the
protection of the  environment has been taken up  by several local associations.  The
Ministry of the Environment and  National Service has held Workshop/Seminars on,
Inter alia,

       National Consultations on Natural Resource Conservation and  Development
21st February 1990

The Institute of Marine Affairs held a seminar on Environmental Impact Assessment:
"Approaches to Socio-Economlc Impact Assessment  "December 12. 1989".

       Today the debate on the environment Is being advanced by:

       (i)Mlnistry of the Environment and  National Service
       (il)Minlstry of Planning and Mobilization
       (ililmstitute of Marine Affairs.

One can say that the Issue Is gathering momentum.  The  question we must ask is what is
the Immediate task.

Environmental Pollution and the Ethical Question

We must begin by admitting that the Caribbean  Basin states are all vulnerable  to
growing environmental pollution due to new industries.  Their economic conditions
can be easily described as desperate. Efforts to rejuvinate their economies from within
have not met with much success. While efforts are being made to secure foreign loans, it
is being advanced that foreign direct Investment(FDI) is likely to be the most fruitful
route.  The question therefore is how do we ensure that the Industries which are in the
offering are not those in flight  due to stringent legislation In their previous base of
operation.  The reality of the situation Is that most technology transfer agreements are
contracts of adhesion, contracts between unequal parties. Invitations to Direct Foreign
Investment must be seen more or less In the same light. Often the "beggars cannot  be
choosers".
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The  developing countries must rely upon the integrity of the donor and upon the
surveillance of the investment agencies and what ever bilateral fraternal relations they
may be able to draw upon from other developed countries. The frightening point to note
is that the recipient of the D.F.I does not have resident in the country the technical
competence to evaluate the full extent of the risk that may be involved. They must rely
totally on a moral and ethical code relating to industrial pollution and environmental
degradation. While some western European countries have proposed such a code, and
while bilateral agreements between countries may have been worked out on such code
pervades the industrial market place.  In the United Nations family of Organizations
(UNIDO, WHO. UNEP, etc.), guidelines have began to emerge  on transboundry movement
of toxic and hazardous waste.  We can only hope that an industrial code of ethics for
multi-nationals will be soon in coming.  One would also hope that the World Bank and
the I.M.F. as well as the other funding agencies will pay more attention to those aspects
of the constitutions of aid and loan. But a code of ethics alone will not be able to protect
the non-developing countries. What exactly should constitute the code of ethics is yet
another question but in essence it should be in international agreement indicating
what should be done and what should not be done.

The  lead role must come from the United Nations  Agencies working in the area, the
international Academies of Science, the Environmental Agencies  of the developed
countries e.g. USEPA and the international professional engineering bodies. They can
assist developing  countries in selecting clean technologies, in monitoring  existing
technologies and in cleaning up after technologies and Industrial processes have been
installed which do not constitute clean technology.

Summary

While  the paper presented the basis of the crisis between  Industrialization  and
Development on the one hand and Environmental Degradation and Pollution on the
other, the central inevitability of the march of Industry is not being negated or  resisted.
The  central message must be that  the  developing countries must have technical
assistance in recycling technologies, clean up and  disposal technologies. They must set
out to acquire clean technologies. This must  govern all technical aid agreements and
must underlie all discussion on transfer of technology.

The  next important question is that the case for an Environmental Policy cannot be
overstated.  This must be a vital hard core element in any Industrialization policy.  The
Environmental Policy must Identify and treat with the principal elements:

       (i)     Administration and organizational structure
       (ii)    Monitoring and inspection
       (ill)   Legislation and regulations
       (iv)   Enforcement and sanctions
       (v)    Avoidance and protection
       (vi)   Clean up and restoration
       (vii)   Education and mobilization

Technology is not inherently bad.  Technology must be used in the service of man and
not recklessly, oblivious of the negative impact on them and the environment.

Under-developed countries can benefit a great deal  from the development of a code of
ethics for industrial contracts and Technology Transfer agreements.  This can form
part  of the technical assistance package between the  developed and the under-developed
or non-developed countries.
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1.     SUITE. Winston H.E.: "The Dilemma of the Industrial Planner in a Developing
Country".  Presented at the International Conference on Industrial Risk Management
and Clean Technologies; organized by UNIDO and the International Association for
Clean Technologies. Vienna, Austria; November 13-17, 1988.

2.     SUITE. Winston H.E.: "Industrial Disaster Mitigation and the Management of
Technology Change -  A Selected Review of the Trinidad  and Tobago Experience".
Presented at the Second International Conference on Management of Technology
sponsored by the University of Miami College  of Engineering and  the Institute of
Industrial Engineers. Miami, Florida; February 27 - March 2.1990.

3.     SUITE. Winston H.E.: "The Export of Hazardous Waste to the Caribbean Basin
Region".  Presented at the Ninth (IX) UOEH International Symposium and the first Pan
Pacific Corporative Symposium on Industrialization and Emergency Environmental
Health Issues - Risk Assessment and Risk Management.  Kitahyushu, Japan 2-6 October
11
4.     SUITE. Winston H.E.:   "Legislative Mechanism and  Industrial Disaster
Preparedness  - A Review of the Trinidad and Tobago Experience.  Prepared for
presentation at "International Experience or Industrialization,  Urban Development
and Environmental Pollution" in conjunction with 1990 Annual Meeting of Air and
Waste Management Association. Pittsburgh, June 24 - 29, 1990

5.     GLASGOW.  Carl:   Institute  of Marine Affairs, Trinidad and Tobago:  "A
compilation of the laws regulating the use of the Coastal Environment:  IMA/9/83",
November 1983.
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                     AN INNOVATIVE GRADUATE THESIS;
                A TEAM EVALUATION OF USED OIL END USES
      Cynthia J. Talbot, ABB Environmental Services, Inc., Portland, Maine

      James P. Byrne, U.S. EPA Region I, Boston, Massachusetts

      Carol A. Cody, U.S. EPA Region I, Boston, Massachusetts

      Patrick J. Doyle, ENSR Consulting and Engineering, Inc., Acton, MA

      Anna H. Mayor, Sanford Ecological Services, Inc., Southborough, MA

      Anne M. Reid, Goldberg-Zoino & Associates, Inc., Trumbull, CT

      Sheryl K. Rosner, Vermont Law School, South Royalton, Vermont
      In 1989, a team of graduate students specializing in Hazardous Materials Manage-
ment at Tufts University evaluated the potential health and environmental risks associated
with re-use, recycling, and disposal alternatives for used automotive oil. Research into
used oil management practices produced a list of currently employed end uses which was
narrowed to 14 based on process similarities and potential releases.  A qualitative human
health risk assessment identified 14  contaminants of concern,  evaluated the potential
effects of each practice for each contaminant of concern, and resulted in a ranking of end
uses according to their relative potential for posing risks.  A qualitative environmental
assessment was also conducted.

      This "Capstone" project concluded a multi-disciplinary Master  of Science degree
program which included course work in environmental policy, science, and engineering.
The study required broad use of these varied technical abilities, as well as management
and interpersonal skills. Successful completion of the project required us to recognize and
use these non-technical skills. By working as a "consultant-like" project team, we were
required to establish a scope of work, schedule, budgets, review process, and report format
which met  the needs  of the client -  the Massachusetts Department  of Environmental
Protection.  As with any project, resource and time constraints added to the learning
process.  These  indirect lessons  provided  the students and advising professors with a
learning tool which proved far more valuable than a typical graduate research thesis.
                                       643

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                                INTRODUCTION

      This paper discusses the educational value of a unique graduate thesis conducted
under the Hazardous Materials Management Program at Tufts University.  The paper
presents an introduction to the multidisciplined graduate program and a description of the
technical scope of the project which was entitled "Used Motor Oil in Massachusetts: A
Prioritization of End Uses  Based on Human Health and  Environmental Risk."  The
discussion of the project's initiation and execution includes  highlights of how the group
organized; developed the project's scope, schedule, and budget; and assigned tasks. The
paper concludes with students' reflections on  the  applicability and relevance of the
educational experience to their present positions as environmental professionals.
           THE HAZARDOUS MATERIALS MANAGEMENT PROGRAM

      This project concluded the first year of the Master of Science program in Hazardous
Materials Management at Tufts University in Medford, Massachusetts. The program was
developed to meet the growing need for trained professionals in the multidisciplined field
of environmental  management by providing for the study of interrelated environmental
health, science, technology, management, and policy issues.  In tribute to this variety, the
program was established with three specialty tracks: Management and Policy, Treatment
and Clean-up Technology, and Hazardous Materials and Public Health.

      The degree program requires all students to complete four core courses regardless
of specialization:  Hazardous Materials, Fate and Transport of Environmental Contami-
nants, Health Effects  and  Risk Assessment, and  Hazardous Materials Management
Strategies.  These courses provide students with the fundamentals of the field.  In addition,
students choose specific courses in one of the three tracks over two semesters and during
a summer institute of condensed courses.  Throughout the year, students are required to
attend bi-weekly forums offering opportunities to meet with practicing professionals and
to examine issues  that tie classroom studies with state-of-the-art technology as it is applied
by those working  in the field.

      The multidisciplinary nature of the Hazardous Materials Program was reflected by
the diversity of students who completed the program the first year and participated in the
project.  Our eight-person team ranged in age over 12 years, and in work experience from
essentially zero to over 10 years working for industry or in consulting positions.  Some
entered  the program with  the intent of  changing career directions  from traditional
engineering to environmental fields, while others wanted to broaden their formal education
                                       644

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in their current field of employment.  One student wanted to strengthen her technical
background before pursuing a career in environmental law.  Undergraduate degrees
included political science, environmental science, soil science, wildlife biology, and ocean
engineering.

      The "Capstone" is the final degree requirement of this program.  It was defined in
course  descriptions  as  requiring  students  to  work  in  "consultant-like" teams  with
government officials and industry representatives to address a current environmental issue.
Rather  than a traditional thesis, the program's developers envisioned a student team,
working on a project for  a client outside of the academic community, with "real world"
deadlines and resource constraints. In addition, the project was to encompass all the
disciplines studied during the previous academic year.
                  PROJECT INITIATION AND DEVELOPMENT

      As described previously, the Capstone  project is assigned by a  "client" and
implemented by a "consultant-like" team of graduate students.  The 1989 Capstone was
commissioned by the Massachusetts Department of Environmental Protection (DEP) to
determine the most favorable  end uses for used motor oil based on human health and
environmental  risk.   The  need for this  study  evolved  from the recent increase  in
enforcement of the State's "mandatory used oil take-back law."  DEP anticipated that more
oil would enter the management system, and was seeking to recommend the most environ-
mentally sound end uses for this material.

      With little more direction than the project goal  stated  above, the team set out to
develop a scope of work, budget (for expenses other than direct labor), and schedule. The
project team had a total of three months to complete the study. During this time the team
needed to organize themselves, plan a scope of work and a milestone schedule, research
the topic and evaluate data, and produce  a final report;  all  while fulfilling other class
requirements and job responsibilities.

      To assist the group in organizing the project, the team attended a class in group
dynamics led by a professional  consultant. Through this exercise they learned about each
others' expectations, fears, desires, and  needs as they related  to working in a group.  In
retrospect, understanding each team members' strengths  and weaknesses helped reduce the
number of personality conflicts that  are normal in any intense group situation.

      To give  all students  the opportunity to run meetings,  the group chose to have a
"rotating leadership position" rather than a designated group leader. We scheduled weekly
meetings with the academic  advisors. This provided a regular opportunity to communicate
with all project team members. During the rest  of the  week individuals or small groups
worked independently on specific tasks. This organization was necessary to meet the needs
of students' part- and full-time  work schedules, travel needs (two students had commutes
                                       645

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of over two hours), and family commitments.

      The rotating leader's role was to schedule meetings, set agendas, ensure that notes
were taken and distributed, facilitate discussion from all group members, and maintain the
focus of the meeting. The rotating leadership concept produced several negative situations.
Stronger personalities and more experienced team members naturally fell into leadership
roles over the course of the project, creating some difficulty because they were not elected
or officially designated.  On the other hand, lack of this evolution would have hurt the
project because the group was easily distracted and fragmented if not reminded of the
ultimate goal.
                             PROJECT EXECUTION

      The primary tasks of the project involved research and data evaluation, application
of data to a qualitative assessment of risks, and preparation of written and oral reports.
Successful completion of each task required assignment of responsibilities to individuals
or small groups, establishing schedules, and coordinating work between the individuals or
groups.  As each phase of the project neared completion, more detailed organization and
coordination was needed to bring the project together.

BACKGROUND

      The first phase of the project involved intensive research into general aspects of
used oil generation and management. This task was accomplished through phone and mail
inquiries to industries and regulatory agencies, site visits to interview companies operating
in the used oil management industry, and a computerized literature search.

      This  research revealed that  approximately 20  million gallons  of  used oil  are
generated annually in Massachusetts. Unlike most other states, Massachusetts regulates
used oil  as a hazardous  waste.  This stringent regulatory framework imposes several
requirements on generators, transporters, and disposal facilities.  Under the Used  Oil
Retention Act, retailers of motor oil are required to accept up to two gallons of used oil
per day per person with proof of purchase. If strictly enforced, this law would provide a
network  of collection centers and greatly increase the amount  of used oil entering  the
management system.  DEP seeks to promote a  safe end use for oil in the system by
recommending alternatives which pose the least risk to human health and environment.

END USE ALTERNATIVES

      Through this research the team collected information from which they assembled
a long list of nationally and internationally practiced end use alternatives.  The list was
categorized to reflect the most commonly employed end uses, and to group those with
similar processes and potentials to release contaminants into the environment. Fourteen
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distinct end uses (Table 1) were identified and classified into four categories. Continued
research  during  the course of the project and input from industries involved in these
practices provided a basis for continually revising the list and classifications.

      In the interest of efficiency, the team divided into four groups of two to research
end uses by category. Individuals chose areas to research based on their backgrounds and
interests.  Research focused on aspects of the end use which result in potential releases
such as air emissions, waste generation, and disposal.

QUALITATIVE RISK ASSESSMENT

      The next task was to evaluate the potential risks posed by each end use. Because
there are many accepted methods of evaluating risks, the team enlisted assistance from a
risk assessment professional and adjunct Tufts professor. Her recommendations helped
guide us away from conducting a quantitative risk assessment  and instead steered us
towards a more appropriate approach, given our time and resource  constraints, a qualita-
tive risk assessment. This assistance also enabled us to develop a framework from which
to conduct such an analysis.

      Research  showed that used oil composition is varied and the possible constituents
are numerous. In accordance with accepted risk assessment procedures, the team decided
to narrow the list by identifying target contaminants of  concern (COCs). Chemical and
physical property and toxicity data were gathered by dividing the  COCs among the team.
During a meeting of all group members this data was reported on large tables, and COC
selection was conducted by group consensus.   The COCs were chosen by  grouping
chemicals with similar properties; comparing property, toxicity, and concentration data; and
choosing the one(s) most likely to have adverse health effects. For example, among the
benzene/toluene/xylene group of gasoline hydrocarbons,  benzene was chosen as the
representative COC because of its higher volatility and carcinogenicity.

      With COCs selected, the four groups previously established to research end uses
began to evaluate potential releases of the COCs and exposure pathways. Individual
matrices  were developed for rating  the potential  risks using a numerical scale.  The
ultimate fate of the COCs and the potential for transport through air, water, and soil were
the primary  bases for assigning  risk ratings.   Qualitative judgements were  made  by
balancing the severity of effects for exposure, availability/mobility in the environment, and
concentration in used oil.  The team agreed that end uses with multiple source releases
(e.g., incineration produces air emissions and ash by-products) all potential releases were
considered in the rating.

      During this process the students drew from their varied backgrounds and previous
year of course work. Process and chemical engineering and waste treatment knowledge
was  required to  understand the reprocessing  and re-refining technologies  and burning
systems.  Chemical fate and transport concepts were used to evaluate the  persistence and
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                TABLE 1. USED OIL END USE ALTERNATIVES
                                                              Relative
Classification/Alternative	Risk Ranking

RE-REFINING AND REPROCESSING TECHNOLOGIES
      •     Acid/Clay Re-refining                                    10
      •     Vacuum Distillation with Hydrotreating                    8
      •     Chemical Treatment/Demetallization/Clay Polishing         7
      •     Vacuum Distillation with Clay Polishing                    8

BURNING WITH CONTROLLED EMISSIONS
      •     Incineration (hazardous waste and municipal)               1
      •     Asphalt Batching Plants and Cement Kilns                 4
      •     Large Utility Boilers                                     3

BURNING WITH UNCONTROLLED EMISSIONS
      •     Space Heaters (vaporizing and atomizing)                12/14
      •     Small Residential Boilers                                13
      •     Industrial Boilers (without emission controls)               6

OTHER END USES
      •     Landfilling                                             2
      •     Landfarming                                            5
      •     Disposal in Storm and Sanitary Sewers                     9
      •     Uncontrolled Dumping  and Road Oiling                   11
of COCs in air, water,  and soils.  This understanding was particularly important to
evaluating the availability of COCs for exposure. Principles learned during our Health
Effects and Risk Assessment course were relied on to understand toxicity data and possible
exposure pathways.  (Similarly, many of these same studies were required to sort out the
data when selecting the COCs.)

      Our initial approach was  based  strictly  on human health risks. Several  team
members with ecological and biological backgrounds convinced the group that environmen-
tal risk is a critical factor in determining  the overall risks of end uses, thereby protecting
public health, welfare, and the environment. These students formed a small sub-group
later  on in the project to  address this issue and  research methods for conducting an
environmental assessment and the potential effects of COCs on a hypothetical ecosystem.
The extremely complex interrelationships of ecological systems, the difficulty in defining
these systems,  and  the difficulty  of predicting  contaminant  concentrations in the
environment prevented completion of an  ecological assessment for all identified end uses.
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However, the results of the general assessment were used to support the overall ranking
of end uses.

END USE RANKING AND IMPLEMENTATION

       During three days of group meetings the small groups which had researched end
use categories brought their initial risk ratings to the team for discussion and consensus.
A comprehensive risk rating table was developed to sum the risk ratings for each end use
from each exposure route. This rating was used to compare end uses and rate relative risk
potentials. Alternative end uses with lower numbers represented the least potential for
adverse effects on human health. The relative ranking of end use alternatives is indicated
on Table 1.

       Although simple to describe on paper, the relative ranking process was in fact more
difficult than originally imagined.  Whereas in other segments of the project  different
backgrounds helped  to facilitate the decision-making process, the diversity made this
particular exercise difficult.   It was important that the ratings be consistently applied,
however the rationale for each rating was often changed the next time a similar circum-
stance arose. New information from later ratings required changes to end uses rated early
on, and there were many opinions about how risk ratings should be assigned.  This made
it very difficult to reach consensus and proceed to the next phase of work. Nonetheless,
progress was made and the end uses were rank ordered as shown on Table 1.

REPORT PREPARATION

       Our primary  goal of  end use ranking accomplished,  the group  again divided
responsibilities according to personal talents and interests to get the job done.  Some
students took on the  task of typing, editing and generally producing what was to become
a 150-page report.  Writing styles varied greatly, and one person accepted the task of
overall editor.  Another student, with a demanding work schedule which often precluded
him from working with other group members, took on the task of producing the graphics
for the report,  a  job which could be performed on an independent schedule.  One person
accepted the tedious task of assembling and listing the over 100 references used in the
project and checking reference notations in the text for consistency and accuracy. Other
students researched the feasibility of implementing the preferred alternatives by contacting
industry representatives and regulatory officials.

RESULTS

       Implementation of three of the preferred end uses (hazardous waste incineration,
landfarming, and landfilling) was judged to be  inapplicable  in  Massachusetts due to
regulatory restrictions, capacity limitations, and/or public opposition. The feasibility of
utility boilers,  asphalt batching plants, and municipal incinerators was further evaluated
based on economic and practical advantages and  disadvantages of recycling used oil in
                                       649

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these respective capacities.  Utilities and asphalt batching plants are willing to accept and
consume used oil as a fuel  supplement.  They have abundant oil burning capacities and
realize lucrative economic  incentives by burning a less expensive fuel.  It was agreed,
however, that cumbersome  permitting procedures and a need for high quality assurance
programs for the incoming  fuel are the  main disadvantages of these end uses.

      In addition, the group proposed that although municipal incinerators may be a
feasible option,  more  information is  needed to make  a final  determination.   The
disadvantages of municipal  waste incinerators were found to be (1) inadequate capacity
when used solely as a start-up and shut-down fuel; (2) unwillingness of the industry to
accept the oil without a fee; and (3)  possible negative public reaction to burning a
classified Hazardous Waste in the Commonwealth of Massachusetts.

      Although not strictly part of our scope, the group's  enthusiasm generated three
specific recommendations for improving the management of used oil.

       1.     Establish a more  efficient permitting  process to  expedite
             decisions on  pending  applications  for utility boilers and
             asphalt batching plants.

       2.     Initiate further studies on  the feasibility of using used oil as an
             auxiliary fuel  in municipal incinerators.

       3.     Institute a source reduction program to decrease the amount
             and upgrade the quality of used oil entering the management
             system.

       Another task not strictly included  in  our scope was  consideration of  source
control/waste minimization strategies. Several team members with particular interests in
this  area researched this issue.  Suggested methods of source reduction for motor oil
include the use of water soluble oils, substitution of oils, extending the useful life of oil
products, reformulation, use of biodegradable oils, and employee training programs aimed
at waste minimization.
                                 CONCLUSION:
               BENEFITS AND DRAWBACKS OF A GROUP THESIS

       As described previously, this project differed from a typical graduate thesis in many
ways. First, it was a group project rather than an individual effort.  This factor allowed the
team to perform a  tremendous amount of work in a short time, but required more
organization  and communication, and compelled eight  individuals  to work  together.
Pursuit of individual interests  gave way  to  combining efforts on the client's desired
objective to meet the established schedule and budget.
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      Similar to the execution of a project under a typical matrix company organization,
the wide diversity of team member backgrounds and interests presented difficulties and
benefits during the life of the project, enabling the group to more completely address the
issue of used motor oil.    On one hand, this individual variation provided the team with
specific talents to contribute to the project. While editing, typing, graphics and proofrea-
ding skills were necessary to complete the project, some students were more proficient at
research, others at writing.  In addition, this project required knowledge of engineering,
chemistry, biology, environmental fate and transport, toxicology, environmental law, and
public policy. The team's diversity provided the needed capabilities in each of these areas,
which allowed for the most efficient use of resources for successful completion of the
project. Like a real consulting team, each member did his or her part to contribute to the
success of the whole.  In contrast, this diversity sometimes made it more difficult  to keep
the group focused on the scope of work and agree on the approach.

      While some thesis research is supported by grants from interested parties, not unlike
"clients", this project was performed to meet specific short term goals of the Massachusetts
DEP.  This meant that the  final product, the report, needed to support recommended
alternatives for the re-use or recycling of used oil.  The final product  of eight individual's
efforts needed to be formatted into one  report, without style or format changes,
repetitions, or omissions.

      After completion of the project we looked back at the program and thought about
what the experience had meant to us. The benefits varied according to the background
of each person. Those in the group with experience in the environmental field enhanced
their professional development, sharpening their  interpersonal and management skills and
learning to interrelate different fields.

      Probably the most important benefit  of this project was the emphasis of the
"process" of project execution and development of interpersonal skills. How we relate to
others on a project team and to our clients, what skills and interests are most valuable to
a group effort, how we communicate with others, and how we react under pressure were
all lessons that would not have been learned in  a traditional thesis.

      Overall, a group thesis is recommended as a valuable method of providing students
with hands-on academic training coupled with professional development.  Producing a
document that serves the needs of a real client increased our motivation and attention to
quality throughout the project.  Since completing the project in August 1989, we believe
that the "Capstone" was invaluable in preparing us for working in consulting or regulatory
organizations. The students agreed that no exam nor individual project could have given
them the educational experience that came out of this unique graduate thesis.
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           Presentation at the Opening Plenary Session
                             of the

        INTERNATIONAL CONFERENCE ON POLLUTION PREVENTION:
              CLEAN TECHNOLOGIES AND CLEAN PRODUCTS
             by: Dr. A. Tcheknavorian-Asenbauer
                 Director
                 Industrial Operations Technology Division
                 United Nations Industrial
                   Development Organization
     Mr. Chairman, Honorable Guests, Distinguished participants
from governments, non-governmental organizations, and the private
public.

     It is a pleasure for me, today, to address this Conference,
on behalf of the General Director of UNIDO, Mr. D.L. Siazon, and
to thank the Conference organizers, the U.S. Environmental
Protection Agency, and the International Association for Clean
Technology, for inviting UNIDO to take part in this important
Conference.

     The fact that we have gathered here today is partly due to
the historical and current international mission of this city.
Washington, as a center for many international organizations,
allows a cross-fertilization of ideas, politics and expertise,
and important contributions to the problems with which the
international community is confronted.  I trust this Conference
will be marked by the determination to go ahead and achieve
tangible results in an area which is a truly vital one for all
mankind.

     The internationally well-known Brundtland Report, "Our
Common Future," and other timely reports from national and
international organizations concluded that intensification and
broadening of environmental policy are urgently needed.  However,
we are realizing that achieving a higher environmental quality
will be a process that will last several decades.  We need the
exchange of technical know-how and strategic approaches at
national, regional, and international levels in order to ensure
that we reach our common objective of sustainable development.
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     Acid rain, depletion of the ozone layer, global warming,
hazardous wastes, pollution of coastal and inland waters, are all
supranational or even global issues, impinging on the health and
survival of humanity.  They cannot be solved in isolation.  Work
at the national level has to be linked with work at the
interregional and international levels.  International
conferences and international agreements are highly desirable,
promoting global awareness and exerting moral persuasion on
national governments and industry.

     In light of international awareness, the United Nations
Industrial Development Organization  (UNIDO), which has been
mandated to give developing countries technical assistance in the
field of industry, is working seriously in integrating
environmental management in all aspects of transfer and
application of industrial technologies.  Without such
environmental management, no sustainable development will be
possible in an already endangered world.  While it is true that
the complexity of environmental problems, the technological
feasibility, and the financial implications of solutions are
different from country to country, and particularly between
developing and industrial countries, we will still find ourselves
in the same boat, or to put it more adeguately for our modern
times, in the same spaceship.  We cannot opt out of that system.

     We, in UNIDO, interpret "environmental management" as the
prevention and/or abatement of undesired effects of industrial
activities with emphasis on promoting a preventive approach
through clean technologies.  Our thinking reflects current
international awareness in an effort to reverse the environmental
degradation.

     At the operational level, a wide spectrum of industrial
experts in agro-industry, engineering,  metallurgy and the
chemical industries, as well as in feasibility studies,
management, planning, institutional infrastructure and human
resource development, are taking part in the implementation of
different activities in the field of the environment through the
provision of expert services, supply of required equipment and
arrangement of training.  In 1988, UNIDO had 51 technical
cooperation projects under implementation that dealt entirely or
in part with the environmental aspects of industrial development.
By early 1989, UNIDO had developed over 80 new project proposals
in the field of environment totaling US$44 million.   These
projects cover air and water pollution control, solid waste
control, waste utilization, hazardous-waste management, and
various aspects of industrial safety and emergency contingency
planning.   An Environmental Coordinating Unit is being
established to ensure integration of environmental considerations
into all UNIDO projects.  We hope that this forum will give us
the opportunity to find partners to cooperate in the
implementation of the above mentioned projects.
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     The challenge before UNIDO and other international
organizations is to help developing countries to develop these
policies and strategies that will promote not only remedial
solutions to environmental problems, but solutions, technological
solutions, that will reduce industrial waste generation and will
be more conducive to sustainable development.  From UNIDO's
experience in promoting industrial development, these solutions
will not come about unless international organizations respond to
two issues.

     First, developing countries must be assisted in acquiring
the know-how and awareness that enable them to identify, assess
and adapt technologies and management practices that will
safeguard the sustainability of their natural and human
resources.  They must be persuaded, by implementing specific
projects, that pollution prevention pays.  They need to see that
the introduction of clean technology can reduce costs and at the
same time reduce harmful pollutant discharge to the environment.
These projects must demonstrate that the benefits of clean
technology, reduced production costs, and mitigation of harmful
effects on human health and the environment, can exceed the costs
of the new investments.  A list of projects will be available at
the Conference.

     Second, the industrial countries through bilateral and
multilateral efforts make additional development resources
available to implement this approach quickly and fully.
"Additionally," no conditionality of resources, is a necessary
ingredient to implementing solutions.  Developing countries want
to improve their standard of living in general, but if resources
are limited, the choice is difficult to make.  Financial
constraints have been, therefore, a major bottleneck in expanding
the integration of environmental resources management as widely
and as rapidly as would be desirable.

     Nevertheless, noticeable progress has been achieved in
developing countries.  An increasing number of decision-makers
are actively pursuing external assistance in strengthening their
know-how and measure in both remedial and preventive programmes
for the minimization of the deterioration of water, air, and land
resources.  The need to reduce waste and especially, hazardous
wastes, is perceived as one of the priorities among many
developing countries.

     Clearly, we in the multilateral organizations stand to
benefit from the work of governmental and non-governmental
organizations, such as the co-hosts of this important conference:
the U.S. Environmental Protection Agency, and the International
Association for Clean Technology.  Increasing awareness of the
potential of clean technology is clearly necessary if developing
countries are to appreciate its benefits.  I would like, in this
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stage, to mention that the cordial and useful cooperation that
UNIDO has with UNEP and other UN organizations such as UNDP, The
World Bank, and WHO.

     We, in UNIDO, are particularly pleased that the formation of
the International Association for Clean Technology took place
during one of our public awareness events, the International
Expert Workshop on Hazardous Waste Management, which took place
in Vienna in June 1987.  We share with pride the good work of the
Association.

     During this Conference, there will be ample opportunity to
exchange expertise in policies, strategic approaches, and
technologies promoting pollution prevention and clean
technologies.  The combination of economic, technical, and
industrial interests with environmental management is a great
challenge for the future.  This Conference can play an important
role in the ongoing international debate about the relevance of
clean technology for achieving sustainable development in
developing countries.

     For the next three days, you have indeed a challenging task,
and I am wishing you a fruitful, successful Conference!
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               CLEAN PRODUCTION:  FROM CONCEPT TO
            INTERNATIONAL CAMPAIGN THROUGH NETWORKING

                         Beverley Thorpe
                          Lisa J. Bunin

                    Clean Production campaign
                    Greenpeace International

Networking is the lifeblood of Greenpeace.  It is the key to our
success as an organization.  We build "networks" for circulating
and soliciting  ideas, philosophies and positions in order to
influence and initiate activities to protect the future of the
ecosphere.  Our network consists of the public, politicians,
professionals and other public interest groups who have a common
interest in halting human activities which adversely affect the
environment.

Action and information campaigns provide the springboard
for getting our message out to the public, and in turn,
broadening our global network of contacts and supporters.
Such campaigns further serve to raise key issues of environmental
concern onto the international political agenda, for
examination and discussion by the media, and to facilitate in-
creased awareness and involvement by the public.

"Reduce It, Don't Produce It," and "Clean Production" are the
banner headlines used to support Greenpeace's campaign against
toxic pollution.  These simple yet effective phrases convey the
message that the only way to truly solve the toxic waste crisis
is to eliminate the source of the problem—toxic products and
waste.  Through active campaigning by Greenpeace and others,
this concept has been increasingly adopted and promoted by people
throughout the world as the only realistic way out of the
pollution crisis.

Yet the implementation of these concepts in national and interna-
tional political fora is only beginning.  And here's the crux of
the problem.  This paper discusses two different approaches to
promoting the adoption of Clean Production strategies and activi-
ties by government and industry.

Part one examines a waste disposal campaign and examines how
"networking" on the issue of Clean Production led to a ban on
incineration at sea.  It shows how public opposition was a cru-
cial element in leading to a political decision to ban this
practice and it also shows how waste disposal technology is a
major disincentive to waste reduction.

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Part two examines Greenpeace's campaign to expose and propose
remedies for the current lack of an integrated  Clean Production
strategy by North Sea states.  It is concluded that the promotion
of Clean Production will entail a switch to the focus on the
product itself that will entail a complete reassessment of pro-
duction and ultimate phase-out of harmful processes and products.
To achieve this will involve a new societal involvement and
closer networking by policy-makers, industry and the public.
NETWORKING AND THE PHASE OUT OF OCEAN INCINERATION

The US Experience

Greenpeace launched its campaign against incineration at sea in
1982, when it became clear that the United States government
wanted to import the European technology to provide a panacea for
the country's growing waste crisis.  At the same time in Europe,
there was growing concern that the technology, intended as an
interim step in the phase-out of ocean dumping, was emitting
dioxins in the North Sea.

The aim of Greenpeace's campaign against ocean incineration is
threefold:

1)  to stop the use of the world's oceans for dumping industrial,
    chemical waste;

2)  to target toxic waste generation as the source of the waste
    crisis and its elimination as the only solution;

3)  to block the spread of another polluting disposal technology
    which results in the perpetuation and legitimization of
    wasteful and harmful -industrial practices.

In the United States, the Greenpeace campaign began to network
and share information with communities along the proposed waste
transport route to the waste storage facility in Emelle, Alabama.
This was done in preparation for a public hearing on the proposed
issuance of a permit to burn PCB-contaminated waste in the Gulf
of Mexico.  More than 6,000 people attended the first public
hearing on the issue, in Texas in 1983.

An anti-ocean incineration network emerged in coastal
communities in anticipation of future proposals,  with Greenpeace
informally designated as the national coordinating body.
Included in the coalition were Congressional,  state and local
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officials of the potentially impacted states.  Due to intensive
public protest, in 1984, the Gulf proposal was withdrawn as was a
subsequent proposal, in 1986, to burn PCBs in the North Atlantic
off the East Coast.  No burn has taken place in the U.S. since
1982, due to a strong network of people who lacked confidence in
the proposed ocean incineration programme.

The European Experience

The end to ocean incineration in the US, provided the necessary
fuel to fire the campaign in Europe.  In 1985, 1986 and 1987
(1,2,3) Greenpeace published several critiques on ocean
incineration.   Each report highlighted the fact that ocean
incineration discouraged the development of waste reduction
technologies and that its availability perpetuated waste
generation.

One report noted that "safer methods involving process
modifications to reduce hazardous waste generation are simply not
attractive to industry if it can send its by-products to the
lowest bidder, instead of fronting capital for process
improvements."(4)  The issue of liability was also key.  Another
submission pointed out that ocean incineration allowed industry
to escape responsibility for its hazardous waste generation
because the resultant environmental damage could never be linked
to the original waste generator.(5)

This information was circulated to decision-makers in all North
Sea governments to draw their attention to scientific and
technical flaws associated with the technology and its supporting
theories.  Several Greenpeace actions aimed at forcing
incinerator ships back to port served to expand the
organization's supporters and network.  Soon thereafter the
National Union of Seamen in the UK  and the National Federation
of Fishers, in Denmark, launched campaigns to end ocean
incineration.  Local communities in England and the Netherlands
also successfully defeated proposed expansions of port storge
facilities for hazardous waste destined for ocean incineration.
A new European network was born.

Influenced by growing public opposition and extensive media
coverage of the burn ship operations, the Second International
Conference on the Protection of the North Sea agreed to end ocean
incineration by 1995 with a 65% reduction of wastes burned by
1991. (6)

After the Ban:  What Solutions?

What would industries and national governments do to comply with
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this decision?  Caught off guard by the rapid phase-out, the
Commission of the European Community (EC) organized a seminar on
"The Management of Liquid Organo-halogenated Wastes after the
Prohibition of Incineration at Sea." (7)  A paper presented to
the conference by the Institute for European Environmental Policy
pointed out several waste reduction techniques currently avail-
able for  waste streams sent to ocean incineration. (8)  Specifi-
cally, a 15% decline in applications from chlorinated solvent
users in the Federal Republic of Germany was expected to contin-
ue.  This was due to a new waste management policy to recycle,
reuse or eliminate waste formerly sent to ocean incinerators. (9)

The paper further reported that glycerin and polyurethane could
be produced in a chlorine-free process.  Regarding pesticide and
pharmaceutical production, it was noted that "these industries are
rather innovative and will react themselves if the incentives to
miminimize their waste production are sufficient."  Of equal
importance, was the realization that some actual products, such
as PVC, were more of a problem than their resultant waste
streams.

Although process and product substitutions were clearly
available, industry and governments resisted embarking upon a
full-fledged waste reduction initiative.  Land-based
incineration was still the favoured policy alternative despite
the recognition by delegates to the EC seminar that "immediate
substitution of sea incineration by incineration on land faced
problems of public acceptance and licensing."

As a means of refocussing the debate back on waste prevention,
Greenpeace compiled a "Clean Technology/Source Reduction Contact
and Reference list to Facilitate the Phase-out of Ocean
Incineration." (10)  This document, submitted to the London Dump-
ing Convention, shows that waste prevention is a feasible and
realistic option by identifying contacts and source materials on
the regulatory, technical and management aspects of Clean Produc-
tion.  The document has since been published as an information
booklet and widely distributed, to international policy makers,
industrialists, environmental groups and the public.

The North Sea Ban

With heightened public resistence to ocean incineration and
growing concern for the health of the North Sea it became
increasingly difficult for industry to use this waste disposal
option, despite a future end date being agreed.  In Germany, the
largest contributor of wastes, large scale opposition to a
proposed new port storage facility in Emden put pressure on the
government to end the practice sooner.  The subsequent disclosure
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that waste containing dioxins remained in storage awaiting
incineration at sea, led to the abrupt end to the use of ocean
incineration by that country in 1990.

This heightened public concern and subsequent lack of commercial
confidence in the technology led to an earlier termination date
by other North Sea states.  All remaining user countries agreed to
terminate ocean incineration by the close of 1991, at the Third
International Conference on the North Sea held in March, 1990.
(11)  However, although an agreement was finally reached to phase-
out ocean incineration, the question still remains as to what
will actually be substituted in its place.

Submissions by various North Sea states to the London Dumping
Convention reveal a preference for future land-based incineration
and disposal technologies (12) although full access to informa-
tion on European industrial waste generation is incomplete due to
confidentiality and insufficient data.  This raises the issue
that no guidelines were given on the implementation of the phase-
out of ocean incineration.  Neither was there a policy focus to
ensure that public and political concern would not again occur
over the proposed solution to ocean incineration.

THE NORTH SEA - TIME FOR CLEAN PRODUCTION:
The Need for Implementation

The North Sea is a priority campaign area for Greenpeace because
it is the most heavily industrialized sea in the world and is the
direct recipient of most of Europe's waste streams.  The eight
countries who border the North Sea are the UK, France, Belgium,
the Netherlands, the Federal Republic of Germany, Norway, Sweden
and Denmark.

The Ocean incineration Campaign is only one of many Greenpeace
campaigns calling for a halt to the generation of hazardous waste
and products:  the North Sea campaign exposes all the polluting
discharges into the sea while calling for the implementation of
waste reduction programmes.  As has been Greenpeace's experience
with ocean incineration, agreements to reduce the totality of
toxic inputs into the North Sea lack guidance on how this can be
achieved.

The Second International Conference on the Protection of the
North Sea in 1987 agreed to "accept the principle of
safeguarding the marine ecosystem of the North Sea by reducing
polluting emissions of substances that are persistent, toxic and
liable to bioaccumulate AT SOURCE, by the use of the best
available technology and other appropriate measures."  Thus
goals and timelines were set to reduce "dangerous substances"
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by 50% by 1995, while ocean dumping of wastes would end by 1989.

However, a series of reports by Greenpeace analyzed North Sea
national policies and found great discrepancies.  There was no
consensus over what constituted a "dangerous substance" and for
the most part no background data was available to properly assess
the success of a percentage reduction to pollution loads. (13)

Furthermore/ in direct contradiction to preventing pollution "at
source" all national policies to control pollution entering the
North Sea have been based on the use of 'Best Available Technolo-
gy. '(BAT).  For the most part BAT is defined as "end of pipe"
solutions with the added  proviso that economic considerations
define what is considered the "best" that is available. (14)

Extensive national lobbying using these analyses ensued whilst
Greenpeace actions against direct discharges of waste into the
North Sea publicized the theme of Clean Production and '0-2000' -
   the complete reduction of toxic wastes into the North  Sea  by
the year 2000.

The New Environmental Paradigm

As well as critiquing the national implementation plans of the
North Sea states, Greenpeace commissioned a report from a Dutch
university to outline the necessary steps the eight North Sea
would need to implement a Clean Production programme and achieve
zero discharge of toxic wastes.  This report, Protection of the
North Sea:  Time for Clean Production, was sent to all European
Environment Ministers and networked extensively to the public to
force the adoption of this new environmental paradigm for future
policies.  The report introduced the concept of Clean Production
to many legislators for the first time. (15)

As a first priority the report details how Clean Production is
the antithesis to "end of pipe" pollution controls.  Clean
Production is defined as industrial systems which avoid,  or
eliminate hazardous waste and hazardous products, and use a
minimal amount of raw materials, water and energy.  Furthermore
goods manufactured in a Clean Production process must not damage
natural ecosystems throughout their entire life cycle.  Clean
Production, therefore, demands a conceptual and procedural ap-
proach to production.  It demands a total societal commitment by
industry, government and the consumer.

This makes product policy crucial and the following components
can be assessed with this in mind:

          the societal relevance of a product
                              661

-------
          the design of the product and product-development
          the raw materials used in its production
          the consumption phase
          the products in the disposal phase

Clean Production does not include "end of pipe" pollution
controls such as filters and scrubbers or chemical, physical and
biological treatment.  Measures which purport to reduce the
volume of waste by incineration or concentration, mask the hazard
by dilution or transfer pollutants from one environmental medium
to another are also excluded.

The Current Policy Challenge

To this end the report recommended basic criteria the North Sea
states would need to adopt to push the concept of Clean
Production into actual policy and practice.  These can be briefly
summarized:

Industry must do a toxic use audit to fully understand
how much toxic waste is generated.  Clean Production must then be
the first priority option when assessing alternative products and
processes.

Governments must use regulations and economic instruments.
Two key elements are permitting requirements that mandate clean
technologies and strict liability for damages caused by industri-
al processes.  This must be accompanied by full public access to
information and participation in the regulatory scheme.
Enforcement must be sufficient to deter companies from breaking
their permits.  Technical assistance must be available as part of
the support system.

Consumers must become aware of their role in moving society
towards Clean Production.  Full information of a product's life
cycle is essential.  Reduction, reuse and recycling must develop
as the new criteria for product acceptability.

Networking for the Future

The level of debate and discussion on Clean Production is rising.
Since the Third International Conference on the North Sea
there has been a demand by the European Parliament to replace the
use of Best Available Technology with Clean Production
methodology as the modus operandi for North Sea issues. (16)

However, this new paradigm will demand a new type of networking
based on increased awareness of the total societal responsibility
for Clean Production.  It will demand a radical change in indus-
                               662

-------
trial production and consumer behaviour to embody a deeper under-
standing of the connection between production, consumption and
environmental degradation.  Whatever form this networking takes,
it is assured that public campaigns against environmental damage
will transcend issues of waste generation alone and will focus
equally on the product itself. Just as ocean incineration result-
ed in a legislative ban so too must harmful products and process-
es be phased out.  It is Greenpeace's recommendation that those
halogens, previously burned at sea, be the first class of chemi-
cals to be banned as products.  Market force or mandate?  Whatev-
er  the economic method, the challenge now is to  implement  this
move toward Clean Production.

References:

1.  Official Greenpeace Policy on Incineration at Sea. 1985.

2.  Bunin, Stringer.  Incineration at Sea.  Unneeded Technology Poses
Unacceptable Environmental Hazards.  Greenpeace International
Submission to the Joint LlDC/OSCOM Meeting of Scientific Experts
on Ocean Incineration.  27 April — 1 May, 1987.  London.

3.  Bunin, Hillgaard and May.  Ocean Incineration.  The Case for a
Global Ban.  Stichting Greenpeace Council,  1988

4.  ibid. Bunin, Hillgaard and May.

5.  ibid.   Bunin,  Stringer.

6.  Second International Conference on the Protection of the North
Sea.  Ministerial Declaration.  UK Department of the Environment,
London.  April 1988.

7.  Commission  of  the  European Communities.   The  Management  of
Liquid   Organo-Halogenated  Wastes  After  the  Prohibition   of
Incineration   at  Sea.   Directorate-General  XI,   Environment,
Nuclear Safety and Civil Protection.  Final Report.   May, 1989.

8. Vonkemann.  The  Management of Liquid  Organo-Halogenated  Wastes
after  the  Prohibition of Incineration at  Sea.   Institute  for
European Environmental Policy.  Brussels.   May,  1989.

9.  Piasecki, Sutter.  The Origins and Decline of Ocean Incinera-
tion in Europe:   The German Example.  Umweltbundesamt (Federal
Environmental Agency), Berlin, FRG.

10.   Bunin,   Thorpe.   Clean  Technology  Contact  List  -   LDC
Greenpeace Submission.  October 1989
                               663

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11.  Bunin.   Ocean Incineration and the  Implementation  of  the
London Declaration.  Greenpeace International. Submission to  the
Third Preparatory Working Group Meeting on the Protection of  the
North Sea.  The Hague, Netherlands.  LDC March 1990.

12.  NL Submission on alternatives to O.I.  LDC 1988.

13.  0-2000.  No Half Measures.  July PWG Key Paper.  Greenpeace
International.  July, 1989.

14.  MacGarvin.  0-2000.  The Future, Clean Production.  Green-
peace Paper 30 for the Third North Sea Conference.  Jan, 1990.

15.  Baas, Hofman, Huisingh, Koppert and Neumann.  Protection of
the North Sea:  Time for Clean Production.  Erasmus Centre for
Environmental Studies.  Rotterdam.  February, 1990.

16.  European Parliament.  Extract of the Minutes of the Meeting
of Friday, 6 April 1990.  Brussels.
                               664

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 Title: RECOVERY OF CHROMIUM FROM TANNERY WASTEWATERS
         by:    Dimitrios TSOTSOS
                Chemical Engineer

                Ministry for Environment, Physical
                Planning and Public Works
                Environmental Planning Division
                Patission 147
                112 51 Athens
                Greece
Abstract:

    Chromium discharged as effluent  in  concentrations
of 2.000 - 3.500   mg/1,  is recovered and recycled back
into the tanning process by using a method developed by
the  Dutch institute TNO: the collected wastewaters are
treated  with  MgO  (coagulation   -   flocculation
sedimentation) and the produced sludge is redisolved in
sulfuric  acid.    This  solution  is fed back into the
tanning drums by standartized technique,  thus resulting
in savings of "fresh" chromium  quantities of up to  30
- 35%.

    The   removal.   efficiency   is   almost  complete,
producing a clear supernatant  with a chromium  content
of  less  of 2 mg/1 which can be reused for washing and
cleaning purposes.

    This project is now in progress,  being  elaborated
in  a Greek tannery in cooperation of Greek authorities
with Dutch counterparts and the EEC.
                         665

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                     INTRODUCTION
    The tanning production process is  practically  the
transformation  of  raw  animal  hides into leather and
related products.

    The hides are converted into leather  (tanning)  by
means  of  tanning  agents  which  are  either  natural
organic substances (tannins)  or  Cr"5"*  -  salts.   The
discharged  effluents  are  some  of the most polluting
industrial wastes.   Their treatment  and  disposal  is
therefore  vital for the protection of the environment.
This  problem becomes more critical for countries where
most of the plants are  either  small-size  units  with
small  economic  background,  or where they are located
near water bodies and the    effluents  are  discharged
without the appropriate treatment.
        DESCRITION OF THE PRODUCTION PROCESS -
              -  WASTE SOURCES
    The  production  process  can  be  separated  in two
parts:  preparation of the hides to receive the tanning
agents  (beam - house processes) and the tanning process
itself.

BEAM-HOUSE PROCESSES

I.  Washing - Soaking

    The  hides  are  first  washed  to  remove dirt and
blood,  and then soaked   for the removal of salt and for
softening.   The produced wastewaters  contain  a high
organic  load   (BOD»,)  due  to the dirt and blood along
with  a  high concentration of salt.


2.  Fleshing

    The next step  is the removal of  muscle   and   fatty
tissue  adhering   to  the  corium  layer  by  means   of
revolving  knives  while a continuous stream of   water
                         666

-------
carries away the produced impurities.   The wastewaters
from this process contain fat and fleshy particles.
3.   Liming

    Liming is done to swell the hides  for  the  better
penetration  of  the  tanning  agents  and for the hair
removal.   The hides are placed in  vats  containing  a
lime  suspension.    Small quantities of sodium sulfide
are added for the acceleration of the process.    These
waters are heavily polluted with high concentrations of
sodium sulfide,  lime and organic matter.
4.  Unhairing - Washing

    The   unhairing  of  the   hides  is   accomplished
mechanically by means of rolling knives.  Large amounts
of  water  are  used  to  flush  out loosened hairs and
excess lime.  The related wastewaters contain fine hair
epidermal particles and lime.
5.   Deliming - Bating

    The hides  are  washed  and  then  subjected  to  a
process  known  as  bating.    During this process some
proteins,  such as elastin,  are hydrolyzed in order to
avoid  any negative effects on the quality of the final
product.


TAN-YARD PROCESSES

After bating,  the hides are ready for  tanning.    Two
principal  methods of tanning are used according to the
related tanning agents: vegetable  tanning  and  chrome
tanning.
1.   Vegetable tanning

     The tanning operation is carried out in vats where
the   hides  are  kept  in  contact  with  the  tanning
solutions for several days.
                         667

-------
    The waste discharge  is  intermittent  and  heavily
polluted with organic load and colour.
2.   Chrome tanning

    For  the chrome tanning process the bated hides are
first soaked in a solution of sulfuric acid  and  salt,
for  10-16 hours.   This operation (pickling) helps the
better absorption of the chrome salts  into  the  pores
and  tissues of the skins.   After pickling,  the hides
are  kept  in  contact  with   the   tanning   solution
containing  either  salts of Cr1Tx or sodium dichromate
which is reduced to Cr*17  by  reducing  agents.    The
effluents   contain  high  concentrations  of  chromium
salts.

Finishing

    After tanning  a  series  of  operations  known  as
finishing   processes   are   carried  out  to  produce
different types of leather (oiling, dyeing etc.).
              WASTEWATER CHARACTERISTICS
    On Table 1,  a rough distribution of  the  quantity
and  quality  of the wastewaters in a chrome tannery is
shown as a percentage of the total quantity.
                        TABLE 1
Process


Beam-house
Tan-yard
Finishing
Volume of
wastewater
(*)
90
5
5
BOD»
(*)

90
5
5
g ^j-.-S*.
(%) (%)

100
99-100
0-1
    Table 2 shows a similar distribution for a  tannery
using tannins as tanning agents.
                          668

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                        TABLE 2
Process         Volume of wastewater        BOD-
                (*)                      (%)
Beam-house
Tan-yard
Finishing
90
5
5
42
47
11
    Table 3 shows a detailed flow and load distribution
within a tannery.
                        TABLE 3
Qualitative and quantitative data
of tannery wastes

Productior
prccess
Bashisg-Soiihg
tiring
Wasning
Deliising-Bating
Pi:kling
Vegetable tanning
Chrome tanning
Finishing
Hastewater
Valuie, I
of the total
42
IS
16
10
S
3
5
5
BODS S3
Jag'1) fsg/l!
i AAp_1CA -j • ~f\{\
14000-15000 7000
650
4000-6000 100-200
3000-4200 1000
3:00-20000 1300
700-1000 300-2000
2000 500
Dissolved Total
solids sol ids
13500
2tOOO
-
4300
10*00
17000
5000
2000
15000
33000
-
4400-4500
11000
18300
5300-7000
2500
pH
6.6
ll.fi
-
8.2
2.4
5.0
T T
Ji i.
3.9
    The main pollutants found  in  tannery wastewaters
                          669

-------
are   the   high   concentrations  of  organic  matter,
suspended particles and salt.    Two other constituents,
chromium salts and sulfides demand special attention in
order   to   prevent   their  negative  effect  on  the
environment.
             POLLUTION CONTROL TECHNOLOGY
    Several treatment  methods  are  generally  applied
with various efficiency grades.

    Tables 4 shows the related figures.
                        TABLE 4

      Treatment Removal Efficiences

Pol

Screening
Sedimentation
lutant reduct
BOD,
5
25-62
ion ef
SS
5-10
69-96
f iciency
Chromium
0
5-30
(*)
Sulfide
0
5-20
Chemica1
coagulation      41-70     70-97     50-80       14-50

Trickling
filtration       65-80     85-90     25-75      75-100

Activated
sludge           85-80     80-95       75       75-100
    Preventive  measures  -  Treatment  methods.    The
elementary  method  mainly  used  in  small   tanneries
consists  of  the by-products recovery  such  as flesh,
hair  etc.  while  the  use  of  definite water amounts
instead  of  a  stream  of  water  in  the   beam-house
processes   (washing)  helps  to  reduce  the  produced
wastewater volume.
                          670

-------
    The  equalization   of   the   flow    followed   by
sedimentation,  helps  to  remove part of  the suspended
solids  (40 - 50%) and a small  fraction of  BOD»s  (30%).

    Coagulation with lime or iron and  aluminium  salts
is   also   frequently   used   with   various  removal
efficiencies.   However,  the  produced amount of sludge
creates another serious problem.

    The  Dutch  research institute TNO has developed an
alternative solution for the BODa removal  without  any
biological  treatment  using   the  fact that 90% of the
organic matter comes from the  beam-house  process  and
consists mainly of dissolved proteins: After the stream
segregation  from the tan-yard and the sulfide removal,
the  pH  is  requlated  to  3.5    -  4.0   by   adding
hydrochloride or sulphuric acid.  This acidification of
the  wastes  helps  the  flocculation  of  the dissolved
proteins and the production of a floating  "cake"  which
can easily be removed.

    Biological treatment is a generally accepted method
for tannery effluents concerning their organic load and
sulfide  content.    There  are  controversial opinions
about  the  chromium  removal  efficiency  achieved  by
related   biological  treatment  plants  claiming  that
chromium accumulates in the  biological  sludge  in the
form of settleable solids thus being withdrawn from the
liquid wastes,  whereas the opposite assumption is based
on   the   only  slight  alkaline  environment  of  the
biological treatment systems (pH 7.5-8) which prohibits
the quantitative precipitation of chromium salts.

    Combined  treatment  of  tannery   effluents   with
municipal  wastewaters leads to acceptable results when
the hydraulic load coming out  from  the  tanneries  is
kept below 20% of the total quantity to be treated.

    In  any case the removal of chromium is a necessary
step prior to any further treatment.
                   CHROMIUM RECOVERY


          saits  are widely used as tanning agents for
                          671

-------
the production of durable  and  stable  leather  goods,
however  their  discharge  over the effluents can cause
severe damages to the environment.    Therefore  strict
effluent limitations have been adopted (2-5 mg/1) prior
to  their  discharge  either into sewers or directly to
water bodies.

    An effective and attractive method for the complete
removal of chromium constituents is their recovery from
the effluents and their  recycling  in  the  production
(tanning) process.

    A related demonstration project is now in  progress
in  a  Greek tannery which is being elaborated in close
cooperation  of  Greek  and   Dutch   authorities   and
institutions and the European Economic Community (EEC),
which is covering part of the costs.

    The  main  scopes of this project are the recycling
of chromium and the reduction of water  consumption  in
the tannery.

    The  applied  technology  is developed by the Dutch
institute TNO which is  the  technical  project  leader
together  with  the  Greek  Ministry  for  Environment,
Physical Planning and Public Works.
    The technical procedure is based on
aspects:
the  following
    The  tan-yard  effluents  (Cr - content: 3200 mg/1)
are separated from all other wastewaters and  collected
in  a  sedimentation  tank  where they are treated with
magnesium oxide (MgO).   All chromium  salts  are  then
converted  into  chromium  hydroxide (Cr (OH)-a.) - sludge
which is accumulated on the bottom of the tank.   After
the  discharge of the clear supernatant with Cr-content
less than 2 mg/1,  this sludge is redisolved in sulfuric
acid (H:;,:SO^)  and the produced solution is fed back into
the  tanning  drums  replacing  the  required   "fresh"
chromium quantities  of up to 35%.

    The  clear  effluent  can  be  used for washing and
cleaning purposes whereas a further reduction of  water
consumption  can  be  achieved by adjusting the tanning
receipe to skin washing procedures instead of rinsing.
                          672

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    Technical data

-   Daily production

    Chromium consumption
    (as  Cr-compounds)

    Chromium consumption
    (as Cr)

-   Chromium quantity  in
    the    effluents
    (to be recycled)

-   Chromium concentre
    tion   in    the
    effluents
    (before treatment)

-   Chromium concentra-
    tion   in    the
    effluents
    (after treatment)

    Tanning effluent
    quantity


    Economical data

Installation costs   :

Value of recycled
chromium" quantity
(7.5 $/kg)           :

Operational costs
(Chemicals, energy
costs, manpower)     :

Net savings          :
   8 tonnes

   400 kg/day


   68 kg/day  (17 ton/year)



   22.4 kg/day  (5.6 ton/year)
 :  3.200 mg/1




 :  2mg/1


 :  7 rri'Vday




7.500.000 Gdrs (50.000 $)



6.340.000 Gdrs (42.000 $)



1.500.000 Gdrs (10.000 $)

4.840.000 Gdrs (32.000 $)
    Organizational arrangements

    The  demonstration  project  which  is  now   being
implemented  in Greece is  a  good  example of a smooth
                          673

-------
cooperation between several parties.   According to the
programme  formulation  the  following   organizational
scheme has been developed:
Ministry for Environment
(Greece)
Institute TNO
(The Netherlands)
Hellenic Leather Center
(Greece)
Ministry for Environment
(The Netherlands)
Germanakos tannery
(Greece)
European Community (EEC)
Project leader responsible
for the whole project
Project leader responsible
for technical aspects
Laboratory support -
financial arrangements
Financial - organisational
support
Construction - operation of
the recycling installation

Financial support
    The      total  budget  amounts  24.000.000    Gdrs
(160.000  $)  covering  all  aspects  of  the  project:
collection  of  data,   technical  design,   laboratory
analysis.   construction  -  operation,   transfer   of
knowledge, travelling.
                      CONCLUSIONS
    This  demonstration  project  combines  on  a  very
effective way the requirements of minimized  wastewater
discharge with economical benefits for the industry, so
that  the  proper  functioning  and  operation  of  the
related facilities is not only a matter of  control  of
the environmental authorities but also closely  linked
with  the  industry's  economic  interest (raw material
saving).
                          674

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    In  parallel  it  will  help   to   overcome   some
misunderstandings  which  are  widely spread concerning
pollution control,  namely  that  biological  treatment
plants  are  capable  for  the  removal of any chemical
substance  from  wastewaters  and  that  coagulation  -
flocculation   techniques   are   the   only   existing
alternative solution.

    As a matter of principle the reduction of pollution
load at the source and  the  recycling  -  recovery  of
valuable   materials   from   the  effluents  prior  to
discharge should always be the main concern of managers
engineers  etc.   by  tackling   industrial   pollution
problems  and  only  if  all possible techno-economical
possibilities  are  exhausted,   end  -  of  -  pipe  ~
technologies should be applied.

    In   countries  where  the  POLLUTER-PAYS-PRINCIPLE
(PPP) has been  widely  adopted,  the  minimization  of
pollution  load  discharge  into  the  sewer  by  using
recycling - recovery techniques will cut down the usual
fees paid  for  being  connected  with  the  wastewater
collection and treatment system.   It should be kept in
mind that the adoption  of  environmental  taxes  is  a
crucial  aspect  of  equal competition conditions among
industrial  branches: the  industrialized countries are
increasingly complaining that industries in  developing
countries  create  favourable  economic environment for
their industries (lower costs) by neglecting  to  apply
strict pollution control regulations.  And this happens
not  because natural resources are abundantly available
there,  but mainly due to  financial  difficulties  and
ignorance of nature's restricted abilities to cope with
man's disturbing activities.

    Therefore  the  direction  to be followed is clear:
waste minimization at the source, recycling of valuable
material, economy linked with environmental protection.
                          675

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  WASTE  PREVENTION  STRATEGIES  IN THE FLEMISH REGION OF  BELGIUM

             by: P.  Van Acker
                 Kan. De Deckerstraat 22-26
                 B-2800 Mechelen
1.    INTRODUCTION

     In Belgium the coordination and implementation of Waste
Management has been delegated to the three regions.

     Every 5 years, the Executive Government of the Flemish
Region (60 percent of the population, 70 percent of the industry)
draws up a Waste Management Plan that has the force of a decree.
The second plan, for the period 1991 to 1995, contains items
aimed at concretizing an industrial waste minimization program.
With the first Flemish Prevention Plan we aim to reach, among
other objectives, the following goals:

     o    Merge the waste planning and the economic planning in
          order to reach an ecologically sound planning

     o    Draw up a common hazardous substances inventory of the
          Flemish industrial production apparatus

     o    Take stock of the existing technologies for the
          processing of hazardous substances

     o    Obtain and assimilate the low and no-waste generating
          technologies

     o    Determine the means (financial, juridical,
          technological)

     o    Lay down a suitable environmental policy on production
          and consumption of hazardous materials.
                                676

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     The draft decree on waste management will be submitted for
inquiry and scrutiny to the general public and the industry
during the months of September and October 1990.  The definitive
version of the plan will be adopted by the flemish Parliament
before January 1, 1991.  Once approved, it will have force of
decree.
2.
WASTE GENERATION IN THE FLEMISH REGION
     The trend of the total Flemish waste shown in table 1 is
clearly indicative of a substantial increase of the quantity of
waste, running somewhat parallel with the general pace of
economic development.
     Table 1:  General view on the waste product in the
               Flemish region of Belgium.
Haste Type
municipal waste
industrial waste
bulkwaste
dredging spoil
wastewater sludge
sewage. sludge
manure surpuls
construction waste
waste oil
hospital waste
car wrecks
Total
million ton
1985
1,6
3,5(estimated)
8,2
3,0
0,08
0,6
0,3-3
2,0
0,15
0,04
p.m.
18-22
million ton
1988
2,3
5,3(estimated)
6,3
4,1
0,16
0,8
1,7-3,6
4,6
0,2
0,06
0,11
24-28
                                677

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     Due to low energy and raw material prices and  the  almost
total lack of incentives aimed at strengthening the market
recycled products, reducing disposal by dumping proved  nearly
impossible during the eighties and recycling remained at its
perpetual modest level.  The percentage of dumped waste remained
at a constant 40 to 41 percent throughout the years 1982 through
1987.
3.
WASTE PREVENTION PLAN
3.1  Definition of Problems and Means

     On the basis of estimated values  and projected,  idealized
ways of disposal, figure 1 shows the relative  quantities of waste
which, by the early nineties, are  likely to  be set apart either
for recycling, incineration, or dumping.

     Industrial wastes subjected to some form  of preprocessing
(conditioning) are considered as suitable for  recuperative
methods.  The annual increase of industrial  waste, if no change
of policy should occur, is estimated at approximately 2 percent.


     Figure 1:  A diagram of the prognosis of  the offered
                industrial waste having to be  disposed.



RECYCLING
PDNniTIONING
|K|f*EMCD AT ION









10,5%
	 2,5% 	

42°/o


^.-" ~
^--""



-Hlv-.-^

^ — ->.
~"-~
I I I I I I

22,5%


41,5°/o

	 2% 	


20°/o
__„-'


^ ^^


— ^_
"•~Xlr

1 1 1

37,5 %



3 7, 5 "A,

	 1,5% —
9%
14,5%
                                                 PREVENTION





                                                 RECYCLING



                                                 INCENERATION

                                                 DUMPING
                                             year
                                 678

-------
     In comparison with the figures for 1987, preventive measures
are expected to result in a reduction of overall industrial waste
production of about  10 percent by 1995 and 19 percent by the turn
of the century.


3.2  Objectives

     Any initiative  toward preventive measures must be integrated
into both government and corporate management policies.  Steps
taken in this respect will indeed have a definite impact on
nearly all levels and fields of public health, employment,
finances and budget, and transportation.

     To be effective in terms of prevention, the waste management
planning must engage in a research program that encompasses the
entire chain of production.  Measures may be taken either at the
producers side, that is, within the existing economical context,
or on the side of the waste-processing authorities.

     Since waste-disposal problems tend to become more acute the
nearer one gets to the end of the production chain [mainly
because that is where the buck stops (i.e., the mess can no
longer be passed on] one may reasonably expect that this is where
new initiatives in view of a generalized waste-prevention scheme
will eventually spring up.  It is, therefore, of the essence that
the existing Flemish organizations and bodies entrusted with
planning, research,  data gathering, data-base management,
information, legal aspects, and the levying of taxes be put in a
position to exert a  more powerful influence over the actors and
factors that may affect the environment.

     The attention will be focused primarily upon the further
elaboration of preventive strategies,  and secondly, though not
less importantly, upon the stimulation of recycling,  as opposed
to other disposal methods.

     Last but not least, coordination of waste disposal
capacities will be looked into as a means to increase efficiency.
The available budget shall be reserved exclusively to advocate
and subsidize prevention and recovery within the industrial plant
and on the domestic  front.

     According to the principle that the polluter must foot the
bill,  financial and tax incentives in respect of investments in
the construction of  incineration and compacting installations
will be withdrawn.   Financial aid going to the landfills and dump
sites will be cut off.   As a result,  treatment and disposal
processes will be billed at real cost.
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3.3  Affirmative Action

3.3.1  Orientation of the Economical Expansion

     Investments in new technologies that will effect a
significant reduction of waste generation at its very source will
be selectively encouraged through additional expansion subsidies
(1 billion BF or 30 million US dollars).

     Concrete proposals as to standards and criteria will be
worked out between the Minister for Regional Economy and his
Flemish Executive Colleague for the Environment.

     In order to gain a comprehensive insight into the
problematics of waste product generation, the production systems
currently used in each different industrial sector in Flanders
will be looked into.  These audits will imply:

     o    A thorough inquiry into the various production areas in
          the Flemish region, both qualitatively (comparative
          merits of the production systems) and quantitatively
          (pollutant substance inventories, linking of emissions
          to immissions and to energy and raw materials
          consumption)

     o    The drafting of models to assess the quantities of
          waste that may be emitted without a detrimental effect
          upon the environment (self-regenerative powers of
          nature), the charting (at regular intervals) of stock
          inventories for all polluting substances, the
          verification whether previously imposed reduction quota
          are met

     o    Setting forth the outlines of an environment policy
          plan based on a thorough knowledge of the whole refuse
          cycle and a strict followup of the flux of raw
          materials in Flanders.


3.3.2  Stimulating Research and Development

     Research and development in the field of clean technologies
will be stimulated both in the stages of product design  (durable
goods) and of recycling potential (easily convertible materials)
and in respect of most efficient production processes.

     In order to prompt the development and application of clean
technologies, a program of incentives was drafted, embracing the
whole of the environmental problem.
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     Three types of projects are under review:

     o    Sensor projects aimed at ascertaining the feasibility
          of innovative ideas and rating their chances of further
          development

     o    Driver projects, focusing on a given crucial issue and
          searching a solution to specific environmental problems
          through coordination and mobilization of hitherto
          scattered means and know-how

     o    Booster projects, or live-scale try-outs in a market
          situation and demonstrations of a viability of new
          processes.


3.3.3  Agreements With the Industry

     Even though regulations will retain their importance in
certain areas, it must be stressed that even greater attention
will have to be paid to open consultation between the authorities
and the manufacturers in the major industrial sectors.  Public
authorities and the private sector will reach agreements with
regard to possible alternative raw materials, production
standards and packaging methods.

     By mutual agreement, labels will be designed to distinguish
refillable packages from their recyclable or single-use
counterparts.  Along the same lines, a prevention and recycling
strategy in respect of waste byproducts in all stages of
industrial packaging will be formulated.

     If the targets thus set forth cannot be attained by mutual
consensus within a reasonable lapse of time, antipollution taxes
and penalties will be levied on one-way products and stiff
deposits on returnable containers will be made mandatory.


3.3.4  Anti-pollution Taxes

3.3.4.1  Increment of the Taxes

     Antipollution duties on solid waste products have proved to
be an excellent deterrent, discouraging the production of trash
at its source and thus favoring reduction of waste generation.

     Condition to the success of such measure, however,  is that
such taxes be sufficiently high so as to convince the
manufacturers of the financial advantages in curbing waste
production.   The fees to be paid would be commensurate to the
amount and the nature of the trash produced.
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     Since October 22, 1986, taxes on industrial waste ranged
from 1 BF to 100 BF per ton.  On December 20, 1989, tariffs were
significantly raised and presently vary between 10 BF and 3.000
BF per ton.  Reckoned at these tariffs, the annual returns are
estimated at 1.6 billion BF or 48 million dollars.  The levies
will remain at the same level until 1992, and subsequently
increase.

     Recycling activities, on the other hand, are tax-exempt as
far as environmental duties are concerned.  It ensues that
antipollution taxes are also a stimuli to promote recuperation.

     Dumping and incinerating will require substantial
investments which, pursuant to the principle that the polluter
must pay, will ultimately be billed to the manufacturers.  As a
result, the budget to the Flemish Executive Government will no
longer have to set aside funds to subsidize incinerators or
landfills.  The existing incinerating facilities will be
gradually renovated, but only provided the pending initiatives in
relation to prevention and recovery have become fully
operational.


3.3.4.2  The Use of the Tax-generated Income

     The pace of the adoption and implementation of decisions by
the private sector to invest in environmental technologies
(preventive action, recovery, reduced use of hazardous
substances) would surely be increased if the funds collected
through environment taxes are applied:

     o    To gain knowledge and experience in the fields of
          prevention and recovery and to make such know-how
          available to the industry

     o    To take part in venturesome initiatives, which at
          present the private sector is reluctant to take on but
          which are essential for health and environmental
          protection reasons.
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     The snowball effect  of  such ventures in lowering the
threshold for the implementation of clean technologies is
illustrated in figure  2.
     Figure 2:  The effect  of the antipollution taxes
                and the  financial incentives on the
                implementation of clean technologies.
                     co»t of clean technology
                                         anti-pollution taxes
                                                          year
              1111
                          1111
                                      2111
                                                   2111
     The successful  outcome of the measures as indicated above
presupposes:

     o    That  sharp control be exercised as to the faithful
          payment  of the taxes

     o    That  the manufacturers,  and especially small and
          medium-sized businesses, be made aware of the costs of
          waste removal since raising the environment taxes will
          not automatically induce such private enterprises to
          take  immediate steps to switch to clean technologies.

     By increasing the predictability of running cost increments,
manufacturers will be enabled to anticipate future developments.
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     The strongest incentive for the industry to invest in
environmental technologies will be the firm belief in a
consistent, gradually stepped-up, and generally enforced
ecological policy on the part of the authorities.


3.3.5  Licenses

     A rigid licensing policy constitutes one of the most
powerful instruments in the prevention of harmful emissions.  The
generation of waste byproducts (viewed in terms of quantity and
chemical composition) should be regarded as one of the prime
considerations for granting of withholding operation permits and
subjecting production to stringent conditions.  In its advisory
capacity regarding the issuing of licenses and permits, OVAM, the
Public Waste Management Authority for the Flemish Region, firmly
intends to take into account the efforts made to check waste
production.


3.3.6  Spreading Awareness

     The sensitization campaigns are designed to inform and to
impress upon the industries, and, in particular, small and
medium-sized businesses, the notion of the necessity of a sound
waste management as an integral part of general management.

     OVAM  intends to elaborate a standard method for imparting
new attitudes and understanding about environmental issues that
will be made available to interested parties.


3.3.7  International Contacts

     Along the lines of the international contacts of the Flemish
Executive  Minister, OVAM will cooperate, as far  as waste  (solid
liquid sludge) management is concerned, with the EC, the Eastern
European countries, the Organization for Economic Cooperation and
Development and the UNEP.


4.   CONCLUSION

     If this ambitious goal  (i.e., preventing the generation of
waste substances)  is to be achieved, government-inspired actions
will have  to focus on:

     o     Acquiring  knowledge and experience

     o     Centralizing and disseminating relevant information
                                684

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     o    Giving financial aid to businesses either manufacturing
          or using nonpolluting products.


     The conversion of existing industrial activities or
launching of new activities will have to comply with the premises
of a future ecologically safe operation permit that will
incorporate and replace current permits and that will put the
highest premium on waste prevention.  Ecologically sound products
and processes will benefit from expansion subsidies provided both
waste generation and raw material flux are adequately controlled
and checked.
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         WATER POLLUTION PREVENTION IN THE NETHERLANDS

By: Frans A.N. van Baardwijk and H.B.  Pols.
Institute for Inland Water Management and Waste water treat-
ment. (DBW/RIZA), P.O box 17. 8200 AA Lelystad, The  Nether-
lands.

                             SUMMARY

According to some recent environmental policy documents a
further and especially a faster reduction of the pollution of
the surface waters by the industry is necessary.
From an analysis of the common practice in licencing it is
indicated that the water authorities should pay much more
attention to other fields than just technologicy in order to
take away the barriers for the use of clean preventive
measures. Nine points are indicated which are necessary to
improve the use of preventive measures. Implementation of this
preventive approach should result in a new preventive pollution
reduction policy.


                          INTRODUCTION

There is a lot of water in the Netherlands.  Besides this the
country is also densely populated and highly industialized.
This has resulted in pollution of surface waters and sediments.
For some decades however a lot of effort has already been given
to the abatement of poor water quality, resulting in a steady
increase of the water quality.
Recently some new national and international policy documents
have been published indicating strict targets to be achieved
within a couple of years. These targets can hardly be achieved
by continuing the common practice of waste water abatement. So
another way to cope with these problems has to be found.
In this article the Dutch policy for reducing water pollution
is given, as well as the barriers for clean technology in
industry and the approach to overcome these barriers in order
to promote the use of clean preventive technology.


                             POLICY

The legal framework to combat water pollution in the Nether-
lands is provided by the "Pollution of Surface Waters Act"
Section I of the Act states that it is prohibited to deposit
waste, pollutants or noxious substances in surface water,
unless a permit has been granted.
Two basic principles are used in granting licences (1):
- reduction of emission;
- stand-still principle.
These two basic principles have been worked out into the so
called:
- direct emission approach;
- the water quality approach.
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The direct emission approach has been worked out in the concept
of the "best technical means" and the "best practicable means".
The best technical means must be applied for black list sub-
stances, while for other substances, to which the emission
approach applies, the best practicable means must be applied.

The best practicable means (BPM) are technologies by means of
which the largest reduction of emission of polluting substances
is obtained once due allowance has been made for economic
aspects, i.e. what is acceptable from a financial point of view
for a normally profitable company.

The best technical means (BTM) are technologies which produce a
greater reduction than BPM at a greater expense.

A certain residual emission is regarded as acceptable for the
purpose of applying BPM, provided that the water quality objec-
tives are met.
When applying BTM a residual emission is in principle unaccept-
able and water quality objectives are not a point of consider-
ation.
This does not mean that financial aspects and business econ-
omics should not play any role at all in the application of the
best techniques available.
The "standstill principle" is related to the water quality
approach. The water quality may not significantly deteriorate.
Table 1 gives an overview of the application of concepts and
technologies in relation to the substances emitted.

The above mentioned "black-list-substances" correspond with the
list in directive 76/464/EEC of 4 may 1976 of the European
Community .

All this briefly outlines the policy, untill 1988,  when the
Rhine Action Program (2) and the North Sea Action Program (3)
came into force.
These programs, in which several European countries work to-
gether, were initiated because of the common concern about the
quality of these watersystems. These programs aim at a reduc-
tion of certain specified substances. The target is now a
reduction of 50% for all pollutants and 70 to 90% for some
organic micro-pollutants,  within the time-period 1985-1995.

Besides these source reduction targets the National Policy
Document on Water Management (6)  sets limits for the so called
"general environmental quality".  These quality standards for
several compounds in water and/or sediments are based on eco-
toxicological criteria. These standards are much stricter than
the standards in the Water Action Program of 1985 (1).

In working out this policy in daily practice the aim is to
obtain a uniform approach for companies as far as possible.
There can be small or medium-sized companies in certain indus-
trial sectors doing the same type of work in more or less the
same way.
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If this is the case the same provisions to discharges and more
or less the same conditions can be used in the discharge
licence of all these companies. This results in emission
standards for certain sectors of industry, such as the metal-
plating industry. For more complex industries like the chemical
process-industry the differences between companies can be big,
because of different recycling and treatment possiblities
available. So the licences of these industries can and will
differ significantly. For all companies, big and small, indi-
vidual "tailor made" permits are granted to obtain the smallest
emission possible.

These permits are granted by the local water authorities.
In order to maintain a common approach to dischargers all over
the country the National Institute for Inland Water Management
and Waste-water Treatment acts as one of the main advisors of
these authorities.

Not only reduction of the emissions into the water is needed.
From the National Environmental Policy Plan (5) it is clear
that emissions into the air, the soil and the amounts of
(hazardous) waste should be reduced. Especially for solid waste
a prevention plan has been set up.
The combined environmental policy results in a strong appeal on
companies to change their behaviour.


                        COMMON PRACTICE

To achieve certain emission reductions the Waterboard starts
negotiations with the company involved, resulting in a emission
reduction plan submitted by the company.
The main objectives of the plan, the emissions standards to be
achieved, as well as the timeschedule are put into the licence,
if they are accepted by the Board.
In this process of negotiation the water authorities will first
pay attention to the production process itself.
The policy mentioned above gives the authorities the possibil-
ity to ask for the environmentally best processes and equip-
ment, according to the BPM and BTM-principle. For example the
installation of a chlorine production unit based on mercury
electrolysis will not be permitted because of the proven
membrane-process, which avoids the emission of mercury.
Unfortunately new/alternative processes are often not taken
into account because of the financial uncertainties, product
quality, the time-pressure to reduce the pollution, etc.

The second subject in the "permit-negotiations" are the raw and
auxiliary materials used. For example the use of certain quali-
ties of phosphate-ores in the fertilizer industry can dramati-
cally influence the quality of the waste water. By using the
good qualities available smaller amounts of cadmium will be
emitted.
So in the licence the reduced cadmium amounts which are the
result of the better ore-quality will be stated. Of course the
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company is free to use ore of lesser quality, if additional
measures are taken and the set emission limits are not ex-
ceeded.

The auxiliary chemicals used should be reviewed also in order
to avoid the ones which are most harmful to the environment. In
the Netherlands the textile-finishing industry has created a
database for this purpose. In cooperation with the water
authorities certain "black" chemicals will be selected and
replaced if possible. Because of the large number of chemicals
the possibilities are unfortunately not always checked.

If all possibilities of process changes and internal recycling
have been paid (more or less) attention to, waste water treat-
ment comes into discussion as a major aspect.


Besides legislation the Government has some other instruments
to stimulate the abatement of waterpollution.
First of all levies based on the emission of the oxygen demand
of the discharged waste water are used to finance subsidies for
measures taken by local water boards and companies.
This results mainly into end-of-pipe treatment, in which the
suppliers of (standardized and low-priced) equipment play an
important role.

There is also a special subsidy to stimulate the development of
clean technology. This Governmental subsidy is given for
research projects for which the laboratory stage has been
completed, but where practical implementation is restricted by
the technical and/or economical risks involved. Projects that
qualify for such assistance must have certain novel technologi-
cal features, must be beneficial to the environment and have
the potential to be applied on a relatively wide scale. It is
hoped that government subsidized research of this type should
reduce the risks mentioned. In addition, the Dutch government
also supports demonstration projects involving clean technol-
ogy. (7)
Examples of clean technology project are:
- substitution of cadmium in the metal plating industry;
- the development of a clean phosphate fertilizer production
  process;
- measures to improve fish processing techniques.
- electrochemical treatment of process waste water containing
  halogenated organic compounds;
Nevertheless the spin-off of these projects is rather low,
because there is hardly any enforcement by the government to
invest in clean technology rather than in end-of-pipe-treat-
ment. Not even if the expences are equal. Secondly the com-
panies are not aware of stricter regulations in the (near)
future. In the third place transfer of the generated know-how
is insufficient.

Looking at these instuments  (legislation and subsidies) the
possibilities to promote the development and subsequent use of
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clean technology seem to be present.  Nevertheless the results
are poor.

The emissions of pollutants from the industry are reducing, but
too slowly to achieve the targets set in the policy plans.
So a new approach is required.
Realizing that the targets can only be achieved if more preven-
tive measures are used, the barriers for clean technology
should be known.
                      PREVENTIVE APPROACH

Licencing is considered the most direct way to influence
companies. So a project was set up to figure out the prevention
prohibiting points in this process.
The way the licencing process is run by the waterboard and
advise is given by the Institute now and the way it should be
run and advise should be given to obtain more preventive
results in the near future was analysed using the Integrated
Definition-method (IDEF).  This analysis was carried out in
close cooperation with the Netherlands Organization for Applied
Scientific Research (TNO)  (4).
The analysis resulted in nine points which need the attention
of the Water authorities in order to achieve more preventive
measures taken by the companies.
These functions are summarized below.

1.  Necessity of measures.
It was observed from the analysis that normally not everybody
involved is fully aware of the need to reduce certain emiss-
ions. This can cause a problem in introducing measures. E.g.
local politicians may support the company in its resistance to
invest in certain environmental measures if they not fully
understand the reasons.
So first of all the necessity of measures must be clear to all
the parties involved.  This includes the companies and the
authorities in charge of other fields than waterpollution, e.g.
air, soil, safety, etc.  If these parties know and agree on the
necessity of measures, targets can be set and may be expected
to be firmly supported.

2.   (Non)technological know-how.
Untill now the problems met in emission reduction are appro-
ached from the technological point of view. The technological
know-how should ofcourse be up-to-date. But other fields are
almost ignored, although these fields play important roles in
the decisions on investments.
From the analysis it is clear that know-how on environmental
effects of chemical substances, policy-making in other depart-
ments, technological aspects of preventive management, environ-
mental management, decision-making and economics in companies
and in industrial sectors are necessary to successfully intro-
duce preventive measures.  Special attention should be given to
the possibilities to change the attitudes within companies into
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a higher level of environmental awareness.

3.  Discharge standards.
Companies always complain that the government uses the vague
concepts of "Best Practicable Means" and "Best Technical Means"
in demanding efforts on emission reduction, in stead of setting
clear limits to be reached within a certain perio of time.
The analysis indicated that permits which did not contain dis-
charge-standards (preferably for a period of several years) can
be prevention prohibitive. Also an over tight time schedule for
the reduction of emissions will force companies to look for
existing possibilities. Mostly these will turn out to be end-
of-pipe treatments. (E.g. "I will not change a big part of my
process, if you cannot assure me that you or one of your col-
leagues will not be back with new demands within the next 10
years".)
So it should be made clear to the companies which discharge-
standards they will have to meet in the (near) future for all
environmental compartments involved.
These standards must be coherent and there must also be a time-
path to come from the present situation to the situation indi-
cated.

4.  Company specifics.
The specific information about the company which the Waterboard
depends on in the negotiations about the implementation of
emission reduction measures, is mostly not very much more than
that which the company itself has offered. So the Board can
hardly support suggestions for drastic changes by arguments in
terms of pro's and con's of the specific situation.
According to these observations know-how on technology, econ-
omic feasibility of process-investments, organisation of the
decision-making on investments is necessary to be an acceptable
partner in the negotiations with the companies or sectors of
industry involved. Also some knowledge of the companies'
culture and the way the company is organised will be very
usefull.

5.  Consistency of policy.
Evidently there is a gap between policy-makers and the people
who execute the policy in the day-by-day contacts with individ-
ual companies. This gap should not be too large. The companies
will not rely on statements made by the executors, if the
policy-makers speak loudly about another (stricter) policy. So
to create an atmosphere of mutual trust, it is necessary that
within the water compartment all authorities involved speak the
same language. The policy of abating water pollution should be
clear to all involved. In fact, in the negotiations with the
companies all authorities, not only from the water compartment,
have to work coherently from the same back-ground, (see also
point 3).

6.  Consistency of regulations.
The analysis performed pointed out that the environmental
regulations are not always very consistent. The authorities
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involved should be aware of gaps, resulting in undesired (non-
preventive) solutions of the environmental problems.
Regulations for the different environmental compartments have
to be coherent. Also the fine-systems have to be coherent and
consistent. "Internalization" of companies regarding the envi-
ronmental effects of their activities might be necessary to
overcome inflexible regulations.

7.  Transfer of know-how.
The analysis clearly indicates that companies are not always
aware of possible process-technological improvements. Especial-
ly in the smaller companies there is a lack of know-how on
process technologies. Alternative processes, improved process
units and so on are unknown. Most reports written by environ-
mental authorities and/or private consultants on these subjects
are addressed to the same or other authorities. These reports
are often not easily available for small companies and/or not
easily understandable for the people in these small companies.
So to improve the use of preventive measures the authorities
have to take care of the transfer of the necessary know-how.

8.  Quality control.
Mistakes during the production-process can easily result in
huge spills into the environment, slightly increased direct
discharges, as well as emissions into the environment elsewhere
within the product life-cycle, caused by reduced quality of the
product itself. Control systems on the "environmental quality"
of resources, process operations and products have to be incor-
porated in the common product quality control systems.

9.  Governmental discharge control.
The number of checks carried out by the authorities on the
discharges is limited. The first purpose of any entrepreneur is
making money. So care for the environment will take second
place at best. In this case circumstances of non-compliance
with the discharge-standards will occur.
The government should create an instrument to minimize the
companies' opportunities for non-compliance. Besides a strict
environmentally directed quality-control-system (see 8) within
the company itself, which can be checked by the authorities
effluent-monitoring might be usefull.

The nine functions, all of which have to be fulfilled for the
implementation of preventive management in private companies,
are in all their coherences depicted in figure 1. In the centre
are the two main items for preventive management: "investment
in advanced process technology" and "the daily process oper-
ation" .
                         IMPLEMENTATION

From the resulting "preventive approach" it can be concluded
that there are clearly other barriers, besides financial
uncertainties.
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In order to implement the proposed approach, information is
needed on fields in which neither the Institute for Inland
Water Management and Waste water Treatment nor the Waterboards
usually have much experience, such as economy and other non-
technological fields.
Therefore a project will be set up to investigate what kind of
knowledge exactly is needed and where it is available.
This project (8) will be set up in close cooperation with the
researchgroup of Prof.D.Huisingh of the Erasmus University
Rotterdam.
Primarily the aim of the project will be to bring about attitu-
dinal changes in environmental management and decision-making,
by giving examples and by influencing the attitudes of both
companies and authorities.
To gain experience with this new approach in practice some
cases-studies will be set up with selected companies.
Complementary to the approach mentioned these studies will be
enhanced by the experiences gained within the Pollution
Prevention Pays-concept.
The results of this cooperation should contribute to establish
a new preventive, pollution reduction policy.
                           CONCLUSION

According to the present waste water abatement policy in the
Netherlands, sharpened by the Rhine Action Program and the
NorthSea Action Program a further and especially a faster
reduction of the sources of pollution is necessary. To obtain
this reduction at one of the sources (industry) preventive
measures are needed.
From an analysis of the common practice in licencing it is
indicated that the water authorities should pay much more
attention to other fields than just technology in order to take
away the barriers for the use of clean preventive measures.
Nine points all of which have to be fulfilled for the
implementation of preventive management in private companies
are indicated to improve the use of preventive measures:
1.  Prove the necessity of the emission reduction to all people
    involved.
2.  Improve not only the available technological know-how, but
    also the know-how in the fields of e.g. economy, sociology
    and decision-making.
3.  Stipulate discharge-standards and time schedules.
4.  Improve company or industry-specific know-how.
5.  Organise consistence between policy-makers and policy-
    executors .
6.  Define consistent regulations and fine-systems
7.  Take care of the transfer of (preventive)  technological
    know-how,  especially to smaller companies.
8.  Demand quality-control-systems within the companies.
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9.  Set up or improve the governmental control system of
    discharges.

The generated nine points preventive approach will be worked
out in a project together with the Erasmus University
Rotterdam.
As major part of this project some case-studies at selected
companies will be carried out.
All this should result in a new preventive pollution reduction
policy.
                           REFERENCES

1.  Water Action Programme, 1985-1989 The Netherlands.
2.  Rhine Action Programme, 8th Ministerial Conference on the
    pollution of the Rhine, Strasbourg, October 1987.
3.  North Sea Action Programme. Ministerial Declaration on the
    Second international Conference on the pollution of the
    North Sea. London, november 1987.
4.  Brascamp, M.H., J.Quakernaat,  B.L. van der Yen and H.J.van
    Veen: DBW/RIZA and prevention in behalf of water
    management. TNO-report, nr. 89-355, November 1989 (in
    Dutch).
5.  National Environmental Policy Plan. The Netherlands 1989.
6.  National Policy Document on Water Management. The Nether-
    lands 1989.
7.  Luin, A.B. van and W. van Starkenburg: Clean technology in
    the Netherlands: the role of the Government. In: Pretreat-
    ment in Chemical water and waste water treatment; Springer-
    Verlag,  1988; pp 139-149.
8.  Baardwijk, F.A.N. van and H.B.Pols: Prevention and the
    pollution of Surface waters from industrial activities.
    A project plan. Annex 2 to ref 9. DBW/RIZA, febr. 1990.
9.  Pols, H.B.: Remedial Measures on the Pollution of Surface
    waters by Industrial Discharges. A main project-plan.
    DBW/RIZA, March 1990.
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       TABLE  1.  OVERVIEW OF  THE APPLICATION  OF CONCEPTS AND
         TECHNOLOGIES IN  RELATION  TO  THE  SU6TANCES EMITTED.
Type of substance
Blacklist substances
          Other   pollutants
clean up primarily on
the basis of

measures on basis of
any further
requirements based on
                     specific organohalogen
                     compounds mercury
                     cadmium etc.
emission approach
best  technical means
unacceptable
concentration  in the
aquatic environment
heavy   oxygen-
metals  consuming
       substances

       phosphate
       nitrate

emission approach
                                            best practicable means
water-quality objectives
                                              sulphate chloride heat
water quality
objectives approach

acceptability of
discharges and steps  to
be taken depending on
the water-quality
objectives aimed at.
                                            Define
                                            consistent
                                            regulations and
                                            fine-system
Prove necessity
of taking
measures
                                                                                       8
                                                                             Demand quality
                                                                             control-system
                                                                             within the
                                                                             companies
                         Organise consistence
                         between policy-makers
                         and policy-executors
                                     Improve
                                     industry-specific
                                     know-how
     Figure  1.  The  nine  functions  for preventive management.
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               New  Directions in Waste Minimization  Technologies:
                 Water Conservation Offers  Multi-Faceted  Benefits

                                     Amy Vickers
                            Brown and Caldwell Consultants
                                 Boston, Mass. 02116
Introduction

       Over the past decade, innovative technologies and advances in water supply management
have demonstrated that the science of water conservation has much to contribute to the emerging
field of pollution prevention. Numerous case studies show  that reductions in water demand
significantly reduce energy, natural resource use, waste generation, wear and tear on system
infrastructure, and deterioration of water quality. Conservation also benefits both water supply and
wastewater systems, such as publicly owned treatment works (POTWs). In addition, the more
efficient use of water can help stave off the destructive political conflicts that are often associated
with water supply management today.

       This paper explores the techniques and benefits of  water conservation and outlines
recommendations to help integrate them into future utility management and pollution prevention
programs.

Growing National Water Shortages

       Once relegated to the vast dry regions of the western United States, water supply problems
now affect virtually every major urban region east of the Mississippi.  Record droughts and
shortages are now occurring in parts  of California and Florida.   According  to the U.S.
Congressional Budget Officei, 170 of the nation's 756 large urban water supply systems now
need additional supplies.  The era of easy water developments is over: economic constraints,
environmental concerns, and political conflicts have significantly hampered  development of new
large sources. Further, the EPA's recent decisions to use Section 404 of the Clean Water Act to
prohibit new source development proposals in Denver (Two Forks Dam) and Rhode Island (Big
River) are indicative of a potentially far-reaching federal role in water supply expansion decisions.

       As new water supply options dwindle, many communities are  finding that water
conservation can serve as a valuable complement or alternative to supply-side strategies.  And on
the other side of the water equation — wastewater — many POTWs are finding that loads can be
reduced by conservation programs. The implementation of system wide conservation programs is
being shown to reduce  water and wastewater facility  operating costs and their associated
environmental burdens.  Moreover, such conservation efforts have sometimes resulted in the
deferral of capital expenditures and resources for new or expanded water and wastewater treatment
facilities.

Water Demand Strains Many Resources

       The production of potable water for public, agricultural, industrial, commercial, and
recreational use, as well as the treatment and management of the resulting wastewater loads, takes a
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 toll on the environment. The costs have hardly begun to be assessed.  They involve extensive
 infrastructure, land, energy, chemicals, and intrusion upon the natural ecology of surface and
 groundwater sources. While modern sanitary engineering has provided dramatic improvements to
 public health and the environment  since the cholera epidemics of the turn of the  century,
 wastewater treatment plants with their enlarged system capacities to serve our ever-growing
 population nevertheless strain their receiving environs.   Further, water is often the vehicle for
 pollution from inefficient industrial processes and agricultural applications involving excessive
 chemical and energy use.

 Water Conservation Comes of Age

       Where conservation was once viewed as a temporary means to achieve demand reductions
 during droughts or other water emergencies, the modern "science" of conservation has created new
 means to achieve permanent and substantial water savings.  Since the late 1970s,  water
 conservation "tools" have grown  beyond public education campaigns promoting voluntary
 reduction in water use to the development of water-efficient plumbing fixtures and appliances,
 cooling equipment, industrial processes, turf and irrigation methods and equipment, and other
 measures. In addition, advanced computer forecasting models and statistical techniques have been
 developed for more accurate assessment of water use and costs.

 Conservation Technologies & Benefits: Some Case Examples

        Experience has shown that most  water  utilities can reduce their water demand and
 wastewater loads from 5 to 15 percent by implementing a  comprehensive demand reduction
 program.2  Conservation strategies, encompassing both hardware and behavioral changes, are
 available for each water use sector.  The  strategies that result in the most  water savings are
 described below:

       Plumbing Fixture Retrofit.  Installation  of water-efficient plumbing fixtures ~ toilets
 that use  1.6 gallons per flush (gpf), showers that use 2.5 gallons per minute (gpm), and faucets
 that use from 2.0 to 2.5 gpm — can  significantly reduce residential and sanitary water use.  The
 total  estimated  annual household water savings from a  retrofit  of conventional  toilets,
 showerheads, and faucets range from 13.5 gallons per capita per day (gpcd) for replacement of
 fixtures  installed after 1980  to 33.5 gpcd for pre-1980 fixtures.  For a typical 2.7 person
 household, these ravings range from  13,300 to 33,000 gals/year, a savings of 39 to 61  percent
 over the present estimated household budget of 34,000 to 53,700 gal/year for high water-use
 fixtures.3

       Case Study: Santa Monicar  Calif. To help conserve supplies and reduce loads on the
 Hyperion wastewater treatment plant, the city of Santa Monica, California has initiated a program
 to replace 12,000 conventional toilets with low-flow fixtures; anticipated savings are 835,000
 gallons per day (gpd). The city plans to use the old toilets to construct an artificial offshore reef in
 Santa Monica Bay to attract fish and vegetation back into the area.

       Industrial/Commercial.  Water is used by industry and commercial establishments
 primarily for cooling, process water,  sanitation, and landscape irrigation. Cooling-water needs
 have been estimated to  account for about 70 percent of the gross water use of chemical-process
 industries nationally. Often, cooling water is uncontaminated and can be reused for landscape
 irrigation, cleanup, and other purposes. Replacement of once-through cooling processes with
recirculated systems has been shown to provide some of the largest water savings and the most
rapid  investment payback.
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       Case Study: San Jose. Calif.  In 1985, the city of San Jose, California, began a 10-year
conservation plan with a goal to reduce wastewater flows by up to  12 million gallons per day
(mgd) in order to delay a $180 million expansion of its San Jose-Santa Clara Water Pollution
Control Plant (WPCP). All user sectors - residential, commercial, industrial, and institutional —
were involved.  At that time, system demand was growing at a rate of about 3 mgd per year. As
part of the city's program to reduce wastewater flows, 15  companies in the electronics
manufacturing, metal finishing, paper processing, and food processing industries were surveyed to
assess the water, energy, and chemical cost savings realized from their conservation efforts.
Conservation measures by the companies reduced water consumption by more than 1 billion
gallons per year. Economic benefits from the conservation steps resulted in a combined savings of
about $2 million per year. The most common conservation measures taken by the companies were:
water use monitoring, recycling, reuse, cooling tower use, equipment modification, improved
landscape irrigation, and employee education. Some of the electronics manufacturing and  metal
finishing companies surveyed were able to reduce their use of chemicals by reusing makeup and
rinse waters that they had previously discharged and rebatched. While total  operation and
maintenance cost savings achieved from the entire demand reduction program will not be known
until 1995, it was originally estimated that over $40 million in gas, electricity, chemical treatment,
and associated system operating costs would be saved if the 12 mgd goal was reached.*

       Landscape and Turf Management. Significant water savings can accrue from  more
efficient residential lawn  watering and landscape irrigation for public parks, office parks,
cemeteries, golf courses, and road meridians.  About 50 percent of residential water demand goes
to outdoor use, mainly lawns, gardens, and other landscaped areas, and studies have shown that
most homeowners typically provide twice as much water as is actually needed. Homeowners who
modify their irrigation practices can reduce their turf water requirements by 30 to 60 percent
without sacrificing the quality of their lawns. Reduced watering is further beneficial to the health
of a lawn because waterlogged turf increases it's susceptibility to disease.

       Lawn and landscape areas are typically overwatered because of faulty irrigation systems or
because of ignorance of its true water requirements.  The efficiency of typical landscape irrigation
methods has been estimated to be 50 to 80 percent.*  Better availability and proper use of BTa data
and moisture sensors to normalize outdoor irrigation for local weather conditions can help reduce
outdoor watering. Another low-water-use landscape measure is xeriscaping, a term referring to the
application of environmental-appropriate horticultural practices. Xeriscaping involves  seven
principles: (1) proper landscape design, (2) soil improvement, (3) use of mulches, (4) reduction of
turf areas, (5) zoning irrigation systems, (6) selection of low-water-demand plants, and (7)
attentive maintenance. Xeriscapes have been developed extensively in California, Florida, and the
southwestern United States.

       Cage Study: North Marin Water District, California.  In 1985, the North Marin Water
District conducted research on the use of water, labor, fertilizer, fuel, and herbicides in traditional
landscapes in planned housing developments (townhouses and condominiums). While the dollars
savings attributed to decreased fuel  and herbicides were small, study  results showed that
aEvapotranspiration describes the total water used by a lawn. The rate at which it is used is called
the "ET rate"--water applied in excess of ET is not used by the lawn, and thus is wasted. The two
factors that largely determine ET rate and, hence, the lawn's water requirements, are grass species
and climate.
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significant savings could be realized by the use of a water conserving design.  Homes with water-
conserving landscapes used 54 percent less water monthly than homes without, and this reduction
in water and labor costs accounted for more than 80 percent of the total savings. Estimated cost
savings to the homeowner were $75/year.6

Measuring the Economic and Environmental Benefits

       Determining the economic  savings and beneficial environmental impacts of water
conservation can be a complex process. For instance, the marginal cost of resources to produce
(treat, pump, and dispose) an additional unit of water and wastewater can be identified for a
particular utility.  Such costs are typically for energy and chemicals. Nationally, the average
marginal cost of water supplied is about $1.00/1,000 gallons, and $1.50-$2.00/1,000 gallons for
wastewater collection, treatment, and disposal.  But the less obvious long-term capital benefits
from conservation, such as  the downsizing of pipes because of decreased residential water demand
or the  decreased  wear-and-tear on  infrastructure from more efficient system loads, are just
beginning to be assessed. Further, the benefits of reduced environmental impacts are not easy to
gauge since they affect many ecological systems and it is difficult to isolate the influence of one
source. The environmental and economic advantages of conservation are outlined below:

       Water.  Preservation of natural surface  water and groundwater hydrologic balance,
including free-flowing rivers and streams, wetlands,  freshwater fisheries, and related wildlife
habitats and species.

       Wastewater and Septic Systems.  Decisions to postpone or not to expand or build
new water supply  systems lead to reduced need for related wastewater facilities and result in cost
savings. The reduced wastewater volumes associated with water conservation can also extend the
life of an overloaded septic system. This will delay or eliminate the need to expand existing drain
fields,  allow future systems to be smaller,  thereby preserving land area and reducing system
installation costs.  Some communities allow for reduced hook-up fees and utility charges where
water efficient fixtures are used, bringing direct cost savings to the customer.

       System  Operating and Capital Costs Reduction.  Reduced water demand leads to
decreased water supply needs and reductions in the associated capital investments and operating
costs.   Reduced water demand will also lessen wastewater loads and  lower unit costs for
wastewater collection, treatment, and disposal. Conservation can also result in less wear-and-tear
on system and prolong the life of the system infrastructure. Facility expansions can be delayed and
sometimes averted;  the resulting cost savings could be applied to help stabilize utility costs or
upgrade existing facilities.

       Water Quality.  Water  conservation is inextricably linked to the  preservation of water
quality, particularly for well-drawn groundwater supplies.  By decreasing the rate at which
groundwater is pumped, water conservation can reduce the rate of infiltration of such contaminants
as saltwater, septic leachate, leakage from underground storage tanks, hazardous wastes, and other
pollutants into an aquifer.  Slowing this rate of infiltration could have a significant impact on the
viability of a groundwater supply system serving public drinking water needs.

       A good example of the link between water quality and water conservation is the city of
Fresno, California, a community of 270,000 people in the center of the agriculturally rich San
Joaquin Valley.  A history of heavy groundwater pumping and the use of agricultural chemicals in
the surrounding area have created a water crisis in Fresno. According to David Todd, Water
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Conservation Coordinator for Fresno, overpumping by the City is pulling contaminants toward
wellfields.7 The city has had to close 34 wells because of contamination by dibromcchloropropane
(DBCP), an agricultural pesticide. As a result, Fresno is trying to reduce water demand and slow
the migration of contaminants toward other wells in the area. The City Council has voted to retrofit
81,000 single-family homes with water meters and also advocated the use of 1.6 gpf toilets in all
new construction. Community leaders hope that these and other vigorous conservation measures
will buy them time to find new, uncontaminated sources of water for Fresno.

       Agricultural Productivity.  According to Sandra Postel, Vice President for Research at
the Worldwatch Institute, "Most of the vast quantity of water diverted by and for farmers never
benefits a crop: worldwide, the efficiency of irrigation systems averages less than 40 percent."
She goes on to describe the ecological toll of excessive irrigation: "By far the most pervasive
damage stems from waterlogging and salinization of the soil....[O]verwatering of fields raises the
underlying groundwater. Eventually, the root zone becomes waterlogged, starving plants of
oxygen and inhibiting their growth.  In dry climates, evaporation of water near the sou surface
leads to a steady accumulation of salt that also reduces crop yields."*  Also, in die last few
decades, excessive irrigation has washed high levels of toxic selenium out of the soil, a process
that would have taken centuries with natural rainfall. In the U.S., more than 4 million hectares -
approximately 20 percent of the nation's irrigated land - are watered by pumping in excess of
recharge.'

       The Lower Colorado River Water Authority (LCRA) has developed an aggressive
agricultural water conservation that has reaped substantial water savings and related  benefits.
LCRA own and operates two irrigation canal systems which together supply water to irrigate about
60,000 acres of rice each year. Rice irrigation is the largest use of water within the areas served by
LCRA, and it generates an income of approximately $300 million per year. In 1987, LCRA
initiated a conservation program to reduce water use  for rice irrigation. The LCRA program
consists of four  major activities: canal rehabilitation, on-farm conservation research, fanner
education, and farm water measurement.  These conservation measures have thus far reduced
water use for rice irrigation by approximately 70,000 acre-feet or 25 billion gallons a year. This
represents approximately 70 percent of the City of Austin's water use each year, or enough water
to serve the demands of a city of 300,000 people. LCRA has estimated that rice irrigation water
demands can be further reduced by another 65,000 acre-feet in the years to come. Other benefits
from the program include: reduced costs to pump water, lessened risk of water shortages during
drought that could jeopardize rice irrigation needs, higher lake levels for recreation, and improved
farm productivity and profitability.*0

       New Building Construction Savings.  Reduced water and wastewater volume loads
on buildings will allow downsizing of water and sewer service lines and help reduce construction
costs and costs for pipe.

       Sustainable Growth. Throughout history it has been  shown that the maintenance of a
prosperous and healthy civilization hinges, in part, on its ability to maintain sustainable resources
and development. The conservation of water is insurance  for future prosperity and continued
growth because it balances supply with demand, and makes water a renewable resource.  Every
home, industry, or farm equipped with water-efficient fixtures, equipment, or using  sound
irrigation practices will extend existing water supplies for future development.
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 Conclusions and Recommendations

       In order to ensure sustainable water supplies for this country's future, as well as minimize
 the associated use of chemicals, energy, and other natural resources, we must lower the demand
 side and promote conservation as the most cost effective and efficient supplier of choice. We need
 strategic planning on the federal, state, and local levels to develop renewable water resources and
 to reduce wastewater generation.  A comprehensive assessment of the benefits associated with
 water conservation needs to be developed and publicized.  The EPA's leadership in the
 development of policy and programmatic and educational assistance in the area of conservation and
 integrated water resources management is clearly needed by both the public and private sectors.  As
 part of that effort, the following recommendations are provided:

       1.     The total water, energy, and waste minimization benefits of water conservation
 need to be assessed. A model to identify all the factors and impacts of conservation should be
 developed and made available to communities and water and wastewater utilities.

       2.     Water conservation efforts should be focused on the biggest users so as to ensure
 the largest and most cost-effective savings.  A  number of sophisticated and proven benefit/cost
 models are  available to assist in this regard.   The Metropolitan Water District of Southern
 California and the South Florida Water Management District are both good examples where such
 analysis has been applied."

       3.     Water conservation programs should be combined with industrial and commercial
 toxics reduction  programs as they are mutually beneficial. Pretreatment programs should have
 incentives that include conservation. Currently, many states' industrial pretreatment programs
 have disincentives to conservation since they measure contaminant outflows per unit of water
 instead of total concentration.

       4.     Federal support of proposed  national plumbing standards for water-efficient
 plumbing fixtures and appliances is needed now.  The "National Plumbing Products Efficiency Act"
 (H.R. 1185/S.583), now pending in the U.S. Congress, would establish  water-efficient plumbing
 standards nationwide. Passage of this legislation would reduce daily U.S. water use by 3.4-8.4
 billion gallons a day if fully implemented in  1990.  Currently, more than 10 states and major cities
 have enacted laws or plumbing codes to require the use of 1.6 gpf toilets, 2.5 gpm showerheads,
 and 2.0 gpm faucets. However, federal standards are needed to ensure the nationwide availability
 and installation of water-efficient fixtures.4

       5.      Development of national guidelines  and incentives programs to promote water
 conservation is necessary to heighten public  awareness about the need  for and benefits of
 conservation.

       6.      Federal and state properties  should be assessed  to determine their potential for
 water and economic savings from conservation measures. Substantial taxpayer dollars are spent
 on maintaining federal and state housing authorities, institutions, military installation, and other
 facilities.

       7.      The disincentives to conservation - pricing inequities, ignorance, and resistance to
new engineering  approaches need to be eliminated. Many water utilities still do not charge  their
customers for  the true cost of water services and the same is true  for wastewater. Hence, the
economic burden is unfairly  distributed  among certain user classes  and taxpayer groups.
Historically, water conservation has been a low priority for many large users, such as industrial
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customers, since they often pay for water and wastewater service on a declining block rate
structure that offers a more favorable per unit charge compared to smaller users. They lack an
incentive to reduce their water demands and wastewater loads. In addition, in the future we must
set water rates not only by volume but also by efficiency of use.

       8.     Agricultural irrigation needs to be examined to develop more efficient equipment
standards and practices. Further, the impact of water use efficiency on food production needs to be
assessed.
NOTES
       1.


       2.


       3.


       4.



       5.


       6.


       7.

       8.


       9.


       10.


       11.
U.S. Congress. "Congressional Record, Proceedings and Debates of the 100th
Congress, Second Session." Vol. 134, No. 146. Wash., D.C., October 14, 1988.

Maddaus, William O. Water Conservation. American Water Works Association.
Denver, Colorado.  1987.

Vickers, Amy. "Water Use Efficiency Standards for Plumbing Fixtures: Benefits
of National Legislation."  Journal AWWA.  May 1990.

"Case Studies of Industrial Water Conservation in the San Jose Area." Prepared by
Brown and Caldwell Consultants for the City of San Jose, California Office of
Environmental Management.  February 1990.

"Water Conservation in California." Bull. 198-84. California Department of Water
Resources. Sacramento, CA. July 1984.

Nelson, John O.  "Water-Conserving Landscapes Show  Impressive Savings."
American Water Works Annual Conference, Denver Colorado. June 1986.

Personal communication. David Todd, City of Fresno, Calif. (Jan. 1990).

Postel, Sandra.  Water for Agriculture: Facing the  Limits, Worldwatch Paper 93
(Washington, D.C.: Worldwatch Institute, December 1989).

Dickason, Clifford, "Improved Estimates Groundwater Mining     Acreage,"
Journal of Soil and Water Conservation, May-June 1988.

Personal communication. Mike Personett, Lower Colorado River Authority (June
1990).

Macy, Peter P., and Maddaus, William O. "Cost-Benefit Analysis of Conservation
Programs." Journal AWWA.  March 1989.
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                PROCESS OPTIONS FOR WASTE MINIMIZATION AND
            METAL RECOVERY FOR THE METAL FINISHING INDUSTRIES


                by:     C.W. Walton, A.C. Hillier, and G.L. Poppe
                       University of Nebraska-Lincoln
                       Department of Chemical Engineering
                       Lincoln, Nebraska 68588-0126


                                      ABSTRACT

     There is growing environmental concern with the methods of waste disposal used for han-
dling hazardous materials in the metal finishing industry. A resulting need exists to develop
and implement the best existing and potential technologies for waste minimization and resource
recovery.  The objectives of this  study were to identify and briefly describe both existing and
potential future methods for minimizing and recovering metallic wastes in the metal finishing
industries.  Included  in the evaluation are the advantages and disadvantages  of the various
methods available and under development. Existing minimization techniques include counter-
current rinsing, drag-out reduction, and waste segregation.  Recovery methods investigated
include evaporation, ion exchange, reverse osmosis, electrodialysis, and re-smelting of metallic
wastes. Discussions on future methods also cover combination technologies with the trend to-
ward development of closed-loop processes. Investigation has shown that additional research
must be done to make the developing technologies economically feasible.  These  challenges
are being met by increasing contributions from the technical community, particularly chemical
engineers.  Finally, the metal finishing industries must be willing to join in the development
and implementation of these new technologies if we are to successfully  answer  environmental
concerns.


                                    BACKGROUND

     Electroplating of metals became feasible in 1840 and has grown until it now ranks as an
important specialty industry, with nickel, copper, and chromium as examples of the most impor-
tant plating metals (1). Electrodeposited metals serve either a decorative or structural purpose,
or sometimes both, by providing a pleasing appearance and/or various desirable engineering
properties.  Electroplating finds  application in many areas, including electronic, automotive,
aerospace, and household products.

     An example of this dual purpose application is chromium plating, which has both decorative
and "hard" or industrial-use. These hard chromium coatings possess such desirable engineering
properties as heat, wear, corrosion and erosion resistance, and a low coefficient of friction (1).
Chromium is deposited primarily from a chromic acid (CrOs as I^CrC^) solution, which is
highly toxic.

     A major concern in metal electroplating  is the high toxicity of plating chemicals and,
therefore, the process requires extensive measures to prevent release of hazardous material to
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the environment. Releases come primarily from discharge of improperly treated rinsewater,
though spray from  the  plating bath surface  (particularly while using aeration for mixing),
spills, and occasional plating bath disposal (because of uncorrectable composition) can also be
of concern. In addition,  since chemical precipitation of heavy metals is the primary method of
treatment of these waste materials, disposal of hydroxide sludge is a significant problem. When
confronting these problems, concern must include the short and long-term effects on the health
of the plating shop workers and the public  in general.

    Concern  for public  safety  has lead to growing environmental regulations on the federal,
state, and municipal levels. Regulations include the Resource Conservation and Recovery Act
(RCRA)  and the Hazardous and Solid Waste Amendments of 1984 (2,3). As with all man-
ufactures, the plating industry must deal with unfounded fears  of the public about anything
involving chemicals, especially  when the chemicals are deemed "toxic" by public institutions,
such as the government or the press. To command public confidence, not only must we continue
to responsibly handle these hazardous materials, but we must make our successes known to the
public, which, at a technical level, will involve developing improved means for disposal and
ultimately recovery of valuable resources through process improvements and new technologies.

    The minimization, recovery, and treatment methods employed for wastes produced by any
electroplating process, however, can be very complicated. The subject is an area of chemical
engineering, involving chemical reactions (both  chemical and electrochemical) and unit oper-
ations (such as mixing and filtration) (1), typically referred to as electrochemical engineering.
Developing feasible solutions must involve full consideration of all technical, legal, and economic
implications.

STEPS IN WASTE MANAGEMENT

    A successful waste management program requires using a systematic approach. One possi-
ble approach has four major steps (4). Step I involves planning and organization. The program
goals must be determined and a task force organized. Step  II is the assessment stage where
the specific process is evaluated and is the  most important step. The assessment stage can be
summarized with five basic operations:
   1. collecting and compiling process and  waste stream information,

  2. prioritizing waste streams,

  3. site inspection,

  4. generating  options, and

  5. screening options.

Once the various options have been evaluated, Step III in the waste management program is
a feasibility analysis of both the technical and economic factors. Step IV is implementation of
the chosen waste management program.

    A successful waste management program involves a number of general techniques, the first
being inventory management, which includes  both  inventory and materials control. Possible
controls consist of hazardous chemical inventory size reduction, as well as material loss and
damage reduction during handling and production. A second useful technique involves produc-
tion process modifications  in the form of maintenance programs,  material changes, and process
equipment modifications (4). The  final  technique of a sound waste management program is
that of waste minimization and recovery. A successful management program will implement all
three techniques simultaneously.
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     Generally, those methods involving waste minimization and recovery demonstrate some
form of integrated waste treatment system (5), which tends to treat wastes at the source. A
typical block diagram of an integrated waste system is illustrated in Figure 1 (5).  The advan-
tages of such a system include simplified supervision and control, reduction of waste treatment
costs, simplified sludge handling, and improved rinsing. The major drawbacks include a neces-
sity for additional process equipment and operation expense, as well as possible degradation of
plating if not operated properly.


                                     OBJECTIVES

     The objectives of this study were to identify and briefly describe both existing and potential
future methods of waste management for minimizing and recovering metallic wastes in the metal
finishing industries,  including evaluation of the advantages and  disadvantages of the various
methods available and being developed.


                       EXISTING/CONVENTIONAL METHODS

CURRENT DISPOSAL TECHNOLOGY

     Chemical precipitation is currently the primary method used in the treatment of electro-
plating waste  streams (1,5,6). The most common precipitation technique is hydroxide treat-
ment, which involves altering the pH of a solution with sodium or calcium hydroxide to precip-
itate  the heavy metal hydroxides. The drawbacks  to hydroxide precipitation, however, include
the dependence of precipitate solubility on pH and  the difficult  dewatering characteristics of
the resulting sludge. Another chemical technique  uses soluble and insoluble sulfides, with the
advantages of wider  acceptable  pH range and much  better thickening and dewatering charac-
teristics of the metal sulfides produced. However, the major drawbacks include the presence of
toxic sulfides and possible evolution of hydrogen sulfide gas in the process. The metal hydrox-
ide sludge produced after dewatering must be fixed to prevent leaching, typically with portland
cement, and then disposed of in a landfill. Future constraints on land disposal will increase the
pressure  to eliminate precipitation as a method of waste treatment.

MINIMIZATION TECHNIQUES

    The first  option one should consider to reduce wastes is minimization because it is the
least  expensive reduction technique and is often quite easily implemented. The cost of waste
treatment depends largely  upon the volumetric flow rates of waste  and the concentration of
pollutants in the waste water (7) areas where minimization efforts should be focused.

    To reduce volumetric  flow rates, modified rinsing methods should be analyzed. Since the
rinse process is the primary contributor to waste streams, a countercurrent application  (such as
in Figure 1) may be  more  appropriate. For example, simply using a  two-tank counter current
rinse  system, water usage (and subsequent waste water  production)  can be reduced  by 99%
over a single tank system (7).

    The  primary contributor to the quantity of waste.material produced by plating operations
is drag-out, which is the  liquid material that adheres to the plated parts and rack when removed
from the  plating tank. Drag-out may be controlled and hopefully  minimized by adjusting such
factors as bath  density and  viscosity, geometry of  pieces,  drainage time (the most readily
controlled factor), positioning of pieces, and velocity of withdrawal (5).  Other options  that
may reduce chemical drag-out include using spray rinses or ah- knifes above the plating bath
and reducing the bath concentration itself (7).
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                                                                  Finished
                                                                  Part
                                                                   r
Drag—in
Drag— out
               /            \         r\         r\
        Bath
     Impurities
 Recovered
 Concentrate
                             ._•—.*••*»»»*»»*•».•—
                                            Rinse System
                      Return
                      Recovery
                      System
                                 Recovered
                                 Rinse Water
                               Blow Down
                               (impurities)
                                               Make—up
                                                Water
             Figure 1: General integrated waste treatment system.
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     Other minimization options are also  available.  Segregation of wastes is an  important
technique for reducing treatment loads.  When wastes are mixed, they become diluted and
require larger treatment facilities for cleaning and re-separation. Also a mixture of wastes is
given the hazard classification corresponding to the most dangerous material present, leading to
higher disposal and liability costs. Reducing the frequency of tank dumps is another option that
will lower treatment costs  (5).  Using less hazardous materials in the actual plating processes
may also be beneficial. Other cheap and effective tools for waste minimization include using flow
regulators, conductivity probes, reuse of contaminated rinses, and good housekeeping (cleaning)
practices (7).

RECOVERY TECHNIQUES

     When low cost plating line modifications or rinse-and-recycle modifications are not avail-
able, chemical recovery may be an option.  A number of useful techniques exist for plating
material recovery and range from simple evaporation to electrodialysis. With all of these meth-
ods, waste chemicals are recovered, as the name implies, and are  sold or reused in some part of
the process.

     Evaporation is the oldest, simplest, and most durable of the recovery methods.  Three
evaporation techniques find common use (6).  The first is atmospheric evaporation,  which can
use waste process heat as an energy source.  The second is vacuum evaporation, which allows
liquids to boil at lower temperatures, thereby  preventing thermal  degradation of bath additives,
such as organic brighteners (7).  The major problem with vacuum evaporation is  the need  for
more sophisticated equipment and expense. The third option is a simple film evaporator.

     The advantages to evaporation techniques include  versatility, reliability, and recovery of
nearly 100% of dissolved solids.  Nevertheless, the disadvantages include a large initial invest-
ment, large energy requirements, possible need for stream pretreatment, and return of the entire
stream to the plating bath (i.e., impurities  are not removed, but  concentrated) (5,8,9).

     Ion exchange is another recovery option. Of any method, it is  the best in flow rate per dollar
invested, but the worst in water conservation  (6). Ion exchange removes metals and impurities
by using polymeric resins  that replace the harmful, or valuable,  ions in solution  with  safe,
inexpensive ones. The great advantage of ion exchange is its ability to reduce the concentration
of dissolved metals to  very low levels; the fluid discharged from the column typically contains
less than 0.5 ppm of the toxic material (10).  Ion exchange works best for dilute solutions and
is effective for a large number of metals (9).  The major drawback is that the exchange resins,
usually in the form of beads, must be regenerated by flushing with a suitable acid,  caustic or
brine solution, leading to added expense and downtime, as well  as another stream that must
be treated and/or recovered.  A useful configuration of ion exchange columns involve having at
least two connected in parallel to allow for  continuous operation  while regeneration occurs.

    Reverse osmosis (RO) is a more complicated recovery method. It requires applying pressure
to a concentrated solution  to overcome the natural osmotic pressure and force permeation of
water through a membrane  (5).   The concentrate may then be treated or reused and the
pure permeate (water) recycled.  Reverse  osmosis units come in  three basic configurations:
spiral, tubular, and hollow fiber (5). A few drawbacks of RO include an inability to produce
a sufficiently concentrated return stream  and  no removal of impurities (9). There  may also  be
degradation of the membrane caused by plugging with salts or permeate compression.

    Electrodialysis is a recovery method that lends itself to closed systems and is often  used
to reclaim metals (6).  As the name implies, electrodialysis is electrolytically assisted dialysis,
where an  applied potential forces ions to  migrate through an  ion selective semi-permeable
                                           707

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membrane. Electrodialysis is good for high drag-out rates and is also effective for concentrating
rinse waters to high strength (6). The efficiency, unlike reverse osmosis, improves with increasing
metal salt concentration and the only major drawback is a need for careful maintenance and
operation (9).

    A final recovery method that finds application is electrolytic recovery and is usually applied
for drag-out tanks or spent strong solutions. It involves an electrochemical reduction of ions to
elemental form onto a cathode for subsequent removal. The process requires a drag-out recovery
tank, an electrolytic recovery tank (usually with stainless steel cathodes), and  a recirculation
pump (5). High flow rates or good agitation are also needed to circulate the bath. The major
advantage is  that it tends to minimize the load on the waste treatment system and pollution
discharge rates while also avoiding the conversion of metal ions to sludge.

    Once the metals ions have been reduced, three options for handling the  metal/cathode
combination  exist. The metals may simply be disposed of when plated onto a cheap, plastic
substrate. A high surface area cathode may also be employed where a fibrous or filamentous
substrate collects the metals, which are then chemically stripped for resale. The final removal
option is employed when a high purity metal extract is desired.  A solid slab of high  purity
metal may be reduced onto a flat cathode  for mechanical stripping and resale on secondary
metal markets (9). The disadvantages of electrolytic recovery include problems  operating with
dilute solutions  (low conductivity),  a large electrical energy requirement, and the diffusion
controlling factors (8).


             FUTURE/POTENTIAL METHODS OF WASTE TREATMENT

    By far, chemical precipitation has  been the  most popular waste treatment method, but
due to the increasing costs of landfilling, new methods of hazardous waste treatment have been
focusing on waste minimization. The ultimate goal is to achieve "closed-loop" operation where
all raw materials entering the process line exit as part of the finished product.  In this regard,
conventional  processes have been improved, more effective combinations of existing technologies
have been developed, and new, creative technologies continue to be researched.

    A problem with conventional electrodialysis processes has been fouling of the membranes.
Nearly all new electrodialysis installations utilize a reversible process in which the cell polarity
is periodically reversed, thereby reversing the flow to and from the concentrate and depleting
chambers (11).  Flow reversal tends to redissolve or physically purge precipitates and surface
films, but requires membranes that can function in either the anion- or cation-selective modes,
and platinum-coated titanium electrodes that can function either as cathodes or anodes.

    Conventional electrolytic recovery techniques have recently evolved into fluidized bed elec-
trochemical reactors, which has improved the economics of removal and  recovery of metals
from dilute solutions.  (12). The typical cell  consists of a set of apertured, expanded-metal-
mesh electrodes immersed in a bed of small glass beads.  The bed is fluidized  to about twice
its packed depth by pumping rinsewater upward through a distributor  particle  bed. The glass
beads continuously scrub the surface  of the electrode and promote mixing, which brings fresh
solution to the electrode surface.  This type of electrochemical reactor has been successfully
used to recover gold, silver, cadmium, nickel, nickel-iron alloy, copper, and zinc (12).

    A new variation of an older concept involves application of ultrafiltration (UF) and hyper-
filtration (HF) to electroplating waste minimization and has been particularly effective for the
removal of suspended solids, oil and grease, large organic molecules, and complexed heavy met-
als from wastewater streams (11). In UF and HF, a membrane retains materials based entirely
                                           708

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 on size, shape, and molecule flexibility. Feed solution is pumped through a membrane module
 and the membrane acts as a sieve to retain materials that are too large to pass through its pores.
 The retained materials (concentrate) then exit the module separately from the purified solvent
 (the permeate).  The difference between UF and HF is only in its selectivity. Hyperfiltration
 typically removes species with a molecular weight between  100 and 500 g/mol;  ultrafiltration
 removes species with a molecular weight greater than 500 g/mol (11).

     Since  individual waste minimization processes cannot  always achieve the desired degree
 of recovery, combinations of individual processes have been developed which utilize the major
 advantages of the separate processes.  Several examples of a combination of ion exchange and
 electrolytic recovery exist.  Typically, the solution produced from regeneration of an ion ex-
 change column is much more concentrated than the influent  waste  stream and may be ideal for
 further treatment by electrowinning. Electrolytic recovery converts the toxic metals in solution
 to their elemental form, often as metal sheets that can be reused, sold for scrap, or otherwise
 safely  disposed.  However, electrowinning is not as effective as ion exchange for reducing dis-
 solved metals to low concentrations and, therefore, the residual solution is directed back to ion
 exchange for further treatment, thus creating a "closed loop" (10).

     Another alternative is the re-smelting of traditional electroplating waste sludge to recover
 the metals, which has been implemented for reprocessing of iron,  nickel and chromium-mixed
 sludge (13). The resulting ingots are sold to stainless steel manufacturers. The major advantage
 of this process is the elimination of the long-term liability associated with landfilling. However,
 the process is highly energy intensive and not easily applied to  small scale operations with the
 current technology. Presently, only a few reprocessing facilities exist in the mid-Atlantic region
 of the  U.S., leading to potentially prohibitive shipping costs.

     New, creative technologies are constantly being researched.  Among these is the electro-
 dialytic ion exchange  (EDIX)  cell, which consists of alternate bipolar and cation  permeable
 membranes between an anode and cathode, as shown in Figure  2 (14).  The wastewater stream
 enters  the  regenerate chamber where metal and hydrogen ions migrate across the cation  per-
 meable membrane into the concentrate chamber. To balance the negative ions remaining in the
 regenerate chamber, water is separated into hydrogen ions and hydroxide ions by electromotive
 force within  the bipolar membranes.  The hydrogen ions replace  the  migrating positive  ions
 while the hydroxide ions migrate to the anode and react to form oxygen gas and water. In
 the concentrate chamber the formation of hydroxide ions balance the positive ions that have
 migrated from the regenerate  chamber  through  the cation permeable membrane,  while the
 hydrogen ions formed  migrate  to the cathode and are reduced to form hydrogen gas. Initial
 process analysis of the EDIX system indicates that a single pass process is not capable of pro-
 viding a water stream suitable for disposal, but does greatly reduce the metal ion concentration
 and could  possibly be used in series and/or in conjunction with  other processes to create a
 closed-loop process (14).

     Other creative research has focused on using vermiculite and partially converted shellfish
 waste (15) as a medium to  adsorb metal ions from solution. The ions are then recovered by
 eluting the medium and directing the resulting concentrated stream back to the plating bath.

    New technologies are becoming more economically feasible due to the increasing costs  and
restrictions of current  disposal methods  (i.e., disposal  of precipitate sludge in landfills).  The
trend is definitely toward closed-loop configurations, although never fully obtainable  due to
unavoidable contaminant build-up that can result in reduced product quality.  Nevertheless,
the closed-loop efforts greatly  reduce the amount  of sludge produced and can still pay for
themselves through reduced sludge-removal costs.
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ANODE
           FROM RINSE TANK
               OH
                       REGENERATE
                         CHAMBER

                           (R)
TO FINAL TREATMENT
                                           FROM CONCENTRATE  TANK
                                                       H
                            CONCENTRATE
                             CHAMBER

                                (C)

                            CATIONS
                                  OH
H
                                                         CATHODE
                                               TO CONCENTRATE TANK
           BIPOLAR  MEMBRANE
                                     -  CATION PERMEABLE MEMBRANE
             Figure 2: Schematic diagram of the electrodialytic ion exchange (EDIX) cell.

-------
    Finally, microcomputers can be utilized as a powerful tool to evaluate the performance
of new and existing treatment systems (16).  Programing languages, such as FORTRAN and
BASIC, and spreadsheets can be used to develop mathematical  models of systems to evaluate
their operating feasibility without physically building prototype models and conducting labo-
ratory experiments, thereby saving time and expense.  Also, these models are convenient for
evaluating existing systems, as well as developing an economic evaluation of alternatives (16).
To fully utilize these tools, the electroplating industry will require increased technical expertise
in the fields of chemical,  electrochemical and environmental engineering.


                                    CONCLUSIONS

   1. There is a need to continue developing near closed loop processes for reuse of raw materials
     before they become treatable wastes,  which  involves emphasizing waste minimization,
     stream segregation, and contaminant minimization.

   2. New technologies, such as in the area of electrodialysis, are being developed. They will
     need to be tested under actual operating conditions.

   3. Computers in general, and microcomputers in particular,  are a valuable, but under uti-
     lized, tool in the surface finishing industry for evaluating existing and future technologies.
     Training and exposure to example applications will be necessary to change this situation.


                                RECOMMENDATIONS

    Continued development  of new technologies, and  combinations of them, are needed in
order to approach the closed loop operation goal.   To accomplish this,  the surface finishing
industry must be willing to support research efforts and to try new technologies as they develop.
Improving waste minimization and recovery methods will also require a higher level of technical
expertise  in the industry to  allow for proper evaluation  of technical  and economic options,
as well  as operation of these new processes.  Hiring chemical  engineers with environmental
and electrochemical backgrounds is essential for technical/economic  analysis and  additional
specialized training of operators.


                               ACKNOWLEDGEMENTS

    Funding for presentation of this work from the National Association of Metal Finishers,
Washington, D.C., is gratefully acknowledged.

    Although the work described in this article has  been funded in part by the United States
Environmental Protection Agency under assistance agreement number R-815709, to the Uni-
versity of Nebraska-Lincoln through the Hazardous  Substance Research Center for U.S. EPA
Regions 7 and 8 headquartered at  Kansas State University, it has not been subjected to the
Agency's peer and administrative review and therefore may not necessarily reflect the views of
the Agency and no official endorsement should be inferred.


                                    REFERENCES

   1. Lowenheim, F.A. Electroplating.  McGraw-Hill, New York, 1978.  p. 537.

   2. Gold, R.F. Stabilization of F006. Paper presented in Session M: Environmental II, AESF
     SUR/FIN '89, Cleveland, Ohio, June 1989. p. M-2.
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 3. Philipp, C.T., Rostoker, W., and Dvorscek, J. Solids Detoxification—Beating the Land
    Ban. Paper presented in Session M: Environmental II, AESF SUR/FIN '89, Cleveland,
    Ohio, June 1989. p. M-3.

 4. Freeman, H.M. (ed.). Hazardous Waste Minimization. McGraw-Hill, New York, 1990.

 5. Cherry, K.F. Plating Waste Treatment. Ann Arbors Science Publishers Inc., Ann Arbor,
    Michigan, 1982.

 6. Roy, C.H. The Operation and Maintenance of Surface Finishing Wastewater Treatment
    Systems. American Electroplaters and Surface Finisher's Society, Orlando, Florida, 1988.

 7. Environmental Pollution Control Alternatives: Reducing Water Pollution Control Costs
    hi the Electroplating Industry. EPA/625/5-85/016, U.S. Environmental Protection Agency,
    Washington, D.C., 1985. 62 pp.

 8. Bray, S.S.  Resource Recovery from Electroplating Rinse Baths. Master's Thesis. Uni-
    versity  of Nebraska-Lincoln, Lincoln, Nebraska, 1988.

 9. Steward, F.A., and McClay, W.J. Waste Minimization Alternate Recovery Technologies.
    Metal Finishing,  Guidebook Directory 1990. 88:1A: 818, Jan 1990.

10. Ryan, J., Hulbert, G., Fleet, B., and Kassirer, J.  Case Study of a Minimum Discharge,
    Heavy Metal Waste Reduction System at Aeroscientific  Corporation, Anaheim, Califor-
    nia.  In: Proceedings of the 10th AESF/EPA Conference on Environmental Control for
    the Metal Finishing Industry.  American Electroplaters and Surface Finishers Society,
    Orlando, Florida, 1989. p. 327.

11. MacNeil, J., and McCoy, D.E. Membrane Separation Technologies. In: H.M. Freeman
    (ed.), Hazardous  Waste Minimization. McGraw-Hill, New York, 1989. p. 6.91.

12. Aguwa, A.A., and Hass, C.N. Electrolytic Recovery Techniques.  In:  H.M. Freeman (ed.),
    Hazardous Waste Minimization.  McGraw-Hill, New York, 1989.  p. 6.41.

13. Walton, C.W.  A Critical Review of Chromium Plating  Waste Treatment and Recovery
    Methods.  In:  K. Newby (ed.).  Proceedings of the 2nd  International AESF  Chromium
    Colloquim. American Electroplaters and Surface  Finishers Society, Orlando, Florida,
    1990 (in press).

14. Walton, C.W., Quan, J.R., Bray, S.S., and Thompson, T.T.  Initial Process Design of a
    Membrane System for Metal Recovery from Electroplating Rinsewater. In: Proceedings of
    the Conference on Hazardous Waste Research 1989.  Kansas State University, Manhattan,
    Kansas, 1989. p.  374.

15. Coughlin, R.W., Deshaies, M.R., and Davis, E.M. Chitosan in Crab Shell Wastes Purifies
    Electroplating Wastewater. Environmental Progress. 9:1: 35, Feb 1990.

16. Walton, C.W., and  Poppe, G.L.  Applying Microcomputers to the Analysis of Waste
    Treatment and Recovery Processes. In: Proceedings of the llth AESF/EPA Conference
    on  Environmental Control for the Surface Finishing Industry.  American  Electroplaters
    and Surface Finishers Society, Orlando, Florida, 1990. p. 275.  Also:  Plating & Surface
    Finishing.  77:6: (in press), Jun 1990.
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                                CFC POLLUTION:
            REPAIRING THE OZONE HOLE THROUGH MUNICIPAL LEGISLATION

               by:  Frances E. Winslow, Ph.D.
                    City Manager's Office
                    City of Irvine, CA
      From the beginning of the Industrial Revolution to the end of World War
II, industrial expansion was viewed everywhere as a positive good whose
environmental impacts were the price to be paid for progress.  The dramatic
rise in the standard of living and the decrease in mortality justified the
rivers turned to industrial sewers and the SMOG-laden air.

      By the 1960's the devastation in some areas was great enough to generate
a legislative response at the State and Federal levels in the United States.
Foaming rivers and polluted bathing beaches resulted in such regulations as
California's 1969 Porter-Cologne Water Quality Control Act, and the Clean
Water Act of 1972 and Safe Drinking Water Act of 1974 at the Federal level.
Other States undertook the remediation of large areas lost to industrial
pollution.  The State of New Jersey created the Hackensack Meadowlands
Development Commission to clean up the Hackensack River and its adjacent tidal
lands in 1968.  However, local government environmental efforts were generally
limited to weed abatement, fire and building code enforcement, and refuse
regulation legislation.

      In 1989 the city of Irvine passed an ordinance, resulting in the
regulation of the use of ozone-depleting chemicals within the city limits.  As
one of the 200 largest cities in the United States, and a major industrial
center in Orange County, the city exerted a leadership role in acting on
scientific information developed at the University of California, Irvine.
Japan Prize-winner Dr. Sherwood Rowland pioneered research on the effect of
chlorofluorocarbons in the stratosphere.  Years of research demonstrated a
clear connection between the release of CFC's and the destruction of the ozone
layer that protects the Earth from ultraviolet light.  Satellite photographs
of the Antarctic confirmed the existence of a seasonal hole in the ozone layer
of significant size.  Based on the length of time that CFC's remain capable of
interacting with ozone, scientists on Dr. Rowland's team predict a significant
increase in the amount of ozone destruction over the next decades, even if CFC
release were stopped today.

INTERNATIONAL EFFORTS TO REGULATE CFC'S

      Dr. Rowland's research had come to the attention of the United States
Government, and international cooperative efforts were undertaken to end the
use of CFC's.  The Montreal Protocol of 1987, signed by about 50 nations to
date, commits the signatory nations to lowering the production of CFC's to 50
percent of the overall 1987 production by 1999.  A 1989 review of the
scientific data led to an agreement for a total phaseout by 2000.  However,
while the industrialized nations are signatories to the Montreal Protocol and
its amendment, most of the developing nations are not.
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LOCAL ACTION

      While standards for dealing with the CFC problem can be set at the
international and national level, effective implementation requires active
local cooperation.  Each point source of CFC emissions lies within the
jurisdiction of a local or county government.  Developing an implementation
plan that is suitable for the entire world, or even for the whole United
States, will be a lengthy process.  During the developing, CFC's will continue
to be released into the atmosphere.  Local governments can work with the local
community to effectively create local regulations that reduce CFC emissions
quickly.  While each municipality may release only a small portion of the
world-wide total of ozone depleting compound emissions, each molecule of CFC
that is recycled or destroyed is a contribution to the health of the
stratospheric ozone layer.  The present state of the art in recycling and
product substitution is developing in response to national and international
deadlines.  Shorter local timelines have the effect of hastening the
development of safe alternative products and processes in advance of the
market pressure.

      In the winter of 1988-89, the city of Irvine formed a staff committee to
review the city's own uses of CFC's, including styrofoam cups for public
functions, air conditioning units in city vehicles and buildings, and halon
fire extinguisher systems installed in computer rooms.  When it was discovered
that alternative products and recycling systems were available for some
applications, a program was discussed for a shift away from the purchase and
use of ozone-depleting compounds.

      Mayor Larry Agran encouraged the development of a larger vision of the
application of this information.  He reminded the staff that global
improvements begin with local action.  He suggested "think locally, act
globally" as the theme for the development of legislation to improve the
health of the stratosphere.  Mayor Agran augmented the Irvine city staff
committee with Council aides with past experience in environmental legislative
areas.  An active program to develop a city-wide ordinance to ban ozone
depleting compounds was begun.


LOCAL BUSINESS RESPONSES

      The local business community, contacted through the business license
list, received postcard notification of the introduction of the ordinance for
first reading.  Each business was invited to send a representative to testify,
and an extensive public hearing was held.  Some businesses were concerned that
their competitive edge would be lost because of the higher cost of alternative
technologies.  Others were concerned that customers would simply turn to other
suppliers to continue to receive the formulations they desired.  Council
member Cameron Cosgrove pointed out that local businesses would actually
develop a competitive advantage because they would be "ahead of the curve" in
implementing the changes needed by the turn of the century.  The
implementation of the ordinance also provided a field for entrepreneurs to
develop new products that would be CFC-free, with Irvine as a ready market.
The major chemical companies are also moving toward CFC-substitutes in
response to the international agreements.  Irvine businesses would be able to
convert to newer chemicals before the rush for last-minute compliance with
international protocols.  A local businessman, Dan Russell, stated his
willingness to comply with the ordinance was based on his concern for his own
children.  "I want them to have a good environment," he said.

      Other business community members raised concerns about the proposed     „
legislation.  Some pointed out that their activities are controlled by
governmental entities, such as the Food and Drug Administration regulation of
medical products manufacturing standards, and the military specifications
built into contracts with the Department of Defense.  Others asserted that
their use of CFC's is a very small part of their manufacturing process, and
the cost of retooling would be prohibitive.  The higher cost of known
substitutes was a concern for many of the small businesses.  Product safety
was a major concern within the business community, as toxicity testing on
                                      714

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alternative chemicals has not been completed.  In many cases the alternative
chemicals are very new, and no testing has begun.  Many alternatives are known
to be more hazardous in the workplace, which is why many of the CFC
applications were developed originally.


ORDINANCE REGULATING CFC USE

      Following an interchange of ideas, the ordinance "Governing the
Manufacture, Distribution, Sale and Recycling of Products which Utilize Ozone-
Depleting Compounds" (No. 89-21) was passed by the City Council on August 22,
1989.  After a section on definitions, the document includes a section
outlining the specific prohibitions on the manufacture, sale, or distribution
of products utilizing ozone-depleting compounds.  There is a prohibition on
the use of ozone-depleting compounds in new or replacement building
insulation, and regulation of the disposal of ozone-depleting compounds
contained in discarded building insulation.  Sections regarding the use of
CFC's in cooling systems include the requirement to recycle ozone-depleting
compounds used as coolants in refrigeration and/or air conditioning units,
restriction on the sale of ozone-depleting compounds used as coolants, and
restrictions on the disposal of refrigeration or air conditioning units or
systems.  Other sections include a requirement for a permit to release halon
to test fire extinguishing equipment, and reclamation of halons from portable
fire extinguishers during servicing.


ENVIRONMENTAL PROGRAM COORDINATOR

      The ordinance created the position of Environmental Program Coordinator
in the City Manager's Office.  The duties are to oversee the administration of
the ordinance, the establishment of regulations for the implementation of the
ordinance, and the enforcement of the ordinance.  The coordinator is also
required to provide information to businesses seeking help in obtaining
alternative technologies or recycling equipment.  A small library of
information was developed during the subcommittee research phase that provides
one basis for community information.  The coordinator is required to develop
an educational program to provide information to local businesses on the
dangers and hazards of products made with ozone-depleting compounds.  He is to
establish a program to encourage the development of alternative chemicals and
technologies to replace ozone-depleting compounds.  Concepts developed during
the ordinance draft phase included the establishment of a city-based grant
program or some other  incentive program to reward the development of safe
alternative compounds.  He is to work with other levels of government
regarding the regulation of ozone-depleting compounds.  There is also a
provision to research  the need for a technical assistance funding mechanism to
assist establishments  in the implementation of a recovery or recycling program
for ozone-depleting compounds, or the proper destruction of ozone-depleting
compounds.


SCIENCE ADVISORY COMMITTEE

      Within the ordinance, a Science Advisory Committee was established as a
permanent city committee to assist the coordinator with the implementation of
the program.  The City Manager or his designee is the chair of the  committee.
The creation of this committee is an  acknowledgement that the business
community had both significant expertise to offer and a major economic stake
in the outcome of the  legislative initiative.  All members of the local
business community were  invited to attend the initial meeting and to sign up
for the subcommittees.

      About 50 citizens  attended the  first meeting of the Science Advisory
Committee, with many of  them selecting a subcommittee assignment.   The sub-
committees were designed according to the major uses of CFC's in the Irvine
area.  The  subcommittees are Solvents, Medical Applications, Air Conditioning
and Refrigeration, Halons, Military Contractors, and Foam Plastics  and
Insulation.  The subcommittees each met individually, selected a recorder, and
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developed a statement regarding the anticipated impact of a CFC-ban on their
portion of industry.  They also undertook research projects to ascertain the
available alternative technologies and recycling possibilities in their areas,
and other mitigation measures that would measurably decrease the amount of
CFC's released to the atmosphere.  There was a consensus that while the goal
is the ban of CFC's in all applications, the near-term goal is the elimination
of CFC-releases to the atmosphere within a very short timeframe.  Therefore,
recycling and containment technologies were carefully researched for immediate
application.

      Each subcommittee submitted its findings to the whole Science Advisory
Committee.  Potential for immediate action, areas for near-term application,
and future goals were recommended.  Following an evaluation of this
information, one representative from each subcommittee was appointed to the
Exemption Committee to work with the Environmental Program Coordinator to
develop an over-all exemption standard and application procedure.  These
standards would take into account the availability of alternative technologies
and products, recycling systems, product safety/effectiveness information, and
the existence of contractual limitations.  The Exemption Subcommittee reviewed
the information from all the subcommittees, and developed guidelines for
companies seeking an exemption from the bans on CFC's imposed in the
ordinance.  The focus remained the immediate elimination of CFC release to the
atmosphere, and the near-term elimination of the use of CFC's in manufacturing
and packaging.

      Since many of the members of the Science Advisory Committee are actively
involved in a business that uses ozone-depleting compounds, they can offer
current technical information on systems and processes that may provide
beneficial alternatives to existing technology.  Many of the representatives
are from large firms that have the expertise to discover emerging
technologies, and to evaluate them for their own use.  This information may
then be shared, with their permission, with other businesses seeking
alternatives.  For example, Cal Sonic has undertaken a major study of
degreasers pursuant to purchasing an aqueous unit.  The information that they
developed regarding suppliers, costs/benefit considerations, and cleanliness
standards will be useful to others needing similar technology.  They have
offered plant tours of their new equipment to other businesses.  This kind of
cooperation is possible only because the Science Advisory Committee provides a
mechanism for the exchange of ideas and information.  Since the committee
members are volunteers, the cost to the city of having the committee is small.


EXEMPTIONS

      The ordinance also includes provision for the granting, by the City
Council, of exemptions from the regulations of the ordinance for specified
periods of time.  The exemption application must review the technical,
practical, and economic viability of the alternatives considered, and the
health, safety, and environmental impact of the alternatives.  The exemption
must be requested for a specified period of time, and the applicant must
include information on the alternatives under consideration, and the measures
that have already been undertaken to minimize or eliminate the release of
ozone-depleting compounds.  Since the immediate goal is elimination of the
emission of CFC to the stratosphere, recycling and reclamation are critical
components of an exemption application.

      Several classes of exemptions were included in the body of the
ordinance, recognizing either the unavailability of safe substitutes, or the
imposition of a requirement for CFC use by another regulatory agency.  These
include Federal regulations (military contractor, FDA-regulated manufacturer),
public safety considerations  (the use of halon for fire fighting),
refrigeration and cooling applications, licensed health care facilities, and
de minimus emissions  (less than 55 gallons or 450 pounds per year emitted to
the atmosphere).  In dealing with the exemptions based on the activities of
Federal agencies, the Environmental Program Coordinator has an affirmative
obligation to urge the responsible agencies to hasten the approval of
substitute technologies and substitute products.  Because the uses of CFC's
                                      716

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governed by Federal regulatory agencies may continue for some time, applicants
for exemptions under this section must show a good faith effort to recycle CFC
products used in their processes and to minimize emissions.  Although certain
processes may not be changed, or certain solvents must be used, mitigation
measures such as vat covers, air filters, or recycling systems can still
restrict the emission of CFC's to the atmosphere.

      Halon will be permitted for use in fighting fires until a safe
alternative is available.  However, halon may not be released in any other
circumstance.  All testing must be conducted using another gas.  Servicing of
halon fire extinguishers must include recycling and must prevent the release
of any CFC to the atmosphere.

      The availability of the de minimus exemption recognizes the cost-
benefit issues related to retooling or changing a process where CFC is a minor
component of the system.  Businesses that emit only small amounts of CFC to
the atmosphere may have to make a very large investment to create a small
relative beneficial impact on the CFC release problem.  The small user must
still show a good faith effort to phase out CFC uses over time.  De minimus
exemptions are granted only a year at a time, and as technology improves, and
costs for systems and alternative products come down, this exemption will be
carefully reviewed, and possibly eliminated.

      The exemption for the licensed health care facilities is also based on
the small amount of CFC used for the sterilant application.  While some
sterilizing applications can convert to steam or heat/pressure systems,
plastics and optics might be damaged by these processes.  There is no safe
alternative to the current CFC-ETO mixture when ETO is the sterilant of
choice.  Some manufacturers of sterilizers are developing recycling or
reclamation systems that might be available for the small sterilizer market
within the next few years.

      Some companies currently using CFC's have undertaken research to
eliminate the use of CFC's in the near future.  In some cases the firm will
request an exemption from the ordinance requirements until a specified piece
of machinery can be purchased and installed.  In some cases firms are
undertaking testing of alternative technologies, with a specified timeline for
evaluation and decision-making.  These firms will submit one exemption
application with a series of "milestones."  As each of the milestones is
reached, the firm will submit a report to the Environmental Program
Coordinator.  As long as the milestones are met, the exemption will remain in
force.  At the end of the milestones the exemption will end, because the new
process or product should be in use.  If difficulties are encountered that
alter the original milestones, the firm must confer with the coordinator
regarding an extension, or a new exemption process, depending on the nature of
the difficulty.  For example, if the manufacturer is delayed in delivering
equipment, an extension might be arranged.  If the planned process proved to
be faulty and a new approach is needed, a new exemption application with new
timelines would be needed.

      Some firms are unable to develop an alternative to the current CFC uses.
These firms will be applying for a 1 year exemption,  during which time they
will be required to undertake research into alternative products and
technologies.  The coordinator will assist them in locating possible sources
of information, including trade associations, other firms using similar
processes, or library materials.  The fee for a "no known alternative"
exemption rises each year.  There is no commitment to renewing a "no known
alternative" exemption after the first year.  The ordinance is enforced as a
California penal code misdemeanor offense.


NATIONAL IMPACT

      The impact of Irvine's sweeping local ordinance was felt even during its
final development stage.  In July 1989,  the Center for Innovative Diplomacy
sponsored the North American Congress for a Stratospheric Protection Accord in
Irvine.   Representatives from more than 20 other jurisdictions shared their
                                      717

-------
experiences in promoting environmental responsibility at the local level.
Local legislators from Toronto, Canada, and Berkeley, California, shared
information on the success of legislation passed in their jurisdictions.
Irvine's ordinance, the most comprehensive municipal regulation of ozone-
depleting compounds to date, was reviewed by the members.

      Since that time action has been taken in other municipalities.  The city
of Newark, New Jersey, passed its own comprehensive ban on CFC's on October 4,
1990.  Austin, Texas, is developing an ordinance similar to these first two.
Colorado local legislators are seeking a regional approach to CFC-banning
laws.  Cambridge, Massachusetts, developed a comprehensive ordinance that
targets businesses and universities in that city.

      Other municipalities have selected portions of the ozone-depleting
chemicals issue for immediate local action.  Minneapolis, Topeka, and Berkeley
are recycling coolant from old appliances.  San Jose, Albuquerque, and
Berkeley will regulate auto air conditioner emissions by requiring recycling
equipment at repair shops.  By initiating legislation at the local level,
communities can begin to lower CFC emissions in the areas most politically
acceptable to their citizenry.  Rather than have no action because of industry
lobbying, local legislators are able to evaluate plans for reducing CFC
emissions that can be implemented with maximum public support.

      Once some action has been successfully undertaken, the more
comprehensive steps can come in phases.  For example, in areas of the country
where the weather is cold most of the year, the ban on foam building
insulation might not be practical.  However, recycling the coolant from auto
air conditioners and from discarded refrigerators and air conditioners would
not work a hardship on citizens, and would create a new industry for an
enterprising local entrepreneur, while also benefitting the stratosphere.
Once substitute building foam insulation materials are available, the idea of
replacing and destroying the old materials as buildings are refurbished or
replaced will be an easier step than an immediate ban.


LOCAL MARKETING

      Local legislation also enables city leaders to market the  idea of
atmospheric ozone protection in a way that will most strongly appeal to the
citizens.  Some communities already have a strong commitment to  environmental
issues, so the protection of the ozone layer can be tied in to efforts to
clean up rivers, lessen air pollution, or plant trees.  In other communities
the people are not as motivated toward environmental issues.  Local
legislation to lessen CFC emissions will need to be marketed there as a cost-
saving measure, emphasizing the international commitment to eliminate the
production of CFC's by the turn of the century.  If people understand that the
price of the CFC's will rise dramatically when the supply drops  after 2000,
they will be more  interested in recycling, or finding product substitutions.

      The industrial community  is a crucial part of the success  of a program
to eliminate CFC emissions.  Irvine's ordinance was developed in a committee
that included business leaders.  The Science Advisory Committee  provided the
opportunity for  industry leaders to comment on the provisions during the
developmental phases.  By having businesses participate from the early  stages,
a base of industry support  for  the legislation was developed.  The
participation of business leaders also assisted city staff in better
understanding the  community  impact of various aspects of the proposed
legislation.  As a result of some business concerns, there were  additions to
the exemption categories early  in the ordinance development.

      The support  of  large  local corporations that understand the inevitable
changes taking place  in the world production of CFC's helped to  build business
community acceptance  for the ordinance.  Some larger firms took  the initiative
to investigate alternative  processes and products, and presented this
information at the public hearings.  Having the  support of the business
community is  important, especially in  areas where many }obs are  at  stake in
CFC-using industries.  It is difficult to generate public support for
legislation that may  result  in  lost jobs  for voters.
                                      718

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LOCAL IMPACT ON LARGER JURISDICTIONS

      Community-based legislation can address local issues and concerns.  It
can be both responsive to community needs and environmentally responsible.
Regional cooperation offers the possibility of developing packages of local
legislation that address concerns that cross political boundaries.  The
regional approach may be especially important for smaller communities that
would need to cooperate to develop economically viable recycling or disposal
facilities.  Comprehensive State and Federal legislation may be more difficult
to develop because of competing interest groups.  Local and regional
legislation can point the way for State and Federal laws by developing a
series of regulations based on local consensus.  State-wide legislation can be
based on those activities found to be acceptable to most communities.

      Community-based legislation may also have an effect on Federal agencies.
Once many jurisdictions have shown their interest in alternative technologies
and product replacements for CFC applications, the regulatory agencies may be
more encouraged to proceed with safety and toxicity testing.  The FDA is not
reviewing alternative sterilizing methods at the present time, for example.
Perhaps If more jurisdictions were encouraging the use of alternative
technologies these investigations would become a higher priority with the FDA.
Also, local legislators could work with their Federal representatives to
develop funding for the FDA and other agencies needing to undertake expensive
testing programs for alternative products.  If representatives from several
States snared a common concern for product testing, Federal legislation to pay
for the product testing might be easier to pass.


CONCLUSION

      Irvine's ordinance to regulate the emission of ozone-depleting compounds
is a model for other municipalities concerned about the environment.
Municipal action has the potential to directly affect emissions to the
atmosphere.  Regional cooperation can broaden the benefits of local action,
and make some activities economically feasible through economy of scale.
Municipal and regional actions provide a pattern of legislative consensus that
State and Federal legislators can support.  Local action sends a signal to
Federal regulatory agencies that there is a need for testing of alternative
technologies.  The combined efforts of municipalities across the United States
can indeed have a global impact, resulting in a significant reduction of CFC's
emitted to the atmosphere.

      Now is the time to repair the ozone hole through municipal legislation.
                                      719

-------
A HOVEL LOW-POLLUTION APPROACH FOR THE MANUFACTURE OF
               BLEACHED HARDWOOD PULP
                Alfred Wong and Jiri Tichy
               Arbokem Inc..Vancouver,Canada
ABSTRACT
Kraft pulp is the reference chemical pulp in the wood pulp and
paper industry. The traditional kraft pulping process offers
versatility in using virtually any type of lignocellulosic raw
material,and production of physically strong pulp.
Unfortunately,the kraft pulping yield (from raw material) is
low,and the resulting pulp is difficult to bleach. Air
emission from kraft pulp mills is extremely odoriferous.
Chlorine and chlorine-based compounds are the conventional
reagents used to achieve high pulp brightness and physical
strengths,at a relatively low costs. Bleaching with chlorine
also produces considerable amount of deleterious chlorinated
substances in the process effluent and in the finished pulp.

The present research work at Arbokem Inc. (Canada) has focused
on the development of an improved means to manufacture high
quality chemical pulp without the use of chlorine or chlorine
dioxide in the bleaching steps.

The technology is centred on the use of neutral sulphite
pulping with the aid of 9,10-anthraquinone (NSAQ Process).
Either sodium or potassium base may be used. Typically the
unbleached aspen (Populous tremuloides) pulp has a brightness
in the range of 65 to 70 points. In contrast.unbleached kraft
pulp has a brightness of less than 35 points. The NSAQ Process
typically provides 5 to 10% points higher yield than that of
the traditional kraft process. Thus,NSAQ pulp requires
considerable less intensive bleaching than kraft pulp. Our
laboratory test results showed that high brightness pulp
(>86%) can be  readily achieved with the use  of  only oxygen  and
hydrogen peroxide as bleaching reagents. No  chlorine or
chlorine dioxide is required. The resulting  pulp strength and
optical  properties are  comparable to those of bleached kraft
pulp.

Because  only oxygen and hydrogen peroxide are used as  the
bleaching reagents,the  bleaching effluent may be recycled,for
use within the manufacturing  process,to a very  substantial
degree.  Even  if no bleaching  effluent is recycled to the
pulping  chemical system,the  pollution loading of the raw
untreated bleaching effluent  is  forecasted to be less  than
3  kg BOD/MT  pulp,and less  than 3 kg Pt-Co colour/MT  pulp.
                              720

-------
INTRODUCTION

Conventional sulphite pulp is generally recognized to have
lower physical strengths than kraft pulp. In the early 1970's,
sulphite pulping in the alkaline regime was discovered to
provide a pulp with similar quality as that of conventional
kraft pulping [1]. This new sulphite pulping technique was
noted to give higher-yield and easily-bleachable pulp. A small
sulphite pulp mill might be less expensive to construct and
operate than a similar-size conventional kraft mill.

The alkaline sulphite pulping approach was never
commercialized because its delignification rate is nearly
5 times slower than that of a kraft process. Fortuitously,the
addition of anthraquinone-type (AQ) catalyst was found to be
very effective in accelerating the sulphite delignification
rate [1,2]. In practice,AQ addition has been generally
observed to be much more effective for the alkaline sulphite
process than for the kraft process [3]. The use of the
sulphite-AQ process to make a very high linerboard has gained
considerable interest in the USA and elsewhere during the past
few years [4-7]. Typically,the yield advantage over "high
yield" kraft pulp is 15 to 25%,based on oven-dry wood.

As given by its name,neutral sulphite-anthraquinone (NSAQ)
pulp is made by sulphite pulping of hardwood (or softwood)
chips under mild alkaline  conditions. Anthraquinone (AQ) is
added as a pulping catalyst. Anthraquinone has been approved
for used as a catalyst in  pulping by the U.S. Food and Drugs
Administration [8] since 1980.

Most of the deciduous forest in Canada and northern United
States is aspen (Populus tremuloides). In Wisconsin and
Minnesota,aspen sulphite and mechanical (groundwood) pulps
have been used in integrated paper mills for more than 50
years. During the past 5 years,aspen has been gaining rapid
acceptance as an excellent wood furnish for the production of
premium-grade market kraft pulp and BCTMP [9,10].

The purpose of this work was to develop a process for the
production of market-type  bleached aspen pulp based on the
NSAQ pulping,and bleaching without the use of chlorine-based
chemicals.
                              721

-------
EXPERIMENTAL

Canadian aspen wood (Populus tremuloides) was sampled from
deciduous forests in Quebec and Alberta provinces. A small
amount of black poplar (Populus balsamifera) was also
included in the wood furnish of several test runs. In all
cases,wood chips were used within 3 months of the felling.

Laboratory pulping and effluent tests were conducted at the
Arbokem laboratory in Montreal. Additional pulping tests were
performed under contracts from Arbokem at the laboratories of
Econotech Ltd. (New Westminster,Canada).Universite du Quebec
(Trois Rivieres,Canada),and Lakehead University (Thunder Bay,
Canada).

Both one-litre "bomb" and 10-litre (with liquor-recirculation)
batch digesters were used. Oxygen bleaching was carried out in
a stirred autoclave. Peroxide bleaching was conducted using
conventional laboratory-bag techniques. Pulp testing was made
with TAPPI and CPPA Technical Section Test Methods.
RESULTS AND DISCUSSION

Unbleached Pulp

Previous work on Canadian aspen  (Populus tremuloides) has
suggested that aspen is probably the most suitable hardwoods
for use with the NSAQ pulping process  [11,12]. Unlike Canadian
maple  (Acer spp.) and birch  (Betula spp.),aspen can be readily
pulped with the NSAQ technique  [13]. Table I  shows the results
of  seyeral pulping  tests made with some representative NSAQ
cooking conditions  with different chip samples. The aspen  NSAQ
pulps  normally had  an unbleached brightness in the range of
58  to  69 points,and pulping  yields between 62 and 65%. In
contrast,aspen kraft pulp normally has a brightness of only
about  35 pts and a  total (unbleached)  pulp yield of about  55%.

Unlike the kraft cooking method,the NSAQ pulping process
offers a very wide  range of  operating  conditions (including
time,temperature and chemical charge)  to produce virtually any
desired  grades of  pulp. For  example,the ratio of sulphite  to
alkali may be adjusted  for the  production of  a softwood  pulp
with  kraft-like strength [14,15].

As  given in Figure  l,the tear-tensile  strength relationship  of
NSAQ  aspen pulp is  compared  favourably against that of  the
example  aspen kraft pulp.
                              722

-------
Bleached Pulp

NSAQ aspen can be bleached readily to high brightness. In
order to fully utilized the high-brightness of the unbleached
pulp,aspen NSAQ is best pre-bleached with oxygen. Kovasin et
al. [16] has reported that oxygen pre-bleaching is ideally
suited for the processing of NSAQ softwood pulp. Conventional
bleaching such as CEDED is not the most appropriate approach.

Moreover,with continuing increased emphasis on the presence of
chlorinated organics in finished pulp and in effluent,it is
prudent to use non-chlorine based bleaching chemicals.whenever
possible.

Kappa number of unbleached NSAQ aspen does not offer the same
guideline on bleachability as that of kraft pulps. The
residual lignin is believed to be different in unbleached NSAQ
and kraft pulps [12].

As shown in Table II,a sequence such as OPP or OpP could be
used to produce high-brightness "chlorinated-organics free"
aspen pulp with high viscosity. The brightness stability of
peroxide-bleached pulp is good. For example,the brightness of
OPP-bleached pulp (Sample B31,Table II) decreased from 85.3
pts to 83.5 pts,in a year storage at room temperature.

The oxygen-peroxide bleached pulps had high bleaching yields.
Typically,the bleaching yield in the peroxide stage is 100%.

In comparison,a kraft aspen pulp,with comparable unbleached
Kappa number,would be extremely difficult to achieve this
brightness level in such two stages of bleaching.

Figure 2 shows that OPP-bleached NSAQ aspen pulp has good
strength properties of papermaking.

Effluent

Because no chlorine or chlorine dioxide is used in bleaching,
there would no involuntary production of dioxins,furans and
other chlorinated organics in this type of pulp mill.

The oxygen pre-bleaching effluent is proposed to be routinely
recycled to the pulping chemical system.

As shown in Table II,we have found that Na2Si03 may be
replaced by commercial DTMPA (diethylene-triamine-methylene-
phosphonic acid) or DTPA (diethylene-triamine-pentaacetic
acid) peroxide stabilizers,with little or no adverse effects
on achievable bleached pulp brightness [17].
                              723

-------
With the displacement of silicate,the possibility is now
opened to recycle a substantial amount of P-stage bleaching
effluent to the pulping liquor system. There would be no
chlorine-related chemicals in the OPP bleaching effluent.

In the OPP sequence,the estimated discharge of COD would be
about 10 kg/ADMT pulp,if no Pj and ?2 effluents are
recycled to the pulping liquor system. The corresponding BOD
discharge of untreated combined P-stage effluent would be less
than 4 kg/ADMT pulp.

From our laboratory test data,the discharge of colour in the
combined P-stage effluent has been forecasted to be less than
3 kg/ADMT pulp. In comparison,a modern "OCED-bleached"
hardwood kraft mill would have a colour emission of the order
of 20-30 kg/ADMT pulp [18].

With such low levels of BOD and COD in the bleaching effluent,
it is expected that the raw P-stage bleaching effluent would
have a very low degree of toxicity to fish.

Because the spent sulphite pulping liquor is alkaline,the
evaporator condensate would have a low BOD loading. From our
lab-scale liquor evaporation experiments,we have estimated the
BOD loading to be about 6 kg/ADMT pulp.

The excellent quality of the raw effluent (bleachery +
evaporator condensate) would provide an opportunity for the
extensive recycle of this effluent (after conventional
biological treatment to reduce BOD and COD) for re-use within
the manufacturing process.

Commercial Development

The aspen NSAQ technology is ready for commercial practice.
Digester operation is relatively simple. The entire fibre and
liquor lines could be based on existing commercial process
equipment. There are NSAQ pulp mills (softwood for bleachable
grades,and hardwood for packaging grades) in commercial
operation in Finland,Japan and New Zealand for nearly 8 years
[19-21].

Established sulphite recovery systems,such as a standard
recovery boiler followed with a Tampella TRP or Stora chemical
conversion unit,may be used safely and efficiently. Unlike the
kraft process,the emission of odoriferous reduced sulphur
compounds from the burning of spent NSAQ liquor would be
several orders of magnitude lower.
                              724

-------
Because NSAQ aspen pulping is a low-alkalinity approach,
separate lime kiln and causticization unit operations would
not be required. In fact,soda ash instead of caustic soda may
be used as the pulping chemical make-up.
CONCLUSIONS

The neutral sulphite-anthraquinone (NSAQ) pulping process was
investigated as a means to produce an economical aspen market
pulp. Canadian aspen (Populus tremuloides) can be cooked and
bleached readily. This excellent response to NSAQ processing
is perhaps unique among the common temperate zone hardwoods.

The major findings of the present study were:

1. Unusually high yield of 60 to 65% (for a full chemical
   pulp) can be obtained.

2. Unbleached pulp has a very high brightness,up to 70 pts.

3. Unbleached pulp is easily bleachable.using the OPP or OpP
   sequence,to achieve 85 to 90 pts brightness.

4. Oxygen/peroxide bleaching would not result in any residual
   chlorinated organics present in the finished pulp or in the
   effluent.

   This bleaching approach opens the possibility of substan-
   tial recycle of the bleachery effluent into the pulping
   liquor system.

5. If recycle of the P-stage effluents was not practiced,the
   discharges of BOD and colour in the raw effluent would be
   less than 4 kg/ADMT pulp and less than 3 kg/ADMT pulp,
   respectively.
LITERATURE CITED

1.  Ingruber,0.V.,Kocurek,M. and Wong,A.,eds.,"Sulfite Science
    & Technology",Pulp and Paper Manufacture,Vol. 4,3rd Ed.,
    Joint Textbook Committee of the Paper Industry,TAPPI-
    CPPA/TS,Montreal,Canada,1985.

2.  Kettunen.J. et al.,"Effect of Anthraquinone  on Neutral
    Sulfite and Alkaline Sulfite Cooking of  Pine",Paperi ja
    Puu,61,11:685 (1979).
                              725

-------
3.  Wong,A.,"Anthraquinone - a review of its market potential
    in wood pulping in North America",73rd CPPA Technical
    Section Annual Meeting Preprints.Montreal.Canada,
    January,1987.

4.  Stradal.M. et  al.,"70%-Yield Alkaline Sulfite-
    Anthraquinone  Pulp for Linerboard" , Tappi ,66_, 10 : 75 (1983).

5.  Isatalo,I. /'Neutral Sulfite Anthraquinone (NS-AQ) Pulp as
    Raw Material for Kraft Linerboard".Paperi ja Puu,65.9;52
    (1983).

6.  McDonough,T.J. and Paulson,T.W.,"Sulfite-Anthraquinone
    Pulping of Southern Pine for Linerboard",Proc. 1985 TAPPI
    Pulping Conference,Hollywood.Florida,USA,November,1985.

7.  Wong,A.,"Neutral Sulfite-Anthraquinone Pulping for
    Linerboard: a lower temperature and mild alkalinity
    approach",Tappi,71,2:83 (1988).

8.  Federal Register,Vol.45,No.47.March 7,1980. Page 14846.

9.  Wong,A.,"Review of Pulping and Papermaking Properties of
    Aspen".Canadian Forestry Service.Report No. Fo-42-101/
    1987E,Edmonton,Canada,1987. ISBN 0-662-520-3.

10. Wong,A. and Szabo,T.,eds.,"Proc. of the Workshop on Aspen
    Pulp,Paper and Chemicals",Canadian Forestry Service,
    Report No. Fo-42-91/20-1988E,Edmonton,Canada,1987.
    ISBN 0-662-15944-6.

11. Wong,A.,"NSAQ Pulping of Aspen",Pulp Paper Jour..38.4:5
    (1985).

12. Macleod,J.M.,"Alkaline  Sulfite-Anthraquinone Pulp from
    Aspen",Proc.  1CC5 TAPPI Pulping Conference.Hollywood,
    Florida,USA,November,1985.

13. Wong,A. and Scares,M.,"Expert  System for the Operation  of
    Neutral Sulphite-Anthraquinone  (NSAQ) Pulp Mills",Proc.
    1986 TAPPI Pulping Conference.Toronto,Canada.October,1986,

14. He,P.  and Lai,Y.,"Influence of  sulfite  on  the  effective-
    ness of anthraquinone in  soda  pulping",Tappi,69,12:89
    (1986).

15. Fullerton.T.J.  et al.,"Enhancement  of pulp strength  by
    soda-AQ pulping with sodium sulphite. The  soda-low
    sulphite-AQ process" .APPITA ,.42., 7 : 288  (1988).
                              726

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16.  Kovasin.K. et al.,"Bleaching of NSAQ  Pulp  Using Initial
    Oxygen Stage",paper presented at  the  71st  CPPA Technical
    Section Annual Meeting.Montreal.Canada,January,1985.

17.  Wong,A. and Tichy,J.,"Peroxide  Bleaching  of  NSAQ Pulp
    without Silicate",paper to be presented at the 1990 TAPPI
    Pulping Conference,Toronto,Canada,October,1990.

18.  Singh,R.P.,ed.,"The Bleaching of  Pulp",TAPPI Press,
    Atlanta,USA,1973. pp.  423-461.

19.  Rimpi,P.."Chemical Cycle  and Recovery in  the First
    SAP-Market Pulp Producing Mill",Proc. 1983 TAPPI Pulping
    Conference,Houston,Texas,USA,November,1983.

20.  Wong,A.,"Future of sulphite pulping  looks promising in
    Canada",Pulp Paper Jour . ,37_, 6 :14  (1984).

21.  Wong,A.,"Very high yield  sulphite pulps gaining increasing
    acceptance",Pulp  Paper Jour . , 3_£, 7 : 28  (1986).

AK6657
        X
        w
        o
        
-------
         00

        si
         £
                                       OPP (85.5)
                            CEDED [12]
                            (92.5)
                   J	I
                                         (  ) brightness pts
                             I   I   I   I   I
                         6     8     10

                       BREAKING LENGTH,km
                                     12
          Figure  2-  Tear-Tensile Strengths of Bleached
                     Aspen NSAQ Pulp
          Table I  -  Representative NSAQ  Pulping Tests

Test  Run                       A53    A41      A884A    A1615N

Wood  furnish
Aspen, %
Balsam poplar, %
Total Na20 charge,
% on o.d. wood
Sulphite/Total Na20
AQ,% on o.d. wood
Liquor/wood ratio
Time to max. temp., rain.
Maximum temp.,deg. C.
Time at max. temp.,min.
Total pulp yield,%
Rejects, %
Kappa number (scr.)
Viscosity , mPa. s
Brightness, unbl. ,pts
100
0
18

0.85
0.1
4.0
125
175
90
65.1
1.25
26.3
51.3
63.7
100
0
18

0.85
0.1
4.0
125
175
120
64.6
0.7
24.0
53.3
58.2
90
10
18

0.85
0.1
4.0
125
175
90
64.7
3.5
21.6
NT
69.4
100
0
18

0.85
0.1
3.5
120
165
300
62.0
0.8
16.7
68.9
NT
NT
not tested
                                 72B

-------
     Table II - Bleaching of Selected Aspen NSAQ Pulps
Test Run No.
Kappa number
Bleaching Sequence
First Stage
Oxygen pressure , psig
H202,%
NaOH,%
MgS04.7H20,%
DTMPA,%
Time ,min .
Temp. ,deg . C.
Consistency ,%
Kappa number
Brightness, pts
Viscosity , mPa . s
Second Stage
H202,%
NaOH,%
Na2Si03,%
MgS04.7H20,%
DTMPA,%
Time ,min.
Temp . , deg . C.
Consistency ,%
Brightness , pts
Viscosity ,mPa. s
Third Stage
H202,%
NaOH,%
Na2Si03,%
DTMPTA,%
Time ,min .
Temp. ,deg. C.
Consistency ,%
Brightness , pts
Viscosity , mPa.s
B1615N
16.7
OP

80
--
2.1
0.5
--
30
92
12
9.8
63.8
35.1

3.0
1.7
3.5
--
—
330
60
10
79.5
NT

_ _
—
—
--
—
—
—
—
—
A884A
21.6
OPP

60*
--
1.5
--
--
30
90
12
NT
NT
NT

1.5
1.4
5.0
--
—
120
75
14
84.8
NT

1.0
1.4
5.0
—
120
75
14
86.3
NT
B31
15.7
OPP

60*
—
2.0
—
0.25
30
110
12
5.0
72.3
38.1

0.5
1.0
—
0.5
0.15
120
75
12
82.6
34.5

1.5
3.0
--
0.35
120
75
12
85.3
29.3
A884B
29.0
OpP

60*
2.0
1.5
0.5
—
50
110
12
NT
87.0
NT

1.0
1.5
5.0
0.5
—
120
75
14
90.5
NT

_ ^
—
__
—
—
—
—
—
—
Note:
1. All chemical charges are based on o.d. pulp
2. NT = not tested
*  Estimated
                             72S

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   AND CT-FAT* TECHNOLOGY IN DEVELOPING COUNTpnffi; TITO CASE OF GHANA

                          -By   Dr. Gregory B. Tawson
                          Industrial Research Institute,
                          P.O. Box M 32, ACCRA, Ghana


                                  ABSTRACT

This paper gives a brief account of the problems associates with industrial development
and its attendant pollution impacts in a developing country, Ghana.

It examines efforts so far made in preventing pollution and looks at various policy
options and strategies for the  promulgation, propagation and promotion of clean
technologies within the broad context of sustainable development.  It is hoped that
these options and strategies coulld be applied, with modifications, in most developing
especially African countries.

1.0    INTRODUCTION

The problems  of underdevelopment are well-known. However, the issues involved in
the development of natural resources for inudstrialization and economic development
of poor or developing  nations  are  diverse and complex that in most cases, easy
solutions elude policy makers and implementors.

Socioeconomic issues like provision of adequate food and water supply, clothing,
housing, health  care, education, poverty and squalor and high population growth
confront many of these  countries.
In trying to resolve these issues, these countries adopt measures and policies which lead
to high external trade deficits, high  inflationary rates and overexploitation of natural
resources.

Efforts at industrialization raise in their wake the importation of raw materials,
machinery and technologies, some of which may be obsolete and/or environmentally
unfriendly,  improper  resource allocation  and  utilization, shortage  of skilled
manpower, liquidity problems, underutilization of installed capacity and pollution of
the ecosystem.

Besides, some of these countries in the third world are forced or cajoled into accepting
toxic wastes to be dumped on their land, where there are no facilities to treat them, to
the detriment of the peoples' health and ecosystem

The need therefore for  developing countries to look at industrial development in the
overall context of environmentally sustainable national development, incorporating
pollution prevention measures and policies, is imperative.

2.0    CLEAN TECHNOLOGY - SUSTAINABLE DEVELOPMENT:  RELATIONSHIP

2.1     Clean Technologies (CT)

Clean technologies may involve any of the following:
•      product redesign or reformulation
•      process modification
•      technological  innovation
•      raw material substitution
•      recycling and reuse of wastes.

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Hence it is clear that clean technologies have several advantages over conventional
technologies, including:
•      Source reductionof wastes and pollutants
•      resource generation
•      waste minimization
•      risk and hazard reduction

2.2    Substalnable Development (S.D)

Sustainable national development envisages:
•      adequate food supply and food security
•      adequate and treated water supply
•      provision of abundant energy
•      conservation of natural resources including game and wildlife, forests, land, etc.
•      adequate clothing and shelter
•      primary health care and disease education
•      protection of the overall environment

2.3    CT-SD Relationships

The common  factor between  these two  parameters in the environment.  The
environmental challenge of this decade, therefore, as optly describe by the theme of this
Conference is  Pollution Prevention:  Clean Technologies and Clean Products for
Sustainable Industrial Development. Clean technologies will promote primary health
care, optimal resource management and better living conditions.

3.0    CLEAN TECHNOLOGY AND POLLUTION PREVENTION STRATEGY

3.1    Policy Direction and Options

In view of the desired growth in industrial activities in developing countries and the
Government's determination to increase industrial output through  structural reforms.
increased private  sector development and investments, etc, it is expedient to examine
options for Industrial Pollution Prevention  and Clean Technologies with a view of
finding alternatives for  undertaking  environnentally-sound  sustainable industrial
development.

These could include technical, managerial, legislative and policy options. [1]

       3.1.1  Technical Options

       Introduction and enforcement of sound hazardous waste disposal methods (viz,
       labelling, storage, transportation, handling, treatment, and final disposal).
       This may be very expensive for most industries.
       Acquisition and transfer of clean technological processes that limit the amount
       of by-products and wastes.  This may involve the acquisition, not only of
       machinery but also new raw materials-could be expensive.
       Recycling and utilization of by-products and wastes for the manufacture of
       secondary raw materials of  less stringent quality.  This is environmentally
       cost-effective.
       Identification and characterization of hazardous pollutants and their control
       in industry.
       Standard setting, monitoring and evaluation of impact  parameters (source
       persistence, toxicity, bioaccumlation, etc).
                                     731

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       3.1.2  Managerial Options:

These could Include the Incorporation of environmental protection, workers'
health and safety as well as hazard mitigation measures into Companies' management
and workers' training programme.

       Provision of resources by top-management for the planning, implementation
       and monitoring of preventive environmental programmes.

       Cooperation between Ministries and institutions that deal with industry, health
       and  environment  in  formulating and implementing  long-term  action
       programmes on Risk Management and Pollution Control.

       3.1.3  Legislative Options

       Institution of penalties for environmental pollution (above standard tolerance
       levels) in industries.

       Enactment of  an Environmental Impact Assessment Legislation/Decree for
       compliance by present and future industries.

       Institutional  strengthening  of  Sanitation and  Occupational Health
       Enforcement Agencies.

       Provision of legislative backing for the Environmental Protection Council.

       3.1.4  Policy Options

       Formulation of Industrial, Science and Technology Policy

       Formulation of an Environmental Action Plan to facilitate environmentally
       sustainable economic development in the  Country.

       Introduction and  incorporation of an  Environmental Impact Assessment
       Policy and procedures in all aspects of industrial establishment (selection,
       sitting operation and monitoring) in the country.

       Establishment of  emergency planning  and  response  programme for risk
       assessment,  hazard  identification  and preventive risk  management in
       industries.

       Establishment of an Industrial Pollution and Waste  Management  Center or
       laboratories to undertake base-line data acquisition,, surveys, emission level
       monitoring and evaluation, environmental  standards  setting, industrial
       pollution, risk and hazard management  and industrial consultancy on waste
       management technologies.

       Establishment of Regional  Cooperation in Pollution Prevention and Clean
       Technology through Regional Networks.

 3.2    Key Directions to Pollution Prevention

 A 5-step direction is proposed for Pollution Prevention and  Clean Technology in
 developing countries. [2]
                                     732

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1.      Prevent Generation
2.      Recycle and Reuse
3.      Treat and Control
4.      Minimize Exposure
5.      Educate and Train

3.3    Objectives and Mode of Implementation

       3.3.1  Prevent Waste Generation

       Evolve mechanism  for the development or acquisition of environmentally
       benign technologies, processes and products in all sectors of the economy.

       Establish a system of regulations and laws to ensure EIA and standards
       compliance in trade,  commerce and industry.

       Educate industries,  entrepreneurs  and population on use and abuse of the
       environment,  waste  minimization and source reduction, technology and non-
       technological approaches to pollution prevention and clean technologies.

       3.3.2  Recycling and Reuse

       Assessment of industriul, agricultural and municipal wastes-types  and
       quantities and their  recycling potential.

       Assessment of existing  technologies  and possibilities  of  adapting clean
       technologies waste reduction, and recycling techniques.

       Techno-Economic and marketability assessment

       Conduct of R&D studies in the areas of product, process, socio-economic, and
       anticipatory research in recycling and reuse.

       Pilot plant studies and technology transfer and adoptation.

       Promotion and propagation of reusability and recyclability as well as demands
       for recycled materials.

       3.3.3  Treatment and Control

       Treatability Evaluation

       Hazardous Waste Management Research and Development

       Application of  cost-effective  and  best-demonstrated available technology
       (CEBDAT) for Treatment and Disposal of Waste.   Waste Reduction Innovative
       Technology Evaluation (WRITE)

       3.3.4  Minimization of Exposure

       Site inspection and waste  stream identification

       Performance evaluation of disposal sites, treatment facilities, and
       recycling technologies
                                    733

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      3.3.5  Education and Training
Current  awareness programmes,  formal and  informal education  and  training
programs on the following:
                                                                 environment)
      Industrial Safety and Occupational Health
      Resource Conservation, Recovery and Management
      Environmental Pollution Control
      Risk and Hazardous Wastes (nature and impacts on man and the
      Research in Clean technologies and Clean Products

4.0   THE CASE OF GHANA

4.1.O  Country Profile

      4.1.1  Geographical
Ghana lies on the coast of the Atlantic Ocean along the Gulf of Guinea (W.A). between
lat. 4o 50' N and 6 o (550 km), border-Togo, Cote d'lvoire and Burkina Faso, It has 10
regions, 110 districts and 47,800 communities.

      4.1.2  Demographic
The current population of Ghana is 14 million with a rate of population growth 2.6%,
MMR 10.2/1000, IMR - 90/1000, life expectancy is 56 years, whilst maternal and infant
mortality rates are 10.2 and 90 per 1000 respectively.

      4.1.3  Industrial
There are about 4,073 industries in about 10 sectors.  2,098 of these are small scale
industries whilst  1975 are classified as medium-to-large scale. There has been a two-
fold increase in the number of industries since 1979, 67.7% of which are situated in the
Greater Accra Region alone.  Most of  these are  now operative around 30% of installed
capacity. [1]

42.0  Problems Facing Industries

The problem areas confronting the Ghanian industrial sector are:

       Expertise, raw material acquisition, finance and tax  structure  choice and
       upgrading of technology, QC, spare  parts, and external competition and quality
       control, as well as environmental pollution control, waste management,  risk,
       hazard and emergency response management.

4.3.O  Status of Environment
 1.
       4.3.1  Air pollution

       Mining areas: Arsenic Pollution is prevalent in the mining areas as show below:
       [3.4]

Foodstuff
Vegetation
Water
Soil
Hair
PRESTEA.
6,000 ppm
360 ppm
2-6 ppm
70.48 ppm
540 ppm
OBUASI
0.65- 14.75 ppm
4,700 ppm
1.40 ppm
147.5 ]
77-194
ppm
10 ppm
WHO LIMIT
1.00 ppm
—
0.05 ppm
—
0.03 ppm
                                     734

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 2.     This has been related to the "black spot" skin cancer In the areas. VALCO also
       discharges fluoride-laden fumes from its aluminum smelter

 3.     Oil Refinery at Tema emits  hydrocarbon fumes into the atmosphere in and
       around Tema.

       4.3.2 Water Pollution

 Analysis of water from the Ankobra River near Restea shows up to 10-64 ppm of
 cyanide.  Heavy metal pollution, specific organics,  dyes, paints, pigments and grease
 together with very low BOD (0-06 - 0.9 mg/1) and DO (0.8-3.5 mg/1) values characterise
 the Odan River, Kovle Lagoon and water bodies around the Volta Basin.

       4.3.3 Solid Wastes

 These include solid wastes from the following industries:

             4.3.3.1        Mining Industries
 Gold, bauxite,  manganese  and ore-beneficiation industries.  Wastes incllude gold
 tailings, sludge, scrap metals and equipment, etc. [5]

             4.3.3.2        Chemical Industries
 These include the following industries: Chlor-alkali, salt, surface, coating, food, glass.
 pharamaceutical, oils, fats, soaps and  detergents, fermetation, and other chemical
 processing industries.  A conglomerate of hazardous and toxic wastes are generated,
 that could be very imicable to human health and safety.

             4.3.3.3        Other Industries
 Other industries like the metal and metallurgical, textile, plastics, paper and printing,
 food processing, agro-based, construction and petroleum industries also generate a lot
 of solid wastes.  For example, about 377,000 tons of scrap has been estimated in Ghana
 [6] and about 8,500 tons of waste plastics per year in Accra-Tema. [7] The main oil
 refinery GHAIP  at Tema distributes petroleum products to thousands of filling stations
 that service maintenance workshops throughout the country.  A great deal of used
 lubricants with  high lead levels are discharged into the ecosystem.

       4.3.4  Noise and Vibration

 Through this source of pollution has not been given all the necessary attention in
 Ghana its impact on the workers in manufacturing and construction industries is quite
 high.

 4.4    INDUSTRIAL POLLUTION MANAGEMENT IN GHANA

 4.4.1  Experience in Pollution Management in Ghanaian Industries

 The Mining Sector is guided by a set of environmental regulations under the guidance of
 the Mines Department. However, emission levels and environmental standards have to
 be set to make the regulations effective.

 Most of the manufacturing industries in Ghana have no  facilities for waste-water
 treatment, neither  do they have monitoring devices for air and water emissions.
 Besides, effective waste management in these industries are virtually absent.

 Dumping  and open burning are the main methods of waste disposal and treatment.
These are not cost-beneficial, neither are they environmentally sound.
                                     735

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4.4.2  EPC

The Environmental Protection Council set up by the Government of Ghana has, so far
been carrying out programmes of education campaigns without a legislative backing. It
uses facilities from the CSIR to carry out laboratory work.  Hence in the absence of
legislative  instruments,  EIA  policy,  laboratory  facilities  and  well-trained
environmental scientists, the EPC is unable to do the monitoring, standard setting,
risk assessment and industrial pollution-cum-waste management.

4.4.3  Research Institutions

Some CSIR institutes, notably Institute  of Aquatic Biology and Water Resources
Research Institute have monitored mainly water effluents.  The Industrial Research
Institute of the CSIR has, In the past two years, undertaken a project  on Recycling,
Utilization,  Quality  Control and  Environmental Pollution Control  of Industrial
Wastes. The first phase of this project involved current awareness programme and data
collection  through a  survey of over 74 industries, [1] and confirmed the fears that
industrial  pollution might assume alarming proportions very soon. If mitigation steps
are not taken as soon as possible.

4.4.4  The Factory Inspectorate

This organ works under the auspices of the Ministry of Labor and Social Welfare.  It
conducts on-site inspection of factories to assess internal pollution,  occupational
safety and hazard mitigation measures. It seems,  however, that there is the need to
coordinate its activities with those of the Environmental Protection Council and the
Industrial Research Institute for an effective implementation of its perfbramnce.  The
lack of testing laboratories make this even more urgent.

4.4.5  The Government's Environmental Action Plan (EAP)

The Government set up a National think tank on Environmental Issues In March 1988,
to draw up a working programme of action on the environment to be embodied in its
second  Structural Adjustment  Programme.    The  group  was  charged with the
responsibility of addressing issues on the environment pertaining to deforestation,
desertification, soil degradation, exploitation of natural resources and environmental
control. IRI was nominated to serve on the Think Tank.

The group identified  key issues, missing information areas for further study and
research,  policies to  be Implemented and made  appropriate  recommendations  to
Government for the  planning,  implementation,  monitoring,  and coordination  of
environmental programmes In Ghana.

Further to the work  of the Think Tank, the Government set up working groups to
prepare an  Environmental Action Plan (EAP) on  the Issues of Land Management,
Forestry and Wildlife, Water Management, Marine and Coastal Ecosystems, Mining,
Industry and Hazardous Chemicals.

The EAP is  to define  a  set of policy actions,  related Investments and  institutional
strengthening activities to make Ghana's development strategy more environmentally
sustainable.

A proposal for the setting up of an Industrial waste Management Research Laboratory
under IRI was submitted to government by the Industrial Research Institute. The EPC is
also being assisted by UNEP/IEO to draw up an Industrial Environmental Policy.
Conferences, seminars and workshops are being organized to coordinate all sectorial
work being done in the country.
                                    736

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4.5   Linkages

Whilst efforts  are  being made to increase internal linkages,  cooperation  and
coordination between all organizations and institutions Involved in the work of the
environment, institutional and governmental linkages with various  international
organizations like the UN is also given priority attention. UNIDOs assistance to Ghana
is setting up the Industrial Pollution on Waste Management Research Unit is very much
desired, its assistance In training Ghanaian personnel is also appreciated. UNEP, FAO
and WHO have also contributed In no small measure.


5.O   CONCLUSIONS AND RECOMMENDATIONS


Though the number of Industries in Ghana is small, nonethless identifiable impacts on
the environment has been substantial.  Taking cognisance of the fact that most
technologies Imported  into  the country did not incorporate  environmental
considerations and/or pollution prevention/mitigation measures, it has become very
imperative to take remedial steps to curtail the degree of environmental pollution,
especially in the areas of mining, chemical and textile sectors.

Government's  concern has been backed  up by  concrete  actions to  enhance
environmentally sustainable development in Ghana.  Hence, Ghana's experiences as
well as the various options outlined in this paper can serve as guidelines or examples
for other struggling developing countries.
REFERENCES

1.    Yawson  G.E.  (1989):  "Recycling, Utilization and Environmental Pollution
Control of Industrial and Agricultural Wastes".  Status Report, I.R.I, Aara. 41 pp.
                                    737

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       International Conference on Pollution Prevention:
             Clean Technologies and Clean Products

  Session 37:  Hazardous Waste Minimization in DoD Operations
                Washington, DC - June 12,  1990

        HAZARDOUS WASTE MINIMIZATION:  MAKING IT HAPPEN

                              by
                    Paul J.  Yaroschak,  P.E.
          Head, Shore Facilities Environmental Protection
            Office of the Chief of Naval Operations
                           ABSTRACT

     This paper:
     o  describes problems and success stories relative to
implementation of hazardous material (HM)  management and
hazardous waste (HW) minimization programs in a large, diverse
organization, specifically the U.S. Navy.
     o  describes how the Navy defined the HW problem,
established RDT&E goals, assessed current technologies, and
implemented both HM control and HW minimization programs.
     o  highlights unique shipboard problems and progress in
reducing HM use.
     o  discusses program goals, first year results, and future
plans.
     o  attempts to project progress 5 years from now and
outline barriers to success.
                          PRESENTATION

     Pervasive and long-lasting changes that will affect our
way of life are occurring in the area of hazardous materials
(HM) and hazardous waste  (HW) management.  Compared to the way
we did business 20 years ago, a revolution is underway.  These
changes are in various stages in almost every size industry,
business, and government organization.   Eventually, it will
even invade our private lives and change our household habits.

     One could characterize the 60s and 70s, at least in the
U.S., as a period of free love, a declining human birth rate,
and reduced acceptance of responsibility by individuals.  The
80s look like a turning point.  Can we predict what will be
                             738

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said about the next two decades?  We're certainly entering an
age of more caution:  cautious spending, cautious sex, and
cautious handling of HM/HW.  I would offer that it's going to
be a time of a declining birth rate for HW and increased
responsibility (and liability) for industry .  . . and you'll
get little for free, except maybe something you don't want.  To
cop a phrase, we've entered the era of industrial birth
control.

     With those sobering thoughts as a departure point, I would
like to describe the Navy's program in hazardous waste
minimization, or HAZMIN.  I view HAZMIN as a subset of the
broader term, pollution prevention.  HAZMIN consists of any
actions taken to minimize the disposal of HW.   Obviously, the
most effective actions are those that eliminate the generation
of HW in the first place.  Therefore, putting in place a
comprehensive HM control and management program is vital and
was one of our first and most visible efforts.  Before I
describe our HM control and management program, let me set the
stage by providing a brief history.  The Navy actually laid the
groundwork for HAZMIN program before the 1984  RCRA amendments
requiring HAZMIN.  The trends in both HW disposal and liability
pointed the way.   Before we decided on a strategy for HAZMIN in
the Navy, we wanted to ensure that the problem was clearly
defined.  We also wanted to make better use of our RDT&E
resources to solve field problems.  Therefore, one of our early
actions was to task our Naval Civil Engineering Laboratory to
develop an Initiation Decision Report (IDR).

     Figure 1 illustrates the IDR concept.  This first element
of the IDR is a problem definition.  This took considerable
field work and data analysis.  The result is a detailed look at
the major Navy processes that generate HW.  Most important, we
identified 19 processes that generate over 95  percent by volume
and over 90 percent by cost of the Navy's HW.   This allowed us
to narrow 'our focus, and get the "biggest bang for the buck".

     The next element of the IDR was the assessment of current
HW minimization technologies applicable to our specific
wastestreams.  We divided the technologies into four classes:

          TO   Proven technologies in use in the Navy.

          Tl   Proven technologies in use in industry, readily
     adaptable to the Navy.

          T2   Technologies claimed, but needing T&E.

          T3   Technologies (or wastes)  needing RDT&E.

     Based on the technology assessment, we've taken two
actions.  First,  technologies defined as TO and Tl are being
                             739

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     RDT&E • Tech Transfer Process
NEED OR PROBLEM
                     • DEFINE PROBLEM
                     • NARROW FOCUS
                     • ASSESS TECHNOLOGY
RDT&E PLAN
 (Motion Picture)
TECHNOLOGY TRANSFER
         PLAN
        (Snapshot)
                FIGURE 1.
           HM/HW Management
     HM Control
        I
    SPECIFICATION
     PURCHASE
     INVENTORY
       IS^UE
     USE/REUSE
 WASTE SEGREGATION
     /STORAGE
     DISPOSAL-
       HW Minimization
     MATERIAL SI
       PROCESS
BSTITUTION
CHANGE
      RECYCLING/RECOVERY
          TREATMENT
        •DESTRUCTION
          DISPOSAL
     HM/HW Management Elements
              FIGURE 2.
                  740

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implemented as soon as possible, wherever feasible.  We have
established a HW minimization technology transfer team
specifically to help our field installations use the
technologies.  The team also serves as a clearinghouse for all
HAZMIN efforts in the Navy.  Second, technologies T2 and T3
were analyzed to see if RDT&E was warranted.  A computer model
was developed to aid in this analysis.  The decision on whether
to spend limited RDT&E resources on a technology is influenced
by such factors as risk, capital cost, level of skill to use,
percent HW reduction achievable, and whether another government
agency is already sponsoring RDT&E on the technology.

     Our second step was to set policy and develop an action
plan.  How do you make HAZMIN happen in an organization as
large and as diverse as the Navy?  A crucial element is to
ensure that all levels of the organization are involved and
committed.  The following provides the key elements I believe
are necessary for success:

          A corporate goal (top-down)
          A strategy and action plan (bottom-up)
          Technology transfer (across)
          Reporting
          Assessment
          Incentives
          Publicity
          Funding

     The Navy has a short term and long term corporate goal.
Our immediate goal is a 50 percent reduction, by weight,  in the
amount of HW disposal from 1988 to 1992.   Our baseline year is
1987.  We based our goal on disposal reduction because we can
most easily measure and track HW disposal through an existing
reporting system.  However, this past year,  we changed our
reporting procedures to tie each HW back to a generating
process.  Therefore, we now can track both HW generated and
disposed.  Our long term goal is tied to our philosophy of
Total Quality Management (TQM)  in that we want a continual
reduction in HW generation as we strive for total elimination
of HW disposal.  If we have mission needs that necessitate the
use of a HM, we want to be sure that we have applied Best
Management Practices (BMP)  and the Best Available Demonstrated
Technologies (BADTs) to each process in order to eliminate or
minimize the amount of HW disposed.  We've begun development of
a BMP/BADT guide for all known process wastestreams in the
Navy.  This guide will be updated regularly as technologies,
procedures, and science evolve.

     In 1989, we changed life in the Navy forever by requiring
all Navy installations to implement a HM control and management
program.  The program is patterned, to some degree,  after a
program pioneered by the Naval  Aviation Depot (NAD)  in
                             741

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Pensacola, Florida.  Here are some of the key elements of the
program:

          Intervening in the acquisition cycle of weapons
systems, equipment, and facilities to ensure that HM use is
minimized throughout lifecycles.

          Development of facility level authorized HM use
lists.

          Systematic review of existing specifications and
procedures to eliminate HM use where feasible.

          Implementing overall HM control and management
programs, including hazard communications, at Navy
installations.

     Figure 2 shows how HM control and HAZMIN are interrelated
and interdependent.  A good HM control program starts with work
procedures and product/process specifications that minimize the
use of HM.  Specifications can often be modified to substitute
a nonhazardous material or the process itself can be changed so
that HM are no longer used.  On the right hand side of the
figure, we see that materials substitution and process changes
are effective ways of minimizing HW; thus we nave our first
connection between HM control and HW minimization.  Likewise,
control of HM use and reuse is connected to the HW minimization
elements of recycling/recovery.

     Let's look at some of the major actions underway.  One of
our biggest problems has been the large amount of hazardous
waste offloaded by our ships after extended operations at sea.
The Naval Supply Systems Command is attacking this problem in a
number of ways.  First, a list of approved HM is being
developed for each type of ship.  This is no small task.  Their
are over 6000 Naval Stock Numbers (NSNs)  for HM.  The master HM
list will be completed by October, 1990.   Eventually, each ship
in the fleet will have an individual authorized HM use list
which contains the minimum number of HMs needed to accomplish
the mission.  After June 1991, all open purchase of HM is
terminated and any new entries into an approved list after June
1991 must be accompanied by a one-for-one removal.  Also, each
ship recently has been provided with a CD-ROM player in order
to have full access to Material Safety Data Sheet (MSDS)
information on each HM authorized.  Second, units of issue are
being reviewed and reduced to the amounts normally expected to
be needed.  In other words, you get just enough to do the job,
not a stockpile.   Third, shelf lives are being adjusted to
better reflect reality.  Much of the HW offloaded by Navy ships
to shore facilities resulted from expired shelf lives.  These
shelf life estimates were provided in the past by the
manufacturer with no checking or adjustment by the Navy.  The
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motto on ship now will be "want not, waste not" or, at least,
"no waste before its time".

     The elimination of plastics waste disposal by Navy ships
at sea is another major effort.  We have research underway in a
number of parallel efforts: (1) development of a sinkable,
biodegradable plastic acceptable to the marine environment,  (2)
developing standard test methods to determine degradability,
(3) developing alternative food packaging technologies instead
of plastics, and (4) development of shipboard plastic
processing equipment so plastics can be brought back to port
for recycling.  We already have prototype equipment and have
identified processors who can recycle plastic "waste" into
useful products.

     At our shore facilities, paint stripping operations
present one of our biggest problems.  Normally, solvents or
solvent-based chemicals are applied to aircraft, torpedoes, and
other equipment to destroy the paint or its ability to adhere.
The paint and solvent mixture are then scraped or washed off
with water.  An early success stories is the use of a dry
plastic media blasting (PMB) technology to replace wet solvent
stripping.  The plastic media is used in equipment very similar
to sand blasting.  There are two main differences.  The plastic
media removes the paint, but does not seem to harm most
underlying materials.  Second, the media can be collected by a
vacuum system or other means and recycled.  The process has
been approved for use on torpedoes, transportation and
construction equipment, and aircraft component parts.
Certification for airframes is being withheld pending tests
related to "microdents" and material stress.  We also have a
T&E project underway to determine the loss of media and reduced
effectiveness after numerous cycles.

     PMB is a good example of a Tl technology.  It was
developed and was being used by industry.   At least one
commercial airline company has been using the process.  The
future may hold even better ways to remove paint.  Some of the
T2 and T3 technologies being investigated are as follows:  (1)
laser paint removal using a robot-operated,  pulsed CO2 laser;
(2) flashlamp paint removal using electromagnetic pulses; and
(3) cryogenic paint stripping.

     A number of our plating processes for corrosion protection
use cyanide as a complexing agent.   RDT&E efforts are underway
to investigate acceptable noncyanide processes and develop
systems for minimizing cadmium cyanide wastes.  An electrolytic
treatment unit has been under evaluation October 1988 at the
NAD in Norfolk,  Virginia.  Cadmium ions in solution are reduced
to elemental metal and recovered in the form of a solid sheet
on the cathodic side of the electrodes.   The recovered cadmium
is returned to the plating bath.  Cyanide is oxidized on the
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anodic side of the electrodes.   The unit has operated under
field conditions for over 2000  hours without problems or
failures.  A 99% reduction in cadmium and cyanide was achieved
and the wastewater volume was reduced by 90%.  A "user data
package" is being developed so that this technology can be
spread throughout the Navy.

     The Naval Ordnance Station in Louisville Kentucky recently
adopted an innovative system for chrome plating which reduced
chromium discharges more than 85%.  The system included
installation of a closed loop rinsing system using reverse
osmosis, utilization of a new "bright dip formula" containing
75% less chromium than the previous formula, and replacement of
the dichromate deoxidizer with a chromium-free deoxidizer.  The
Naval shipyards conduct hydroblasting to remove scales from the
water side of ships' boiler tubes.  Field tests have been
completed on a system to recycle hydroblast water.  Three
cycles of use resulted in a 75% reduction in wastewater.

     From a Navywide standpoint, can we meet our five year, 50
percent reduction goal?  I'm still optimistic, but we are going
to face some major  "bean counting" problems.  In 1989, the Navy
increased the amount of solvent recycling by 50% over 1988 and
the total HW generation in 1989 is down 7% over 1988.  However,
gross, unadjusted numbers for HW disposal for our first two
years, 1988 and 1989, actually went up slightly as compared to
1987.  With so many success stories, how could this happen?
We're continuing to analyze the data, but preliminary
indications point to a number of factors all working
interactively:  First, our reporting system  is getting much
more effective.  We're counting better.  Second, our employees
are much more sensitive about improper disposal.  More "small
quantity" wastes Navywide are being disposed of through our HW
management system vs. down the drain or in the dumpster.  In
the aggregate, this can be substantial.  Third, and most
significant, more wastes are being designated as HW and
entering our reporting system.  As an example, the state of New
Jersey began listing bilge water from ships  as HW and EPA's new
Toxic Characteristic Leaching Procedure  (TCLP) adds 25 more
organic parameters  to the test for HW.  The  bottom line is
this:  we're making great progress on a process by process
basis, but new sources are popping up.  This will reguire
continual adjustment of the FY 87  "baseline" to show progress.
It is also a good reason to use the TQM philosophy of continual
reduction in HM use and ensuring BMP/BADT are applied to all  of
our processes rather than  just set numerical goals.


                     QUESTIONS AND ANSWERS

Q.  How  do the Services go about  collaborating to avoid
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repetition and redundancy?  For example, I've seen a couple of
things on plating.

A.  A number of ways.  Within the Navy we have a separate
technology transfer team/technology transfer office.  Their
role is simply to keep in touch with what's going on outside
everywhere, to make sure that the technology is transferred
within the Navy, and hopefully that we don't duplicate.  Also
the research laboratories work very very closely together.  As
an example, if you take a look at chromium plating or cyanide
or any of these, you'll find out that each of the Services is
doing something a little bit different, and they collaborate.
The system that we put in down at Norfolk is a bit different
than the system the Air Force is working on.  We trade notes,
and we find out which one is better.  I'm not saying there's no
duplication, there certainly is some of that.  Some of that's
healthy, some of it's not.

Q.  Is there a tech transfer office for each Service?

A.  Yes there is, and there is a central office that
coordinates all research, also.  Let me put it this way.  Some
of the duplication is healthy, and I think we minimize it.

Q.  What success are you having in taking an improvement in
technology and applying it to similar processes in other plants
or other locations?  In other words, do you see that it can be
easily transferred, or are there design or other barriers to
implementation across the board?

A.  There are usually unique problems at a location that need
to be worked out, and I'll give you a perfect example of that.
The Air Force has gone full bore using plastic media blasting.
The Navy has gone full bore using it in certain areas - ground
support equipment, component parts, torpedoes.  We're not using
it on airframes.  The reason we're not is we have specific
concerns that we are trying to work out right now - microdents
and stress on the substrate.  Secondly, after two or three
cycles of plastic media blasting, not only are you blasting
with plastic media, you are now blasting with dust and chips
and other things from the floor, and we're worried about the
effects on expensive aircraft skin, so we're not ready to
release it at this point for use.

Q.  How long lasting are those beads?

A.  That's one of the things that's being looked at.  The Air
Force actually has a lot more experience than we do.  There is
some research underway to look at how long they can be
recycled.
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Q.  What kind of program do you have for materials
substitution?  Is it being done base by base,  or is it being
done through research and development?

A.  It's not being done through research and development.
Actually, it's being done in two places.  It's being done at
what I'll call the grass roots level and at the top level.  The
grass roots level are the people who carry out the
specifications, in weapons systems, for example.  They see
something in there that calls for hazardous material, and they
immediately begin to question it up the chain.  At the other
end, at our program manager level, at our weapons managers,
etc., they are also going through all their entire
specifications and procurement documents, to see where they can
spec out materials.  Not only spec out materials in the actual
production of the equipment or weapons system, but spec out
hazardous materials in the logistics life cycle, the
maintenance cycle, also.  We're trying to work it from both
ends.

Q.  Playing on that, is it manpower intensive, or is there a
computer program you can use to search key words, for instance?

A.  None that I know of right now.  There are some computer
applications being used, but it's not as grandiose as one might
think it is.  It's not uniform.  They're individual
applications for various weapons procurement managers.  There's
nothing you can go across the entire Navy and search
immediately.  It's just not that nifty.

Q.  How are you tweaking your baseline?  To index things you
almost need to look at hazardous waste production against a
unit of production, and that's a problem, I think, the generals
had.  They didn't link that reduction to any index of the base.
Are you looking at going back and trying to retrofit unit
production into generation?

A.  Yes we are.  I chaired a joint group recently.  Some of the
people in this room were on that panel.  We looked at producing
a hazardous waste index for the logistics community to start,
because if you can't do it for the logistics community, who can
you do it for?  We came up with a little formula for doing it,
but the formula requires some individual mission factors for
each type of facility.  Shipyards are a type of facility.
They're going to require a special little mission factor.  For
example, you take the amount of hazardous waste in pounds they
produce, and you divide it by some unit production mission
factor that's unique to those people.  We think we can come up
with an index.  We're working that right now.  In fact, there's
a briefing this month to the Joint Logistics Commanders on the
progress with that.
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Q.  Are you doing that by  linking  it to personnel  hours
involved in production lines, or what?

A.  The group is looking at the best way to  do  it,  and there
are a number of ways to do it.  You can look at widgets
produced, ships put out of shipyard, direct  work hours related
to that particular product.  There's about ten  different ways
you can look at it.  We're trying  to figure  which  is  the best
right now.

Q.  Are you a contact point for that group?   I'm working on the
same kind of thing for DOE.

A.  Yes.  You can contact  me.

Q.  Just a comment.  RCRA  is a conservation  act, not  just a
waste measurement act.  The real intent with conservation is tc
measure success by reductions in procurement.   If  you've
actually reduced your chromic acid purchase  by  99%, you've more
than met the intent of RCRA.  If you have an internal problem
where your total waste volume or waste coming out  is  still the
same, that's not a RCRA problem.   I think RCRA  would  be happy
to see 99% reduction in natural resource through your
procurement reductions

A.  Congress and everybody else is asking us "What are your
hazardous waste disposal numbers for this year,  so we have to
track this credibly?"

                              END
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